ML20034B786
| ML20034B786 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 04/23/1990 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Dewease J LOUISIANA POWER & LIGHT CO. |
| References | |
| EA-89-212, NUDOCS 9005010008 | |
| Download: ML20034B786 (3) | |
Text
APR 2 319T In Reply Refer To:
Docket: 50-382 EA 89-212 Louisiana Power & Light Company
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ATTN:
J. G. Dewease, Senior Vice President l
Nuclear Operations 317 Baronne Street-New Orleans, Louisiana 70160 l
Gentlemen:
Thank you for your letter of March 21, 1990, in response to our letter and l
Notice of Violation dated February 8,1990.
We have reviewed your reply and l
find it responsive to the concerns raised in our Notice of Violation. We will 4
review the implementation of your corrective actions during a future inspection to detemine that full compliance has been achieved and will, bc maintained.
i Sincerely.
M/
Sanuel J. Collins, Director Division of Reactor Projects cc:
Louisiana Power & Light Company L
ATTN:
R. P. Barkhurst, Vice President Nuclear Operations P.O. Box B K111ona. Louisiana 70066 Louisiana Power & Light Company ATTN:
J. R. McGaha, Jr., Plant Manager i
P.O. Box B j
Kiliona, Louisiana 70066 j
I Louisiana Power & Light Company ATTN:- L. W. Laughlin, Site Licensing Support Supervisor P.O. Box B l
K111ona, Louisiana 70066 g
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l Louisiana Power & Light Company,
Louisiana Power & Light Company ATIN:
G. M. Davis, Manager Events Analysis Reporting & Response t
P.O. Box B K111ona, Louisiana 70066 Monroe & Leman ATTN:
W. Malcolm Stevenson, Esq.
201 St. Charles Avenue, Suite 3300 New Orleans, Louisiana 70170-3300 Shaw, Pittman, Potts & Trowbridge ATTN: Mr. E. Blake 2300 N Street, NW Washington, D.C.
20037 Middle South Services, Inc.
ATTN:
Ralph T. Lally, M: nager of Quality Assurance P.O. Box 61000 New Orleans, Louisiana 70161 Chainnan Louisiana Public Service Commission One American Place, Suite 1630 Baton Rouge, Louisiana 70825-1697 Louisiana Power & Light Company ATTN:
R. F. Burski, Manager, Nuclear Safety and Regulatory Affairs 317 Baronne Street New Orleans, Louisiana 70112 Department of Environmental Quality ATTN: William H. Spell, Administrator Nuclear Energy Division P.O. Box 14690 Baton Rouge, Louisiana 70898 President, Police Jury St. Charles Parish Hahnv111e, Louisiana 70057 Mr. William A. Cross Bethesda Licensing Office 3 Metro Center Suite 610 Bethesda, Maryland 20814 i
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l Louisiana Power & Light Company U.S. Nuclear Regulatory Commission ATTN: Resident Inspector P.O. Box 822 K111ona, Louisiana 70066 i
U.S. Nuclear Regulatory Comission ATTN:
Re<ional Administrator, Region IV 611 Ryan ilaza Drive. Suite 1000 Arlington, Texas 76011 j
bectoDMB(IE14) bec distrib. by RIV:
R. D. Martin Resident Inspector SectionChief(DRP/A)
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DRSS-FRPS MIS System j
Project Engineer (DRP/A)
RSTS Operator RIV File DRS D.Wigginton,NRRProjectManager.(MS:
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Lisa Shea, RM/ALF l
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I Leute4 ens Power & LigM Company 5 317 aarcme street i
P.O. Dos 60MO New Orieans. LA 70160 0MO Tot 404 696 2006
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Nuolaar Seiety & RegAtory Anairs.
Manager i
W3P90-0254 A4.05 i
QA March 21, 1990 I
U.S. Nuclear Regulatory Commission
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Subject:
Waterford 3 SES i
4 Docket No. 50-382 License No. NPT-38 NRC Investigation Report'No. 4-89-002 I
Reply to a Notice of Vielation (EA No.89-212) l Gentlemen in accordance with 10 CTR 2.201 Louisiana Power & Light hereby submits in the response to the Notice of Violation identified in your j
letter dated February 8, 1990. Note, this submittal date reflects the ten day extension that was granted by Mr.,D.D. Chamberlain of your office during a telephone conversation with Mr. L.W. 1.aughlin of LP&L on March 13 1990.
