ML20011F140

Responds to Violations Noted in Insp Rept 50-382/89-41. Corrective Action:Review of Independent Verification Requirements Re Maint Activities Performed

ML20011F140
Person / Time
Site:	Waterford
Issue date:	02/21/1990
From:	Burski R LOUISIANA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
W3P90-0247, W3P90-247, NUDOCS 9003010284
Download: ML20011F140 (3)

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Louisiana Power & Leght Company

~' 317 Barorve Sweet - '

P. O. Boa 60340 Now Orisans, LA 7o160 0340

, Tol. 604 fi95 2805 _

. R.F. Buroki 5 Nuclear Satoty & Rogunatory Affaire-Manager  ;

3 W3P90-0247 A4.05 QA February-21, 1990 U.S. Nuclear Regulatory Commission ATTNt Document Control Desk Washington, D.C. 20555 Subjectt Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report 89-41 Centlement In accordance with 10 CFR 2.201, Louisiana Power 6 Light hereby submits in Attachment 1 the response to the violation identified in Appendix A ,

of the subject inspection Report.

l If you have'any questions concerning this response, please contact .5 L.W.'Laughlin at (504) 464.3499. "

.Very truly yours, .;

Q>~ :/ a.J RFB/DMU/esf ,

Attnthment

-cet Messrs. K.D. Martin, NRC Rebio!8 IV F J. Hebdon. MRC-NRR j D L. Wigginton, NRC-NRR E.L. Blake U.M. Stevenson >

NRC Resident Inspectors Office

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Attachment to '

W3P90-0247 Page 1 of 2 ATTACEMENT 1 LP6L RESPONSE TO THE VIOLATION IDENTIFIED IN APPENDIX A Or INSPECTION REPORT 89-41 VIOLATION NO. 8941-02 Failure to Follow Independent Verification Procedures Technical Specification (TS) 6.8.1.a requires, in part, that written procedures shall be implemented as recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, which includes administrative procedures for safety-related activities.

Administrative Procedure MD-1-025, Revision 0, " Independent Verification Program," Section 5.2, requires an independent verifier to watch the other -

person perform the tank designated for verification in the applicable procedure and verify that the task is completed as prescribed.

Work Authorization (WA) 01051422 implemented the above program by requiring independent verification of each step in the procedure for charging nitrogen into the main steam isolation valve operator cylinders.

Contrary to the above, on December 25, 1989, a maintenance technician

. charged the A main steam isolation vsive operator wita nitrogen in accordance with WA 01051422, without the ivdependent verification being performed.

This is a Severity Level IV violation.

RESPONSE

(1) Reason for the Vi J1ption f

The root cause of this violation was cor.iusion within the Maintenance bepartment over the definition of independent verification and when it was required. Work Authorization (WA) 01051422 was written to recharge the Main Steam Isolation Valve (MSIV) operator nitrogen Secumulators. Various steps in the work instructions were required to be " verified". It was these steps the violation contends were not independently verified in accordance with Administrative Procedure MD-1-025, Revision 0. Independent Verification Program. Section 5.2 of this procedure requires the independent verifier do more than watch the person performing the task to be verified. The independent verifier shall actually verify that the task is complete.

Verification of the MSIV A accumulator charging work instructions were not performed in accordance with the above.

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W3P90-0247:

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A review of the incident has shown that maintenance personnel did not j understand-a step marked " verified" required the same level of i attention as that marked " independent verification". Because the work l instructions were marked " verified" and not specifically " independent {

verification", it was thought that the instructions in MD-1-025 were j not applicable. . A step marked " verified" was generally viewed as a- J 1ess stringent verification specified as a result of conservative work j practices and not a procedurally mandated independent verification j with strict performance criteria. Confusion over the requirements for  ;

independent verification resulted in an improper verification being j performed.  !

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(2) Corrective' Steps That Have Been Taken and the Results Achieved )

To correct the above, n: review of independent verification requirements as they relate to maintenance activities was-performed. _,

It was determined that a principle cause of the violation was confusion over the' independent verification procedure, MD-1-025. This l procedure which is a departmental procedure was deleted in its entirety on January 22, 1990. The Maintenance Superintendent then )

issued Fa' onance Directive (MD) 29 to clarify the Maintenance .

Departn . osition on independent verification. The directive states that '

ed" and " independent verification" are synonymous. The criteri esently used when performing an " independent verification" d will .e used when a work instruction is required to be "ver . As departmental procedure MD-1-025 has been deleted, the Mi ac Department will conduct independent verifications in at, ace with UNT-5-010 Independent Verification Program, a PORC  !

approved procedure. j 1

(3) Corrective Steps Which Will be Taken to Avoid Further Violations 1

The Maintenance Department has initiated Maintenance Directive 29-discussing verification and independent verification as it applies to maintenance activities. The Maintenance Department will be given 1, 4

-training on the new directive. This training will be complete by April 30, 1990.  ;

7. (4) Date When Full Compliance Will Be Achieved  ;

Training of maintenance personnel on MD 29 will be complete by April  !

30, 1990. LP&L will be in full compliance at this time. .

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