ML20245A665
| ML20245A665 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 04/18/1989 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Dewease J LOUISIANA POWER & LIGHT CO. |
| References | |
| NUDOCS 8904250324 | |
| Download: ML20245A665 (2) | |
See also: IR 05000382/1989002
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=In Reply' Refer To:.
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Docket: .50-382/89-02
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Louisiana-Power & Light Company
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LATTN:."J. G. Dewea'se,-Senior Vice President
Nuclear Operations
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317 Baronne Street:
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New Orleans, Louisiana?'70160
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Gentler.;en:
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- Thank you for your letter of April 3,1989, in response to our letter and the
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. attached Notice of Violation dated March 2, 1989. As'a-result of.our~ review,
- we. find that additional information,' as discussed with your Mr. D. V. Gallodoro
(during a. telephone call on April 13,1989) is needed with respect to
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-Violation ~382/8902-02. Specifically, please describe the process and technical
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bases that are used to support dedication of this material.
.In regard to'the second example of Violation 382/8902-03, after review of the.
'information supplied, we concur.that this example does not represent a
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. violation of your Procedure UNT-7-021.
Please provide the supplemental information within 30 days of the date of this -
letter.
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Sincerely,
Original Signed By.
L. I, Callan
L. J. Callan Director-
Division of Reactor Projects
cc:
Louisiana Power & Light Company
ATTN:
R. P. Barkhurst, Vice President
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.. Nuclear Operations
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P.O. Box B
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- Killona, Louisiana 70066
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~ Louisiana Power & Light Company
ATTN:
N. S. Carns, Plant Manager
P.O. Box B
Killona, Louisiana 70066
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Louisiana Power & Light Company
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Louisiana Power & Light Company
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. ATTN:
R. F. Burski, Manager, Nuclear
Safety & Regulatory Affairs
317 Baronne Street
P.O. Box 60340
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New.0rleans, Louisiana 70160
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- Louisiana Power & Light Company
ATTN:
L. W. Laughlin,' Site
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. Licensing Support Supervisor
P.O.. Box B
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- Killona, Louisiana 70066
Louisiana Power & Light Company
ATTN:
G. M. Davis, Manager, Events
Analysis Reporting & Response
P.O. Box B
Killona, Louisiana '70066
Middle South Services
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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:
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R. D. Martin, RA
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Section Chief (DRP/A)
RPB-DRSS
MIS System
Project Engineer (DRP/A)
RSTS Operator
RIV File
0. Wigginton, NRR Project Manager (MS:
13-D-18)
Lisa'Shea, RM/ALF
W. McNeill
I. Barnes
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LOUISi ANA / 317 BARONNESTREET
P. O. BOX 60340
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(504)595 3100
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POWER & LIGHT
NEW ORLEANS, LOUISIANA 70160
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April 3,1989
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U.S. Nuclear Regulatory Commission
ATTN:
Document Control Desk
Washington, D.C. 20555
Subject: Waterford 3 SES
Docket No. 50-382
License No. NPF-38
NRC Inspection Report 89-02
Gentlemen:
In accordance with 10 CFR 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
T.J. Gaudet at (504) 464-3325.
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Very truly yours,
R.F. Burski
Manager
Nuclear Safety & Regulatory Affairs
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RFB:TJG:ssf
Attachment
cc:
R.D. Martin, NRC Region IV-.
J.A. Calvo, NRC-NRR
D.L. Wigginton, NRC-NRR
NRC Resident Inspectors Office
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E.L. Blake
W.M. Stevenson
NS41567C
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"AN EQUAL OPPORTUNITY EMPLOYER"
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ATTACHMENT 1
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LP&L Responses to the Violations Identified in Appendix A
of Inspection Report 89-02
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VIOLATION NO. 8902-01
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Failure to Adhere to Documented Drawings
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Criterion V of Appendix B to 10 CFR Part 50 and the licensee's approved
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quality assurance program description require that activities affecting
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quality shall be prescribed by and accomplished in accordance with
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documented instructions, procedures, or drawings, of a type appropriate to
the circumstances.
Design Drawing 1564-1539, R26 for pressurizer surge line Sample Isolation
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Valve 2SL-V2505 specifies that the material for Item 11 (valve gland studs)
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shall be ASME SA-193 Grade B6 or B7.
