W3P86-0014, Responds to Violations Noted in Insp Rept 50-382/85-28. Corrective Actions:Procedure UNT-5-002 Revised on 860113 to Clarify Requirements & Responsibilities Re Corrective Maint Process

Responds to Violations Noted in Insp Rept 50-382/85-28. Corrective Actions:Procedure UNT-5-002 Revised on 860113 to Clarify Requirements & Responsibilities Re Corrective Maint Process

ML20140E846
Person / Time
Site:	Waterford
Issue date:	01/31/1986
From:	Cook K LOUISIANA POWER & LIGHT CO.
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20140E842	List: IR 05000382/1985028 W3P86-0014, Responds to Violations Noted in Insp Rept 50-382/85-28. Corrective Actions:Procedure UNT-5-002 Revised on 860113 to Clarify Requirements & Responsibilities Re Corrective Maint Process W3P86-0032, Responds to Violations Noted in Insp Rept 50-382/85-33. Corrective Actions:Meeting Called on 860117 to Resolve Problem of Measuring & Test Equipment Accumulating in Radiation Control Area
References
W3P86-0014, W3P86-14, NUDOCS 8603280212
Download: ML20140E846 (6)

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l OUISIANA 44e oe-o~oe smeer . ao oox eooe 2 O W E R & L I G H T / NEW ORLEANS LOUISIANA 70174-8000 . (504) 3GO-e345 MIDDLE SDUTH UTIUTIES SYSTEM January 31, 1986 W3P86-0014 A4.05 QA Mr. Robert D. Martin Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 ~

Arlington, TX 76011 @ M D M %q

Subject:

Waterford 3 SES FFB-31986  !

Docket No. 50-382 Yfi

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License No. NPF-38 ft NRC Inspection Report 85-28 Attachment A gives the Louisiana Power & Light Company (LP&L) responses to Violations numbered 8528-01 and 8528-02 which were cited in the subject NRC Inspection Report. Additionally, as requested, LP&L addresses in Attachment B the concern of excessive number of procedure errors.

If you have any questior.s on the responses, please contact G.E. Wuller, Onsite Licensing, at (504) 464-3499.

Very truly yours, 8603280212 860319 PDR ADOCK 05000382 G PDR K.W. Cook Nuclear Support & Licensing Manager KWC:KLB:sms Attachments cc: NRC, Director, Office of I&E G.W. Knighton, NRC-NRR J.H. Wilson, NRC-NRR NRC Resident Inspectors Office B.W. Churchill W.M. Stevenson (L-OlkQb J

ATTACHMENT A'

. to W3P86-0014 Sheet 1 of 4 LP&L RESPONSES TO VIOLATIONS IN INSPECTION REPORT NO. 85-28 VIOLATION NO. 8528-01 Technical Specification 6.8.1 requires, in part, that written procedures be implemented for activities in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. . Performance of maintenance on safety-related equipment is one of the activities specified in 3

Appendix A, Regulatory Guide 1.33, Revision 2. Licensee Procedures UNT-5-002, " Condition Identification and Work Authorization";

MM-6-003, Rotating Equipment Repair"; and QP-10-001, " Inspection" were three procedures required to accomplish the work specified in Condition Identification Work Authorizations (CIWA) 022173 and 022169 which involved Charging Pumps A and AB.

Contrary to the above, UNT-5-002, MM-6-003, and QP-10-001 were not properly implemented in that:

1. UNT-5-002, Attachment 6.2, page 7 required the work group supervisor and shift supervisor / control room supervisor initials to be noted in block 29 of the CIWA. This was not done for CIWAs 022173 and 022169.

2. UNT-5-002, Attachment 6.3, page 7 required that the applicable technical manual number and sections be entered in block 28 of the CIWA. This was not done for CIWAs 022173 and 022169.

3. UNT-5-002 required that block 48 of the CIWA contain the applicable part numbers. For CIWA 022173 this block was completed but not with part numbers.

4. MM-6-003, Section 4.0 and Section 5.0 state that precautions and initial conditions be included in the CIWA. These items were not included for CIWAs 022173 and 022169.

, 5. CIWAs 022173 and 022169 required hold points as described in QP-10-001 for verifying cleanliness of components prior to reassembly. These hold points were not incorporated in the maintenance and should have been per the guidance of QP-010-001.

This a Severity Level V violation.

