ML20005F536

Provides Addl Info Resulting from Questions Raised During 891211 Enforcement Conference.Review of Fire Protection Program Audits Determined That Problem Re Insp Sequence Not Identified

ML20005F536
Person / Time
Site:	Waterford
Issue date:	12/19/1989
From:	Dewease J LOUISIANA POWER & LIGHT CO.
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20005F527	List: ML20005F536
References
W3P89-0338, W3P89-338, NUDOCS 9001160368
Download: ML20005F536 (2)

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-y 7 teet h DEC 201989 $h g8g-0338 04 -ih QA December 19, 1989 R. D. Martin Regional Administrator, Region IV i U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive - Suite 1000 s

) Arlington, Texas 76011

Subject:

Waterford 3 Docket No. 50-382 License No. NPF-38 Enforcement Conference-Additional Information

Dear Mr. Martin:

As a result of questions raised by your staff in the enforcement conference on December 11, 1989, LP&L is providing the following additional information.

NRC personnel questioned whether the procedural . inadequacy identified in 1988 had been emred into LP&L's corrective action program. Although in preparing for the e m -ecement conference we established that the procedure had'been corrected; h April JN we also determined that a quality notice (QN) had not been issued.

A QN has now been initiated and the engineering review will: be formalized.

NRC personnel questioned whether any of our QA audits of the Fire Protection .  !

Program identified the problem with Procedure ME-13-100 and, if so how the problem was dispositioned. A. review of the Fire Protection Program audits determined that while audits did result in the issuance of a number of audit findings, the problem related to inspection' sequence had not been. identified.

NRC personnel questioned whether the interview process'was: sufficient to determine whether a larger problem exists'than was first disclosed, observing that a i sampling inspection might provide further assurance that a problem does not-  !

exist. LP&L has reviewed the interview process and we conclude it was adequate to detarmine the scope of the problem in this particular instance. We believe_-

that the information we received from the individuals during the. interviews - .

was true and accurate. The confidentiality of the'information.provided by  !

those interviewed was assured and','in general, the individuals were not requested  ;

to provide information related to their own experience. The interview process t questioned both maintenance and supervisory personnnel responsible for performing the work and QC personnel responsible for performing hold point verifications, ,

and both groups clearly understand and implement their responsibilities with  ;

respect to hold points.

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Enforcement Conference-Additional Information l Page 2 4 December 19, 1989 i

NRC personnel were concerned that the procedure was inadequate for a long period  ;

of time and personnel worked around the procedure rather than take appropriate actions to have the procedure corrected. As we have discussed with your staff previously, this has been an area of concern to us.as well. LP&L has undertaken programs to upgrade procedures, enhance procedural compliance, and to_ educate our personnel on management's standards and expectations. We believe that although this type of problem' occurred in the past, there is an improving trend in this area.

The above responds to questions raised in the enforcement corference. _ I would also like to inform you of other actions I have taken subsequent to the enforcement conference. First, a letter will be issued from myself to all Nuclear Operations.

personnel outlining the actions LP&L:has taken as-a result of these events and the expectations of management. Secondly, the involved' individual has agreed to meet with QA/QC personnel to openly discuss his personal experiences-regarding this incident. This will be completed by January 15, 1990; Thank you for this opportunity to provide additional information. If you have any questions, please call.

Very truly yours, 0 b cc: Messrs. F.J. Hebdon, NRC-NRR '

D.L. Wigginton, NRC-NRR E.L. Blake W.M. Stevenson NRC Resident Inspectors Office .

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