ML20246N313
| ML20246N313 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/31/1989 |
| From: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Dewease J LOUISIANA POWER & LIGHT CO. |
| References | |
| NUDOCS 8909080085 | |
| Download: ML20246N313 (3) | |
See also: IR 05000382/1989008
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- In Reply' Refer To
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' Docket:: 150-382/89-08a
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Louisiana Pov.r & . Light! Company
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, ATTN:
J. G. Dewease, Senior Vice President
. Nuclear Operations'
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317 Baronne Street
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New Orleans, Louisiana ,70160
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Gentlemen:-
Thank you for your letter of June 15 1989, in' response to our letter and
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Notice of. Violation dated May 16, 1989. We have reviewed your reply and '
find it responsive to the concerns raised in Example 1 of our Notice of
Violation. However, we need additional clarification of the statement in your
response that, implied that your mechanical maintenance personnel believed that
Essential Chiller; B was contaminated. The. inspector did not see any
. radiological control? in'effect, and there was no specific radiological work
- permit. We would not expect to see trained radiation workers breaching systems
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believed to be' contaminated without such~ controls. Please provide a
" supplemental < response to clarify this matter.
'Your basis for denial of Example 2 of the violation has' been reviewed and we~
have concluded that the facts presented do not provide sufficient b.*cis for
withdrawal of. this portion.cf the. violation. The mechanic applying 5'e torque
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wranch with' an adaptor did not demonstrate an understanding of torge < rench
awtor effects on torque application. Therefore, a procedure was net Jed for
reference.
Please provide c supplemer.tal response to this violation example to
Jclarify this matter along with corrective: actions to prevent recurrence.
Your basis:for denial of Example-3 of the violation has been reviewed and we
have concluded that the facts presented do not provide sNfficien'. basis for
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withdrawals of this portion of the violation. The inspecter identified the
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missing' fasteners after the maintenance technicians completed the required
. procedural inspection for loose or missing parts. This has been discussed
with your maintenance department manager and he has connitted to take
appropriate corrective action. Please proude a supplemental response to this
portion of the violation, which identifies the corrective actions taken.
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Please provide the.above'noted supplemental'responsesLwithin.30 days of the
'date of this letter.
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Sincerely,
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-Jares L. Milhoan, Director -
Division of Reactor Projects
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cc:
Louisiana Power & Light Company
ATTN:'
R. P. Barkhurst,-Vice President
Nuclear Operations
P.O. Box-B'
Killona, Louisiana 70066'
. Louisiana _ Power & Light Company.
- ATTN:
J. R.- McGaha, Jr. ,, Plant Manager
'P.O.' Box Br
K111ona.. Louisiana. 70066
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. Louisiana Power & Light Company-
ATTN:
R. ' F. Burski, Manager,' Nuclear
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Safety! & Regulatory. Affairs
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3171Ba'ronne Street
P.O.. Box 60340
New Orleans, Louisiana 70160
. Louisiana Power &' Light- Company
. ATTN:. LL.f W. Laughlin, Site
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Licensing Support Supervisor
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P.O. Box B'
K111ona, Louisiana -70066
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- Louisiana' Power & Light Company
ATTN:
G. M.t Davis, Manager Events
Analysis Reporting & Response
P.O.. Box'B'
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' -Killona, Louisiana 70066-
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Middle South Services
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ATTN:c Mr. R.=T.1. ally
P!O. Bo'x 61000
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-itouisiana Radiation. Control Program Director-
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Louisiana Power & Light Company
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R.-D. Martin, RA
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MIS System
Project Engineer (DRP/A)
RSTS Operator
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D. Wigginton, NRR Project Manager (MS:
13-D-18).
Lisa Shea, RM/ALF
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LOUISIAN
P O W E R & L i G Hg@- NEW ORLEANS, LOUISIANA 70160
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p. O. sox 80340
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- (504) 595 3100
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June 15, 1989
A4.05
U.S. Nuclear Regulatory Commission
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ATTN: Document Control Desk
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Washington, D.C. 20555
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Subject: Waterford 3 SES
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Docket No. 50-382
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License No. NPF-38
NRC Inspection Report 89-08
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Gentlemen:
In accordance with 10 CFR Part 2.201, Louisiana Power & Light hereby
submits in Attachment 1 the response to the Violation identified in
Appendix A of the subject Inspection Report.
