ML20063E547
| ML20063E547 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 06/02/1982 |
| From: | Mclendon G LOUISIANA POWER & LIGHT CO. |
| To: | Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20063E526 | List: |
| References | |
| W3K-82-0309, W3K-82-309, NUDOCS 8207130453 | |
| Download: ML20063E547 (6) | |
Text
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LOUISIANA /,42 OuiaONOe Srneer POWE R & LIG H T/ P O BOX 6008
- NEW ORLEANS. LOUISlANA 70174 * [504) 366-2345
' YON sYsYN) u June 2, 1982 G. D. McLENDON Senior Vice President W3K-82-0309 0-3-A35.02.01 ll(hh {b {_k$.I
/
Mr. G. L. Madsen, Chief, M Jg Reactor Projects Branch, Region IV U. S. Nuclear Regulatory Commission O
611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012
SUBJECT:
Waterford SES Unit 3 USNRC Inspection Report 50-382/Rpt. 82-05
Dear Mr. Madsen:
The following information regarding the violations cited by the USNRC Inspectors in IE Inspection Report No. 50-382/Rpt. 82-05 dated April 27, 1982, is herewith submitted:
A.
Failure to Provide Prompt and Appropriate Corrective Action to Negative Inspection Findings Regarding Reactor Vessel Cleanliness Criterion XVI of 10CFR50, Appendix B, states that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected.
Contrary to the above, an inspection of the following documents shows failure to promptly correct conditions adverse to quality.
A significant number of daily housekeeping reports by NISCO QC from July 31, 1981, through March 3, 1982, show unacceptable cleanliness of reactor vessel. These reports (NISCO House-keeping Inspection Report Form FS-o8) show ' repeated rejected cleanliness. Reports stating conditions such as " Dirt, Trash, l
Debris" in reactor vessel.
" Trash in Bottom of Vessel,"
" Broken Light Bulbs, Trash, Dirt, Debris" in reactor vessel are often repeated.
This is a Severity Level IV Violation (Supplement II.E).
8207130453 820629 PDR ADOCK 05000382 G
PDR J
r Mr. G. L.-Madsen.
Page 2
' The following information is : submitted:
Corrective Action Taken and Results Achieved
- NIS00 is in the process of cleaning the Reactor Vessel at this time.
A cover was placed over -the RV. Pool area to protect. against the work activities in the containment building. - Other contractors have partially removed the cover so that work activities can continue in the Pool area.
Corrective Action Taken to Preclude Repetition The Lead Engineer is now dispositioning rejected [ items noted cut House-keeping Reports as he receives them. He then submits the Reports to the Superintendent for corrective action. NISCO QC will. perform a weekly in-depth surveillance to verify that corrective action, as noted on the Housekeeping Report, has been taken.
1 Date When Full Corrective At* ion Was Achieved May 20, 1982.
4 B.
Failure to Follow Procedures for Protection of and Access to-Reactor Vessel,- Reacter Vessel Head, and Upper and Lower Internals
- Criterion V of 10CFR50, Appendix.B', requires.that activities affecting safety be performed in accordance with 'the prescribed. procedures or instructions.
4 f
Ebasco Care and Maintenance Instructions for the reactor vessel and-
- reactor vessel head, CM1-33, Rev._7, and CMI-37,.Rev.-3, respectively, l
require. varying degrees of cleanliness and. varying work ' zones and cleanliness requirements.
\\
i Contrary to the above,. on March 2,1982,- the NRC Inspectors observed
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the following:
4
- a.
The reactor vessel with " Fish, Net" covering.only.
b.
The reactor internals 'not covered.,
i c.
Reactor head-mcovered.
- d. 'Two contrc' riement drive mechanisms were open to the atmosphere.
I c.
Access e...rol not established on reactor vessel 1 head or reactor
~
I' upper int ernals.
af. Access montrol to reactor vessel and core support barrel inadequate.
4 g.
Considerabic dirt in reactor vessel and components.
h.
Dirt in and on reactor vessel h' ad '
e
' This is a Severity Level IV Violation (Supplement II.E).
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e-Mr. G. L 'Madsen Page 3 6
The following information is' submitted:
Corrective Action Taken and-Results Achieved The'" Fish Net". covering has been replaced with "Loretex." The'Loretex a.
covering has_ been partially removed by other contractors so that-work activities can continue in the RV pool area.
- b. ' The Reactor Internals are being worked at this' time and cannot be :
covered.
~
c.
The Reactor Head has been cleaned and covered.
'd '. Bags have been placed-over each-C.E.D.M. to protect against airborn
. contaminants.
e.
NISCO initiated -a nonconformance report on access control of the Reactor Head. As corrective action on the NCR,,a wooden barrier was -
constructed around ' the Reactor Head area to replace the wire. The Reactor upper internals are being controlled at tlur same access entrance as the Reactor Vessel,
~
f.
