ML20215D364
| ML20215D364 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/08/1986 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Dewease J LOUISIANA POWER & LIGHT CO. |
| References | |
| NUDOCS 8612160340 | |
| Download: ML20215D364 (2) | |
See also: IR 05000382/1986016
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In Reply Refer To:
Docket: 50-382/86-16
Louisiana Power & Light Company
- ATTN:
J. G. Dewease, Senior Vice President
Nuclear Operations
N-80
317 Baronne Street
New Orleans, Louisiana
70160
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Gentlemen:
Thank you for your letter of November 13, 1986, in response to our letter
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and the attached Notice of Violation dated October 16, 1986. As a result of
our review, we find that additional information,~ as discussed with your
Mr.-G. E. Wuller during a telephone call on December 1,1986, is needed.
Specifically, for Violation 382/8615-05, Part II you have provided no
assurance that there are no other anchor bolts for which the nuts were
installed with less than full thread engagement.
If other anchor bolts were
incorrectly installed, than an appropriate evaluation of the seismic
qualification of each affected piece of equipment would be expected.
Please provide the supplemental information within 20 days of the date of this
letter.
Sincerely.
OrIEfact Slaned Dy
'J. E. Ga3:l:rdo
J. E. Gagliardo, Chief
Reactor Projects Branch
cc:
Louisiana Power & Light Company
ATTN:
G. E. Wuller, Onsite
Licensing Coordinator
P. O. Box B
Killona, Louisiana
70066
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Louisiana Power & Light Company
ATTN:
R. P. Barkhurst, Plant Manager
P. O. Box B
Killona, Louisiana
70066
Middle South Services
ATTN: Mr. R. T. Lally
P. O. Box 61000
tiew Orleans, Louisiana
70161
Louisiana Power & Light Company
ATTN:
K. W. Cook, Nuclear Support
and Licensing Manager
317 Baronne Street
P. O. Box 60340
New Orleans, Louisiana
70160
Louisiana Radiation Control Program Director
bectoDMB(IE01)
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R. D. Martin, RA
SectionChief(RPB/C)
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ProjectInspector(RPB/C)
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17 BARONNE STREET
P. O. BOX 60340
POWER & LIGHT
NEW ORLEANS, LOUISIANA 70160
(504) 595 3100
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November 13, 1986
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Mr. Robert D. Martin
Regional Administrator, R gion IV
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U.S. Nuclear Regulatory Commission
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611 Ryan Plaza Drive, Suite 1000
Arlington, TX 76011
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Subject: Waterford 3 SES
Docket No. 50-382
License No. NPF-38
NRC Inspection Report 86-16
Dear Mr. Martin:
Attached is the Louisiana Power & Light Company (LP&L) response to
Violation Nos. 8616-02, 8616-03 and 8616-05 which were cited in the subject
NRC Inspection Report.
If you have any questions on the responses, please contact G.E. Wuller,
Onsite Licensing, at (504) 464-3499.
Very truly yours,
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K.W. Cook
Nuclear Support & Licensing Manager
KWC KLB ssf
cc: NRC, Director, Office of I&E
G.W. Knighton, NRC-l.7R
J.H. Wilson, NRC-NRR
NRC Resident Inspectors Office
B.W. Churchill
W.H. Stevenson
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"AN EDUAL OPPORTUNITY EMPLOYER"
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ATTACHMENT
to W3P86-2800
Sheet 1 of 8
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LP&L RESPONSE TO VIOLATION NOS. 8616-02, 8616-03 and 8616-05
VIOLATION NO. 8616-02
Technical Specification (TS) 6.8.1.f requires that written procedures
covering the implementation of the fire proteccion program be established
and implemented.
FP-1-017. Revision 2. " Transient Combustibles and
.Hesardous Materials " is a procedure that implements a portion of the fire
protection program. Sections 6.1.18 and 6.3 of FP-1-017 require that
combustible liquids shall be placed in safety cane and stored in designated
cabinets when not in use.
Contrary to the above, on August 19, 1986, six safety cans, each partially
full of combustible liquid, were found unattended in areas containing
safety-related equipment.
This is a Severity Level IV violation.
