W3P89-1046, Responds to NRC Ltr Re Violations Noted in Insp Rept 50-382/89-01.Corrective Actions:Involved Maint Personnel Counseled by Maint Mgt & Memo Stating Authorization for Operation of Valve by Operations Personnel Issued
| ML20247J246 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 05/22/1989 |
| From: | Burski R LOUISIANA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3P89-1046, NUDOCS 8906010078 | |
| Download: ML20247J246 (14) | |
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1 LO UISI AN A / 317 BARONNE STREET P. O. BOX 60340
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POWER & LiG HT NEW ORLEANS, LOUISIANA 70160 (504) 595-3100 UrIOksEsM May 22, 1989 W3P89-1046 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. NFF-38 NRC Inspection Report 50-382/89-01
REFERENCE:
LP&L Letter W3P89-3018, dated April 20, 1989 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. LP&L requested, see referenced letter, and the NRC granted a 30 day extension of the original response date during a telephone conversation held on May. 4,1989 between J. Cagliardo of the NRC and R.F. Burski of LP&L.
Please contact me or Robert J. Murillo at (504).595-2831 if you have any questiens concerning these responses.
Very truly yours, R.F. Burski Manager Nuclear Safety & Regulatory Affairs RFB/RJM:dc Attachment cc:
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 r
8906010070 890522
^;:.1 PDR ADOCK O$000382 g
a PNU f \\
"AN EQUAL OPPORTUNITY EMPLOYER" J
't-c Attachment One To LP&L Letter W3P89-1046 Attachment One LP&L Responses To Violations Identified In Appendix A, Of Inspection Report 50-382/89-01 EA.
Violation 8901-05 Failure to Follow Equipment Control Procedures Waterford Steam Electric Station, Unit 3, Technical Specification 6.8.1 requires that written procedures be established, implemented, and main-tained for procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A, paragraph 1.c, requires that administrative procedures be developed for-equipment control. The following three cases are examples of failure to adhere to equipment control procedures.
1.
Louisiana Power & Light (LP&L) Maintenance Procedure MD-1-014, Revision 2, " Conduct of Maintenance," paragraph 5.1.5, requires that plant equipment such as pumps, valves, and breakers, which are portions of systems used for power generation, will not be operated by maintenance personnel unless specifically directed to do so by the shift supervisor (SS)/ control room supervisor (CRS) or as a part-of an approved maintenance procedure authorized to be performed by the SS/CRS.
Contrary to the above, on January 31, 1989, the NRC inspector observed that a mechanical maintenance worker operated Water Chiller Outlet Isolation Valve CHWMVAAA121B during the performance of main-tenance work authorization (WA) 01021204 without specific direction from the SS/CRS or authorization in an approved maintenance procedure.
2.
LP&L Administrative Procedure UNT-5-010, Revision 0, " Independent Verification Program," paragraph 5.2.1, requires that independent verification be performed on components, which could have been mispositioned during maintenance.
Paragraph 5.5.2 applies inde-pendent verification requirem.nts to systems listed in Attachment 6.1.
This attachment identffzed the chilled water system as requiring independent verification.
Contrary to the above, independent verification of proper positioning of Chilled Water System Manual Valve CHWMVAAA121B was not performed following valve manipulation during activities performed byN/A 01021204 on January 31, 1989.
3.
LP&L Administrative Procedure UNT-5-003, Revision 7, " Clearance Requests, Approval and Release," paragraph 3.4, states that a danger tag, when in place, prohibits the operation of equipment or systems, which could jeopardize personnel safety or endanger equipment.
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Attachment One To LP&L Letter W3P89-1046 Contrary to the above, on January 31, 1989, the NRC inspector observed that a mechanical maintenance worker turned the valve operating hand wheel for Valve FS-325 while the hand wheel had a danger tag (89-103-5) attached.
This is a Severity Level IV vi'lation.
RESPONSE
1.
LP&L's Position Regarding the Violation LP&L edmits parts 1 and 3 of violation 8901-05. The reasons for the violation are personnel error and the lack of detailed guidance for the operation of valves and implementation of danger tags.
LP&L denies part 2 of violation 8901-05.