If you have any questions concerning this response, please contact
T.J. Gaudet at (504) 454-3325.
Very truly /
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/ours,
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M
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Niclear Safety & Regulatory Affairs
RFB:TJG:ssf
Attachment
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cc: _R.D. Martin, NRC Region IV
F.J. Hebdon, NRC-NRR
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D.L. Wiggirton, NRC-NRR
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NRC Resident Inspectors Office
E.L. Blake
W.M. Stevenson
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"AN EQUAL OPPORTUNITY EMPLOYER"
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Page 1 of 5
ATTACHMENT 1
LP&L Response to the Violation Identified in Appendix A
of Inspection Report 89-08
VIOLATION NO. 8908-01
Failure to Follow Procedures
. Technical Specification 6.8.1.a requires, in part, that written procedures
shall be established, implemented, and. maintained as recommended in
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Appendix A of Regniatory Guide ~1.33, kevision 2, February 1978.
Contrary to the above, below are three examples of.where the licensee
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failed to follow established procedures:
1.
Paragraph 4.7.6 of Procedure MD-1-021, Revision 2 "M&TE (Measuring
and Test- Equipment) /.: countability," prohibits use of radiologically
controlled test gauge; on noncontaminated systems.
Contrary to the above, on Mar h 6, 1989, a test gauge labeled " Caution
Radioactive Material" was connected to Essential Chiller B, a
noncontaminated system.
2.
Paragraph 4.2.1 of Procedure MM-6-011, Revision 3, " General Torquing
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and Detensioning," requires the mechanic to refer to Attachment 10.2
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of the same procedure when using torque wrench adapters.
Contrary to the above, during performance of Work Authorization
01029819, the maintenance mechanic checking torque on. Dry Cooling
Tower Fan 12B hub bolts, and using a torque wrench adapter, failed to
utilize Attachment 10.2, nor did he have it available at the job site.
3.
Paragraph 8.2.5 of Procedure ME-4-371, Revision 4, " Maintenance
Procedure Emergency Feedwater Pump Motor," requires inspection for
loose or missing nuts, bolts, or other hardware following component
maintenance.
Contrary to the above, after observing what appeared to be an
inadequately performed inspection by the licensee's technician, the
NRC inspector found three missing fasteners on a motor cover plate
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which should have been found following maintenance on the motor.
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This.is a Severity Level IV violation.
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RESPONSE-
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(1) Reason For The Violation
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The root cause for example one cited in the violation was an.
inadequate procedure, the basis'of which is provided below. LP&L
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denies'that examples two and'three are violations of failing to follow
procedures. A-discussion of the basis for denial is provided on pages
3 and.4 for~exemple.two and 4 and 5 for example three.
Example 1
The guidance provided'in Procedure MD-1-021'was not detailed enough to
ensure that Mechanical Maintenance personnel who are responsible for
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using M&TE in a Radiation Controlled Area (RCA) are familiar with 1)
the use of M&TE on a'noncontaminated system located within the RCA and
2) which plant' systems are contaminated versus those that are not
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contaminated. A contributing cause to this deficiency was inadequate
training of Mechanical Maintenance personnel on the Health Physics'
Clean Tagging Program.
The purpose of MD-1-021 is to provide guidance for the inventory
control and issuaner of plant M&TE. Section 4.7.of MD-1-021 (Revision
2) describes the responsibilities of the M&TE useis. Paragraph 4.7.6
states that RCA M&TE is_to be used on contaminated plant, systems only.
and non-RCA M&TE-is to be used on noncontaminated systems. -Paragraph-
4.7.7. states that non-RCA M&TE being used in the RCA on
noncontaminated systems is tagged with a clean system equipment tag in
accordance with Letter No. W3H86-0052 (which describes the Health
Physics Clean Tagging Program) and'as directed by Health Physics.
