ML20247H850
Jump to navigation
Jump to search
| ML20247H850 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 09/08/1989 |
| From: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Dewease J LOUISIANA POWER & LIGHT CO. |
| References | |
| NUDOCS 8909200118 | |
| Download: ML20247H850 (2) | |
See also: IR 05000382/1989007
Text
{{#Wiki_filter:.
__ , . . . _
_ _-
1 .
'
- . ,4 c , " ,
SEP - 81989
1
~
'
In Reply Refer To':'
sDocket: 50-382/89-07
y' ,
e
Louisiana Power & Light Company ..
ATTh: J. G. Dewease, Senior Vice President'
Nuclear. Operations
317 Baronne Street
j New Orleans. Louisiana 70160
.
Gentlemen:'-
I Thank you for your letters, dated May 31 and August' 21,1989, in response
- to our letters, dated April 17 and July 21, 1989. We have reviewed your
August 21 letter and we disagree with your denial of the violation for the
?2'i reasons ' delineated in our letter of July 21, 1989; however, your corrective
actions appear to be responsive to the issues raised in our Notice of
,
Violation. Therefore, your denial is moot. 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.
Sincerely,
Odc!nalSlaned By:
Tronas P. Gwynn
James L. Milboan, Director
Division of Reactor Projects
'
cc: .
.
,
Louisiana Power & Light Company
ATTN: R. P. Barkhurst, Vice President
Nuclear Operations
P.O. Box B
-
"l
.Killona, Louisiana 70066
' Louisiana Power & Light Company
ATTN: J. . R. McGaha, Jr. , Plant Mar.ager
P.O. Box B
Killona, Louisiana 70066
RIV:RI:MQPS *
kHcNeill/cjg.
C:MQPS *
IBarnes
D- 'S *
JCallan
N/
RP
Milhoan
/ /89 / /89 Q/g/89 9/[/89
*previously concurred
8909200118 890908
PDR ADOCK 05000382
Q PDC [[#l
L _ _ - - _ _ - - . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ k k fL__
y ,. ,3,
- - - - -
- - - - - - - - ,
m < , -
1 a. , s
y ,
y ,
,
;, .
:. ,.
>
,1
e,
^
'
.g: 3 , ,
,
4 "
g g 2. f . 1 g 4
,
- 'E'
, .
(!- g,
-'
,iLouisiana Power'& Light' Company. -2 '
,: s. .
-
'
' Louisiana Power & Light Company
~
~ ATTN:. - R. F. Burski, Manager,' Nuclear > '
sSafety & Regulatory Affairs
~
.
317 baronne Street '
s F P.O.' Box.60340;
..
New Orleans, Louisiana'.'70160
~
. Loubiana Power & Light Company
.
~
' ATTN: .L. W. Laughlin, Site
. . Licensing Support Supervisor
'
'P.O.eBox B.
K111ona,:LouisianaE70066:
Louisiana. Power & Light Company-
! ATTN: G. M. Davis, Manager, Events.
Analysis Reporting &-Response
'
'
-P.O. Box B.
-K111ona. Louisiana 70066
Piiddle. South Services
ATTN: MrF R. T. Lally
P.O.' Box 61000
New Orleans, Louisiana- . 70161
Louisiana Radiation Control' Program Director
.,.
bec to DMB.(IE01)
.
bec distrib.lby RIV: 1
RRIL . ,
R. D. Martin, RA
Section Chief.(DRP/A), DRP .
RPB-DRSS MIS System
. Project Engineer.(DPP/A) RSTS Operator
RIV File DRS
D. Wigginton, NRR Project Manager (MS: 13-D-18)-
< Lisa Shea, RM/ALF
.I..Barnes
W. McNeill
'g.'
1
F
? ' l:
mi. C _ _ _ _ . _ _
- - - - - - - - _ - - . . _ - __ _ -
l
!
N. .,
. ,' * l
* n
. e
e P. O. BOX 60340
l O UISI AN A / 317 BARONNE
POWER & LIGHT NEW ORLEANS, STREET
LOUISIANA 70160 * (504)595-3100
i
NONs*OYE W3P89-1536 3
'
A4.05
QA
l
'
August 21, 1989 [d(Chh[k\//fl % ;
'
U.S. Nuclear Regulatory Commission J i
]'
'
l ATTN: Document Control Desk ! AUG 2 2 l989 .
