W3P86-1949, Responds to Violations & Deviation Noted in Insp Rept 50-382/86-13.Corrective Actions:Rev 2 to Drawing SM-896 Closed Out on 860627,questionable Wires Replaced in Valves SI-225B & SI-227B & Rev 3 to Procedure OP-903-001 Approved
| ML20212P380 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/22/1986 |
| From: | Cook K LOUISIANA POWER & LIGHT CO. |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| W3P86-1949, NUDOCS 8609030109 | |
| Download: ML20212P380 (5) | |
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LOUISI AN A / 317 BARONNESTREET
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P. O. BOX 60340 POWER & L1GHT NEW ORLEANS, LOUISIANA 70160 (504)595-3100 Su NEvsYIU August 22, 1986 W3P86-1949 A4.05 QA Mr. Robert D. Martin Regional Administrator, Region IV i
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U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000
,Q Arlington, TX 76011 AUG 2 51986 LW
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Subject:
Waterford 3 SES
!L Docket No. 50-382
_j License No. NPF-38 hRC Inspection Report 86-13
Dear Mr. Martin:
Attach.ed is the Louisiana Power & Light Company (LP&L) response to Violation Nos. 8613-01, 8613-02 (Attachment A) and Deviation No. 8613-03 (Attachment B) which were cited in the subject NRC Inspection Report.
l If you have any questions on the responses, please contact G.E. Wuller, Onsite Licensing, at (504) 464-3499.
Very truly yours, 8609030109 860322 PDR ADOCK 03000392 G
PDR K.
. Cook Nuclear Support & Licensing Manager KWC:KLB:ssf cc:
NRC, Director, Office of I&E G.W. Knighton, NRC-NRR J.H. Wilson, NRC-NRR NRC Resident Inspectors Office D(
B.W. Churchill W.M. Stevenson 1)
"AN EQUAL OPPORTUNITY EMPLOYER" 10I
V i
ATTACHMENT A to W3P86-1949 Sheet 1 of 3 LP&L RESPONSE TO VIOLATION NOS. 8613-01 & 8613-02 VIOLATION NO. 8613-01 Technical Specification (TS) 6.8.1 endorses NRC Regulatory Guide 1.33, Revision 2, which in turn endorses ANSI N18.7, 1976. ANSI N18.7, 1976 requires that modifications of equipment shall be preplanned and performed in accordance with written procedure.
PE-2-006, Revision 7, " Station Modifications," is an approved procedure which specifies the requirements for implementation of modifications to safety-related plant structures, systems, and components, and particularly in Section 5.9.5 requires that the action engineer redline any control room drawings affected by a modification.
Contrary to the above, for Station Modification 896, "CCW Surge Tank Vent Line Isolation," the appropriate control room drawing was not redlined.
This is a Severity Level IV violation.
RESPONSE TO VIOLATION (1) Reason for the Violation As part of the closeout process for SM-896 drawings LOU-1564-G-160 Sheet I and LOU-1564-G-170 Sheet 2 were redlined in the control room.
on 7/23/85. Since the time of this redline and prior to SM-896 being finally closed-out both drawings were revised and reissued. When these drawing revisions were issued, the previous redline markups were not carried over to the later revisions issued.
The drawing control program as implemented allowed this to happen I
because there was no specific procedural requirement to verify that all redlines on control room drawings had been incorporated in drawing revisions placed in the Control Room.
(2) Corrective Action That Has Been Taken On June 27, 1986 SM-896 revision 2 was closed out.
During the closeout process drawing LOU-1564-G-160 Sheet 1 (the only effected document) was updated by the interim revision procedure (PMP-323).
An initial review of all controlled drawings in the Control Room was conducted to determine if any additional drawing deficiencies could be identified. The results of this review indicated that procedural variances existed and should be corrected.
e ATTACHMENT A to W3P86-1949 Sheet 2 of 3 i
(3) Corrective Action That Will Be Taken The deficiencies identified during this review of Control Room controlled drawings with " work complete" postings will be corrected by j'
September 1, 1986. Procedures (PMP-323 and PE-2-006) will be revised to restrict redlining of control room drawings and require short term followup with interim revised drawings.
In addition, a comprehensive review of all completed Station Modifications and affected drawings will be conducted to assure that the drawings reflect as-built conditions.
(4) Date When Full Compliance Will Be Achieved The drawings having deficiencies identified in the initial review will be corrected by September-1, 1986. Any additional discrepancies identified during the comprehensive review will be corrected by October 31, 1986.
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ATTACHMENT A to W3P86-1949 Sheet 3 of 3 VIOLATION NO. 8613-02 10 CFR Part 50, Appendix B, Criterion XVI, which is implemented by Section 17 of the Louisiana Power & Light Nuclear Operations Quality Assurance Program, requires, in part, that, " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected."
Contrary to the above, prompt action was not taken to correct deficiencies in that, on April 9, 1986, valves SI-225B and SI-227B were identified as possibly not meeting the requirements of the Licensee's equipment qualifications program which implements the requirements of 10 CFR Part 50.49.
Yet, required corrective actions to bring the valves into compliance were not taken until June 18, 1986.
This is a Severity Level IV violation.
RESPONSE TO VIOLATION (1) Reason for the Violation Corrective action was not taken to change out the questionable wiring on valve operators because placing valves SI-225B and SI-227B out-of-service would put the plant in a degraded safety condition and require entering a Limiting Condition for Operation. This work was identified on the Plant's Forced Outage Work List and was to be completed at the earliest opportunity.
(2) Corrective Action That Has Been Taken Based on further emphasis by the Project Engineering EQ Group and the Plant Maintenance Department on the significance of discrepancies in environmentally qualified equipment, clearance to work on these two valves was approved on June 18, 1986. The questionable wires were replaced that same day and the valves were returned to service.
(3) Corrective Action That Will Be Taken No further corrective action necessary.
(4) Date When Full Compliance Will Be Achieved Full compliance with 10 CFR Part 50, Appendix B, Criterion XVI was achieved on the valves in question on June 18, 1986.
ATTACHMENT B a
to W3P86-1949 Sheet 1 of 1 LP&L RESPONSE TO DEVIATION NO. 8613-03 DEVIATION NO. 8613-03 In response to IE Bulletin 85-01, " Steam Binding of Auxiliary Feedwater Pumps," the licensee stated in a letter dated February 26, 1986, that, "Upon reaching a 230*F reading, control room supervisors are instructed that corrective action is required to vent, drain, and fill as required to bring the temperatures down."
In deviation from the above, the NRC inspectors could find no procedural implementation of the 230*F limit or the action specified to be accomplished at that temperature. Questioning of a number of senior reactor operators demonstrated they were not cognizant of such a limit.
RESPONSE TO DEVIATION (1) Reason for the Deviation Procedure OP-903-001, " Technical Specification Surveillance Logs," did not adequately incorporate the specific operator actions to be taken pursuant to LP&L response to IE Information Notice 84-06.
(2) Corrective Action That Has Been Taken Operations Procedure OP-903-001, Revision 3, Change 6 was approved on July 29, 1986. This change added the requirement that "If steam binding is indicated, OR if discharge temperature exceeds 230*F on a pump, perform Attachment 10.15 for the affected pump."
(3) Corrective Actio'n That Will Be Taken No further action is being considered.
(4) Date When Full Compliance Will Be Achieved Full compliance was achieved with the procedure change on July 29, 1986.