When requesting the M&TE the user completes the M&TE Record of
Accountability. Form (Attachment 6.4 of the MD-1-021).
Indication of
whether'or not the M&TE is to be used in a RCAimust be provided.on-
this form. However, the procedure lacks a necessary step to clarify
the usage of M&TE on a noncontaminated system located within the RCA.
Additionally, the M&TE Record of Accountability Form does not provide
space to log.whether the M&TE is to be used on a contaminated or
noncontaminated system.
Consequently, during a repair of the low pressure economizer float on
-Essential Chiller "B" under Work Authorization No. 01033378, a
contaminated gauge was installed on the noncontaminated Essential
Chiller "B" system. The responsible Mechanical Maintenance personnel
were unaware that the Essential Chiller is noncontaminated and were
unfamiliar with-the Clean Tagging Program.
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(2) Corrective Steps That Have Been Taken And The Results Achieved
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Example 1
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On 04/14/89 a Radiological Deficiency Report (RDR No. 89-09) was
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generated to document the deficiency and to implement the necessary
corrective actions.
Training on the Clean Tagging Program was provided to Mechanical
Maintenance personnel on 06/06/89.
(3) Corrective Steps Which Will Be Taken To Avoid Further Violations
Example 1
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MD-1-021 will be revised to ensure that guidance on the use of M&TE inL
the RCA on a noncontaminated system is provided. Additionally,
Attachment 6.4 will be revised to provide space to indicate whether or
not the M&TE will be used on a contaminated system.
(4) Date When Full Compliance Will Be Achieved
The above noted procedure revision will be implemented by Augurt 15,
1989, at which tine LP&L will be in full compliance.
BASIS FOR DENYING EXAMPLE TWO OF THE VIOLATION
LP&L denies that Paragraph 4.2.1 of procedure MM-6-011 was violated. The
following information substantiates this position.
One of the purposes of MM-6-011 is to provide instructions for use of
manual and hydraulic torque wrenches, adapters and torque multipliers.
Section 4.2 of MM-6-011 provides a list of procedural limitations.
Paragraph 4.2.1 states that if the final torque value is outside the
range of manual torque wrenches, accessibility is limited, or other
reasons prevent the use of manual torque wrenches without adapters or
multipliers, then refer to Attachment 10.2 (Use of Torque Wrenches and
Accessories) and Attachment 10.3 (Use of Hydraulic Torque Wrenches) to
determine the best torquing method.
Plant Maintenance Procedure MD-1-014, " Conduct of Maintenance" outlines the
administrative requirements for performing maintenance activities and
instructs personnel in the conduct and philosophy of maintenance at
Waterford 3.
Section 5.3 of MD-1-014 describes the control and use of
procedures, instructions and drawings.
Paragraph 5.3.11 specifically
states the following:
Work plans associated with maintenance and modification
activities will determine if procedure use in the field
is required. Planning personnel will ensure usability
and correctness of procedures when planning maintenance
activities. UNT-04-009 provides the requirements for
verification and use of "in-hand" procedures.
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The "in-hand" use of procedures is attually. described in Section 5.10 of
- Plant Administrative Procedure UNT-04-009, " Control Distribution, Handling
'and1Use of Plant Procedures." Paragraph 5.10.2 specifically states that
when "in-hand"' procedures a'e not required, the user.shall review the
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Lprocedure prior to performance of the activity to assure the content has
not been changed by a recent revision.
. When performing preventive maintenance work on Component Cooling Water Dry
Cooling Tower Fan.12B under Work Authorization No. 01029819, a torque
wrench adapter was;needed to check the torque of the fan hub bolts.
The.
mechanic, who was familiar with~the scope of work involved, knew that the
required torque value had been entered into the work package, had
preplanned the work and already made use of Attachment'10.2 prior to
leaving for the job site. Consequently, as allowed by the above cited
sections of MD-1-014 and UNT-04-009, he did not bring a copy of the
procedure with him to perform the work. As substantiated on page four of
the Inspection Report, the torque applied was verified to be within
acceptable limits.
