ML20114D440
| ML20114D440 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/30/1984 |
| From: | Cook K LOUISIANA POWER & LIGHT CO. |
| To: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20114D436 | List:
|
| References | |
| W3P84-2386, W3P84-2424, NUDOCS 8501310314 | |
| Download: ML20114D440 (12) | |
Text
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c Louisimma 2 O W E R & L I G H T ! New c-LEANS LOUISWA 4.ao.-o~o.1 m.
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. (504) 3SEH2345 MIDDLE SDUTH UTIUTIES SYSTEM August 30, 1984 W3P84-2424 0-3-A35.02.01 3-A20.27
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Mr. John T. Collins Regional Administrator, Region IV gg) g g ggd U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive f)
Suite 1000 Arlington, TX 76011
SUBJECT:
Louisiana Power & Light Comppny Waterford 3 SES Docket No. 50-382 NRC Inspection Report 84-25
REFERENCES:
- 1) NRC letter dated 7/31/84, J.E. Gagliardo to R.S. Leddick, LP&L.
- 2) Documentation of Telephone Communications dated 8/30/d4, G.E. Wuller to E.H. Johnson, NRC Region IV (attached)
Dear Mr. Collins:
This is to confirm the extension requested for the Louisiana Power and Light Company response to the violations 8425-01 and 8425-02 of the reference (1) letter.
In accordance with the extension verbally granted by Mr. E.H. Johnson per the attached reference 2, LP&L will provide responses by September 13, 1984.
Yours very truly,
/
K.W. Cook Nuclear Support & Licensing Manager KWC/GEW/ss Attachment cc:
E.L. Blake, W.M. Stevenson, J.E. Gagliardo, D.M. Crutchfield, J. Wilson, G.L. Constable, E.H. Johnson 8501310314 850128 PDR ADOCK 05000382 PDR G
1 DOCUMENTATION OF TELEPHONE COMMUNICATIONS DATE:
8/30/84 T
1:00 ENDS P.M.
PARTY CALLING:
G.E. Wuller / -
LP&L (Name)+
(Company)
Chief Reactor Projects Branch 1 PARTY ANSWERING:
E.H. Johnsoa NRC Region IV (Name)
(Company)
SUBJECT:
Extension Request-FILE:
3-A1.04.01 NRC Inspection Report-84-25 (Violations)
SUMMARY
(INCLUDING DECISIONS AND OR COMMENTS) 1.
LP&L requested an extension of the response to URC on Violation 8425-01 and 8425-02 from August 30, 1984 to September 13, 1984. Extension was requested to provide additional time needed to develop corrective steps and for QA validations of responses.,-
- 2. ~ Mr.E.H.JohnsonverballygranteEtheextension.
2 ACTION REQUIRED:
LP&L to provide response to violations by September 13, 1984.
DISTRIBUTION: n _ R. Toddick. F.J. Drumraond, R.P. Barkhurst, T.F. Gerrets, D.E. Dobson r_U. Onnk. R.11. Nelson. 9.W. Herrin, K.L. Brewster, W.fi. Morgan, R.F. Burski, M. A. Triggs, L.F. Storz, R.A. Savoie, Administrative Support, Nuclear Records Ebasco - J. Debruin, NRC - G.L. Constable, E.11. Johnson, Region IV 4
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- W3P84-2386-8/30/84 t'
- Page l'of 10 T
ATTACHMENT
'LP&L RESPONSES TO VIOLATIONS AND NRC INSPECTION REPORT 84-25 A.
VIOLATION NO. 8425-01 Licensee Document Controls for Vendor Manuals and Technical Data 10CFR Part 50, Appendix B, Criterion V, requires, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include approrriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
Contrary to the above, the licensee had not required procedures to be issued to assure that Ebasco review and approve vendor manuals and technical data prior to use; to assure that manuals are not changed =
'after issue without approval; to assure that uncontrolled manuals are not used; to assure that maintenance required to maintain qualification of' safety-related equipment is accomplished; and to assure that Combustion Engineering manuals and Availability Data Program (ADP)
. Technical Bulletins are obtained, verified as accomplished, controlled, and used for maintenance as applicable..
