ML20154P980

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/88-13

ML20154P980
Person / Time
Site:	Waterford
Issue date:	09/26/1988
From:	Callan L Office of Nuclear Reactor Regulation
To:	Dewease J LOUISIANA POWER & LIGHT CO.
References
NUDOCS 8810030259
Download: ML20154P980 (2)

See also: IR 05000382/1988013

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SEP 26 Il2

In Reply Refer To:

Docket: 50-382/88-13

Louisiana Power & Light Company

ATTN: J. G. Dewease, Senior Vice President

Nuclear Operations

317 Baronne Street

New Orleans, Louisiana 70160

Gentlemen:

Thank you for your letter of August 17, 1988, in response to our letter and

Notice of Violation dated July 18, 1988. We have reviewed your reply and find

it responsive to the concerns raised in our Notice of Violation. We will review

the implementation of your corrective actions during a future inspection to

determine that full cortpliance has been achieved and will be maintained.

Sincerely.

Onginal Sgad Sp

l'. J: CALLAN

L. J. Callan, Director

Division of Reactor Projects

cc:

Louisiana Power & Light Iompany

ATTN: G. E. Wuller, Ons ite

Licensing Coordinator

P.O. Box B

Killona, Louisiana 70066

Louisiana Power & Light Company

ATTH: N. S. Carns, Plant Manager

P.O. Box B

Killona, Louisiana 70066

Middle South Services

ATTN: Mr. R. T. Lally

P.O. Box 61000

New Orleans, Louisiana 70161

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Louisiana Power & Light Company -2-

Louisiana Power & Light Company

ATTN: R. F. Burski, Acting Manager

Nuclear Safety and Regulatory

Affairs

317 Baronne Street

P.O. Box 60340

New Orleans, Louisiana 70160

Louisiana Radiation Control Program Director

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RRI R. D. Martin, RA

SectionChief(DRP/A) DRP

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Project Engineer, DRP/A RSTS Operator

RIV File D. Wigginton, NRR Project Manager

DRS Lisa Shea, RM/ALF

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August 17, 1988 W3P88-1270

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U.S. Nuclear Regulatory Comission

ATTN: Document Control Desk

Washington, D.C. 20555

Subj ect: Waterford 3 SES

Docket No. 50-382

License No. NPF-38

NRC Inspection Report 88-13

In accordance with 10CFR Part 2.201, Louisiana Power & Light hereby submits

in Attachment I the responses to the Violations identified in Appendix A of

the subject Inspection Report.

If you have any questions concerning these responses, please contact

L.W. Laughlin, Site Licensing Support, at (504) 464-3499.

Very truly yours,

yd

R.F. ski

Manager

Nuclear Safety & Regulatory Affairs

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Attachment

ec: * R.D. Martin, NRC Region IV/

J.A. Calvo, NRC-NRR

D.L. Wigginton, NRC-NRR

NRC Resident Inspectors Office

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W3P88-1270

Page 1 of 7

ATTACHMENT 1

LP&L Responses to Violations Identified in Appendix A

of Inspection Report 88-13

A. VIOLATION NO. 8813-01

Inadequate Maintenance Work Instructions

Technical Specification 6.8.1.a requires written procedures to be esta-

blished, 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 circums'tances

for performing maintenance on safety-related equipment.

Procedure UNT-7-005, Revision 2 "Cleanliness Control," is an approved

procedure that 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 manipu-

lated, 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 clean-

linese controls.

This is a Severity Level IV violation.

RESPONSE

LP&L acknowledges that this incident was a Violation of the guidelines

of Regulatory Guide 1.33 in that the work instructions for replacing

control air interface check valve EGA-421B were not detailed enough

relative to the circumstances.

(1) Reason For The Violation

The requirements for dispositioning a condition as "Troubleshoot"

when the failure mechanism or the reason for a degraded condition

cannot be detected easily are provided in Plant Operations Admini-

strative Procedure UNT-05-015. "Work Authorization Preparation and

Implementation". Since specific guidance for determining where to

differentiate between troubleshooting and rework is not provided in

the procedure, a conscientious decision has to be made by maintenance

personnel when in the field performing routine maintenance under a

specific work authorization. Because troubleshooting involves a

logical sequence of events which is determined by the outcome of a

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Page 2 of 7

previous step or action, specific troubleshooting instructions are

difficult to write in the planning process. In this incident, the

extent of work after valve replacement was not known or defined at ,

the time, so a statement to troubleshoot was included on the work

authorization in accordance with UNT-05-015.

The responsibilities and criteria for cleaning fluid systems and

associated components are provided in Plant Administrative Procedure

UNT-07-005, "Cleanliness Control". This procedure, which is based on

the guidance provided in Regulatory Guide 1.37 (Quality Assurance

Requirements for Cleaning of Fluid Systems and Associated Components

of Water-Cooled Nuclear Power Plants) and ANSI N45.2.1-1973 (Cleaning

of Fluid Systems and Associated Components for Nuclear Power Plants)

is written primarily to address fluid systems. Although the diesel

generator air system is listed as a Class "C" cleanliness system in

the attachment of UNT-07-005, the procedure does not realistically

address maintaining cleanliness in such an instrument and control

system. The inspection criteria detailed in the procedure are not

adequate for an instrument systems of such a small size Therefore,

maintenance personnel had the impression that the procedure did

not apply, as was the case cited in this inspection.