Washington, D.C. 20555 l
'
L_ _#
Subject: Waterford 3 SES -
Docket No. 50-382 j
License No. NPF-38
Violation No. 8907-02
Failure of PORC to Meet in a Quorum
and Also to Review Radioactive Releases
Gentlemen:
Louisiana Power & Light (LP&L) hereby submits in Attachment I supplemental
information on the subject violation. This response provides additional
information on Item (1) of the violation, the Failure of PORC to Meet in a
Quorum, that was discussed in a July 13, 1989 conference call between LP&L
and the NRC and was requested in your July 21, 1989 letter. LP&L
previously responded to Violation 8907-02 en May 31, 1989 in Letter No.
W3P89-3024.
Although LP&L still believes that a violation of Technical Specification
Section 6.5.1.5 did not occur, a decision has been made to discontinue
sequential contacting of members as an acceptable option for conducting a
Plant Operations Review Committee Meeting.
If you have any questions concerning this response, please contact T. J.
Gaudet at (504) 464-3325.
Very truly yours,
'
e*
R.F. Burski
Manager
Nuclear Safety & Regulatory Affairs
RFB/TJG/pi
Attachment
cc: Messrs: cR.D.-Martin,-NRC Region IVA
F.J. Hebdon, NRC-NRR
D.L. Wigginton, NRC-NRR
NRC Resident Inspectors Office
E.L. Blake
W.M. Stevenson
"AN EQUAL OPPORTUNITY EMPLOYER"
M M O5 M %-3pp*
_ __ _ _ _ _ _
s ..
*
". _
'*
"
* A
Attachment to
W3P89-1536
Page 1 of 2
ATTACHMENT 1
SUPPLEMENTAL INFORMATION FOR VIOLATION NO. 8907-02
Waterford 3 SES TS 6.5.1 establishes the requirements for PORC. Section
6.5.1.5 states:
"The quorum of the PORC necessary for the performance of the PORC
responsibility and authority provisions of these Technical
Specifications shall-consist of the chairman or his designated
alternate and three members, including alternates."
Item (1) of Violation 8907-02 stated that contrary to Technical
Specification Section 6.5.l.5, " Walk-through meetings...were held in which
PORC did not meet in quorum". However, in each of the cited example
meetings where members were sequentially contacted, the required number of
PORC members reviewed and signed the required documents. Thus, the central
issue.is whether a quorum of PORC cembers must always be present to carry
on PORC business.
Plant Administrative Procedure UNT-001-004 (Revision 8) " Plant Operations
Review Committee," provides'the administrative controls to ensure that
formal onsite reviews were conducted by the PORC for activities described
in Section 6.5.1 of the Technical Specification. PORC Meeting requirements
are described in Section 5.2 of UNT-001-004 (Revision 8). Sub-item 5.2.7
states that a PORC meeting shall be conducted in the following manner:
For a scheduled PORC meeting, a quorum shall be physically present at
the same place; OR
For an unscheduled PORC meeting, the Chairman may select one of the
following methods to conduct a meeting:
A. The quorum shall be physically present at the same place; OR
B. The quorum shall be in continuous communication during the
meeting; OR
p '
,
C. The members are contacted sequentially to conduct their
review and vote. If a dissenting opinion is generated
by a voting PORC member, all PORC members shall be informed
of such opinion before the item is forwarded to the Plant
Manager - Nuclear for approval.
In most cases, items requiring PORC review are placed on an agenda for and ;
subsequently reviewed during scheduled or unscheduled formal PORC meetings. '
LP6L utilizes this method of review to insure that circumstances which
arise and require PORC approval are reviewed at face-to-face meetings which
provide a good interchange of ideas.
1
:
}
- _ - . - - _ - _ - - - - - - - - - -
_. . - - _ _ - __ - _. _ - _ _ _ _ _ _ _ _ _ _ _ _
L ,. . ,'
,
' * "
* *
' Attachment to
W3P89-1536
Page.2 cf 2
Occasionally, some items of lesser significance arise for which a PORC
review may.be required, yet all members may not be present. In the past
under these circumstances, the PORC chairman, after his review, may'have
elected to sequentially contact the PORC members for their subsequent
review and approval. Your July 21, 1989. letter stated that the sequential
contacting of members is at variance with the quorum requirement of the
Technical Specifications and'is contrary to the NRC' Inspection Manual,
Interpretation "STS Sections 6.5.1.6 e and 6.5.2.7 d," dated January 1,
1982. LP&L does not perceive that the process of sequential contacting of-
members, as described above, violates this NRC Inspection Manual-
Interpretation. It is LP&L's opinion that PORC review of proposed
technical specification changes.are too significant for utilization of the
sequential contacting of members. In LP&L's initial response the statement
"[a]t times, however, significant circumstances arise that require PORC to
perform immediate reviews..." was worded incorrectly. The intended meaning
was that a routine or minor matter which required PORC review, in order to
support an in progress plant evolution at a time when PORC. members were not
on site, could be handled by a sequential contacting of.the PORC members at
the direction of the PORC Chairman. The "significant circumstance" was
meant to convey.the time sensitive nature of the in progress plant
evolution, not the nature of the item presented to PORC.