If you have any questions concerning this response please contact T.J. Gaudet at (504) 464-3325.
Very truly yours, RTB/TJG/ssf Attachment i
cc Messrs. R.D. Martin, NRC Region IV Y.J. Hebdon, NRC-hM D.L. Wigginton, NRC-NRR l
E.L. Blake I
W.M. Stevenson NRC Resident Inspectors Office f( - f[* hf f Yr
6 Attcchment to W3P90-0254 Page 1 of 7 i
ATTACHMENT 1
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LP&L RESPONSE TO THE NOTICE OT VIOLATION IDENTIFIED IN YOUR LETTER DATED FEBRUARY 8, 1990 l
VIOLATION A i
Procedure Deficiency Technical Specification 6.8.1.a requires, in part, that written procedures shall be maintained for quality related work as recommended in Appendix A of Regulatory Guide 1.33, Revision 2. February 1978. Appendix A includes procedures for conduct of maintenance.
i 10 CTR $0, Appendix B, Criterion XVI, requires in part that conditions i
adverse to quality be promptly identified and corrected.
i Contrary to the above, prior to April 25, 1988, Maintenance Procedure ME-13-100, " Fire Barrier Installation and Rework," was deficient. An inspection hold point was placed in Section 8.2.6 sequenced such that surfaces to be inspected were covered up with sealant, thus preventing the inspection as intended by the procedure.
In addition, this deficiency in the procedure, a condition adverse to quality, was recognized by LP&L personnel but was not promptly corrected.
This is a Severity Level IV violation.
RESP 0NSE (1) Reason for the Violation LP&L admits this violation and has identified two root causes.
The root cause for Electrical Maintenance Procedure ME-13-100 to be l
deficient in the first place was an inadequate technical review which allowed the incorrect placement of an inspection hold point. The root cause for this procedural deficiency to have existed for such an extended period of time was a lack of procedure compliance in that although personnel performing the procedure were aware of the deficiency (the out-of-sequence hold point), appropriate changes were not mada prior to continuing performance of the repair work. As a result, a condition adverse to quality existed since June, 1985, the date of the associated revision, but was not corrected until April, 1988.
During Revision 3 to the procedure, in June, 1985, it was recognized I
that an inspection hold point was needed in the body of the procedure to ensure that the removal of two inches of sealant material from around the periphery of the damaged area was being properly inspected.
Due to an inadequate technical review of the proposed procedure changes, the hold point vas incorrectly sequenced in the procedure to
I Attcch:ent to l
Page 2 of 7 require inspection of the area after it had been reworked and new sealant had been applied.
It is believed that had a proper technical review been performed the out-of-sequence hold point would have been i
identified and corrected and this violation would not have occurred.
Lp6L also believes that the basis for this condition to have existed for such a long period of time was indicative of a weakness in the 1
implementation of the requirements for procedure compliance. As a result, attitudes on procedure compliance at that time were such that if an individual was familiar with the scope of the work for a specific task, yet it differed from that of the governing procedure.
l the individual could correct the situation at hand without having to
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process a procedure change.
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In this particular instance, personnel involved with the fire l
penetration repair work and its inspection were mainly contractors or 1
personnel from organizations other than those from the Maintenance
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Department who were directly responsible for the procedure and changes i
thereto. Even though many of those that were involved were aware of i
the deficient procedural sequence, they changed the practical sequence to meet what they believed was its intent without recommending or
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pursuing a procedure change. The procedural deficiency was not at that time properly identified as a condition that was adverse to quality. Consequently, it was left uncorrected for an extended period-of time without proper dispositioning until a concern had been raised by an individual performing the repair work.
(2) Corrective Steps That Have Been Taken and the Results Achieved Once the procedural deficiency was brought to the attention of the Maintenance personnel in direct control of the procedure, the proper sequence of the inspection hold point was placed in the procedure under a change that was immediately implemented on April 2$ 1988.
It should be noted however that even though the subject hold point was out of sequence from June, 1985 to April, 1988, a subsequent hold point in the procedure during that time period specifically verified adhesion to the surrounding material. April, 1989 tests demonstrated excellent adhesion of the silicone foam installed even on top of undisturbed seal material. The fire seal inspection that was conducted between November 1988 through November 1989 identified no deficiencies regarding adhesion.
l' To improve the quality of reviews in the future, the current procedure for installation and rework of penetration seals, conduit seals, fire breaks and water barriers (Nuclear Operations Construction Procedure l
NOCP-301) requires a fire protection engineer review of changes to the procedure. Note, ME-13-100, Revision 6 had been replaced in January, l
1989 by proceduras, NOCP-300 for Fire Wrap Installation and Rework and l
NOCP-301 as described above.
