ML20247A295

Notice of Violation from Insp on 890117-0210.Violation Noted:Mechanical Maint Worker Operated Water Chiller Outlet Isolation Valve W/O Specific Direction or Authorization in Approved Maint Procedure & Failure to Control Documents

ML20247A295
Person / Time
Site:	Waterford
Issue date:	03/21/1989
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20247A293	List: IR 05000382/1989001 ML20247A289 ML20247A295
References
50-382-89-01, 50-382-89-1, NUDOCS 8903290091
Download: ML20247A295 (4)

Text

_- _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ . __ - -- ._- _

L e, .

APPENDIX A

. NOTICE OF VIOLATION-l Louisiana Power _& Light Company Docket: 50-382 Waterford Steam Electric Station, Unit 3 Operating License: NPF >

During an NRC inspection conducted during the period January 17 through February 10, 1989, violations of the NRC requirements were identified. The violations involved failure to follow equipment control procedures (three examples), failure to follow a maintenance procedure, failure to follow the requirements of the plant lubrication manual, and failure to control technical-documents as required by administrative procedures. In accordance with the >

" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR d Part 2, Appendix C (1988), the violations are listed below:

A. Failure to Follow Equipment Control Procedures Waterford Steam Electric Station , Unit 3. Technical Specification 6.8.1 requires that written procedures be established, implemented, and maintained for procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Appendix A, paragraph 1.c, requires that administrative procedures be developed for equipment control. The following three cases are examples of failure to adhere to-equipment control procedures.

1. Louisiana Power & Light (LP&L) Maintenance Procedure MD-1-014 Revision 2, " Conduct of Maintenance," paragraph 5.1.5, requires that plant equipment such as pumps, valves, and breakers, which are portions of systems used for power generation, will not be operated by maintenance personnel unless specifically directed to do so by the shift supervisor (SS)/ control room supervisor (CRS) or as a part of an approved maintenance procedure authorized to be performed by the SS/CRS.

s., q ,

Contrary to the above,'on January 31, 1989, the NRC inspector observed that a mechanical maintenance worker operated Water Chiller Outlet Isolation Valve CHWMVAAA1218 during the performance of maintenance work authorization (WA) 01021204 without specific direction from the SS/CRS or authorization in an approved maintenance procedure.

2. LP&L Administrative Procedure UNT-5-010. Revision 0, " Independent Verification Program," paragraph 5.2.1, requires that independent verification be performed on components, which could have been i mispositioned during maintenance. Paragraph 5.5.2 applies l independent verification requirements to systems listed in Attachment 6.1. This attachment identified the chilled water system as requiring independent verification.

8903290091 990321  !

{DR ADOCK 050003S2 l

I PDC

o .

2 Contrary to the above, independent verification of proper positioning of Chilled Water System Manual Valve CHWVAAA1218 was not performed following valve manipulation during activities performed by WA 01021204 on January 31, 1989.

3. LP&L Administrative Procedure UNT-5-003, Revision 7, " Clearance Requests. Approval and Release," paragraph 3.4, states that a danger tag, when in place, prohibits the operation of equipment or systems, which could jeopardize personnel safety or endanger equipment.

Contrary to the above, on January 31, 1989, the NRC inspector observed that a mechanical maintenance worker turned the valve operatir,g hand wheel for Valve FS-325 while the hand wheel had a danger teg (89-103-5) attached.

This is a Severity Level IV violation. (Supplement I)(382/8901-05)

B. Failure to Follow Maintenance Procedure Waterford Steam Electric Station, Unit 3, Technical Specification 6.8.1 requires that written procedures be established, implemented, and maintained for procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Appendix A, paragraph 9.e, requires general procedures to be developed for control of maintenance, repair, replacement, and modification work.

LP&L Maintenance Procedure MD-1-014, Revision 2 " Conduct of Maintenance,"

paragraph 5.1.2, requires that strict compliance with approved procedures and work instructions is mandatory.

WA 01006815 required performance of preventive maintenance on 4160 volt Switchgear 3B-3S in accordance with Maintenance Procedure ME-4-121, Revision 3 4.16-XV Switchgear." Paragraph 8.1.24 of this procedure required torquing of all limit switches, auxiliary switches, and switch ,

tie-bolts. Paragraph 8.1.31 of this procedure required verification of torque of all exposed electrical connections including the switchgear grounding connections. Attachments to the procedure provided appropriate torque values.

Contrary to the above, during the performance of WA 01006815 during the 1988 refueling outage, the paragraphs of Maintenance Procedure ME-4-121 Revision 3, which addresses torquing, were not performed. These paragraphs were marked "N/A" and explanatory notes were added indicating that no loose connections were found, so torquing was not required. No torque wrenches were listed as having been used on this job.

This is a Severity Level IV violation. (Supplement I)(382/8901-06) i l

l l

i

l. .

i 3-4 C. Failure to Follow Requirements of the Plant Lubrication Manual Waterford Steam Electric. Station, Unit No. 3, Technical Specification.n 6.8.1 requires that written procedures be established. -

-implemented, and maintained for procedures recommended in Appendix A of Regulatory Guide 1.33 Revision 2, February 1978. Regulatory Guide 1.33 -

Appendix A, paragraph 9.a. requires, in part, that maintenance that can-affect the performance.of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings' appropriate to the circumstances.

Maintenance Procedure UNT-5-007 Revision 1, " Plant Lubrication Program,"

establishes, in part, the method for lubricating safety-related equipment.

i Step 5.4.2 of UNT-5-007. Revision I states, in part, that " Lubrication ~

activities for plant equipment shall utilize only the lubricants listed 1n 4 the PLM [ Plant Lubrication Manual] unless otherwise specified on a CIWA . . ."

Contrary to the above, three environmentally qualified safety-related motor operated valves inside the reactor building were found by the licensee to be lubricated with an admixture'of two different types of grease in May 1988, even though the PLM only specified the use of Exxon Nebula EP-0.

This is a. Severity Level IV violation. (Supplements)(382/8901-09)

~D.. Failure to Control Technical Documents as Required by Administrative Procedure Criterion V of Appendix B to 10 CFR 50 requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. LP&L Administrative Procedure'UNT-4-002, Revision 2. "Fleid Control of Technical Documents," requires technical documents used in the-field to be " field controlled" and specifies the administrative procedures to be used to provide field control'of technical documents.

Contrary to the above, maintenance data forms, used to prov'ide calibration data for instrument calibration, and instrument Information sheets, containing setpoint information, were not. field controlled in accordance with Procedure UNT-4-002, Revision 2.

This is a Severity Level IV violation. (Supplements)(382/8901-01) i

m ,. .

l :."

4 Pursuant'to the provisions of 10 CFR.2.201, Louisiana Power & Light Company is hereby required to submit.to this" office, within 30 days of the date of this Notice, a written statement or explanation .in reply.. including for.each .

violation: -(1) the reason for the violation if admitted;' (2) corrective steps I which have'been taken and the results achieved; (3) corrective steps which will be'taken to avoid further violations; and (4) the date when full compliance will:be achieved. Where good cause is shown, consideration will be given to I extending your. response time.

Dated at-

.this 2/dArlington, Texas.M 1989 dayoff7/

L