Although LP&L still believes that a violation of Technical Specification
Section 6.5.1.5 did not occur, a. decision has been made to terminate the
use of the sequential contacting of PORC members. Consequently, Sub-item
5.2.7 of.UNT-001-004 vill be revised by October 2, 1959 to delete the use
of the sequential contacting of PORC members which was previously allowed
under method C.
!
l
:
!
_ _ _ _ _ _ _ _ _ _ _ - - _ _ =
_-
. _ _ - . .
!
..
.
., ._
...a.-
* '
,,
,
,
,II\ ,
& ~ \ 055
--
'
LO U I &S LIGHT
POWER I A N A / NEW
si7ORLEANS.
staoNNs STReer . e. O. sox s0340
LOUISIANA 70160 * (504)595-3100
$0!ks svSSN
May 31, 1989
W3P89-3024
A4.05
QA
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 89-07
"
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.
-
Very truly yours,
'
R.F. Burski
Manager
Nuclear Safety & Regulatory Affairs
RFB:TJG:ssf
Attachment e
ec: R.D. Martin, NRC Region IV
F.J. Hebdon, NRC-NRR
D.L. Wigginton, NRC-NRR
NRC Resident Inspectors Office
E.L. Blake
W.M. Stevenson
"AN EQUAL OPPORTUNITY EMPLOYER"
Y Aq 2.01 Of9m fj& G %uvd D . A n to .
- - _ _ . - _ __ _- _ _
Attachm2nt to
.' .
U3P89-3024
*
Page 1 of 8
ATTACHMENT 1
LP&L Responses to the Violations Identified in Appendix A
of Inspection Report 89-07
VIOLATION NO. 8907-01
Failure of SRC to Review Safety Evaluations
Waterford 3 Steam Electric Station (W3SES) Technical Specification (TS)
6.5.2.7.a requires that the SRC be responsible for tne reviewfof safety
evaluations completed under the provisions of 10CFR50.59, to verify that an
unreviewed safety question does not exist.
Contrary to the above, the NRC inspector found that the SRC had not
reviewed four safety evaluations associated with Project Evaluation /
Information Request Nos. 20000, dated August 27, 1986, and 70795, dated
October 8,1986; Condition Identification / Work Authorization Nos.
255672/01017834, dated May 26, 1988; and Special Test Procedure No.
99000104-1, dated April 12, 1988.
This is a Severity Level IV violation.
.
RESPONSE
(1) Reason For The Violation
Technical Specification (TS) 6.5.1.6 requires that the Plant
Operations Review Committee (PORC) maintain cognizance over and
responsibility for various activities including designated procedures
and changes thereto that affect nuclear safety (6.5.1.6a), proposed
tests and experiments that affect nuclear safety (6.5.1.6b) and
proposed design changes or modifications to unit systems that affect
nuclear safety _(6.5.1.6d). TS 6.5.1.7b requires that PORC " render
determination in writing... with regard to whether or not each item
considered under Specification 6.5.1.6a through e constitutes an
unreviewed safety question." To ensure that formal onsite reviews are
conducted by PCRC for the activities described in TS 6.5.1,
administrative controls are provided in Procedure UNT-1-004, " Plant
Operations Review Committee " As described in Section 5.4.7 of
l
UNT-1-004 (Revision 8), the PORC determines for each item it reviews
! whether the item requires SRC/NRC review prior to implementation.
(Attachment 6.4 to the procedure provides list of those items.) As
described in Section 5.4.10 of UNT-1-004 (Revision 8), the items that
1- need to be reviewed by the SRC but not prior to implementation must be
forwarded by PORC to the SRC. (Attachment 6.5 to the procedure
provides a list of these items, one of which is all 10CFR50.59 safety
evaluations.)