Part 1 of violation 8901-05 is that of a mechanical maintenance worker moving the Water Chiller Outlet Isolation Valve CHWMVAAA121B during the performance of maintenance Work Authorization (WA) 01021204.
Clearance 89-104 deenergized the Chilled Water Pump motor and isolated the Chilled Water Pump inlet and outlet valves. Valve CHWMVAAA121B is the manual chiller outlet isolation valve. The valve was contained inside the tag-out boundary.
The valve was moved in order to lubricate the valve operator following maintenance on the valve which included disassembly and assembly of the valve, and not to verify valve lineup or operability.
.Thus, since the valve was within a tagged out boundary and operated as an integral part of a maintenance function, the maintenance personnel erroneously judged that movement of the valve was in conformance with maintenance procedure MD-1-014, Revision 2.
Part 2 of violation 8901-05 specifies that operations personnel did not independently verify the proper valve position of valve CHWMVAAA121B following valve operation performed by personnel in accordance with WA 01021204.
LP&L procedure UNT-5-010, Revision 0, allows the proper valve position to be verified by either independent verificatl,n or a functional test. The Chilled Water loop B, which contains valve CHWMVAAA121B, flow rate and temperature were verified to be < 42 F at a flow rate of >
500gpm in accordance with T.S. surveillance 4.7.12.1 prior to returning the Chilled Water train B to operable status. The temperature was 40 F at a flow rate of 510 gpm. These results were recorded in the station log.
Valve CHWNVAAA121B is located upstream of the flow element for l
essential Chiller B.
Low flow in loop B would have occurred had valve CHWMVAAA121B not been properly positioned.
Thus, any misalignment of valve CHWMVAAA121B would have been identified and corrected.
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Attachment One To LP&L Letter W3P89-1046 Part 3 of violation 8901-05 specifies a third instance of failure to follow equipment cont rol procedures where a mechanical maintenance worker turned the valve operating handwheel for valve FS-325 which had a danger tag attached.
Earlier in the filter changeout for the Fuel Pool Purification system, 1roblems were experienced draining the filter. An operator was summoned to provide help. The operator performed a valve lineup verification, with the, exception of the filter drain valve, and found no other problems.
After discussion with the Control Room and Health Physics personnel, the decision was made to pull the filter element and then locally verify the position of the drain valve.
It was believed that the remote operator might have become disconnected becaus no other cause could be determined that would prevent draining the filcer. Thus, a maintenance person, who performed the filter changeout, verified the position of the filter drain valve, FS-325, following the changeout by rotating the remote operator handwheel in the closed direction while another mechanic locally verified that the valve handwheel turned in the closed direction.
Subsequently, operations personnel determined that back pressure from the Equipment Drain Tank (EDT), which the Fuel Pool Purification Filter drains to, was retarding the draining. The operator involved in this event'thus explained to maintenance personnel that the EDT backpressure
'had been the reason that the filter had not drained. The operator recalls he then told maintenance personnel there was no need to check the position of the filter drain valve locally as had been previously agreed upon. Maintenance personnel did not have a clear understanding of the discussion and therefore still believed the drain valve in question needed to be checked locally. Following the work, maintenance personnel therefore cherked the valve as previously described.
i Maintenance personnel thus erroneously believed verification of the l
position of the filter drain valve was in accordance with procedure UNT-5-003.
2.
LP&L Actions Taken and Results Achieved Part 1 The maintenance personnel involved in part 1 of violation 8901-05 have been counselled by maintenance management.
The counselling emphasized the need for strict adherence to procedures, careful review and under-(
standing of procedures, and communications with cognizant personnel I
anu management regarding perceived questionable procedural steps. The counselling also entailed a review of applicable procedures for operation of plant equipment.
The plant manager issued a memorandum which clearly states that no one except operations personnel shall operate a valve unless specifically authorized by an approved plant procedure or WA signed by the shift or control room supervisor. The memorandum was distributed to site personnel at safety meetings.
