W3P85-1442, Final Potentially Reportable Deficiency Rept 180 Re Failure to Maintain Adequate Control of Vendor Manuals.Initially Reported on 840918.Preventive Maint Program Implemented.Item Not Reportable Per 10CFR50.55(e)

Final Potentially Reportable Deficiency Rept 180 Re Failure to Maintain Adequate Control of Vendor Manuals.Initially Reported on 840918.Preventive Maint Program Implemented.Item Not Reportable Per 10CFR50.55(e)

ML20133H427
Person / Time
Site:	Waterford
Issue date:	08/01/1985
From:	Cook K LOUISIANA POWER & LIGHT CO.
To:	Martin R, Maryin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
180, W3P85-1442, NUDOCS 8508090348
Download: ML20133H427 (4)

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[.OUISIANA 44 os - o~oe= raser . o eoxeoo.

)0WER & LIGHT / New onceANa toWISIANA 70174-8000 9 (504)388- 345

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August 1, 1985 W3P85-1442 A4.05 Mr. Robert D. Martin -

Regional Administrator, Region IV p- a ;; ,

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U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011

{__. t AUG-21995 '

Dear Mr. Martin'

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Subject:

Waterford 3 SES Docket No. 50-382 License No. NPF-38 POTENTIALLY REPORTABLE DEFICIENCY NO. 180

" Failure to Maintain Adequate Document Control Of Vendor Manuals" Final Report

References:

1. Telecon - G.E. Wuller (LP&L) to J.R. Boardman (NRC),

on September 18, 1984.

2. W3P85-1420 from K.W. Cook (LP&L) to R.D. Martin (NRC),

dated June 27, 1985.

3. W3P84-2386 from K.W. Cook (LP&L) to J.T. Collins (NRC),

dated September 13, 1984.

4. W3P85-1237 from K.W. Cook (LP&L) to R.D. Martin (NRC),

dated April 29, 1985.

In accordance with 10CFR50.55(c) LP&L provided telephone notification on September 18, 1984 (Reference 1) of the subject deficiency. Reference 2 rescheduled the submittal of a written report on PRD-180 to August 1, 1985.

Reference 3 provided LP&L's response to related Violation 8425-01 which specified details on corrective actions planned and underway to resolve this violation.

By Reference 4. LP&L rescheduled the date to achieve full compliance for Violation 8425-01 from April 30, 1985 to August 1, 1985. Additionally, Reference 4, notified the NRC that an ongoing program for verifying adequate documentation of decisions concerning preventive maintenance with respect to any deviations from vendor recommendations, as prescribed in vendor manuals, had been implemented at Waterford 3. We informed you that LP&L had performed a technical review of environmentally qualified / safety-related vendor technical manuals, extracted individual vendor recommen-dations applicabic to Waterford 3 f rom those manuals, an:1 was in the process of identifying / evaluating deviations from identified vendor recommendations.

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. Mr. Robert D. Martin W3P85-1442 Page 2 Presently the majority of vendor manual deficiencies noted during the technical review of environmentally qualified / safety-related vendor manuals and the majority of vendor recommendations contained in those vendor manuals have been evaluated against the Waterford 3 Preventive Maintenance Program. Based on a review of the above evaluations, LP&L has determined that the reported deficiency on the failure to maintain adequate document control of vendor manuals is not a reportable deficiency per 10CFR 50.55(e) due to unfounded significance to operational safety. Enclosed are two copies of the final report on PRD-180. Further details on the deficiency are available in our files, should the NRC desire additional information.

truly yours,

'/ 'b4 ook a

es}&b/

K. .

Nucient Support & Licensing Manager KWC:GEW:sms Enclosure cc: NRC, Director, Of fice of I&E C.W. Knighton, NRC-NRR D.M. Crutchfield, NRC-NRR NRC Resident Inspector Office B.W. Churchill W.M. Stevenson

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'o W3P85-1442 FINAL REPORT POTENTIALLY REPORTABLE DEFICIENCY NO. 180

" FAILURE TO MAINTAIN ADEQUATE DOCUMENT CONTROL OF VENDOR MANUALS" INTRODUCTION This report is submitted pursuant to the telephone notification of September 18, 1984 whereby a potential deficiency per 10CFR 50.55(e) was reported. The potential deficiency was based on nonconforning conditions identified by the NRC through an unannounced inspection of LP&L Maintenance.

DESCRIPTION NRC Inspection Report 50-382/84-25 cited LP&L for procedural deficiencies in the control and use of vendor instruction manuals and other technical data. Specific areas of concern noted by the NRC include the following:

1. use of unapproved manuals

2. unapproved changes to manuals

3. lack of procedural control for vendor supplied manuals

4. lack of procedural controls for technical changes

5. lack of procedural control to assure use of vendor manuals recommendations in site procedures A subsequent assessment by the LP&L Operations Oaality Assurance Department noted similar concerns with varying significance, however, it could not be determined whether or not a programmatic deficiency existed with the control of vendor manuals without performing a more in-depth review.

SAFETY IMPLICATIONS Procedural deficiencies in the LP&L document control system for vendor instruction manuals and other technical data may not have provided an effective program to assure proper maintenance and preclude prenature degradation of safety-related equipment. Although isolated cases of procedural deficiencies have been identified, no serious detrimental effects to equipment components have been detected as a result of those deficiercies.

Subsequent evaluations by the Plant Staff related to the corrective actions being taken to resolve Violation 8425-01 are nearing completion. To date, the Plant Staff has not identified any deficiencies during the technical review of environmentally qualified / safety-related vendor manuals or deviations from vendor recommendations contained in those vendor manuals which would have had a significant impact to operational safety at Waterford 3, if 1cft uncorrected.

PRD-180 is deemed to be a non-reportable deficiency per 10CFR50.55(e) on the basis of unfounded significance to operational safety.

• o CORRECTIVE ACTION LP&L has developed and implemented an ongoing program for verifying adequate documentation of decisions concerning preventive maintenance with respect to any deviations from vendor recommendations, as prescribed in vendor manuals. This has been accomplished by reviewing and revising administrative procedures which address the document control of vendor manuals at Waterford 3.

The technical review of all vendor instruction manuals at Waterford 3 is complete. The evaluation of deviations taken to vendor recommendations in vendor manuals for environmentally qualified / safety-related equipment is approximately 93% complete.

The lubricants in the Plant Lubrication Manual have been qualified by Project Engineering for use without changing any previously specified lubricants.

Thic report is submitted as the final report.

J