- -_. _ -_
</
-
I
Attachmsnt to
W3P89-3024
*{ -
Page 2 of 8
Contrary to Section 5.4.10 of UNT-1-004 (Revision 8), three of the
four above . listed evaluations (none of which were assessed to involve
an unreviewed safety question) had not been forwarded by PORC to the
SRC for their review. The root cause for not submitting the
evaluations to the SRC is personnel error. With rege.rd to the other
evaluation listed (PER 20000), although a safety evaluation was
performed, it was not required by TS Section 6.5.1 to be reviewed by
PORC. The evaluation involved only an FSAR change as a result of the
shift from a twelve month to an eighteen month fuel cycle. No
physical modifications were needed and no changes to the plant design
basis were required.- The root cause was a f ailure to have a mechanism
in place to ensure that 10CFR50.59 evaluations are being submitted as
required to the SRC for their independent review. It should be noted
that the lack of receiving these evaluations was a self identified
concern made by the SRC Review Subcommittee during their review of the
Annual 10CFR50.59 Report for 1988.
(2) Corrective Steps That Have Been Taken And The Results Achieved
The cited evaluations have been submitted to the SRC for their
independent review. The SRC has completed their review of two of the
four evaluations and verified that the actions described in the
two evaluations did not constitute unreviewed safety questions.
Completion of SRC reviews of the remainity two evaluations will be
consistent sith the schedule provided below.
Two Quality Notices (QN QA-89-122 and QN QA-89-123) have been
generated to formally address and track corrective actions for the
SRC's lack of receiving various safety evaluations to perform their
independent reviews.
A discussion on the importance in following UNT-1-004 placing emphasis
on the necessity of transmitting such information to the SRC as
required was held with the individual surrently responsible for this
task. (NOTE: The individual actually responsible for failing to
submit the three noted evaluations is no longer filling that
position.)
(3) Corrective Steps Which Will Be Taken To Avoid Further Violations
To ensure that a violation of this type is prevented in the future,
the following will be done at a minimum:
1. Nuclear Operations Engineering Procedurs N0EP-305, " Safety
Evaluations," and UNT-1-004 will be revised to require PORC
review of detailed 10CFR50.59 evaluations; and
2. Af ter review by PORC,10CFR50.59 evaluations will be included as
attachments in the PORC Meeting Minutes.
j
Any supplemental changes necessary to support these changes would te '
addressed and responded to in the QNs listed above.
l
l
j
- - _ _
'
,
Attcch2:nt to
* - W3P89-3024
,
Page 3 of 8
(4) Date When Full Compliance Will Be Achieved
The above action items will be completed by August 1, 1989 at which
time LP6L will be in full compliance.
i
!
.
40
O
L.--______
. _ _ - _ - - _ _ - _ _ _ _ _ _ - _ _ _ _ _
'
,
Attachm2nt to
.* W3P89-3024
-
,
Page 4 of 8
VIOLATION NO. 8907-02
Failure of PORC to Meet in a Quorum and Also to Review Radioactive Releases
W3SES TS 6.5.1 establishes the requirements for PORC. Section 6.5.1.5
states that a quorum is necessary for meetings and'Section 6.5.1.6.m states
that PORC shall review any accidental, unplanned or uncontrolled
radioactive release including the evaluations, recommendations, and
disposition of the corrective actions to prevent recurrence.
Contrary to the above:
(1) " Walk-through" meetings, such as Nos. 88-101, -103, -104', -105, -108,
-109, -111, -113, -115, -116. -118, -121, -122, -123 -125, and -126,
were held in which PORC did not meet in quorum.
(2) Radioactive releases which occurred April 3 and May 23, 1988, were not
reviewed by PORC at Meetings 88-107 and -112 in regard to evaluations,
recommendations, and disposition of the corrective actions to prevent
recurrence.
This is a Severity Level IV violation.
*
RESPONSE
LP&L believes that a Technical Specification (TS) violation did not occur
in either of the above cited instances (Items (1) & (2)) and therefore has -
chosen to deny this violation. The basis to support this position for each
item is discussed below.
ITEM (1)
Plant Administrative Procedure UNT-1-004 (Revision 8) " Plant Operations
Review Committee," provides the administrative controls to ensure that
formal onsite reviews are conducted by the PORC for activities described in
Section 6.5.1 of the Technical Specification (TS). PORC Meeting
requirements are described in Section 5.2 of UNT-1-004 (Revision 8).