RESPONSE TO VIOLATION
=
Corrective Steps Taken and Results Achieved
. 1. -The LP&L' Operations Quality Assurance Department is currently
- performing an audit of the LP&L Document Contro1' System. :As part of this audit, an overa11' assessment of the Vendor Manual Control-Program is being performed. This assessment will' review the past and present problem areas and attempt to define any programmatic:
weakness. 'It will also include recommended short and long term corrective actions.
2.; LP&L is developing a program, based on the results of the F
Operations Quality Assurance audit and the six specific areas of violation outlined in Section 4.0 of'the subject Inspection Report, to assure compliance with ~ 10CFR50, 6ppendix B,' Criterion V.
3.
LP&L participate'd in the Nuclear Utilities Task Action Committee (NUTAC) for NRR' Generic Letter 83-26, Section 2.2.2.
The NUTAC developed a. Vendor Equipment' Technical Information Program (VETIP) to establish a more formal interaction among the' major organizations involved with commercial nucisar power generation.
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.W3P84-2386-8/30/84 Page 2 of 10
~ w Corrective' Steps Which Will Be Taken
- 1.
The results of the LP&L Operations Quality Assurance audit will be evaluated by LP&L management and appropriate corrective actions will be taken to assure compliance with 10CFR50, Appendix B, Criterion V.
2.-
Based on'the evaluation of the LP&L Operations Quality Assurance audit and the corrective actions identified in response to the six specific areas of violation outlined in Section 4.0 of the subject Inspection Report, the Vendor Manual Control Program will be finalized and implemented to assure compliance with 10CFR50, LAppendix B, Criterion V.
- 3. - LP&L will implement the VETIP using the guidelines developed by the NUTAC..
Date When Full Compliance Will Be Achieved
'1.
The results of the LP&L Operations Quality Assurance audit will be evaluated by 10/19/84.
2.
The LP&L Vendor Manual Control Program will be finalized.and
' implemented by 12/31/84.
3.. The VETIP wil1~be implemented by 11/15/85.
- RESPONSES TO SPECIFIC INSPECTION REPORT SECTION'4.a VIOLATION RELATED ITEMS.
4.a Maintenance - Lack'of Procedures for Control of Vendor Instruction Manuals and Other Technical Data 4.a.1 Apparent Use'of Unapproved ~ Manuals Corrective Steps Taken and Results Achieved 1.
By letter W3B84-0607, dated 8/8/84, LP&L requested a status of the review and approval of the technical manuals submitted to Ebasco by letter dated 11/30/82 and that Ebasco develop a program to
' expedite turnaround in their technical manual review and approval process.-
Corrective Steps Which'W111 Be Taken.
1.
LP&L will review the technical manuals in Document Control-to identify;any additional-technical manuals which may require either LP&L or Ebasco review and approval.
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, 3P84-2386-W 8/30/84' Page 3 of:10 2.
Ebasco will' review and approve the remaining technical manuals identified by letter dated' 11/30/84 which will include technical manual 457000469.
3.
Any technical manuals identified in 1 or 2 above which are disapproved by either LP&L or Ebasco will be dispositioned as " uncontrolled", thereby restricting their use for site activities.
Date When Full Compliance Will Be Achieved The above actions will be complete by 3/31/85.
4.a.2 Unapproved Channes to Manuals Corrective Steps Taken and Results Achieved 1.
The checklist generated during the review of technical manual'457000468 was based on.a review of copy "003".
This checklist was subsequently copied and placed in all copies of the technical manual (copies 1 through 8) andf all copies were compiled to ensure compatibility.. The; reviewers statement that " copies 1 and 2 should'be deleted" was interpreted as " copies 1 and 2 should be updated to include the information reviewed against copy y
"003."