(2) Corrective Actions That Have Been Taken

Since the occurrence of this incident, a Maintenance Directive (No.

28) entitled, "Troubleshooting" was developed to provide guidance on

writing troubleshoot instructions and establishing limitations on

what can and cannot be done in the field on work authoritations

dispositioned as "Troubleshoot". The directive instructs Maintenance

personnel to contact their supervisor for clarification if it becomes

questionable as to whether or not a certain activity is allowed under

troubleshoot authority. The directive also points out that trouble-

shooting does not allow deviation from procedural requirements and

that complete and accurate documentation of all steps and actions

taken as well as observations noted is imperative.

With regard to cleanliness control during maintenance on instrument

and control tubing and air lines, Instrument and Control Planners

have been trained and instructed to include Cleanliness Control Forms

(Attachment 6.1 of UNT-07-005) into the work authorization packages

whenever breaking a system boundary.

(3) Corrective Actions To Be Taken

UNT-07-005 will be revised to include responsibilities for establi- '

shing and maintaining adequate cleanliness controls when performing

maintenance activities on instrument and control tubing.

Although not specifically part of the corrective actions for this

violation, it is worthwhile to note that beginning in September,

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1988, a pilot program entitled "Operation ZERO Deviations" will

be implemented at Waterford 3 in the areas of Operations, Mainte-

nance, Security, Heslth Physics and Chemistry. The intent of this

program is to emphasize procedure and work instruction compliance and

to instill in employees the importance of stopping work when neces-

sary as opposed to deviating from a procedure or instruction. This

program emphasizes management concern and efforts toward reducing

unauthorized procedure and work instruction deficiencies.

(4) Date When Full Compliance Will Be Achieved

UNT-07-005 will be revised by September 30, 1988.

B. VIOLATION 8813-02

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 21, 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 replacement of the hydrogen analyzer. No Quality

Notice had been initiated 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.

RESPONSE

LP&L acknowledges that this incident was a violation of criterion II

of Appendix B to 10CFR50 in that a Quality Notice (QN) should have been

issued in accordance with Quality Assurance Procedure QAP-012. "Corrective

Action" since a condition adverse to quality (incorrect wire terminations

that damaged equipment) existed.

(1) Reason For The Violation

Prior to April 20, 1988, terminations were made and verified by

QA Inspection to the Hydrogen Analyzer Sequencer Module. On April

20, 1988, during the performance of functional testing, damage to a

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transistor on a different module occurred. Upon troubleshooting, an

I&C technician found wires on the Hydrogen Analyzer Sequencer Module

to be incorrectly terminated. Subsequently, on April 21, 1988, the

following sequence of events took place: the work instructions were

revised to correctly terminate the Sequencer Module, the work was

completed per the revised work instructions and Quality Assurance

verified the rework and reterminations.

On April 22, 1988, the QA inspector learned from a cognizant member

of the Nuclear Operations Engineering Department that a design

construction package change (DCPC) was going to be issued to address

the wiring error. Based on the premise that the work instruction was

revised, the errors were corrected, a DCPC was to be issued and the

overall concerns were documented in Inspection / Observation Report

88-012,'which was dated April 21, 1988 but signed off by the inspec-

tor on April 22, 1988, the inspector believed that no further a'tions e

were warranted. Consequently, a QN was not issued by Quality

Assurance.

(2) Corrective Actions That Have Been Taken

Two QNs were issued on June 17, 1988 to document the errors made

during the implementation of SH 983. QN QA-88-075 was issued to

Operations QA for the inspection error and QN QA-88-080 was issued to

Nuclear Operations Engineering and Construction for the incorrect

wiring of the hydrogen analyzers. Corrective action taken by QA has

resulted in an emphasis by the Quality Inspection organization on

attention to detail involving inspections.

A training session on attention to details was presented to inspec-

tors on August 8, 1988. Inspectors were cautioned as to the

importance of recognizing, reviewing and understanding the inspection

requirements imposed on the work document. Inspectors were also

reminded to complete all the necessary steps when performing an

inspection. In addition, the ese of inspection observation reports

has been discontinued as a means of problem identification.

(3) Corrective Actions To Be_Taken ,

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Quality Assurance personnel will undergo lessons Learned Training.

Emphasis will be placed on the importance of paying attention to

detail and utilizing the corrective action systems that are currently

in place.

(4) Date When Full Compliance Will Be Achieved

Lessons Learned Training will be completed by September 30, 1988.

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C. VIOLATION 8813-03

Failure To Identify And Correct Deficiencies

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Criterion XVI of Appendix B to 10 CFR Part 50 states, in part, that

measures shall be established to assure that conditions adverse to i

quality, such as deficiencies, are promptly identified and corrected,

and that the causes be determined and corrective action taken to l

preclude repetition. ,

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Contrary to the above, NRC inspectors identified deficiencies in l

safety system operating procedures and/or component identification l

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' l

has failed to establish adequate measures to independently identify, i

correct, and preclude repeated deficiencies with safety system  !

procedures and component identification labeling. l

This is a Severity Level IV violation.