Sub-item 5.2.7 states that a PORC meeting shall be conducted in the
following manner:
For a scheduled PORC meeting, a quorum shall be physically present at
the same place; OR
For an unscheduled PORC meeting, the Chairman may select one of the
following methods to conduct a meeting:
A. The quorum shall be physically present at the same place; OR
B. The quorum shall be in continuous communication during the
meeting; OR
E - _ - - - -_____ _--_ - _ _ _ _ _ _ - ___
__
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
l e
', Attachm2nt to
.' *
. W3P89-3024
Page 5 of 8
C. The members are contacted sequentially to conduct their
review and vote. If a dissenting opinion is generated by a
voting PORC member, all PORC members shall be informed of
such opinion before the item is forwarded to the Plant
Manager - Nuclear for approval.
The approach taken by LP&L for handling PORC Meetings as described above is
necessary to cover every situation that could arise. Whenever possible and
in most cases, items requiring PCRC review are placed on an agenda for and
subsequently reviewed during a scheduled PORC Meeting. At times, however,
significant circumstances arise that require PORC to perform immediate
reviews which cannot wait until the next scheduled PORC Meeting. In these
instances, an unscheduled PORC Meeting must be convened as soon as possible
in the most feasible manner. A gathering of PORC members at the same place
(Type A) may be impossible, particularly in those situations that occur
during off hours. LP&L believes that Type B (Conference Calls) and Type C
Meetings (Walk-throughs) are therefore unavoidable.
LP&L has, however, acknowledged the Inspector's concern (noted on page 9 of
the Inspection Report) with the lack of documentation of PORC review
activities which does not allow verification of the items identified and
followup on such. To address this concern, more detail concerning
discussions held in the meeting and any necessary supporting documentation
will be provided,in or appended to the PORC Meeting Minutes. Additionally,
UNT-1-004 has been revised (current revision is No. 11) to better define
and describe PORC activities. It is also noteworthy of mentioning that
Type C PORC Meetings are currently being annotated as Walk-throughs on the
PORC Meeting Minutes. LP&L feels that this action was necessary because
not all of the sixteen meetings identified in Item (1) were Walk-throughs
(Type C). Some were actually Type A unscheduled meetings.
In addition, LP&L established a task force which was responsible for
developing PORC sub-committees. As part of that responsibility, the task
force re-evaluated PORC activities as they pertain to procedure review to
ensure compliance with Technical Specification 6.5.1.6.a. Based on that
review, a Flow Chart was added to UNT-1-004 to ensure that procedures
receive the proper level of review.
ITEM (2)
PORC review requirements for the activity described in Section 6.5.1 of the
Technical Specifications (TSs) are controlled in Section 5.3 of UNT-1-004
(Revision 8). Sub-item 5.3.1.13 states that the PORC shall be responsible
for review of any accidental, unplanned or uncontrolled radioactive release
including reports covering evaluation, recommendations and disposition of
the corrective action to prevent recurrence and the forwarding of these
reports to the Vice President, Nuclear Operations and to the Safety Review
Committee.
_ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ - - - - - _ _ .
,
. Attachmnt to
, .
* ' -
,
W3P89-3024
Page 6 of 8
On July 29, 1988 during PORC Meeting No. 88-107, a cognizant individual i
discussed in detail the report on the release of radioactivity during
Integrated Leak Rate Testing (ILRT) that occurred on May 23, 1989.
Preliminary discussions of the event were held by PORC during this
particular meeting. After discussing and reviewing the pertinent
information, PORC determined that the incident did not constitute an
" unplanned" release and that the information regarding this release should i
be reported and discussed in the Semi-Annual Radioactive Effluent Release
Report as a " planned" release that occurred through an abnormal release
pathway.
On August 11, 1988 during PORC Meeting No. 88-112, a cognizantiindividual
discussed the report issued on the unplanned and unmonitored release of
radioactivity during the removal of the containment equipment hatch that
occurred on April 3, 1988. Preliminary discussions on the incident, to
include the root cause that had been established, the corrective actions to '
prevent recurrence that had been recommended and the analysis of the
radiological consequences that had been developed, were held by PORC during
this particular meeting. As a re? ult, the PORC agreed that the incident
would be included in the Semi-Annual Radioactive Effluent Release Report as
an unplanned release.
During the SRC review of the above identified radioactive release report,
it was noted that there were several recommendations contained in the
reports. Based o'n the lack of information contained in PORC Meeting
Minutes for Meeting Nos. 88-107 and 88-112, it was unclear to the SRC as to
the status of these recommendations (Reference: LP&L Letter W3P88-0328
dated 12/19/88 from the SRC Chairman to the PORC Chairman).
