ML20244B851

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/89-06. Supplemental Response to Violation Re Control of safety-related Fastener Torque Requested in 30 Days

ML20244B851
Person / Time
Site:	Waterford
Issue date:	06/06/1989
From:	Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dewease J LOUISIANA POWER & LIGHT CO.
References
NUDOCS 8906140005
Download: ML20244B851 (2)

See also: IR 05000382/1989006

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In Re' ply Re'fer To:

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Docket: 50-382/89-06

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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 April 27, 1989, in response to our letter and

Notice of Violation dated March 28, 1989. We have reviewed your reply and find ,

it responsive to the concerns raised in Examples 2 and 3 of our Notice of l

Violation. We will review the implementation of your corrective actions

during a future inspection to determine that full compliance has been achieved

and will be maintained. j

. A problem similar to Example 1 of the Notice of Violation was previously

identified in NRC Inspection Rcoort 50-382/87-31. Your corrective action for

Violation 382/8731-03 (Item 2) included a revision to the mechanical maintenance

procedure in question with no reference to checking other procedures for

similar problems. Again, your response to Violation 382/8906-01 (Example 1)

included corrective action to revise another procedure in question, with no

reference to checking other procedures. Your actions to preclude further

violations related to torque requirements appear to have been focused on the

specific problems previously identified rather than the broader issue of

recurring noncompliance in the control of safety-related fastener torque

requirements. NRC Inspection Reports 50-382/89-01 and 89-08 also contain

Notices of Violation relative to fastener torque requirements.

Please provide a supplemental response, within 30 days of the date of this

letter, addressing actions you will take to avoid further violations in this

area. Additionally, please note that your response did not address the failure

to torque the coupling bolts in accordance with the vendor manual requirements

as cited in Example 1 of the Notice of Violation.

Sincerely,

Original Signed By

E$ad/. 0 A A' e >^

James L. Milhoan, Director

Division of Reactor Projects

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. Louisiana Power & Light Company -2-

cc:

Louisiana Power & Light Company

ATTN: R. P. Barkhurst, Vice

.

'esident

Nuclear Operations

P.O. Box B

Killona, Louisiana 70066

Louisiana Power & Light Company

ATTN: J. R. McGaha, Jr... Plant Manager

P.O. Box B

K111ona, Louisiana 70066

Louisiana Power & Light Company

ATTN: R. F. Burski, Manager, Nuclear

Safety & Regulatory Affairs

317 Baronne Street

P.O. Box 60340

New Orleans, Louisiana 70160

Louisiana Power & Light Company

ATTN: L. W. Laughlin, Site

Licensing Support Supervisor

P.O. Box B

Killona, Louisiana 70066

Louisiana Power & Light Company

ATTN: G. M. Davis, Manager, Events

Analysis Reporting & Response

P.O. Box B

L Killona, Louisiana 70066

Middle South Services

ATTN: Mr. R. T. Lally

P.O. Box 61000

New Orleans, Louisiana 70161

Louisiana Radiation Control Program Director

bec to DMB (IE01)

bec distrib. by RIV:

RRI

R. D. Martin, RA

DRP

Section Chief (DRP/A)

RPB-DRSS

MIS System

Project Engineer (DRP/A) RSTS Operator

DRS

RIV File Lisa Shea, RM/ALF

D. Wiggini.on, NRR Project Manager (MS: 13-D-18)

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NEW ORLEANS, LOUISIANA 70160 * (504) 595-3100

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April 27, 1989 i

W3P89-3006 ,

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U.S. Nuclear Regulatory Comarission ---

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ATTN: Document Control Desk

Washington, D.C. 20555 g hb - g' {

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Subject: Waterford 3 SES i

Docket No. 50-382 1

i MAY - 3 l989

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License No. NPF-38 l!~ <;" -~

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NRC Inspection Report 89-06

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Gentlemen:

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

submits in Attachment'I the response to the Violation identified in

Appendix A of the subject Inspection Report.

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If you have any questions concerning this response, please contact

T.J. Gaudet at (504) 464-3325.

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Very truly yours,

.

R.F. Burski

Manager

Nuclear Safety & Regulatory Affairs

RFB:TJG:ssf

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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

E.L. Blake

W.M. Stevenson

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"AN EQUAL OPPORTUNITY EMPLOYER"

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Attachment to

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Page 1 of 5

ATTACIDfENT 1

LP&L Response te the Violation Identified in Appendix A

of Inspection Report 89-06

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VIOLATION NO. 8906-01

Failure to Follow Procedures

Criterion V of Appendix B to 10 CFR Part 50 and the Approved Quality ,

Assurance Plan for Waterford 3 require that activities affecting quality be  !

prescribed by documented instructions, procedures, or drawings. l

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Contrary to the above, three examples of failure to adhere to procedures j

are delineated below: .

