ML20127H344
| ML20127H344 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 01/15/1993 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-93-0106, W3F1-93-106, NUDOCS 9301220292 | |
| Download: ML20127H344 (5) | |
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W3f1-93-0106 A4.05 QA January 15, 1993 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report 92-26 Reply to Notice of Violation Gentlemen:
In accordance with 10CfR2.201, Entergy Operations, Inc. hereby submits in.the response to the violation identified in Appendix A of the subject inspection Report.
If you have any questions concerning this response, please contact B.R. Loetzerich at (504) 739-6636.
l Very truly yours, f,
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RfB/8RL/ssf Attachment cc J.L. Milhoan, NRC Region-IV D.L. Wigginton, NRC-NRR R.B. McGehee N.S. Reynolds-NRC Resident inspectors Office 2 i O l 9 i
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Page 1 of 4 ATTACHMENT 1 ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLA 110N-IDENTIFIED IN APPENDIX A OF INSPECTION REPORT 92-26 VIOLATION No. 9226-01 i
FAILURE TO PROPERLY IMPLEMENT _ THE CONSUMABLE CONTROL PROGRAM Criterion V of Appendix B to 10 CFR part 50 and the licensee's approved quality assurance program description require that th_e activities-affecting quality shall be prescribed by, and ac_complished in-accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.
Administrative Frocedure UNT-007-003, Revision 8, " Control of Consumable Materials", exempts the control room from its consumable material control requirements and requires that only approved consumables of the Plant Consumable Materials Report be used in the consumable materials controlled area, which includes the reactor auxiliary building.
Contrary to the above, two examples of f ailure to properly implement the consumable control program were identified.
1.
On October 25, 1992, a licensed operator used a. commercial contact cleaner for coin machines and electronic equipment to clean Engineered Safeguards Control Panel-CP-8.- This caused damage to-16 safety-related control switches, making'the switches inoperable.
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This action was not controlled or prevented by documented _.
instructions or procedures. Procedure UNT-007-003 was inadequate in that the control room was exempted from its requirements.
2.
On November 17, 1992, the inspector found.a-tube of glue and a can of odor counteractant-in Switchgear Room B in the reactor auxiliary building, and on November 19, 1992, the inspector found a can of' insecticide;inthemainsteamisolation-valveroom(alsopartofthe reactor auxiliary building). None of these products were on the Plant Consumable Materials Report.
1 This is a severfty Level IV. violation.
..m Attachment to W3F1-93-0106 Page 2 of 4
RESPONSE
(1)
Reason for the Violation
-.i Entergy Operations, Inc. admits this violation and believes that two different root causes existed for the examples listed in the cited violation.
The root cause of the first example, involving an incident in the control room on October 25, 1992, is an inadequate procedure in that UNT-007-003, " Control of Consumable Materials," exempts the control room as a Consumable Material Control Area (CMCA).
It is believed-that this condition resulted in tne incorrect application of a consumable material on a control room panel, causing damage to the control panel switches.
The root cause of the second example, involving the November, 1992, discoveries of unapproved consumables in CMCAs, is inappropriate action in that personnel did not adhere to the requirements of UNT-007-003.
UNT-007-003 states that plant personnel are responsible for ensuring that consumable materials introduced into a CMCA are approved in the Plant Consumable Materials Report and are labelled accordingly, or are accompanied by authorized Consumable Materials-Exception forms. However, this was not done.
l (2)
Corrective Steps That Have Been Taken and the Results Achieved on October 25, 1992, Condition Identification No. 283138 was generated to replace the damaged control panel switches and an Operational Experience Report was generated to alert other operating shiits of this event.
By October 30, 1992, the knobs and covers of the damaged control switches had been replaced and-the switches could operate freely. On November 6, 1992, additional. control panels were inspected for damaoed switches.
The inspection involved a 50 percent sampling of certain control panels (LCP-48, CP-1, CP-2, CP-4, CP-13, CP-14, CP-18,.and CP-33) and a 100 percent sampling of othercontrolpanels(LCP-43,EDG-AandEOG-8). - No damaged switches were identified.
Additional corrective actions taken as a result of the damaged--
control panel switches included the issuance of Standing Instruction (SI) 92-11~and Significance Occurrence Report (SOR)92-019.
SI 92-11 was issued to identify the approved cleaner for cleaning the-exterior surfaces of control panels. - SOR 92-019 was : issued to describe the incident _and to document immediate corrective actions.-
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_a Attachment to l e W3F1-93-0106-Page 3 of 4 i
In response to the November,1992, discoveries of unapproved consumables, the unapproved consumables were immediately removed from the CMCAs. Additionally, Quality Assurance performed a survey to verify that only approved and properly labeled consumable materials were located in radiation controlled areas of the reactor auxiliary building and reactor containment building wing areas.
The survey did not identify any consumable materials that were not approved and labeled per UNT-007-003.
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(3)
Corrective Steps Which Will Be Taken to Avoid further Violations Six specific actions are planned to prevent recurrence:
1.
UNT-007-003 will be revised to define the control room and control panels as a CMCA.
Furthermore, additional-emphasis will be placed on evaluating a consumable material's compatibility.with electrical and plastic components during the approval process.
2.
Signs that identify the control room as a CMCA will be posted on control room entrances.
3.
A task force of representatives from the Chemistry, Operations and Maintenance Departments will be assembled to walk down L
CMCAs and to search for unlabeled and unapproved consumable L
materials.
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4.
Site personnel will be informed of this violation and the revisions to UNT-007-003.at "all hands" meetings.
These-meetings will accentuate the procedural requirement that consumable materials used in a CMCA must be approved and labelled.
-5.
An industry survey will be conducted to identify enhancements that can be implemented at Waterford 3 to improve and create l
tighter chemical controls.
These enhancements will be l
evaluated against the Waterford 3 program and implemented as j
appropriate.
l 6.
Chemistry will interf ace with departments that use consumable.
I materials to identify and approve, as appropriate, those-l-
consumable materials that are currently uncpproved.
If l
consumable materials are identified that can not be approved,-
then actions will'be taken to assure.that they.are not used in CMCAs.
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Page 4 of 4 i
i (4)
Date When full Compliance Will Be Achieved Corrective steps 1 through 4 will be completed by February 26, 1993.
Corrective steps 5 and 6 will be completed by Hay 28, 1993.
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