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-Attachment One g
To LP&L Letter W3P89-1046 d
Part'3 p
p A meeting was held February '1,-1989, to gain an understanding of:the events which, led to the operation.of a compuaent with a danger tag byL maintenance personnel following the changeout'of the. Fuel Pool-Purification filter element on January'31, 1989. The meeting was chaired by the Event Analysis, Reporting, and Response Manager and Maintenance Superintendent.. Maintenance, Health Physics, and Rad. Waste' personnel involved with'the filter:changeout were in attendance along with their supervisors. The events. surrounding the filter'changeout were discussed in detail. A" time'line, causal' factor chart, was developed to analyze the event. The February 1, 1989 meeting provided the forum for Establishing a clear. understanding of the root cause and for appraising cognizant personnel of the need for strict adherence to, careful review
. of, and understanding of procedures.
The previously mencioned memorandum also clearly states that no one shall operate a component with a danger tag until the danger tag'is. properly cleared in accordance with UNT-5-003. Additionally, the memorandum emphasizes the'importance of the requirement by stating that' repositioning.
of-danger tagged components is grounds for termination.
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- 3. : Future Actions-To Be Taken Part 1 l
LP&L will revise applicable maintenance controlling procedures.to.
incorporate. requirements on the movement of valves while performing maintenance activities and guidance on independent verification of valve position following maintenance. The revision will convey that main-tenance personnel may move a valve within a tagged out boundary provided the movement-is performed as an integral part of the maintenance on'that valve and'the valve movement is authorized procedurally or by a WA.
Part 3 LP&L will also revise maintenance procedures MD-Ol-014 to incorporate the guidance in the plant manager memorandum and attachment.
4.
Date When Full Compliance Will Be Achieved LP&L will be in full compliance by June 30, 1989.
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Attachment One
.To LP&L Letter W3P89-1046 B.
Violation 8901-06 Failure to Follow Maintenance Procedure Waterford Steam Electric Station, Unit 3, Technical Specification 6.8.1 requires that written procedures be established, implemented, and maintained for procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A, paragraph 9.e, requires general procedures to be developed for control of maintenance, repair, replacement, and modification work.
LP&L Maintenance Procedure MD-1-014, Revision 2, " Conduct of Main-tenance," paragraph 5.1.2, requires that strict compliance with approved procedures and work instructions is mandatory.
WA 01006815 required performance of preventive maintenance on 4160 volt Switchgear'3B-3S in accordance with Maintenance Procedure ME-4-121, Revision 3, "4.16-KV Switchgear." Paragraph 8.1.24 of this procedure required torquing of all limit switches, auxiliary switches, and switch tie-bolts. Paragraph 8.1.31 of this precedure required verification of torque of all exposed electrical connections including the switchgear grounding connections. Attachments to the procedure provided appropriate torque values.
Contrary to the above, during the performance of WA 01006815 during the 1988 refueling outage, the paragraphs of Maintenance Procedure ME-4-121, Revision 3, which addresses torquing, were not performed. These paragraphs were marked "N/A" and explanatory notes were added indicating that no loose connections were found, so torquing was not required. No torque wrenches were listed as having been used on this job.
This is a Severity Level IV violation.
RESPONSE
1.
LP&L's Position Regarding the Violation:
LP&L admits the violation. The violation is attributed to personnel ecror. A contributing factor is inconsistencies in maintenance procedures.
Maintenance procedures ME-4-101 for 6.9 KV switchgear and ME-4-141 for 480 V switchgear are procedures that are similar to ME-4-121 for 4.16 KV switchgear. These two procedures allow maintenance personnel to designate a step "NA" if the step or condition is not appropriate for conditions at the time of performance of the maintenance activity. The individual concerned had previously performed maintenance in accordance with maintenance procedure ME-4-141 and mentally confused the "NA" provision allowed under procedure ME-4-141 with procedure ME-4-121.
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Attachment One To LP&L Letter W3?89-1046 2.
LP&L~ Actions Taken and Results Achieved The individua1' concerned has been counselled by the cognizant Maintenance Assistant Superintendent regarding the need for strict adherence with procedures, careful review and understanding of procedures, and communi-cation with cognizant personnel and management regarding perceived questionable procedural steps. Additionally, the cognizant Maintenance Assistant Superintendent has reviewed pr e :edures ME-4-141, ME-4-101, ME-4 221 with the concerned individual to assure the procedures are fully understood.
A formal engineering evaluation, PEIR 61143, has been performed to evaluate the sefety significance and operability of the 3B-3S 4160 volt l
switchgear.
j The evaluation concluded that the operability and safety of the 3B-3S 4160 volt switchgear were not adversely affected by the entry of N/A on steps 8.1.24 and 8.1.31 of procedure ME-04-121.
