W3P85-1477, Responds to Violations Noted in Insp Rept 50-382/85-01. Corrective Actions:Procedure UNT-8-001 Revised to Correct Omission of Plant Structures & Environ Qualification Package for Emergency Feedwater Pump Motors Reviewed
| ML20215M729 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 09/19/1985 |
| From: | Cook K LOUISIANA POWER & LIGHT CO. |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20215M710 | List:
|
| References | |
| W3P85-1477, NUDOCS 8611030206 | |
| Download: ML20215M729 (8) | |
Text
r-I OUISIANA f 342 OuAnONOe sraeer POWER & L1GHT/ P O BOX 6008
- NEW OnLeANS LOUISIANA 70174 * (504) 36+2345 Su?$bsE September 19, 1985 W3P85-1477 A4.05 Mr. Robert D. Martin Regional Administrator, Region IV U.S. Nuclear Regulatory Commission B {g g {'a qn9:
7 611 Ryan Plaza Drive, Suite 1000
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Arlington, TX 76011 l
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Dear Mr. Martin:
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Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report 85-01 Attachment A has the Louisiana Power & Light Company (LP&L) responses to Violations numbered 8501-01 and 8501-03 which were cited in the subject NRC Inspection Report. Additionally, per the verbal request of Mr. E. H.
Johnson, NRC Region IV, the LP&L response to the unresolved item No.
8501-02 of the subject report is given in Attachment B.
These responses are submitted under affidavit as required by Section 182 of the Atomic Eaergy Act of 1954, as amended.
If you have any questions on the responses, please contact G.E. Wuller, Onsite Licensing, at (504) 464-3499.
Very truly yours,
/t/
68 8611030206861h82 K.W. Cook PDR ADOCK 050 Nuclear Support & Licensing Manager PDR G
KWC:GEW:sms Attachments cc:
NRC, Director, Office of I&E G.W. Knighton, NRC-NRR J.H. Wilson, NRC-NRR NRC Resident Inspectors Office B.W. Churchill W.M. Stevenson Tc+(s'fST
i ATTACHMENT A to W3P85-1477 LP&L Response to Violations in Inspection Report No. 85-01
- 1. VIOLATION NO. 8501-01 Licensee Failure to Have Procedures to Assure Compliance with Waterford SES Unit 3 Operations Quality Assurance Program, Section 17.2.23, and FSAR Table 3.2.1, Note 12, 10 CFR Part 50, Appendix B, Criterion V requires that activities affecting quality be prescribed by documented instructions and procedures.
Waterford SES Unit 3 Operations Quality Assurance Program, Section 17.2.2.3 states:
" Table 3.2-1 of this FSAR provides the safety-related classification of plant structures, systems, and components and identifies those items subject to the 10 CFR 50, Appendix B, Quality Assurance Program as herein described."
Waterford SES Unit 3 FSAR Table 3.2-1 includes a Note 12 as being applicable for the category " Electric Systems and Equipment."
Note 12 states:
" Electrical Equipment - All cables, relays, motors, switchgear and other electrical equipment serving safety system components required to function during the SSE shall be Class 1E, if they are necessary for the performance of the component's function. All Class 1E electrical equipment will receive applicable portions of 10 CFR 50 Appendix B QA during the operations."
Contrary to the above, the licensee had no procedures to assure implementation of these requirements and commitments.
This is a Severity Level IV violation (Supplement II.d.) (50-382/
8501-01).
RESPONSE TO THE VIOLATION (1) Reason for the Violation Procedure UNT-8-001 governs the procurement of spare and repair parts.
Revision 8 (approved November 15, 1984) of this procedure was in effect during the January 7-11, 1985 NRC inspection period.
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r For the procurement of spare and repair parts, the intent of FSAR Section 17.2.23 and Table 3.2-1 including Note 12 was fulfilled by Revision 8 of UNT-8-001.
This was accomplished by imposing a general procedure requirement that the FSAR, purchase order specifications and regulatory documents be consulted to assure that purchase order documents reflected current requirements.
However, this procedure revision was deficient in not specifically referencing FSAR Table 3.2-1 to determine the safety-related classification and quality assurance requirements for procuring replacement parts for plant structures, systems and components. In addition, Revision 8 of UNT-8-001 required that parts precured for safety-related systems or components be treated as safety-related but omitted plant structures from the requirement. Due to inadequate procedura review, reference to the appropriate FSAR sections was erroneously deleted in Revision 6 (approved May 14, 1984) of UNT-8-001.
For the same reason, the procurement requirements that included plant structures was erroneously deleted in Revision 7 of UNT-8-001.
(2) Corrective Steps Taken and Results Achieved Revision 9 of UNT-8-001 (approved March 8, 1985) corrected the procedural deficiency concerning the omission of plant structures.
