W3P87-1069, Responds to Violations Noted in Insp Rept 50-382/87-07. Corrective Actions:Procedures ME-3-220 & MM-12-001 Will Be Revised to Delete Unnecessary Requirements

Responds to Violations Noted in Insp Rept 50-382/87-07. Corrective Actions:Procedures ME-3-220 & MM-12-001 Will Be Revised to Delete Unnecessary Requirements

ML20214S584
Person / Time
Site:	Waterford
Issue date:	05/29/1987
From:	Cook K LOUISIANA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
W3P87-1069, NUDOCS 8706090333
Download: ML20214S584 (3)

Text

. s

+ P. O. BOX 60340 LO U1S1 POWER AN

& LIGHT A / 317 BARONNESTREET NEW ORLEANS, LOUISIANA 70160 *

(504)595-3100 NU$dhYS May 29, 1987 W3P87-1069 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 87-07 Attached is the Louisiana Power and Light Company (LP&L) response to Violation No. 8707-01 identified in Inspection Report No. 87-07.

If you have any questions on the response, please contact G.E. Wuller, Operational Licensing, at (504) 464-3499.

Very truly yours, I ut $

K.W. Cook Nuclear Safety and Regulatory Affairs Manager KWC:PTM:ssf Attachment cc: R.D. Martin, NRC Region IV J.A. Calvo, NRC-NRR J.H. Wilson, NRC-NRR NRC Resident Inspectors Office E.L. Blake W.M. Stevenson )

8706090333 870529 s f',DR ADOCK 05000392 I

'AN EQUAL OPPORTUNITY EMPLOYER'8 PDR

. o Attachment to W3P87-1069 J Sheet 1 of 2 LP&L Response To Violation No. 8707-01 l VIOLATION NO. 8707-01 Technical Specification (TS) 6.8.1.a requires, in part, that written procedures be implemented for the applicable procedures recommended in i Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Two examples of failure to follow these procedures are listed below:

1. Surveillance testing of emergency power systems is one of the applicable procedures recommended in paragraph 8.b of Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. ME-3-220, Revision 4, " Station Battery Bank and Charger," is an approved surveillance procedure for testing a portion of the emergency power system. Step 8.3.15 of ME-3-220, Revision 4, requires, " Operations isolate the charger from its 125 Vdc PDP by danger-tagging (OPEN) the charger's output circuit breaker on the PDP."

Contrary to the above, on March 10, 1987, Section 8.3 of ME-3-220, Revision 4, was performed on Battery Charger 3AB-1, and the charger was not isolated from its 125 Vdc PDP by a danger tag as required by Step 8.3.15.

2. Procedures for maintenance that can affect the performance of safety-related equipment are recommended in paragraph 9.9 of Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. MM-12-007, Revision 1, " Pipe Hanger Support Installation, Fabrication, Removal,"

is an approved procedure for maintenance that can affect the performance of safety-related equipment. Step 9.5.10 of MM-12-001 requires the installation of lock wire on snubber flange bolts during installation.

Contrary to the above, on March 20, 1987, Snubbers SIRR-1055, SISR-1064, SISR-704, CCSR-1067A, CCSR-1067B, SISR-961A, SISR-961B, and SISR-1064 were found to be installed without lockwire on the snubber flange bolts.

This is a Severity Level V violation.

RESPONSE

(1) Reason for the Violation For both items identified in the violation Waterford 3 maintenance

! personnel failed to strictly follow procedures for performing

maintenance on plant equipment.

(2) Corrective Action That Has Been Taken The following actions have been taken to address the failure of personnel to follow procedures. The Assistant Plant Manager,

Operations and Maintenance issued an Operations and Maintenance Directive (0&M Directive #16) on April 15, 1987, on the subject of l

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

Attachment to W3P87-1069 Sheet 2 of 2 procedure compliance. On April 20 and 21 meetings were held with Operations and Maintenance Department supervisors and craft personnel to discuss the importance of procedural compliance.

For procedure ME-3-220, there is no technical requirement to danger tag the battery charger's output circuit breaker in order to perform the procedure. The procedure, as written, was very restrictive with respect to tagging for an item in which there was no hazard to personnel or equipment.

To address the concern for not lockwiring nuts on snubber flange bolts the manufacturer was consulted. It was determined that lockwiring is not required as long as proper torque is applied during snubber ,.

assembly. As a result, no action is considered necessary to correct field conditions.

In both items above, it has been determined that no technical issues are involved. The above actions are considered sufficient to avoid further violations.

(3) Corrective Action To Be Taken Procedures ME-3-220 and MM-12-001 are being revised to delete the unnecessary requirements. The revisions are expected to be completed by June 5, 1987.

(4) Date When Full Compliance Will Be Achieved Full compliance will be achieved by June 5, 1987.

i I

- . - - - - --- z.-. . . . . _ . - - . . . . - - . . _ - . - . . - . = - . - __+ . _ . _ . - - - - - - , - , -

. . .