1. Work Authorization 01028798 required the B auxiliary component cooling . .

water (ACCW) pump coupling to be reassembled per B&W Pumps Instruction l

Manual 457000254.

Contrary to the torquing requirements included in and referenced by

B&W Pumps Instruction Manual 457000254, the torquing requirements were

not adhered to when the coupling was reassembled on February 16, 1989.

2. Procedure UNT-5-003, Revision 7, " Clearance Request, Approval, and

Release," requires release and removal of a red danger tag before

operating the attached valve.

Contrary to the above, on February 15, 1989, a maintenance technician

operated danger tagged Valve CVC-189 A/B (Charging Pump A/B drain

line).

3. Step 12 of Attachment 10.3 to Procedure OP-903-011, Revision 4, "High

Pressure Safety Injection Pump Reservice Operability Check," requires

placing the B low pressure safety injection (LPSI) pump switch to

"0FF" prior to performing a test start of the A/B high pressure safety

injection (HPSI) pump.

Contrary to the above, on February 4,1989, operating personnel did

not place the I LPSI pump switch to "0FF" prior to a test start of the

A/B HPSI pump.

This is a Severity Level IV violation.

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PISPONSE

(1) Reason For The Violation

Example 1

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The root cause for example 1 of this violation was an inadequate work

instruction. Work Authorization (WA) 01028798 was generated to

perform an alignment check on ACCW Pump 1B. The steps necessary to

accomplish this task were delineated in the Mechanical Maintenance

Attachment Work Signoff Sheet which was included in the WA package.

~~ As required by Step 5 of the Work Signoff Sheet, the pump coupling was

disassembled in accordance with Maintenance Procedure MM-06-004,

" Shaft Coupling Alignment And Belt Tensioning," and Vendor Instruction

Manual 457000254, "B&W Pumps". In Step 6 of the Work Signoff Sheet,

Maintenance personnel were required to perform an alignment check per

MM-06-004 and realign the pump couplicg if required. When performing -

the check, mechanics found the pump alignment to be out of

specification. Consequently, pump realignment became necessary. To

realign the pump the pump motor base bolts had to be loosened. After

properly aligning the pump, the base bolts had to be retightened.

Because the Work Signoff Sheet did not list any torquing

requirements, the bolts were not tightened to any specific torque

value. This action was in direct conflict with Vendor Instruction

Manual 457000254 which states that torque values for motor base bolts

are from 280 to 300 foot pounds.

Example 2

The root cause for example 2 of the violation was personnel error in

failing to follow Plaut Administrative Procedure UNT-5-003 due to a

miscommunication between the Nuclear Auxiliary Operator (NAO) and the

Control Room Supervisor (CRS). UNT-5-003 provides the controls

necessary to safely remove and restore equipment and/or systems from

service to protect personnel and prevent equipment damage. Steps

5.9.3 through 5.9.6 of UNT-5-003 identify the proper sequence for

partial release of danger tags (tags which when in place prohibit the

operation of equipment or systems that could jeopardize personnel

safety or endanger equipment).

While performing maintenance on the A/B Charging Pump under WA

01032239, operation of some header drain valves (CVC-189 A/B and

CVC-193 A/B) became necessary in order to drain the pump. The NA0 in

the field contacted the Control Room to obtain verbal authorization to

partially remove the tags and reposition the drain valves. The CRS,

who misunderstood the request and did not realize that the valves had

been danger tagged, verbally authorized the repositioning of the

valves. Under the supervision of the NAO, the valves were then

operated by Maintenance personnel. These actions were in direct

conflict with UNT-5-003. .

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Example 3

The root cause for example 3 of this violation was personnel error due

to a failure to follow Surveillance Procedure OP-903-011. OP-903-011

provides the instructions for verifying the operability and valve

alignme1t of HPSI Pump A/B each time it is placed in or taken out of

service in place of HPSI Pump A or B (as required by Technical

Specification Surveillance Requirement 4.5.2.1). On 2/4/89,

Operations personnel performed OP-903-011 to allow substitution of  ;

HPSI Pump A/B for HPSI Pump B. This action was accomplished through

the use of Attachment 10.3 to OP-903-011 (Revision 4), "HPSI Pump AB

Replacing HPSI Pump B Data Sheet." As indicated in Step 12 of

Attachment 10.3 (currently Step 17 in Revision 5 to OP-903-011), the

control switch for LPSI Pump B is to be momentarily turned to "0FF".

