IR 05000382/1989037
| ML20006C097 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 01/31/1990 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Dewease J LOUISIANA POWER & LIGHT CO. |
| References | |
| NUDOCS 9002060305 | |
| Download: ML20006C097 (3) | |
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JAN 31.1990
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In Reply Refer To:
Docket: 50-382/89-37 Louisiana Power & Light Company ATTN:
J. G. Dewease, Senior Vice President l
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ituelear Operations 317 Baronne Street New Orleans, Louisiana 70160
7entlemen:
a Thank you for your letter of January 17, 1990, in response to our letter
and Notice of Violation dated December 18, 1989. We have reviewed your reply and find it responsive to the concerns raised in our Hotice 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, i
h"[gYnal ihned By:
Samuel J. Goilins Samuel J. Collins, Director'
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Division of Reactor Projects
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Louisiana Power & Light Company
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JATTH:
R. P. Barkhurst, Vice President Nuclear Operations P.O. Box B
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Killona, Louisiana 70066 i
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Louisiana Power & Light Company ATTN: 'd. R. McGaha, Jr., Plant Managet-P.O. Box B K111ona, Louisiana 70066
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Louisiana Power & Light Company-i ATTN:
L. W. Laughlin, Site i
Licensing Support Supervisor P.O. Box B Killona, Louisiana 70066 i
RIV:RI:PSS C:PSS D:DR M
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$502 $086gp
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Louisiana Power & Light Company-2-
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Louisiana Power & Light' Company.
ATTH:
G. M. Davis, Manager, Events i
Analysis Rtporting & Response
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P.O. Box B
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Killona, Louisiana 70066'
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Monroe & Leman ATTH:
W. Malcolm Stevenson, Esq.-
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201 St. Charles Avenue, Suite 3300 New Orleans, Louisiana 70170-3300 i
Shaw, Pittman, Potts & Trowbridge
ATTN: Mr. E. Blake
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2300 N Street, NW Washington, D.C.
20037 Middle South Services, Inc.
ATTN: Ralph T. Lally, Manager of. Quality Assurance P.O. Box 61000=
New Orleans,' Louisiana 70161 Chairman Louisiana Public Service Commission One American Place, Suite 1630 Baton Rouge, Louisiana 70825-1697
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Louisiana Power & Light Company l
ATTH:
P,. F. Burski, Manager, Nuclear l
Safety and Regulatory Affairs L.
317 Baronne Street
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New Orleans, Louisiana 70112 Department'of Environmental Quality ATTH: William H. Spell, Administrator-Nuclear Energy Division
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P.O. Box 14690
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Baton' Rouge, Louisiana 70898
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President, Police Jury'
l St. Charles Parish l
Hahnville, Louisiana 70057 Mr. William A. Cross Bethesda Licensing Office 3 Metro Center Suite 610 Bethesda, Maryland 20814
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Louisiana Power & Light Company-3-
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U.S. Nuclear Regulatory Commission
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ATTN: Resident Inspector
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P.O. Box 822
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Killona, Louisiana 70066 U.S. Nuclear Regulatory Commission
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ATTN: Regional Administrator, Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011
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bectoDMB(IE01)
bec distrib. by RIV:
t R. D. Martin Resident Inspector SectionChief(DRP/A)
DRP i
DRSS-FRPS MIS System ProjectEngineer(DRP/A)
RSTS Operator
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RIV File DRS F
D. Wigginton, NRR Project Manager (MS:
13-D-18)
i Lisa Shea, RM/ALF C. Johnson T. Stetka i
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,_. _, b Louwena power a upnt company -
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317 Baronne Street P. O. Dos 60340 l
New Orteens. LA 70160 0340 Tel. 50s ses teos '
R. F. Borski '
Numeer Salety & Magulatory Anars-i Manage W3P90-0211 A4.05 l
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January 17 1990
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U.S. Nuclear Regulatory Commission I W) bPK@Qgfq'
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ATTN: Document Control. Desk
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Washington, D.C.
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Subj ect: Waterford 3 SES N
Docket No. 50-382 L
License No. NPF-38
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NRC Inspection Report 89-37
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t Gentlement i
S In accordance with 10 CFR 2.201, Louisiana Power & Light hereby submits in Attachment 1 the response to the Violation identified in Appendix A of the
subject Inspection Report.
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If you have any questions concerning this response, please contact L.W. Laughlin at (504) 464-3499.
Very truly yours, f
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RFB/DDG/ssf Attachment-Messrs. R.D. Martin, NRC Region IV
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cc:
F.J. Hebdon, NRC-NRR
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D.L. Wigginton, NRC-NRR E.L. Blake W.M. Stevenson NRC Resident Inspectors Office
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Page 1 of 3
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ATTACKMENT 1
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LP&L RESPONSE TO THE VIOLATION IDENTIFIED IN APPENDIX A
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0F INSPECTION REPORT 89-37
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l VIOLATION NO. 8937-01 i
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Failure to Tollow a Procedure and Implementation of an Inadequate Procedure
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During an NRC inspection conducted on November 13-17, 1989, a violation of.
NRC requirements was identified. The violation _ involved a failure to
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follow a procedure and implementation of an inadequate procedure.