2.
Vendor manuals have been purged from Maintenance Department spaces and screened for any uncontrolled manuals. Uncontrolled manuals have been returned to Document Control for inclusion in the Vendor Manual Program.
3.
Maintenance Directive'#6, issued 7/24/84, provided clarification of the requirements for use of vendor
-technical manuals at Waterford 3 for the Maintenance Department. An'onsite method of identifying a mechanism to make changes to vendor i-manuals is outlined therein.
4.
A memorandum was issued to'al1~ maintenance-supervisory and salaried personnel on 8/21/84 to emphasize Executive Directive'016, "Use of Controlled Documents".'
5.
Procedure UNT-5-002, Condition Identification and p
Work Authorization, has been revised to provide more guidance on the'use of vendor manuals in.
l.
performing corrective maintenance.
-W3P84-2386.
8/30/84 Page 4 of 10 Corrective Steps Which Will Be Taken 1.
Vendor Manual 457000468 will be re-reviewed as indicated in Item 4.a.1 (Corrective Steps Which Will Be Taken).
2.
Procedure MD-1-004 and MD-1-007 (concerning preventive maintenance) will be revised to provide more guidance on the use of vendor manuals -in determining preventive maintenance requirements.
3.
Procedure MD-1-014, Conduct of Maintenaace, will be revised to provide more general guidance on the use of vendor manuals in conducting maintenance activities.
4.
Vendor manuals will be purged from remaining LP&L Nuclear Operations departments and screened for uncontrolled manuals. Uncontrolled manuals will be returned to Document Control for inclusion in the Vendor Manual Program.
Date When Full Compliance Will Be Achieved 1.
MD-1-004 and MD-1-007 will be revised by 11/1/84.
2.
MD-1-014 will be revised by 11/1/84.
3.
Uncontrolled manuals identified during the vendor manual purge of LP4L Nuclear Operations departments will be returned to Document Control by 12/31/84.
4.a.3 Use of Unapproved Manuals Corrective Steps Taken and Results Achieved
- 1. 'The 583 vendor manuals were recalled on 1/31/84 only because'their review did not address whether the vendor manuals were-safety-related or non-safety-related. These manuals have subsequently been returned to a " controlled" status due to an LP&L management decision to not mark vendor manuals "nafety-related" or "non-safety-related."
2.
Contrary to the inspectors' finding, LP&L does document the issuance of Information Only/ Uncontrolled documents via an " Uncontrolled Document Request Form" identified in PMP-002,-
Document Control. This form requires justification and supervisory signature.
- ' 8/30/84 Page 5 of 10 3.
Vendor manual 457001467 was obtained through issuance of an LP&L Purchase Order (L34206D);
therefore, the manual does not require Ebasco review and approval.
4.
The review of vendor manuals with access numbers higher than 457001259, that pertain to Ebasco purchase orders, has been performed. This review encompassed 638 vendor manuals, of which 79 pertained to-Ebasco Purchase Orders.
74 of the 79 manuals have been processed through the Ebasco Mechanical Document Review and Control (EMDRAC) system.
5.
QP-006-001, Document Control, was issued 8/31/84 and addresses the manner by which " uncontrolled" vendor manuals can be used at Waterford 3.
Corrective Steps Which Will Be Taken 1.
PMP-306..will be changed to delete the requirement to mark vendor manuals " safety-related" or "non-safety-related."
2.
Vendor manuals will be reviewed to delete reference to their being " safety-related" or "non-safety-related."
3.
A review of vendor manuals with access numbers greater than 457001259 will be performed in accordance with 4.a.1 (Corrective Steps Which Will Be Taken).
4.
Document Control personnel will be instructed that issuing vendor manual 457001467 was not in accordance with PHP-002 and that future issuances of Information Only/ Uncontrolled documents must be documented.