(3) Corrective Actions That Will Be Taken To further strengthen the procurement process, procedure UNT-8-001 will be changed to include FSAR Table 3.2-1 in its reference section and will specifically require FSAR Table 3.2-1 to be consulted to assure that procurement documents reflect appropriate quality assurance requirements.
(4) Date When Full Compliance Will Be Achieved To achieve full compliance, implementation of the required procedure changes will be completed by November 30, 1985.
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- 2. VIOLATION NO. 8501-03 Failure to Have Maintenance Procedures for Safety-Related Equipment Which Reflect Equipment Manufacture's Recommended or Suggested Maintenance 10 CFR Part 50, Appendix B, Criterion V requires that activities affecting quality shall be prescribed by documented procedures and instructions.
The licensee has committed to Regulatory Guide 1.33, Revision 2, and ANSI 18.7-1976 (with comments). ANSI N18.7, Section 5.3.5(4), states:
"Where appropriate sections of related documents such as vendor manuals or equipment maintenance instructions provide adequate instructions to assure the required quality of work, the applicable sections of the related documents shall be referenced in the procedure."
Contrary to the above, the licensee failed to have maintenance procedures for Emergency Feed Water (EFW) pump motors which addressed the motor manufacturer's suggested and recommended maintenance for these motors.
This is a Severity Level IV violation (Supplemental II.d) (50-382/
8501-03).
RESPONSE TO THE VIOLATION (1) Reason for the Violation The Preventive Maintenance (PM) Program for the Emergency Feedwater (EFW) Pump Motors was established using the General Maintenance Guidelines provided in the manufacturer's manual.
Included in the program are Maintenance procedures that address the manufacturer's suggested and recommended maintenance for the motors.
The Environmental Qualification (EQ) Package had not been reviewed for additional preventive maintenance recommendations.
(2) Corrective Steps Taken and Desults Achieved A review of the EQ package for the EFW pump motors has been conducted and the preventive maintenance recommended therein has been compared to the PM routine presently implemented on the motors. Disparities between the two (2) programs are being evaluated as part of Waterford's EQ Program, which is scheduled for implementation by November 30, 1985, for safety-related equipment located in a harsh environment.
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r-(3) Corrective Actions That Will Be Taken The Waterford 3 EQ Package is presently under review to ascertain what maintenance items are necessary to maintain the environmental qualification of Waterford's safety-related equipment. A program to implement additional maintenance requirements, as deemed necessary by this review, is underway.
(4) Date When Full Compliance Will Be Achieved All corrective action will be completed by November 30, 1985.
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F ATTACHMENT B to W3P85-1477 LP&L Response to Unresolved Item in Inspection Report No. 85-01 UNRESOLVED ITEM NO. 8501-02 LP&L Procured Operation Phase Spare and Repair Parts for the Emergency Feedwater (EFW) Pump Motors The NRC inspector was informed of the recent failure of an upper motor bearing half for EFW Pump B.
The lower bearing was undamaged. The motor for this safety-related pump requires environmental qualification.
The NRC inspector reviewed purchase order documentation provided by LP&L for EFW pump motor parts procured by purchase requisition (PR) No. 60912, dated June 16, 1982, and LP&L purchase order (PO) No. L22258D, dated November 22, 1982, to Bingham-Willamette. The original technical and QA requirements of this order appear identical to the EBASCO purchase order for the pumps and motors, NY-403431, and its invoked requirements. General Electric (GE) provided the equipment qualification (EQ) documentation for the original pump motors.
On November.22, 1983 Bingham-Willamette sent LP&L a letter stating that CE considered that the requirements on pages 2 through 6 of the LP&L PO " call for specifications far and beyond that used on the original equipment."
By revision 2, dated December 28, 1983, to PO L-22258D (which referenced the Bingham-Willamette letter of November 22, 1983), LP&L deleted:
(1) Quality Assurance Program Requirements (10 CFR 50, Appendix B and ANSI N45.2-1971) from page 2 of the P0.
(2) Procedures for Design Review (ANSI N45.2-11-1974, paragraph 6.1) from page 3 of the P0.
(3) Procurement (N45.2.13-1976) from page 3 of the PO.
(4) Qualification of Personnel (N45.2.6-1973, paragraphs 2.1, 2.2.1 2.2.3, and 2.2.4) from page 3 of the P0.
(5) Reporting of Rejects and Noncompliance (10 CFR 21) from page 5 of the P0.
(6) Collection, Storage, and Maintenance of Records (ANSI N45.2.9-1974, paragraphs 3.2.1, 3.2.6, and 5.0) from page 5 of the PO.
(7) Certificate of Conformance (including certification that the items ordered are qualified to meet the requirements of IEEE 323-1974 and IEEE - 1975) from page 6 of the P0.