RESPONSE

LP&L acknowledges that this incident was a violation of Criterion XVI  !

of 10CTR Part 50, Appendix B in that adequate corrective actions have

not been taken to preclude repeated deficiencies with safety system (

procedures and component identification labeling. l

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(1) Reason For The Violation j

Plant Administrative Procedure OP-100-004, "UNID/EQ Tagging of

Plant Components", delineates the method for replacement of i

Unique Identification (UNID)/ Environmentally Qualified (EQ)  !

equipment tags and also provides the administrative requirements  :

for installation of new UNID/EQ tags. UNID tags which are hung I

as part of a design change are the responsibility of the ,

department or group that implements the change. Since there are ,

no requirements to verify that tags are hung correctly or to use l

controlled drawings for ensuring proper placement of tags, j

inconsistencies in the hanging of UNID tags have resulted.  !

(NOTE: The failure to implement the above requirements has  !

resulted in the incorrect hanging of various tags on the Hydrogen L

Analyzer as was stipulated in this inspection report.)

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Additionally, for components which are identified as not having

UNID numbers, the method in place for assigning a UNID to a compo-

nent, ensuring the UNID tag is hung properly and notifying the

cognizant work groups of this type of situation is not sufficiently

integrated to ensure the elimination of the type of problem described

in the violation. The current approach for addressing these items,

which involves the use of several procedures by several different

groups, has proven to be unreliable. This condition coupled with the

lack of a formal program to identify, correct and preclude deficien-

cies with safety system procedures and component identification

labeling is the basis for the violation.

(2) Corrective Actions That Have Been Taken

In early 1988, the responsibility for trending was transferred from

the QA department to the Event Analysis, Reporting and Response'

(EAR &R) organization, which reports directly to the Plant Manager.

In May,1988, using the QA Trending Program as a baseline, the EAR &R

organization established the Nuclear Operations Trending Program.

This program, which broadens the scope of that which was previously

trended, provides a method for collecting, correlating and analyzing

j corrective action reports in efforts to identify potentially signifi-

cant trands. The Program is utilized for the review and analysis of

Licensee Event Reports (LERs), KRC Reports Quality Notices, Noncon-

forming Condition Identifications, Discrepancy Notices and other

reports which identify incidents or occurrences to determine apparent

and/or root cause.

Plant Administrative Procedure UNT-6-014. "Root Cause Determination

and Trending", was approved in August, 1988. The specific purposes

of this procedure are to establish the requirements for the evalu-

ation and investigation of an event or condition for root cause

determination and to provide a method for the categorization of root

causes and their trending criteria. An adverse trend will be identi-

fled for recurring deficiencies. By the use of an Adverse Trend

Report, an adverse trend, which will include a summary of the defi-

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ciency, root causes and any recommendations, will be submitted to the

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appropriate Department Head, Group Head and Assistant Plant Manager.

The Department Head, with approval by the Assistant Plant Manager,

will be responsible for determining the necessary corrective actions.

After completion of the corrective actions, the item will be trans-

mitted to EAR &R for closure. Implementation of this procedure will

provide a significant enhancement to the existing trending program.

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(3) Corrective /etions To Be Taken

OP-100-004 is being revised to specifically address the repeated

tagging concerns regarding improper installation of UNID tags.

To alleviate inconsistencies that currently exist on two forms,

the forms vill be consolidated into one. This form, the UNID Tag

Replacement Form, will be used to tequest, hang and verify proper

placement of UNID tags. This procedure will also be revised to

require an individual, when hanging or verifying a UNID tag, to

refer to the primary source document for ensuring that the tag is

correctly placed. A procedural requirement will be implemented

to ensure that labeling and/or tagging deficiencies found during

lineups will be appropriately documented so that the necessary

corrective actions will be performed. To ensure that separate

procedures are not utilized by various departments, a Plant

procedure will be developed to cover all aspects of UNID taggirg.

Additionally, to ensure completeness of lineups in safety

systems, the existing Procedure Review Checklist in

Administrative Procedure OP-100-013, "Writer's Guide For -

Operating Procedures", will be revised to require that

valve / breaker lineups be verified with appropriate documentation.

Implementation of these actions coupled with the performance of

ongoing detailed system walkdowns in accordance with Administrative

Procedure OP-10-001, "Duties and Responsibilities of Operators on

Duty", will provide assurance that the procedures for safety related

systems reflect the actual plant configuration to the maximum extent

possible.

The above actions will address the present violation. However, to

provide additional assurance that repeated deficiencies with safety

system procedures and component identification labeling are mini-

mized, Management has set an objective, which is scheduled for

completien by December 31, 1989, to have applicable system engineers

perform walkdowns of the accessible portions of safety systems using

design documentation.

(4) Date When Full Compliance Will Be Achieved

Procedures OP-100-004 and OP-100-013 vill be revised by

September 30, 1988.

Development of the new procedure for UNID tagging is scheduled

for completion by 0, a mber 31, 1988.

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