Date When Full Compliance Will Be Achieved 1.
PMP-306 will be changed by 10/31/84.
2.
Vendor manuals which have been marked.
" safety-related" or "non-safety-related" will be changed to delete these references by 3/31/85.,
3.
The-review and approval of vendor manuals with access numbers greater than 457001259 will be performed by 3/31/85.
4.
Document Control personnel will be reinstructed on-the requirements of PMP-002 by 9/30/84.
I.
W3P84-2386 8/30/84 Page 6 of 10 4.a.4 Lack of Procedural Controls for Combustion Engineering Supplied Manuals Corrective Steps Tsken and Results Achieved 1.
LP&L has verified that vendor manual 9102041 is located in the EMDRAC listing under the Purchase Order for Instruction Manuals (GI525817) as EMDRAC
- 5817-4146, LP&L Film No. 457000146.
No corrective action is necessary because vendor manuals which are sub-vendor to CE are submitted to Ebasco EMDRAC for control.
Ebasco reviews the vendor manuals for applicability to Waterford 3 in accordance with Ebasco procedure E-6, Section 4.4.
This procedure requires the lead Ebasco discipline engineer to review the manual for responsiveness to contract requirements and send a letter to CE accepting or rejecting the vendor manual.
If rejected, the manual is held by Ebasco until an acceptable vendor manual is submitted.
If accepted, the applique stamp is completed and the vendor manual is sent to LP&L.
Corrective Steps To Be Taken None Date When Full Compliance Will Be Achieved Full compliance is met.
4.a.5 Lsek of Procedural Controls for Technical Changes Corrective Steps Taken and Results Achieved 1.
LP&L has obtained the CE ADP Infobulletins issued since 1978 and is presently reviewing them for applicability to Waterford 3.
Corrective Steps Which Will Be Taken 1.
Complete the review of the significant CE ADP Infobulletins for applicability to Waterford 3 anel initiate any corrective actions as a result of this review.
2.
PMP-004, Vandor Manual Control, will be revised to unsure incoming vendor technical information is properly reviewed by PMP-306, Engineering Review, for applicability to Waterford 3.
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,1 W3P84-2386'
'8/30/84 Page 7 of 10 Date When Full Compliance Will Be Achieved 1.z The review of the significant CE ADP Infobulletins and initiation of recommendations for any corrective actions will be complete by 12/1/84.
2.
Revision-of PMP-004 will be complete by 10/31/84.
4.'s.6 Lack of Procedural Controls to Assure Use of Manual i
Requirements in Site Procedures Corrective Steps Taken and Results Achieved 1.
ME-4-810. Low Voltage Power Cable Terminations and Splices, has been deleted.
2.
ME-4-809 Low Voltage (600 Volts and Less) Power and Control Cable / Conductor Terminations and
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Splices, has been revised to cover the crimper requirements that were in ME-4-810.
Illegible pages are now legible. ME-4-809 now reflects only crimpers presently controlled by the M&TE lab.-
3.
The crimper instruction sheets delivered to LP&L-in the boxes with the crimper devices were not considered to be " Vendor Manuals" by M&TE personnel. Those instruction sheets have now been forwarded to Document Control for entry into the Controlled Document System.
4 4.
Instruction knual 457000237 was reviewed and found to be arked safety-related on the knual Review Check?.ize. The reviewers signature crossed these blocka, barely obscuring the safety-related detern.ination.
5.
Vendor knual 457000237 contains Instruction knual B-3645 for Reliance Electric Nuclear Service Class IE Motors for frame sizes of 180 to 5000, which includes LP&L's motors with a frame size of 449.
Page 6 of this manual, under '.' Recommended Lubricant", states, "For motors operating in l
ambient temperature shown below. use the following lubricant or its equal", and continues with a recommendation of Chevron Oil SRI-2.
6.
CMI #174 has not been used to lubricate the containment fan coolers motor' bearings since system
' transfer to the Startup Organisation.