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Contrary to the above, a valve gland stud for Valve 2SL-V2505 had been
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incorrectly replaced with ASME SA-193 Grade B8 material.
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This is a Severity hvel IV violation.
RESPONSE
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(1) Reason For The Viol tion
The root cause of this violation is personnel error.
In accordance
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with UNT-5-015, " Work Authorization Preparation and Implementation,"
a work authorization (WA 01018888) was prepared to install packing
gland fastener material on the pressurizer surge line sample isolation
valve. The existing material was badly corroded and needed
replacement. Section 5.7.5 of UNT-5-015_ states that all replacement
parts and materials installed in plant systems shall be
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"like-for-like" replacements or engineering approved equivalents.
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also states that the parts shall be obtained from the warehouse and be
traceable to a Requisition on Stores (ROS) number.
In an attempt to
comply with Section 5.7.5 of UNT-5-015, Design Drawing 1564-1539, the
field control drawing for this valve, was obtained. When viewing this
drawing, which was a poor quality reproduced copy made from an
aperture card (micro-film), the responsible individual misinterpreted
the material designation to be SA 193 B8_ as opposed to the specified
SA 193 B6.
Consequently, the incorrect material (SA 193 B8 material)
was entered on WA 01018888 and the ROS ticket as a "like-for-like"
replacement. On 4/13/88, the incorrect material was then installed.
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(2) Corrective Steps That Have Been Taken And The Results Achieved
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On.2/9/89, Maintenance generated a quality notice (QN QA-89-037) to
formally address and resolve the concern. On 1/12/89, a non-
.conformance Condition Identification'(CI~ 260888) was issued to
disposition the incorrectly installed material. Calculations
performed under CI 260888 and the application of the SA 193 B8
material as a gland fastener supported the operability of the pressure
bounda ry.
Accordingly, the shift supervisor accepted the use of the
material.
Since Engineering has recommended that the replacement material
conform to the design drawing, the material will be replaced during
the next refueling outage with the correct SA 193 B6 material under
CI 260888 and the associated work authorization (WA 01033177). Note:
this action-is separate from the violation response and, therefore,
does not need to be completed to be in full compliance.
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The individuals responsible for the violation were counselled on the
importance of obtaining clear and legible drawings prior to continuing
work when the field control drawing is of poor quality.
(3) Corrective Steps Which Will Be Taken To Avoid Further Violations
To prevent recurrence, Maintenance Procedure MD-1-014, " Conduct of
Maintenance," will be revised to address the use of unclear drawings.
(4) Date When Full Compliance Will Be Achieved
Procedure MD-01-014 will be revised by June 1, 1989, at which time
LP&L will be in full compliance.
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VIOLATION NO. 8902-02
Failure to Impose 10 CFR Part 21
Section 21.31 of 10 CFR Part 21 requires the licensee to specify on each
procurement document for a basic component that the provisions of 10 CFR Part 21 apply.
Contrary to the above, since 1985, the licensee has not specified on
procurement documents for basic components placed with the Okonite
Company, that the provisions of 10 CFR Part 21 were applicable.
This is a Severity Level IV violation,
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RESPONSE
(1) Reason For The Violation
The root cause ol' this violation is programmatic in that the plant
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procedure that was used for processing procurement documents lacked
adequate instructions for ensuring nuclear requirements were not invoked
when 10CFR part 21 requirements were not imposed.
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Plant Administrative Procedure UNT-8-001, " Processing of Procurement
Documents," described the methods used by plant personnel from 1979-1987
to initiate procurement documents for plant station modifications, spare
and replacement components, subcomponents, parts, material, tools and
services required to support plant operations. Through the use of this
procedure, plant personnel, from 1982-1987, requested purchase orders to
be placed with The Okonite Company for tape and cement which were to be
used as basic components at Waterford 3.
(NOTE: A hasic component, as
defined in 10CFR21.3 means a plant structure, system, component or part
thereof necessary to assure (i) the integrity of the reactor coolant
pressure boundary, (ii) the capability to shut down the reactor and
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maintain it in a safe shutdown condition, or (iii) the capability to
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prevent or mitigate the consequences of accidents which could result in
potential offsite exposures comparable to those referred to in 10CFR part
100). Since the procedure lacked adequate instructions for ensuring
nuclear requirements were not invoked when 10CFR part 21 requirements
were not imposed, six Okonite orders (Purchase Order Numbers 10450,
12403, 14107, 65603, 85303 and 97037) were placed imposing certification
to Qualification Test Reports without imposing 10CFR part 21.