Subsequent to the issuance of the new l
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i, Attcch snt to W3P90-0254 Page 3 of 7 procedures, applicable Nuclear Operations Construction personnel were trained on the procedures. Also, to enhance the existing training and qualifications for personnel involved in the installation of fire seals. Nuclear Training Course Description NTC-129 and the associated Lesson Plan were revised in October and December. 1988, respectively, i
A Quality Notice (QN No. QA-89-278) and a Potential Reporteble Event Report (PRE-89-138) were generated on 12/19/89 to ensure that proper L
dispositioning of the condition adverse to quality was achieved and to properly enter such a condition in the Waterford 3 Corrective Action i
Program (NOP-005).
(Note:
The PRE was dispositioned as not reportable because although the hold points may have been conducted-out of sequence, the final inspection was adequate to ensure fire barrier operation.) NOP-005 has undergone a major revision since this l
procedure deficiency occurred to ensure that conditions adverse to quality and significant industrial safety and plant reliability concerns are promptly identified and corrected.
(NOP-005 did not even exist until December, 1985.)
i LP&L has undertaken numerous programs and corrective action initiatives to upgrade procedures, enhance procedural compliance and to educate personnel regarding management's standards and expectations. As part of LP&L's Improving Human Performance Program.
the Operation Zero Deviation Program was developed to stimulate i
teamwork directed at compliance with plant procedures, work instructions and plant expectations and standards. Although in its initial implementation stage, a Precursor Trending Program was l
recently established to identify, trend and ultimately provide corrective action for deficient conditions, such as procedural human factors deficiencies, which are minor if taken individually but collectively could lead to more serious problems if not addressed in a i
timely manner. A Plant Management Directive was issued on Procedure Compliance.
It specifically states that 1) if a procedure is
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incorrect then fix it before you use it. 2) if a procedure is correct then comply with it and 3) if you have any comments or concerns about the adequacy of a step in a procedure, regardless of magnitude, then contact your supervisor for discussion and potential changes.
Subsequent to the issuance of this violation, this directive was reviewed with plant and Quality Assurance personnel during one-on-one counselling sessions.
The above mentioned programs-(as well as others) display the emphasis that Management has placed on procedure compliance and professionalism. The discussion of such events during plant safety meetings and the issuing of memoranda when such conditions occur have heightened personnel attention to procedural compliance and adequacy at Waterford 3 in the past year to the point in which this type of violation should not be repeated in the future.
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s Attach;ent t3 W3P90-0254 Page 4 of 7 In addition to the above, the Senior Vice President-Nuclear Operations issued a memorandum on 12/19/89 to bring this matter to the attention of all Nuclear Operations Employees.
It addresses this incident specifically and procedure compliance in beneral.
(3) Corrective Steps Which Will be Taken to Avoid Further Violations Based on the actions described above in item (2), LP&L is confident that similar violations will be prevented in the future.
(4) Date When_ full Corp 31ance Will Be Achieved LP&L is currently in full compliance.
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i Attcch= nt to W3P90-0254 Page 5 of 7 VIOLATION B Inaccurate Information Provided to NRC 10 CPR $0.9 requires, in part, that information provided to the Commission by a licensee shall be complete and accurate in all material respects.
Contrary to the above, information provided to the Commission during a June 18-July 31, 1988, inspection at LP&L's Waterford plant was not complete and accurate in all material respects. The information, provided orally in l
response to an inspector's questions, did not accurately reflect the i
sequence of quality control inspections for fire seal repair work, and was material in that the inspector relied upon the information to bring the matter to a close in an inspection report issued on August 25, 1988.
This is a Severity Level IV violation.
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RESPONSE
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l (1) Re3 son for the Violation LP&L also admits this violation and believes that its root cause was personnel error. A Quality Control (QC) inspector, who was responsible for performing inspections of reworked penetration seals l
prior to their being refilled with fireproof insulation, provided inaccurate information to an NRC inspector when questioned by him. A contributing cause to this violation was the procedural deficiency (the out-of-sequenced inspection hold point) that existed from June, 1985 to April, 1988 as was described above in Violation A.