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W3P84-2386 8/30/84 Page 8 of 10 Corrective Steps Which Will Be Taken 1.
MI-5-118, Calibration of Crimpers, is being revised to reflect only crimpers presently on site and in the M&TE Program.
2.
ME-4-811, Medium and High Voltage Power Cable Terminations and Splices, will be revised to reflect only crimpers presently in use by the LP6L Electrical Department.
3.
LP&L will acquire Mobil Oil documentation concerning the equivalency of SHC-32 against Chevron Oil SRI-2.
This documentation will be evaluated and an acceptable lubricating oil will be chosen.
4.
A program to verify adequate documentation of decisions concerning preventive maintenance with respect to any deviations from vendor recommendations, as prescribed in vendor manuals, will be impicmented.
Note: Appendix B-FF14597, sheet 2 of 2 has been ordered for vendor manual 457000237.
Date When Full Compliance Will Be Achieved 1.
HI-5-118 will be revised by 10/1/84.
2.
ME-4-811 will be revised by 10/1/84.
3.
Mobil SHC-32 evaluation will be complete and an acceptable lubricating oil will be designated by 10/15/84.
4.
The review of deviations from verdor recommenda-tions, as prescribed in vendor manuals for safety-related and environmentally qualified equipment, is scheduled for completion by 4/30/85.
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[ W3P84-2386 8/30/84 Page 9 of 10 B.
VIOLATION 8425-02 Failure to Invoke the Requirements of ANSI N45.2.5-1974 in the Maintenance Procedure for Tightening Structural Fasteners 10CFR Part 50, Appendix B, Criterion V, requires " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instrus.tions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished".
The licensee in their FSAR, Section 17.2, commits to Regulatorf Guide 1.33, Rev. 2, February 1978, and ANSI N18.7-19;o as endorsed.
ANSI N18.7-1976, Section 5.2.7, for maintenance and modifications, requires mandatory use of ANSI N45.2.5-1974, "ANS Supplementury QA Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants.
N45.2.5-1974, Section 5.4, "High Strength Bolting", contains qualifications, inspection, and calibration requirements for installation of structural bolting.
Contrary to the above, licensee maintenance procedure, " Structural Bolt Tensioning" MM-6-012, Revision 0, approved May 26, 1982, did not reference nor contain all applicable requirements of ANSI N45.2.5, Section 5.4, relative to verification of botting crew qualifications, calibration, inspection of bolting, and cbecking the consistent acceptability of bolting crews prior to beginning tightening operations.
RESPONSE TO VIOLATION Corrective Steps Taken and Results Achieved 1.
LP&L has verified MM-06-012 " Maintenance Procedure Structural Bolt Tensioning", Revision 0, Change 2 was issued 5/23/84 to reference ANSI N45.2.5-1974.
Corrective Steps Which Will Be Taken 1.
MM-06-012 will be revised to require inspection to verify that the bolting crews understand the meaning of " snug tight".
" Snug Tight" is now specified and defined in MM-06-012. Verification of this condition will be performed by qualified personnel.
8/30/84 Page 10 of 10 2.
MM-06-012 will be revised to require a calibration of the wrenches from "once each working day" to "twice each working day".
The calibration of the automatic cutoff impact wrench in step 8.2.5.1 of MM-06-012 will be the same as identified in ANSI N45.2.5-1974.
3.
The inspection of bolting, as identified in ANSI N45.2.5-1974 will
.be satisfied by placing QC hold points in the body of procedure MM-06-012.
4.
For the record, Plant Maintenance has not performed structural bolting at Waterford 3, to date. However, procedures to perform this work were developed and will be revised.
In addition, LP&L does not have any automatic cutoff impact wrenches.
Date When Full Como11ance Will Be Achieved MM-06-012 will be in compliance with Section 5.4 of ANSI N45.2.5-1974 by 11/1/84.
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