(2) Steps That Have Been Taken And The Results Achieved
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In November 1987, this procedural problem was corrected. On November 9,
1987, UNT-3-001 was replaced with Nuclear Operations Engineering
Procedure NOEP-004, "The Engineering Procurement Process". Step 5.1.3.2
of NOEP-004 requires the procurement engineer to draft procurement
documents in accordance with Nuclear Operations Engineering Instruction
N0EI-152, " Safety-Related Procurement Methods & Standard Technical &
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QA Statements." NOEI-152 (Revision I dated 9/8/87) provides guidelines
and methods for Nuclear Operations Engineering personnel to use when
specifying technical and quality requirements on safety-related
procurercent documents.
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Section 5.2 of N0EI-152 describes the method used to obtain
safety-related structures, systems, components, parts or services that
are subject to unique design or specification requirements or that
cannot be procured to the manufacturer's catalog or industry standards
alone. This method applies to components ordered from The Okonite
Company. Step 5.2.3 specifically states that procurement specifications
suc11 invoke 10CFR part 21 on the supplier. To date, however, The
Okonite Company still refuses to accept 10CFR part 21.
Consequently,
when such action from a supplier occurs, the basic component (s) being
purchased will be identified in the order as commercial grade in
accordance with Step 5.5.11 of NOEI-152.
Items ordered from the Okonite
Company have been since November, 1987 and will continue to be purchased
as commercial grade.
(3) , Corrective Steps Which Will Be Taken To Avoid Further Violations
N0EI-152, as described above, provides adequate instruction to prevent
recurrence of a similar type of violation in the future.
(4) Date When Full Compliance Will Be Achieved
LP&L is currently in full compliance.
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VIOLATION NO. 8902-03
Failure to Follow Procedures
Criterion V of Appendix B to 10 CFR Part 50 and the licensee's approved
quality assurance program description require that activities affecting
quality shall be prescribed by and accomplished in accordance with documented
instructions, procedures, or drawings, of a type appropriate to the
circumstances.
Contrary to the above, the licensee failed to implement procedures as shown in
the following examples:
Contrary to Section 5.7.7 in Procedure N0EI-152, Revision 1, the licensee
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failed to identify shelf life requirements in Purchase Order WP016013 for
Buna-N parts.
Contrary to Section 5.4.3.2 in Procedure UNT-7-021, Revision 1, the
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licensee failed to update at least five vendor technical manuals to
incorporate data to support replacement AGASTAT relays installed during
Modification SM 1701.
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Contrary to Section 5.2.1.4 in Procedure UNT-8-001, the licensee failed
to properly dedicate commercial grade replacement electrical resistors
which had been procured on Purchase Order W117408.
This is a Severity Level IV violation.
RESPONSE
(1) Reason For The Violation
The root cause for examples one and three cited in the violation is
personnel error.
(Note:
LP&L denies that example two is a violation of
failing to follow procedures. A discussion of the basis for denial is
provided on pages 8 and 9.)
Example 1
Nuclear Operations Engineering Instruction NOEI-152, " Safety-Related
Procurement Methods & Standard Technical & QA Statements," provides
guidelines and methods for specific technical and quality requirements
on safety-related procurement dccuments and for dedicating commercial
grade items for safety-related use during the procurement process. Step
5.7.7 of N0EI-152 states that "Other requirements may be noted as part of
the Procurement Documents to identify the need for... shelf life..."
Using this guidance provided in NOEI-152, a procurement engineer
generated a purchase order (P.O. WP016013) to order seal kits for ASCO
solenoid valves on the diesel generator. The Kits contained Buna-N
(Butadine/ Acrylonitrile) items which have a limited shelf life.
(Note: Limited shelf life items are those that have a shelf life of less
than 40 years).
Based on this information and in accordence with Step
5.7.7 of N0EI-152, shelf life data for the Buna-N items should have been
but was not included on the purchase order.