In August, 1988, an NRC inspector was investigating an allegation that had been made by an individual with regard to the failure of a Waterford 3 QC inspector to perform inspections of reworked penetration seals prior to their being refilled with fireproof insulation material. During the NRC inspector's investigation, he noted that the governing procedure (ME-13-100 Revision 6) had undergone a recent change (in April,1988) to correct the sequence of an inspection hold point to verify the removal of two inches of material around the penetration which had incorrectly been placed in the procedure after the area had been refilled with the insulation material rather than before. Although the procedure had remained deficient due to the out-of-sequence hold point for an extended period of time, those involved with the repair work changed the sequence in practice in order to meet what they believed was its intent.
Accordingly, in practice, whenever the responsible personnel completed the removal of two inches of seal material around the periphery of the penetration, they would contact the cognizant QC inspector to perform a visual inspection of the work prior to the next step, refilling the area with insulation material.
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Attcch:ent to i
V3P90-0254 Page 6 of 7 The NRC resident inspector discussed this situation with the responsibts QC inspector. When questioned by the NRC inspector as to the actual sequence of the hold point inspection, the responsible QC inspector replied that verification of removal of two inches of material was always performed prior to the refill of insulation material. On occasion, however, the QC inspector had performed the hold point in the sequence of the procedure af ter the area had been e
refilled. By not providing accurate information to the NRC when orally questioned, the QC inspector violated 10CTR50.9. Although LP&L.
had admitted and accepted thin violation, it is believed that the responsible QC inspector did not make such a statement intentionally or maliciously.
l (2) Corrective Steps That Have Been Taken and the PSsults Achieved LP&L conducted an in depth records review of procedures, inspection logs, test data and reports related to the performance of inspections of reworked penetration seals. As part of the review process, interviews were held with personnel from Waterford.3 Quality Control responsible for performing inspection hold point vetifications and plant maintenance and contractors responsible for performing the reworked seals. The results of the review indicated that this incident was an isolated case (No other evidence of missed inspections was found regarding this individual. Other inspection work conducted by this individual is acceptable. The only other inspector qualified in this particular procedure did 1
not employ a similar practice.);
final inspection of fire seals was done as required by the procedure and provides a high degree of confidence with regard to acceptability of the seal fire seals are acceptable (Obvious seal adhesion problems would have been identified during the fire seal reinspection program conducted from November, 1988 to November, 1989. Removal of seal 1
material to facilitate adhesion was later determined unnecessary by a special test.); and bypassing hold points was not an accepted or common practice at Waterford 3 (There were only 13 missed inspections that were identified out of over 60,000 inspections conducted during 1987-1989. The importance of complying with hold points is clearly recognized by QC and Maintenance personnel.)
Also, the LP&L Quality Team (personnel assigned to receive, investigate, evaluate, resolve, and document Waterford 3 quality / nuclear safety concerns relating to the design, procurement, construction, maintenance, modification, or operation of Waterford 3) determined by review of 128 concerns identified from January, 1987 to November, 1989 that no other quality team concerns relating to inspection were identified during this period.
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1 Attcchment to W3P90-0254 i
Page 7 of 7
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The responsible individual vaa required to meet with Quality Assuranet and Quality Control personnel to openly discuss his personal experience with this incident.
1:. his discussion, he specifically i
addressed procedural compliance, proper identification and documentation of deficiencies, inspection and documentation relating to hold points and the need for' honesty, forthrightness and integrity, i
On 12/$/89, the responsible individual was removed from the performance of all safety-related work for a period of approximately 60 days.
(Note From April, 1989 to 12/5/89, the individual had been removed f rom performing safety-related QA inspections.) The l
individual has since been restored to performing safety-related work i
on a conditional basis with continued monitoring by appropriate supervisory and management personnel. After a period of approximately 6 months, the individual's performance will be evaluated and if found acceptable he will be restored to an unconditional status.
The evaluation shall be documented and made a part of the individual's permanent personnel file.
A letter was issued from the Senior Vice President-Nuclear Operations to bring this matter to the attention of Nuclear Operations personnel.
I lt outlined the actions LP&L has taken as a result of this event and the expectations of management.
1 (3) Corrective Steps Which Will be Taken to A'ioid Further Violations
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Based on the actions described in item (2), LP&L is confidant that similar violations will be prevented in the future.
(4) Date When Full Compliance Will Be Achieved LP&L is currently in full compliance, t
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