RESPONSE TO VIOLATION
(1) Reason for the Violation
Appendix R to 10CFR50 Section K.1 and 2 mandates a licensee to
maintain in effect administrative controls to:
(1) Govern the
handling and limitation of the use of ordinary combustible materials,
combustible and flammable gases and liquids.... and (2) Prohibit the
storage of combustibles in safety-related areas or establish
designated storage areas with appropriate fire protection. Waterford
3 complies with this requirement by way of implementation of FP-1-017
Transient Combustibles and Hazardous Materials. Specifically, section
6.3.2 states, " Approved safety cans (not exceeding 5 gallon capacity
or 2 sallon capacity for class I liquids) shall be used for storing,
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transporting and dispensing quantities of flammable and combustible
(to include lubricating oils) liquids in buildings"... Section 6.3.3
goes on to say, "When not in use, safety cans containing flammable and
eombustible liquids shall be stored in an approved flammable liquids
storage cabinet"...
Due to a significant oil leak on the Main Steam Isolation Valves
(MSIV) it became necessary to temporarily maintain a small quantity of
Fyrquel lubricating oil adjacent to the MSIV skid.
Fyrquel has a
flashpoint of > 455'T and is therefore classified as a Class IIIB
combustible liquid per NFPA-30, Flammable and combustible liquids
code. The addition of this oil in the area constitutes a minor fire
hazard at best.
In fact. Roof Area E has an area of 3,216 ft*, with
an msgumption of 6 full 5 gallon cans of lube oil yielding a total of
4.65E BTU or 1.44E8 BTU /FT8 this would produce a fire duration of
less than 2 minutes for total consumption by fire. Therefore, the
danger of safety-related equipment was negligible.
IF
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Sheet 2 of 8
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(2) Corrective Action That Has Been Taken
As a conservative means of corrective action an approved flammable
liquids cabinet has been placed on the +46 RAB adjacent to the MSIV
area so as to allow for the long-term storage of oil in the area
should expeditious oil addition become necessary. In the past the
rate of consumption of the oil could more accurately be described as
usage rather than storage.
In which case, a safety can would be the
required method or container.
(3) Corrective Action That Will Be Taken
No additional action is felt necessary in that the addition of the
flammable liquids cabinet will serve as extra conservatism in
providing verbatim compliance with the requirements of FP-1-017.
(4) Date When Full Compliance Will Be Achieved
Waterford 3 is in full compliance at the present time.
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ATTACHMENT
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Sheet 3 of 8
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VIOLATION NO. 8616-03
10 CFR 73.55(b)(3)(1) requires, in part, written security procedures "which
detail the duties of guards, watchmen, and other individuals responsible
for security..."
The Waterford 3 physical security plan implements the requirements of 10 CFR 73.55(b)(3)(i).
PS-90-101, Revision 3, " Security Department Organization, Duties and
Responsibilities," in part, implements the Waterford 3 physical security
plan by detailing the duties and responsibilities of security personnel
including the secondary alarm station console operation (SASCO) and the
security officer (S0). These duties and responsibilities include monitoring
equipment on the SAS console in order to fully implement the site security
program.
Contrary to the above, the duties and responsibilities specified in
PS-90-101, Revision 3, were not properly implemented in that, on August 29,
1986, the NRC inspector observed that the SAS console was not being
properly monitored in that publications not related to the job are being
read by the SASCO in the SAS.
This is a Severity Level IV violation.
RESPONSE TO VIOLATION
(1) Reason for the Violation
LP&L acknowledges that on August 29, 1986, the Secondary Alarm Station
(SAS) Console Operator (CO) did have unauthorized reading material on
his post, the SAS.
The Waterford 3 SES Security Force utilized a Shift Supernumary to
tplieve security personnel for lunch and other breaks. The
supernumary is normally dispatched through the SAS to job assignments.
On August 29, 1986 the supernumary was between job assignments and
went to the SAS to await further instructions. Enroute to SAS, the
supernumary stopped in the mens restroom. While in the restroom, the
supernumary found the sports section of the daily newspaper. He
picked up the newspaper and took it with him to the SAS.
Upon arrival (approximately 0953 hours0.011 days <br />0.265 hours <br />0.00158 weeks <br />3.626165e-4 months <br />) at the SAS the supernumary
started reading the newspaper. He handed part of the newspaper to the
SASCO who also read the paper. The resident NRC inspector observed
these actions and reported same to the Shift Supervisor. The Shift
Supervisor relayed this information to the Security Shift Supervisor
at approximately 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br />.