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Example 3
Plant Administrative Procedure UNT-7-021 (Revision 4), " Spare Parts
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Equivalency Evaluation Report (SPEER)/ Parts Quality Level Determination
-(PQD), " provided the methods used to process either a SPEER or a
PQD. A SPEER would be used to determine whether a spare or replacement
part, not of original design or having a technical difference, is
acceptable for use in the original application. A PQD would be used to
determine the quality requirements of a part % hen the quality' level is
unknown and to provide for the dedication of such commercial grade items
in a safety-related application after the quality level has been
dete rmined. Plant Administrative Procedure UNT-8-001, " Processing of
Procurement Documents," described the methods used by plant personnel
from 1979 1987 to initiate procurement documents for plant station
modifications, spare and replacement components, subcomponents, parts,
material, tools and services required to support plant operations.
Using the guidance provided in UNT-7-021 and UNT-8-001, a purchase order
(P.O. W-11794-K) was generated to order thirty replacement electrical
resistors. Step 5.1.10 of UNT-7-021 stated that a PQD shall not be
required for the use of like for like commodity type items for non-code
application or where the code or standard does not specify code material.
Since the replacement resistors were like for like commodity type items,
the parts were ordered as Commercial Grade (QC-3), and in accordance with
step 5.1.10 of UNT-7-021, no PQD was performed. Although this action
appeared to be appropriate, it was in direct conflict with step 5.2.1.4
of UNT-8-001 which stated:
"a SPEER/PER (project evaluation request) shall be initiated for all
parts or components for use in a safety-related system determined
to be ' Commercial Grade' (QC-3) except those items previously
approved and included in Reference 2.16 (UNT-7-003, " Control of
Expendable Material"), 2.26 (UNT-5-007, " Plant Lubrication
Programs"), 2.27 (EAN 457001798, " Plant Expendable Materials
Manual") or other approved engineering design or design change
documents."
Consequently, the ordered parts were designated as Commercial Grade without
the proper dedication. Two of the thirty resistors (under Work Authorization
01017698 and Condition Identification 255518) were installed in a position
indicator as a like for like replacement.(NOTE: Post installation tests had
been performed to ensure that the indicator operated properly.)
(2) Corrective Steps That Have Been Taken And The Results Achieved
Example 1
A Quality Notice (QN QA-89-009) was issued on 1/13/89 to formally
address and track the corrective actions for the procedural violation.
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Procurement Engineers, including the individual responsible for the
procedural violation, were required to review the quality notice and
were instructed to impose shelf life requirements on all orders for
items that have a limited shelf life.
The Waterford 3 Materials Management Information System was updated to
reflect a five year shelf life for the Buna-N items.
Example 3
A Quality Notice (QN QA-89-004) was issued on 1/13/89 to formally address-
and track the corrective actions for the procedural violation.
On November 9, 1987, UNT-8-001 was replaced with Nuclear Operations
Engineering Procedure N0EP-004, "The Engineering Procurement Process."
N0EP-004 addresses commercial grade procurement in greater detail than
did UNT-8-001. To ensure consistency with N0EP-004, UNT-7-021 has been
revised.
In particular, the exemption regarding commodity type items,
Step 5.1.10 of UNT-7-021, has been deleted.
The twenty-eight resistors remaining in the warehouse were downgraded to
non-safety (QC-2). This action will require that a PQD be performed
before the resistors are used in a safety-related application. The 'two
resistors that were installed in the plant were evaluated in accordance
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with N0EP-004, Section 4.4.3, and N0EI-152, Section 5.5 and found to be
acceptable for their intended use.
(3) Corrective Steps Which Will Be Taken To Avoid Further Violations
Example 1
NOEI-152 will be revised to insure that shelf life requirements are
imposed on orders for items.having a limited shelf life.
An overall program will be established to ensure that shelf life controls
are consistently applied in the appropriate plant procedures. A review
of items in stores will be done to identify and correct other shelf life
data deficiencies.
(This effort will be tracked under quality notice QN
QA-89-071 dated 3/17/89).
Example 3
Based on the corrective actions that have been taken for this example,
further violations of this type should be prevented.
(4) Date When Full Compliance Will Be Achieved
Example 1
Revision to Procedure NOEI-152 will be completed by July 1, 1989. The
stores review is expected to be completed by December 31, 1989, at which
time LP&L will be in full compliance.
Example 3
LP&L is currently in full compliance.
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Ba_ sis for Denying Example Two of Violation 8902-03
LP&L denies that Section 5.4.3.2 of UNT-7-021 was violated since the
applicable technical manuals were updated.