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This action avoids an unnecessary start of LPSI Pump B while testing

HPSI Pump A/B. Once HPSI Pump A/B testing is complete, the control

switch for LPSI Pump B is restored to " NEUTRAL" for automatic

operation. On this particular occasion, Operations personnel violated

Step 12 of Attachment 10.3 by leaving the LPSI Pump B control switch

in " NEUTRAL". Consequently, LPSI Pump B inadvertently started after *

the test signal was actuated.

(2) Corrective Steps That Have Been Taken And The Results Achieved

Example 1

On 2/22/89, the Maintenance Department generated a quality notice (QN

QA-89-059) to formally address and resolve the concern. Based on an

evaluation of the maximum torque value that would have resulted from

the incorrect tightening of the base bolts, Maintenance Engineering

determined that bolt / stud damage had not occurred. Consequently, at

Maintenance Engineering's recommendation, the motor base bolts were

released and then retorqued properly to 280 foot pounds per the Vendor

Instruction Hauual. The torquing was witnessed by Operations Quality

Assurance.

To prevent recurrence of a similar event, the Mechanical Maintenance

Attachment Work Signoff Sheet, which appears as a generic attachment

to repetitive WAs that are generated to perform this task, has been

revised. Step 6 of the Work Signoff Sheet now requires the following:

- Perform alignment check per HH-06-004 and

- Realign if required and Torque motor bolts 280 to 300

ft./lbs.

Example 2

On 2/16/89, the Operations Department generated a quality notice (QN

QA-89-049) to formally address and resolve the deficiency. The NA0

who was responsible for this deficiency was counselled. On 2/17/89,

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the Operations Superintendent issued a letter (LP&L Letter W3089-0025)

to Operations personnel to reemphasize the policies on danger tags and,

valve operation. The letter specifically stated the following: 1)

Only operators shall operate valves; 2) Danger tagged valves shall not

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be operated; and 3) The tags must be released and documented.as such

beforehand. The letter also expressed that violation of these

policies will result in disciplinary action.

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Since this was the second instance of a danger tagged valve being I

operated contrary to procedure, the plant manager felt it prudent to l

issue a memorandum to Nuclear Operation's personnel reiterating the

above policies. The memorandum stated the following:

(1) Unless specifically authorized by an approved plant procedure or

a WA signed by the SS/CRS, N0 one except Operations personnel

shall operate a valve.

(2) NO one shall operate a DANGER tagged component.

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a. The purpose of danger tagging equipment in to protect

personnel and prevent equipment damage.

b. ON,LY Operations Department personnel shall hang or remove

Danger Tags. '

c. Once a component is positioned and Danger tagged, NO one

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shall reposition that ccmponent, until the Danger tag is

properly cleared in accordance with UNT-5-003, Clearance

Request, Approval, and Release,

d. Personnel authorized to request or hold clearances shall be

trained in the use of the clearance procedure.

e. Notify your Supervisor if you are assigned to work on a

component that has a Danger tag on it. Danger tagged

components are boundary componentr, to protect you or

equipment and should not be touched.

f. Repositioning of Danger tagged components is grounds for

termination.

To ensure that this information would be brought to the attention of

plant personnel, a discussion on the two events was provided during

the April Waterford 3 Safety Meetings on 4/4/89 and 4/6/89.

Exa.mple 3

After the event, LPSI Pump B ran on recirculation and was promptly

secured. Because this event was reportable as an unplanned manual

Engineered Safeguards Features actuation, a Licensee Event Report (LER

89-003-00) was submitted on March 3,1989. The personnel responsible

for the procedural violation were counselled by the Asr'stant

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Operations Superintendent, emphasizing a more cautious i thorough

approach when following procedures. Additionally, on 2, J/89, the

Operations Superintendent issued a letter (LP&L Letter W3089-0026) to

Operations personnel which addressed the inadvertent start of LPSI

Pump B and discussed the need to rededicate efforts toward procedural .

compliance.

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' (3)'Co'rrective Steps Which Will Be Taken To Avoid Further Violations

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Examples 1, 2, and 3

", Based on the information provided above, LP&L feels confident that-the

necessary corrective actions have been iarplemented to ensure that a

violation for these types of~ procedural deficiencies will not recur.

(4) Date When Full Compliance Will De Achieved

Examples 1, 2, and 3

LP&L is currently in full compliance.

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