In t
accordance with the " General Statement of Policy and Procedure for NRC
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enforcement Actions," 10 CFn Part 2, Appendix C (1989) (Enforcement
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Policy), the violation is listed below:
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Technical Specification 6.8.1.a requires, in part, that written procedures shall be established and implemented as recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
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i Regulatory Guide 1.33. Revision 2, requires that maintenance of
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safety-related equipment be properly preplanned and performed in accordance with written procedures, documented instructions.,or
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drawings appropriate to the circumstances.
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Maintenance Procedure MM-12-001, Revision 1. " Pipe Hanger' Support
Installation Fabrication and Removal," requires that personnel record'
the actual hot / cold load settings of spring hangers after
installation.
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Maintenance Procedure MH-12-004, Revision 1 " Fabrication and i
Installation of Piping," requires a quality control (QC) acceptance sign-off for piping systems, hangers, and supports in accordance with Specification 1564.100 after installation.
Contrary to the above:
(1)
Installation records for Spring Hanger HVSH-4028 indicated that
personnel did not record the actual hot / cold settings as required by procedure after final. installation.
(2) Maintenance Procedure MM-12-004 did not contain adequate QC inspection acceptance criteria for spring hanger settings.
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the result of this inadequacy, Spring Hanger HVSH-4028 was not installed in accordance with design drawing settings.
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l This is a Severity Level IV violation.
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RESPONSE l
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(1) Reason for the Violation j
Item 1 LP&L admits to Item 1 of the violation in that personnel did not-record the actual hot / cold settings for Spring Hanger HVSH-4028 as required by Maintenance procedure MM-12-001. The root cause for this item was personnel error.. Personnel involved failed to record the
spring hanger setting in accordance with procedure MM-12-001.
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This hanger was installed on the Containment Atmosphere Release (CAR)
system on May.18,1988 under Station Modification Package (SMP) 1322 during the Refuel 2 outage. The spring setting was at its upper limit (topped out) and the spring of the pipe support was not loaded and did not support the pipe'as designed.
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Item 2 LP&L admits to Item 2 of the violation involving implementation of an
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inadequate procedure.
Procedure MM-12-004 was inadequate regarding QC inspection acceptance sign-offs for piping systems, hangers and i
supports. Consequently, Spring Hanger NVSH-4028 was not installed in
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accordance with design drawings settings. The root cause for this
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item was improper human f actor engineering of procedure MM-12-004.
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LP&L believes that the overall content of procedure HH-12-004 is adequate. However, the inspection criteria described in procedure MM-12-004 for piping system adequacy and overall appearance is vague and resulted in this violation.
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Because this procedure is intended to provide the general methods that
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control the fabrication, installation, and inspection of piping / components at Waterford 3, no explicit details were factored into the inspection acceptance ' criteria for spring hanger settings.
(2) Corrective Steps That Have Been Taken and the Results Achieved
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Item 1
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Condition Identification (CI) 266769 was issued upon discovering that
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Spring Hanger HVSH-4028 was set at its upper limit and did not support
the pipe as designed.
An engineering evaluation included in the CI concluded that the CAR system was operable and Waterford 3's operability and integrity was not impaired by the as found condition
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of the spring hanger.
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Page 3 of 3-The individual responsible for this violation has lef t LP&L employment
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and no corrective action with the individual is possible. However, a memorandum has been sent to Quality Assurance, Maintenance and Construction personnel discussing the specific violation, corrective-actions and the importance of following procedure. This memorandum
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will be required reading under the Quality Assurance and Construction recurring training program.
The importance of this will be. discussed by the Maintenance Superintendent with Maintenance Supervision.
In addition, review of the installation records by LP&L for Spring Hanger HVSH-4028 indicated documentation discrepancies.
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discrepancies include missing checklists and improperly completed forms. As a result, QN-QA-90-026 was generated to evaluate and resolve the discrepancies.
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Item 2
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Procedure MM-12-004, Revision 1, has been reviewed by Construction l
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personnel in response to this violation.
This review indicated that
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the criteria for the.QC hold point were too general and segments of piping, hanger and support installations may not receive adequate QC l
inspection.
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(3) Corrective Steps Which Will be Taken to Avoid Further Violations Item 1 l
Spring Hanger HVSH-4028 will be acdified and the spring will be reset to its design load.
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It is important to note that supports, including spring cans, are required to be examined under the inservice inspection of class 1
(IWB), class 2 (IWC) and class 3 (IWD) components included in Waterford 3's Ten Year Inservice Inspection Program.
- Based'on this selection process, LP&L is confident that deficiencies in spring can
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installations will be identified and addressed in a timely manner.
s In addition, a follow-up surveillance will be performed by the Site Quality organization to assure that support installations are being
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performed and documented in accordance with site procedures.
Item 2
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Procedure MM-12-004 will be revised to provide greater details regarding inspection criteria concerning the QC hold point for the
installation of piping systems, hangers and supports.
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(4) Date When Full Compliance Will Be Achieved Items l'and 2 The actions identified above will be completed no later than
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September 1,1990, at which time LP&L will be in full compliance.
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