Subsequent to the citing of this
apparent violation during an NRC Exit Meeting, LP&L immediately generated a
quality notice (QN QA 89-005) to document the finding and address its root
cause.
Based on a review of Station Modification (SM) No. 1701 and its
associated documentation, LP&L determined that the manuals had been adequately
updated and no further action was necessary.
Consequently, the QN was
dispositioned as invalid.
The following information substantiates this
position.
Using the guidance provided in Plant Administrative Procedure UNT-7-021,
Revision 1, " Spare Parts Equivalency Evaluation," Spare Parts Equivalency
Evaluation Report (SPEER) No.85-231 was generated to support the replacement
of Commercial Grade Agastat Relays with Class 1E Agastat Relays.
Step 5.4.3.2
of UNT-7-021 (Revision 1) required that changes to documents affected by the
SPEER are to be initiated in accordance with Procedure PE-2-006, " Plant
Engineering Station Modification." Accordingly, SM 1701 was initiated to
update the design documents associated with SPEER 85-231. During the
processing of SM 1701, evaluations were requested and performed to document
the known differences between and applications of the Agastat 7000 Series'
Relays (commercial grade) and the E7000 Series Relays (IE grade).
In general
these evaluations (Reference Project Evaluation Requests 60312, 60536 and
70520) concluded that although the 7000 Series Relays were no different from
the E7000 Series Relays, the E7000 Series should be used for future
replacements of Agastat Timing Relays.
The evaluations became part of the SM 1701 package. Also included in the SM
Package was LP&L's documented actions that were taken to use the E7000 Series
Relays to replace E7000 or 7000 Relays in safety-related applications. The
following actions were taken:
1.
HE-7-005, " Time-Delay Relay Setting Check, Adjustment and Functional
Test," was revised to require that emergency diesel generator (EDG)
agastat relays in safety-related (SR) applications be replaced by SR (E
Series) relays. This procedure also requires that E Series relays be
replaced every 10 years from date of manufacture. The Waterford 3 Plant
Preventive Maintenance Program was revised to include this replacement
frequency.
2.
Maintenance history was reviewed on both EDGs to verify that no
unqualified relays were installed as replacements. This review revealed
that only two agastat relays were replaced and both were replaced by
safety-related relays.
Based on the abeve information, the following notice (Reference LP&L Letter
No. W3E86-0260 dated 11/3/86) was placed in each of the applicable manuals:
This notice serves to accommodate the recent policy of /.merace Corp. to
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provide Agastat relays for safety-related applications with the "E"
prefix designation.
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Agastat 7000 series relays qualified by Amerace Corporation for Nuclear
application have model numbers with an "E" prefix.
Part number design discrepancies may exist where agastat relays are shown
in a particular design drawing that do not have the "E" prefix where in
fact the' corresponding field installed relay may now have the "E"
designation.
Conversely, a field installed relay may be found to be an
Agastat relay qualified by a subvendor (instead of Amerace) and found to
not be from a subgrade batch of commercially produced relays, that do not
have the "E" prefix, in certain applications.
Further information may be obtained from checking the responses to PEIR
70520, PEIR 60312, and PEIR 60536.
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The applicable manuals that were updated with this information were:
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Technical Manuals 457000005, Volume 1 (R [ Revision] 0); 457000212 (R2);
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457000225, Volume 4 (RI); 457000238 (RO); 457000281 (RS); 457000854 (RI) and
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457001225, Volume 3 (R8).
(Note: Technical Manual 457000106 was originally
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listed in SM 1701 as requiring an update, but a revision to this manual was
not actually required as indicated on at Engineering Review Comment Resolution
Form.)
On January 13, 1989, QN QA-89-005 was issued to address the apparent
procedural violation of not updating the noted manuals. After a review of the
information contained in SPEER 85-231, SM 1701 and the applicable Technical
Manuals, the QN was dispositioned as invalid.
(Note:
In addition to the
manuals stated above, Technical Manuals 457000291 (RO) and 4570002146 (RI) had
been included in the QN as needing an update. Both manuals were determined to
be not applicable to the issue.)
Consequently, LP&L believes that the appropriate Technical Manuals were
adequately updated in accordance with UNT-7-021.
Therefore, in light of the
information provided above, LP&L requests that this example be reevaluated.