The Safety Engineer that was controlling access to ~ the Reactor Vessel and Core Support Barrel has ~been terminated. - These areas are 'now' being-adequately. controlled.
g.
NISCO has cleaned the Reactor Vessel and components and is making every effort to maintain the level of. cleanliness required.
h.
NISCO has cleaned the Reactor Vessel Head and is making every effort to maintain the level of _ cleanliness required.
l Corrective Action Taken'to-Preclude Rep'etit' ion
- In addition to the daily housekeeping surveillance, ~ NISCO QC_ will perform a
~
weekly in-depth surveillance of 'all NSSS Components ito verify that the required degree of cleanliness is.beind? maintained.
-The Safety Engineers have been trained ~and indoctrinated in the requirements
-of access control.
Safety Eng'ineers ' Nave been instructed to report to the Superintendent any deficiencies in housekeeping.
Date When Full Corrective Action Was Achieved May 20, 1982 l
C.
Failure to Follow Periodic Maintenance Instructions for Electrical Equipment Criterion V of 10CFR50, Appendix B, requires that activities af fecting safety be performed in accordance with the prescribed procedures _ or instructions, f
LP&L Procedure ME-4-702, Revision 0, " Routine Electrical Maintenance during Construction Phases," paragraph 8.1.5 ' requires the meggering aof l
motors af ter October 26, 1981.
Gulf Engineering Equipment Maintenance Records for CCW Pump Motors, l
HPSI Pump Motors, and LPSI Pump Motors require monthly meggering of the motors after October 26, 1981.
t
e-Mr. G. L. Madsen Page 4 Contrary to the above, the NRC inspector's review of maintenance and startup records on March 3 and 4,1982, revealed that HPSI system (60A) and the LPSI system (60B) were released to LP6L without the periodic maintenance require-ments (megger testing) being current.
After release to LP6L, the maintenance requirements (monthly megger testing) were not performed at the appropriate intervals for the IIPSI, LPSI, and CCW pump motors.
LP6L Startup Group indicated that even though ME-4-702 (3/20/81) existed, they had not initiated the maintenance program to the date of this inspection.
This is a Severity Level IV Violation (Supplement II.E).
The following information is submitted:
Gulf Engineering Company Corrective Action Taken and Results Achieved Ebasco authorized rental of megger in January, 1982. Upon receipt of megger, Culf Engineering commenced meggering on equipment requiring this activity.
Ebasco Engineering evaluated the lack of meggering on Nonconformance Report W3-3353. The results of this evaluation indicate motors incurred no damage as a result of the lack of meggering.
Corrective Action Taken to Preclude Repetition Gulf Engineering released this equipment to LP6L on the following dates:
IIPSI Released 12/11/81 LPSI Released 2/2/82 CCW Released 11/23/81 CMI requirements became the responsibility of LP6L Maintenance on the above dates.
Date When Full Corrective Action Was Achieved Release dates as stated above.
l LP6L Maintenance i
Corrective Action Taken and the Results Achieved
(
[
a.
Implemented the Preventative Maintenance (PM) Program (including meggering per procedure ME-4-702, Rev. 0) for the subject motors on:
l 1)
IIPSI (A):
3-20-82
- 5) LPSI (B) :
3-5-82
- 2) llPSI (B):
3-7-82
- 6) CCW (A):
3-8-82
- 3) IIPSI ( AB) :
3-18-82
- 7) CCW (B):
3-8-82
- 4) LPSI (A):
3-5-82
3-8-82 Megger results on all subject motors were within established acceptance criteria.
l l
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Mr. G. L. Madsen Page 5 b.
Audited all System / Component Releases for equipment not yet included in FM program on 3-7-82 and scheduled PM implementation.
Corrective Act_ ion Taken to Preclude Repetition The program was established for release notification to PM scheduling group on 3-7-82.
Specific instructions, on this program were given to the PM group on 3-7-82.
Date When Full Corrective Action Will Be Achieved As of 3-20-82, PM program was implemented on the HP I, LPSI and CCW motors.
Very truly yours, V
. f. M n G. D. McLendon Senior Vice President CDMcL/LLB/grf
'~
UNITED' STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
Louisiana Power & Light Company
) -Docket No. 50-382 Waterford 3 Steam Electric Station
)
AFFIDAVIT G. D. McLendon'being' duly sworn, hereby deposes and says'that'he'is Senior Vice President of Louisiana Power & Light _ Company; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached response (W3K82-0309) to the Notice of Violation identified in NRC Inspection Report 82-05; that he is familiar with the content thereof; and that the' matters set forth therein are true and correct to the best of his knowledge, information and' belief.
.A Md 4-~
G. D. McLendon Senior Vice President
' STATE OF LOUISIANA)) ss l
PARISil 0F ORLEANS )
Subscribed and swoyn tp before me, aJ otaryJ ublic in and for the Parish and State above named this 4# day of J t/A/r_
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[NotaryPublic My Commission expires b/ /7/l
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