LP&L, however, acknowledges that it would be a better practice to have
documentation available to support the mechanic's use of Attachment 10.2 of
.MM-06-011 prior to his leaving for the job site.
Consequently, MM-06-011
will be enhanced to ensure that calculations thct are performed.through the
use of Attachment 10.2 are documented prior to their application. (Note:
The procedure will be revised by August 15, 1989.)
In light of the information provided above, LP&L believes that Paragraph
4.2.1 of MM-06-011 was adequately performed and requests that this cited
example be reevaluated.
BASIS FOR DENYING EXAMPLE THREE OF-THE VIOLATION
LP&L denies that Paragraph 8.2.5 of ME-4-371 was violated. The following
information substantiates this position.
The purpose of ME-4-371 is to provide specific instructions for the
periodic maintenance and functional testing of the Emergency Feedwater
(EFW) Pump Motor. Section 4.2 of ME-4-371 lists the procedure limitations.
Paragraph 4.2.1 specifically states the following:
The sections of this procedure may be performed individually or in any
sequence. The steps within each section shall be performed in
sequential order.
On March 27, 1989, two associated tasks were being performed.
Functional
testing of EFW Pump Motor A in accordance with ME-4-371 was being performed
.under Work Authorization No. 01033105 and sampling and testing of the EFW
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Pump Motor A bearing lube oil was being performed under Work Authorization
(WA) No. 01033227. At the start of the job each step contained in Section
8.1 of_ME-4-371 (Preparation) was performed in sequence. The steps of
Section 8.1 requiring verification signoffs on the Emergency Feedwater Pump
Motor Record ~0f Performance (Attachment 10.1 of ME-4-371) were signed off
accordingly.
Because the location of performing Section 8.1 of the
procedure was the same as that required by Section 8.3 (+21 level of the
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Reactor, Auxiliary. Building.(RAB)).and due to the allowance contained in
Paragraph 4.2.1 of ME-4 -371, each step in Section 8.3 (Insulation
Resistance And Continuity Test) was-logically' performed next in their
. proper sequence. . Again, those steps requiring verification signoffs on
Attachment 10.1_of ME-4-371 were consequently signed off.
Upon completion of the work that had to be performed on the +21 level of-
, the RAB, the responsibin electrical maintenance technicians proceeded to
the -35 level of the RAB where the EFW Pump Motor is located. Upon
arriving et the -35 of the RAB, two tasks were required. The first task
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was to complete the six steps contained in Section 8.2 of the procedure
(Inspection and Cleaning). After completing the first four steps (8.2.1
through,8.2.4), the technicians: inspected for loose or missing nuts, bolts
or other hardware au required by Step 8.2.5.
It was-then noted by the
technicians that three ' fasteners were missing. The last step of Section
8.2 (8.2.6). states:
Continue procedure or, if no further maintenance or testing'is to be
performed, then proceed to Section 8.4, Functional Testing, to
continue procedure.
At this point, the second' task involving the sampling and testing of the
EFW Pump Motor A bearing lube oil under WA 01033227 was undertaken. After
completing this task and prior to the start of Section 8.4, one of the
technicians left the area and proceeded to the Service Building to obtain
three fasteners. The technician then returned to the -35 level of the RAB
.and replaced the missing fasteners with the ones he had obtained. In
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accordance with Step 8.2.6, the responsible technicians then proceeded with
performing and signing off-the steps contained in Sections 8.4'(Functional
Testing) and 8.5 (Restoration) of the procedure.
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Based on the above information, LP&L believes that Paragraph 8.2.5 of
ME-4-371.was not-violated. LP&L, however, acknowledges that Step 8.2.5
should be listed as a signoff on the Emergency Feedwater Pump Motor Record
of Performance to document completion of the step. Consequently,
Attachment-10.1.of ME-4-371 will be revised to include this step as a
required signoff.
(Note: The procedure will be revised by August 15,
1989.)
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Therefore, Li'&L requests that this cited example also be reevaluated.
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