(2) Corrective Action That Has Been Taken
Immediately upon notification Security supervisory personnel were
dispatched to SAS to investigate the complaint. The supervisors
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Sheet 4 of 8
arrived in the SAS at 1004 hours0.0116 days <br />0.279 hours <br />0.00166 weeks <br />3.82022e-4 months <br />. Upon arrival in the SAS, the
supervisors confirmed the NRC complaint; both the SASCO and the
supernumary had part of the newspaper in their possession. Both
officers were relieved from duty and placed on suspension pending an
investigation.
Disciplinary action was administered, as follows:
SASCO:
Two weeks suspension without pay.
A 90 day reduction in pay and grade to that of a
nuclear watchperson.
(At the end of the 90 day
probation period, the officer will be eligible to
return to Security Officer status).
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SUPERNUMARY:
One week suspension without pay.
A 90 day reduction in pay and grade to that of a
nuclear watchperson. Reduction suspended, and
officer placed on 90 day probation.
Waterford 3 SES has a written " Security Force Disciplinary Standard".
This standard prohibits having unauthorized reading material while on
duty and was in place at the time of the occurrence. Both officers
had signed statements that they had read and understood the policy.
However, we reissued this disciplinary standard to contract security
personnel.
(3) Corrective Action That Will Be Taken
No futher action required.
(4) Date When Full Compliance Will Be Achieved
Action was taken immediately upon notification to Security supervisory
personnel.
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ATTACHMENT
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Sheet 5 of 8
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VIOLATION NO. 8616-05
10CFR50, Appendix B, Criterion X required, in part, that, "A program for
inspection of activities affecting quality shall be established and
executed by or for the organization performing the activity to verify
conformance with the documented instructions, procedures, and drawings for
accomplishing the activity..."
Contrary to the above, the Louisiana Power and Light Company inspection
program was not adequately executed to ensure proper installation of
certain components as described below:
1.
The front and rear anchor welds for the hydroben recombiner power
supply panel B were not installed as required by the installation
drawing.
2.
One of the anchor bolt nuts for the 120V nuclear instrumentation
. static uninterruptible power supply 3MBS panel did not have the
minimum thread engagement required by installation specifications.
This is a Severity Level IV violation.
RESPONSE TO VIOLATION - PAkT I
(1) Reason for the Violation
Nonconformance Report W3-6744 was issued on 8/19/83 by the electrical
subcontractor denoting that the equipment installation checklist for
the Hydrogen Recombiner Panel was not completed, and the installation
could not be reverified due to inaccessibility to the interior of the
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panels.
The reasons for the violations are:
(1) the description of the noted
deficiency (NCR-W3-6744) was not concise as to which particular
installation checklists were not completed (2) the recommended
disp 6sition provided by the electrical contractor provided no proposed
fix to the problem so as to indicate what the deficiency was and (3)
the element of interface being significantly reduced as a result of
the electrical contractor destaffing; were all contributing factora
that caused the mismatch between problem description and recommended
resolution, for the noted NCR.
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To explain the aforementioned and how this could happen, the following
information is provided. The noted NCR was submitted by the
electrical contractor to the Architect-Engineer for logging and
further processing as required by program.
Per procedure, adequate
supporting documentation was to accompany the NCR. Since no
checklists were submitted with the NCR, it appears that the NCR was
forwarded to the Electrical Engineering Department for review and
evaluation of disposition (since it was written by the electrical
subcontractor). At the time of the evaluation, it appears that the
A-E Electrical engineer understood the lack of installation
verification to mean that the internals of the cabinet could not be
verified as completed rather that the physical mounting and attachment
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ATTACHMENT
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Sheet 6 of 8
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of the equipment to its foundation as indicated by the checklists.
This could be attributed to the fact that the incomplete checklists
were not provided as NCR attachment so as to specifically explain the
deficiency.
The A-E Electrical engineer who evaluated the NCR provided
documentation attesting to the fact that the internals of the cabinet
had been correctly installed as the electrical acceptance tests were
successful. The NCR was then closed by an A-E Quality Assurance
engineer based on the documentation provided by the electrical
engineer which supported the acceptance of the cabinet internals,
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electrically.