RESPONSE TO VIOLATION (1) Reason for the Violation If Admitted Parts 2 and 3 of the violation have been classified as errors of omission caused by inattention to detail in the use.of Procedure UNT-5-002. It should be noted that Part 2 had the correct technical manual referenced and only the section number was missing.. In Part 3 the P.O. number was on the CIWA and the part number can be traced using the P.O. number. 'Part 1 is not a valid concern because troubleshooting instructions were not part of the CIWAs, therefore, the' initialing and dating were not required. Part 4 is not a valid concern because this item addresses the requirement of including i

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ATTACHMENT A

. to W3P86-0014 Sheet 2 of 4 Reason for the Violation If Admitted (Cont'd) special precautions, limitations and special initial conditions, where as, none were required for the two CIWAs identified. Part 5 is not a valid concern because the employment of cleanliness control forms in CIWA work packages provides sufficient means to document cleanliness inspections required during maintenance and QC hold points did not.

need to be incorporated.

(2) Corrective Actions That Have Been Taken Procedure UNT-5-002 has recently been revised (1/13/86) to clarify requirements and responsibilities related.to the corrective maintenance process by subdividing the procedure section into discrete subsections such that individuals performing a portion of the CIWA process know exactly what they are required to do. Detailed training was given to explain the new procedural requirements and format prior to the implementation of.the procedure. As a result of the procedure change and training, violations of omission such as these, should be curtailed in the future.

(3) Corrective Actions That Will Be Taken No further corrective actions are planned.

(4) Date When Full Compliance Will Be Achieved Training was completed on January 10, 1986 and the revised procedure became effective January 13, 1986.

ATTACHMENT A

' to W3P86-0014 Sheet 3 of 4 VIOLATION NO. 8528-02 Technical Specification 3.7.4 requires, in part, that two independent trains of ultimate heat sick cooling towers shall be OPERABLE each with a wet mechanical draft cooling tower water basin.with a minimum water level of 97% (-9.86 MSL). Further, ACTION b. of Technical Specification 3.7.4 requires that, with both towers inoperable due to basin lew wat'er level, one tower has to be restored to OPERABLE status-vithin I hour and both restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the initial loss; otherwise be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and. COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Contrary to the above, on November 26, 1985, it was determined that the minimum level had not been maintained in either water basin for a-significant percent of the time since the unit initially entered MODE 4 and the requirements of ACTION b, of Technical Specification 3.7.4 were not followed.

This is a Severity Level IV violation.

RESPONSE TO VIOLATION (1) Reason for the Violation If Admitted A calibration procedure caused the. level instruments for the wet cooling towers to' indicate an acceptable water level when in fact the basins had less water than the required Technical Specification minimum. When the Control-Room personnel were notified that the wet cooling tower basin level instruments may have had a calibration problem, the basins were filled to the~over-flow level. The Technical Specification was met in that action was taken to completely fill the basins as soon as the potential problem was identified.

The procedure used to calibrate these instruments (MI-5-622, Wet Cooling Tower A & B Level Instrumentation) was written specifically.

for these instruments. The data used to generate the procedure was in error, however, there is no reason.for LP&L to believe that this concern would be a generic problem.

Although the basin water level for both Wet Cooling Towers was below

'the Technical Specification level for a time longer than allowed by Technical Specifications, the volume of water in the basin was greater than the volume-for the most limiting event described in the Final Safety Analysis Report.

(2) Corrective Actions That Have Been Taken Both wet cooling tower basin water level transmitters were recalibrated on November 27, 1985. After recalibration (CIWA-023709),

Plant Engineering evaluated the package to determine the required reference point changes. The reference point changes were implemented for "B" cooling tower basin on January 10, 1986 and for "A" cooling tower basin on January 16, 1986.

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ATTACHMENT'A to W3P86-0014

~ Sheet 4.of 4 (3) Corrective Actions That Will Be Taken

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, .No further changes are intended.

(4) Date When Full Compliance will be Achieved

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All corrective actions were completed on' January 16, 1985.

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, ATTACHMENT B to W3P86-0014 Sheet 1 of 1 In addition to the two violations identified in the' report, it was requested.that LP&L respond to the excessive number of procedure errors

-identified in paragraph 8 of Inspection Report No. 85-28. The following response is submitted:

This concerns the annunciator response procedures and includes problems such as setpoints not up-to-date and inconsistencies between similar procedures. The annunciator response procedures will be reviewed and changes made to correct these problems. The annunciator response procedures are used as the first step in troubleshooting a problem and identifying abnormal conditions.- The procedures, as a

.whole, are being reviewed at Waterford 3 for consistency and compatibility with the emergency operating procedures beginning with the off-normal procedures. We review these procedures biannually; however, the annunciator response procedures addressing safety-related annunciators will be reviewed by June, 1986. Changes will be made as necessary'in procedures that control set. points to ensure that a mechanism exists for timely inclusion of such changes in the annunciator response manual.

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