ML20151E235

Notice of Violation from Insp on 880501-0617.Violation Noted:Start Air Sys Actuated Using Inappropriate Work Instructions & Deficiencies Identified in Safety Sys Operating Procedures &/Or Component Identification Labeling

ML20151E235
Person / Time
Site:	Waterford
Issue date:	07/18/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20151E230	List: ML20151E226 ML20151E235 ML20151E239
References
50-382-88-13, NUDOCS 8807250422
Download: ML20151E235 (2)

Text

p _- _

gl APPENDfX A NOTICE OF VIOLATION Louisiana Power & Light Company Docket: 50-382

'Waterford Steam Electric Station, Unit 3 Operating License: NPF-38 During an NRC inspection conducted May 1 through June 17, 1988, three violations of NRC requirements were identified. The first violation' involved a failure to provide 'and-implement adequate work instructions for work on safety-related components. The second violation involved a failure to implement-quality assurance procedures. A failure to identify and correct deficiencies was identified as the third violation. In accordance with the "General Statement of Policy and . Procedure for NRC Enforcement Actions,"

10 CFR Part 2, Appendix C (1988), the violations are listed below:

A. -Inadequate Maintenance Work Instructions Technical Specification 6.8.1.a requires written procedures to be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Regulatory Guide 1.33 requires procedures appropriate to the circumstances for performing maintenance on safety-related equipment <

Procedure UNT-7-005, Revision 2,'"Cleanliness Control," is an approved procedure tha' requires cleanliness control requirements to be established when opening emergency diesel generator air systems.

Contrary to the above, on May 11, 1988, control air valves were manipulated, the starter system disconnected, and the start air system actuated using work instructions that were not appropriate in that they did not include these tasks and they did not require the implementation of cleanliness controls.

This is a Severity Level IV violation. (Supplement I) (382/8813-01)

B. Failure to Implement Quality Assurance Procedures Criterion II of Appendix B to 10 CFR Part 50 states, in part, that a quality assurance program shall be documented in procedures and carried out in accordance with those procedures.

Quality Assurance Program Procedure QAP-012, Revision 6 "Corrective Action," requires initiation of a Quality Notice when conditions adverse to quality are identified.

Contrary to the above, Quality Assurance Inspection Report 88-012, dated April 12, 1988, noted that several wires of hydrogen analyzer "A" had been landed at the wrong terminal points and accepted by quality assurance inspectors during the repalcement of the hydrogen analyzer. No Quality 8807250422 000718 PDR ADOCK 05000302 G. PNU

a 2, 2

Notice had been initit.ted on this condition which is adverse to quality as of June 15, 1988, when the NRC inspector reviewed the work documentation.

This is a Severity Level IV violation. (SupplementI)(382/8813-02)

C. Failure to Identify and Correct Deficiencies

-Criterion XVI of Appendix B to 10 CFR Part 50 states, in part', that measures-shall be established to assure that conditions adverse to '

quality, such as deficiencies, are promptly identified and corrected, and that the causes be determined and corrective action taken to preclude repetition.

Contrary to the above, NRC inspectors identified deficiencies in safety system operating' procedures and/or component identification labeling during ten inspections performed from February 1, .1986, through May 31,

, 1988. Again, on June 7,1988, the NRC inspector identified procedural and component identification labeling deficiencies with the hydrogen analyzer system. Licensee management has failed to establish adequate measures to independently. identify, correct, and preclude repeated deficiencies with safety system procedures and component identification labeling.

This is a Severity. Level ;V violation. (SupplementI)(382/8813-03)

Pursuant to the provisions of 10 CFR 2.201, Louisiana Power & Light Company is hereby required to sa5mit to this office within 30 days-of the date of the letter transmitting tnis Notice, a written statenent or explanation in reply, including for each violation: (1) the reason for the violation if admitted, (2) the corrective steps which have been taken and the results achieved,

.(3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is shown, con?,ideration will be given to extending the response time.

Dated at rlingto Texas, this / ay of 1988 y- n - -, -_ - - - .