Subsequent to the above, on January 5,1989 during PORC Meeting No. 89-02,
PORC reviewed the two reports (as reported in the Semi-Annual Radioactive
Effluent Release Report for the first half of 1988) related to the above
discussed releases and approved the recommended-corrective actions. To
assure that these recommendations would be implemented appropriately,
individuals were assigned lead responsibilities. Then on 03/15/89 a
memorandum was issued by the PORC Chairman to the SRC Chairman to inform
him of the status of the recommendations. With regard to the 5/23/88
incident, the memorandum stated that a TS change and an Offsite Dose
Calculation Manual change would be pursued to add the ILRT depressurization
pathway. With regard to the 04/03/88 incident, it stated that a new
procedure (OP-08-011) was currently being developed to maintain ope ; tion
of shield building ventilation during equipment hatch removal until
containment purge can be initiated. (NOTE: This procedure was approved on
04/14/89.)
Although the above actions may be construed as not being timely (which in
both cases involved outage related work where timeliness of corrective
action did not have to be inanediate), the required PORC actions (5.6.5.1,
'
UNT-1-004, Sub-item 5.3.1.13) were performed.
In light of the above information, LP&L requests that this cited violation
be reassessed.
. _ _ _ _ _ _ _ . _ _ - _ _ _ _ - _ _ -
-
.
".
* ' *
* Attachm:nt to
* W3P89-3024
Page 7 of 8
VIOLATION NO. 8907-03
Failure to Identify and Control Materials with limited Shelf Life
Criterion VIII of Appendix B to 10 CFR Part 50 requires that measures shall
be established for identification and control of materials, parts, and
components.
The Nuclear Operations Management Manual in Section V, Chapter 8. Revision
3, paragraph 3.4, requires that items having limited shelf life shall be
identified and controlled to preclude the use of items whose shelf life has
expired.
Contrary to the above, formal measures were not established for control of
materials and equipment for which vendors had made unsolicited shelf life
recommendations. For example, the Material Management Information System
specified no shelf life dates for Stockcode 152-C19300 (mass flovmeter) and
Stockcode 101-D53873 (0-Ring). Vendor documentation received for these
items specified, however, shelf lives of 3 years and 20 years,
respectively.
This is a Severity Level IV violation.
.
RESPONSE
(1) Reason For The Violation
The root cause of this violation is that an overall program did not
exist to ensure that shelf life controls were being applied
consistently. The shelf life program had been comprised of individual
group procedures, where each group had their own part of the program.
, !
Based on a review of existing inventory thht is currently being
conducted, it appears as though the bulk of the items identified were
received between 1981 and 1984. Contributing causes for each item
found appear to vary from case to case, but in each case the data was
not entered in the Waterford 3 Materials Management Information
System. Some purchase orders required the shelf life data while
others did not. Furthermore, some vendors supplied the shelf life
data while others did not.
l (2) Corrective Steps That Have_,B,een Taken And The Results Achieved
A quality notice (QN QA-89-071) was issued on 3/17/89 to formally
On 3/31/89,
address and track corrective actions for this issue.
Administrative Procedure UNT-8-015. " Shelf Life Program," was
approved. This program provides:
- guidance for identifying limited shelf life items, j
- a method for establishing and assigning consistent and economical
shelf life expiration dates;
_ _ _ _ _ _ - - _
---_-_ _ _ _ .
'
',. Attachm2nt to
'
.- W3PB9-3024
Page 8 of 8
- instructions, forms and references for evaluations to extend a
previously assigned shelf life, and
- instructions for dispositioning expired items and for receiving,
storing, issuing, reordering and specifying limited shelf life
items.
(3) Corrective Steps Which Will Be Taken To Avoid Further Violations
l
A review of existing inventory in stores is being done to identify and
correct limited shelf life items without shelf life controls. This
review is being tracked by the Waterford 3 Commitments Management
System (ID No. A16159). It should be noted that in the interim, a
review of the EPRI Guideline for establishing, maintaining, and
extending the shelf life capability of limited life items (NCIG-10,
draft 5) was conducted. Based on the review of this document, there
appears to be no ic=ediate concern for items without shelf life
controls because actual aging data on the items affected (which are
elastomers) indicates very long shelf lives !14 to 60 years).
(4) Date When Full Compliance Will Be Achieved
The review of existing inventory and imposition of shelf life controls
when necessary will be completed by December 31, 1989, at which time
LP&L will be in full compliance.
l l
.
O
i l L _- - _ __ _ }}