(2) Corrective Action That Has Been Taken
A.
Temporary Alteration Request No.86-095 was issued on 9/4/86 to
correct the hardware deficiencies associated with the B Hydrogen
Recombiner and work was completed on 9/5/86.
B.
Station Modification Package (SMP) 1712 was initiated after it
was determined that the seismic qualification of the Power Supply
Panel B was deficient. This station modification was issued to
revise the design drawings to accurately reflect the as built
configuration of the B panel. The update of the drawings was
complete on 10/13/86.
C.
NCR-W3-6744 was annotated with SMP-1712 to show reference to the
document which actually provided corrective action.
D.
Nonconformance reports which were generated during the
construction phase of the project were reviewed for technical
adequacy. The scope of this review included a sampling of NCR's
dispositioned and/or evaluated by the electrical engineer and
those closed by the QA Engineer who both had provided input to
NCR-W3-6744. Also NCR's submitted by the electrical contractor
which showed deficiencies as a result of missing or incomplete
.
' documentation were reviewed. The intent of this documentation
review was to verify that no other conditions similar to this
violation exists as a result of misrepresented documentation.
There were a total of thirteen (13) NCR's dispositioned or
evaluated by the Electrical engineer that were reviewed to verify
the disposition or evaluation adequately addressed the
nonconforming condition.
In all cases, the disposition or
evaluation did adequately address problem description.
There were a total of twenty-six (26) NCR's closed by the QA
engineer that were reviewed for adequate closure. The review
determined that adequate justification for closure of the NCR's
did exist.
There were also twenty-six (26) NCR's that described incomplete
or missing documentation by the electrical contractor that were
reviewed. Many of these NCR's were the same ones closed by the
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Sheet 7 of 8
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QA engineer who closed NCR-W3-6744. It was noticed that these
NCR's contained a more clear and concise definition of the
problem and an amplified recommended disposition when compared to
the NCR that documented the Hydrogen Recombiner deficiency. In
all NCR's reviewed, it was determined that the proposed
resolution did match the deficiency and the corrective action
taken was adequate.
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(3) Corrective Action That Will Be Taken
No further action is deemed necessary.
(4) Date When Full Compliance Will Be Achieved
A.
SMP-1712 was complete on 10/13/86.
B.
Physical work was complete on 9/5/86 via the Temporary Alteration
Request No.86-095.
C.
Review of the NCR's was completed on 10/24/86.
D.
NCR-W3-6744 was referenced with SMP-1712 notation on 10/31/86.
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ATTACHMENT
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Sheet 8 of 8
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VIOLATION NO. ~ 8616-05 Continued
RESPONSE TO VIOLATION - PART II
(1) Reason for the Violation
Based on available records, LP&L does not believe that the
circumstances in this instance are sufficient cause for LP&L to be
cited as having violated 10CFR50 Appendix B, Criterion X.
Although
two of the anchor bolt nuts on SUPS panel 3MB-S were found upon recent
inspection to have less than full thread engagement, there is
documented evidence that a general QA inspection was performed on the
subject anchor bolts following rework of the panel's installation via
CIWA-83791', in accordance with the applicable inspection procedure
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(WQC-169). This inspection indicated that all bolts were tightened at
the time and that the work was acceptable. The inspection report no.
5-25-1 wording was of a general nature, and did not individually
address verification of each specific criterion of the applicable
construction procedure (CP-697). These criteria did require that a
minimum of one thread of an anchor bolt must protrude through the nut,
but did not require any torquing for ASTM A307 anchor bolts.
The
inspection report shows no indication of not having met the minimum
thread engagement criterion.
(2) Corrective Action That Has Been Taken
LP&L has performed calculations to reconfirm the seismic integrity of
the as-found installation of the panel.
These calculations were based
on a thorough inspection of the panel mounting, including measurement
of thread engagements, bolt angles, and nut-to-base plate contact
surface areas. Results of these calculations show that the seismic
qualification for this panel is still valid.
(3) Corrective Action That Will Be Taken
Ne further action is deemed necessary.
(4) Date When Full Compliance Will Be Achieved
The calculations performed to reconfirm the installation was
acceptable were completed on 9/10/86.