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F Based on a telephone communication between the NRC inspector and Bingham-Willamette on January 22, 1985, this was the last change to P0 L22258D received by Bingham-Willamette and was the revision in effect when PO items 1, 2, and 3 were shipped, and the order was considered as complete by
-Bingham-Willamette on April 16, 1984.
The NRC inspector was provided a copy of Revision 3 to PO L22258D. This revision was identical to Revision 2 except that it required a Certificate of Conformance, but it also deleted certification that the items are qualified to meet the requirements of IEEE 323-1974 and IEEE 344-1975.
This will remain an unresolved item pending review during a subsequent inspection by the NRC inspector of a purchase order document package containing all documentation related to LP&L PO L22258D.
(50-382/8501-02)
Response to Unresolved Item 8501-02 i
LP&L Purchase Order No. L22258D covered three separate replacement parts; bearing, oil ring and stator, for the electrically powered Emergency Peedwater Pumps. Discrepancy Notice (DN) 1752-84 was written during the receipt inspection because the paper work received with the order was inadequate. Subsequently, two of the items were evaluated for acceptability by
- Spare Parts Equivalency Evaluation Reports (Speers)85-102 and 85-101. After these Speers were completed, the hearing and oil ring were found to be acceptable for use in the motor.
The third item on the P.O. (motor stator) remains on hold in the warehouse.
LP&L is in the process of obtaining documentation from GE that the motor stator is acceptable for use in its intended application. LP&L will ensure that the part is suitable for use in its intended environment before the part is accepted for use.
Obtaining the necessary documentation and performance of the required engineering by LP&L should be completed within 90 days.
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4 W3P85-1477 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of
)
.)
Louisiana Power & Light Company.
) Docket No. 50-382 Waterford 3 Steam Electric Station
)
AFFIDAVIT K.W. Cook, being duly sworn, hereby deposes and says.that he is Nuclear Support & Licensing Manager of Louisiana Power & Light Company; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached responses to Violations Nos.8501-01 and 8501-03; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.
K.9. Cook Nuclear Support & Licensing Manager STATE OF LOUISIANA
)
) ss PARISH OF ST. CHARLES)
Subscribed and sworn to before me, a Notary Public in and for the Parish and State above named this 19th day of SePtenber 1985.
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/1 Notary P'UFile My Commission expires at death.
0-4 I OUISIANA J
P O W E R & L 1 G H T! P O BOX 6008
- NEW ORLEANS. LOUISIANA
,42 ouiRoNos smer 70174. (504) 366-2345 UTIUTIES SYSTEM March 14, 1986 W3P86-0044 A4.05 QA Mr. Robert D. Martin Regional Administrator, Region IV m)
B R in. '
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r4 U.S. Nuclear Regulatory Commission
'Jb 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 g lgg
Subject:
Waterford 3 SES Docket No. 50-382 Licens? No. NPF-38 Response to Violation No. 8527-03
Reference:
LP&L letter W3P86-0019, dated 2/14/86, subject: NRC Inspection Reports 85-04 and 85-27.
Dear Mr. Martin:
This is to clarify and correct a discrepancy we found in the LP&L response to the subject violation which was provided via the referenced letter. It also confirms the same information that was verbally related on February 21, 1986 to Mr. J.G. Luehman, NRC Resident Inspector.
The response to Violation No. 8527-03, via the referenced letter, specifically stated:
1.
Under the section entitled, Corrective Action That Has Been Taken -
For Part 2:
"In conjunction with the EQ program, 0-rings were replaced using a proper lubricant and the access covers were torqued during the last quarter of 1985 on the Model 1153 Rosemount transmitters located in the containment."
2.
Under the section entitled, Date When Full Compliance Was Achieved -
l For Part 2:
" December 31, 1985" i
Unfortunately, due largely to the magnitude of information provided in the referenced 1ctter and the scheduled response date, the completion of corrective action was erroneously reflected in the response to Violation No. 8527-03. Replacement of the 0-rings on one Rosemount 1153 transmitter l
l located in the containment was not completed at the time given in our l
response.
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.c Mr. Robert D. Martin W3P86-0044 Page 2 Subsequently, on February 21, 1986 the 0-rings were replaced on the one Model 1153 Rosemount transmitter in containment which was not previously reworked. Completion of the corrective action for Part '2 of Violation 3527-03 is properly stated as February 21, 1986.
Very truly yours, K.W. Cook Nuclear Support & Licensing Manager KWC:GEW:ssf cc: NRC, Director, Office of I&E G.W. Knighton, NRC-NRR J.H. Wilson, NRC-NRR NRC Resident Inspectors Office B.W. Churchill W.M. Stevenson l
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