Step 8.1.24 had been previously added to the procedure to address problems solely applicable to the elevating mechanism. Therefore, the intent of this step was to check only the switches ani'cie bolts for the elevating mechanism which have no function in breaker operation once the breaker is racked in.
Verification of the positive interlock of the clos:. g circuit is required in accordance with procedure OP-100-010, Attachment 6.3, before the breaker is declared operable, resulting in an independent verification of breaker operability. Step 8.1.31 was considered N/A because no electrical connections were disconnected. The insulated bus connections were tested with infrared scanning under full load conditions prior to the outage to ensure electrical continuity. There is no need to evaluate the other l
safety'related switchgear since the above mentioned work was performed only for 3B-3S 4160 volt switchgear.
3.
Future Actions To Be Taken LP&L will revise maintenance procedures ME-4-101, HE-4-121, and HE-4-141 to assure they are consistent regarding the provisions for designating a step "NA".
The guidance for designating a step "NA" will be consistent with approved and controlled maintenance procedures, for example, MD-1-014 and MD-1-028.
LP&L will also prepare a formal lesson plan on procedures ME-4-101, i
ME-4-121, and ME-4-141.
Maintenance personnel will receive training on the lesson plan.
4.
Date When Full Compliance Will Be Achieved I
LP&L will be in full cumpliance by October 15, 1989.
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Attachment One To LP&L Letter W3P89-1046
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Violation 8901-09 Failure to Follow Requirements of the Plant Lubrication Manual Waterford Steam Electric Station, Unit No. 3, Technical Specification 6.8.1 requires that written procedures ba established, implemented, and maintained for. procedures recommended in. Appendix A of Regulatory Guide
.1.33,. Revision 2, February 1978.. Regulatory Guide 1.33, Appendix A, paragraph 9.a, requires, in part, that maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
Maintenance Procedure UNT-5-007, Revision 1, " Plant Lubrication. Program,"
establishes, in part, the method for lubricating safety-related equipment.
Step 5.4.2 of UNT-5-007, Revision I states, in part, that " Lubrication activities for plant equipment shall utilize only the lubricants-listed in th'e"PLM [ Plant Lubrication Manual] unless otherwise specified on s-CIWA..."
Contrary to.the above,.three environmentally qualified safety-related motor operated valves inside the reactor building were found by the licensee to be' lubricated with an admixture of two different types of grease in May 1988, even though the PLM only specified the use of Exxon Nebula EP-0.
This is a Severity Level IV violation.
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. RESPONSE 1:
1.
LP&L's Position Regarding The Violation LP&L admits to the violation, in that, in May 1988 three environmentally qualified safety-related motor operated valves were found by LP&L'to be lubricated contrary to.the requirements of the PLM. The reason for the-violation.is personnel error.
In addition to the specifics identified in the violation, a number of observations and weaknesses in the lube program were discussed in the body of the inspection report. The following response addresses the l!
violation and these additional concerns.
j There are two different aspects to this issue, the mixing of grease with different soap bases, and assuring the application of the intended
. grease. These aspects are discussed separately.
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I' Mixing of Grease The mixing of grease with different soap bases is in large part attributed to.the evolution of the practice and policy for the use of grease.
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Attachment One To LP&L Letter i
PRE-88-048 documented that the grease type in the gear boxes of Limitorque MOV actuators SI-HVAAA 332A, 332B, 401A and 401B inside containment were found to be indeterminate during preventative maintenance that was per-i formed in May 1988. Subsequent laboratory analysis and evaluation established that the grease for MOV actuators 331B, 332A, and 332B, had a mixture of Mobilux and Nebula greases.
The subject MOVs were lubricated during the first refueling outage in November 1986, and Plant Lubricating Manuti (PLM) and the maintenance work orders specified Nebuta EPO for the grease.
The next preventative maintenance to check or lubricate the subject valves was due in May 1988 during the second refueling outage, at which time the type of grease in the subject valves was found to be indeterminate.
LP&L therefore be-lieves based on'a review of records, that the mixing of the greases occurred during startup activities in 1984 and 1985 at Waterford 3.
During startup activities, the PLM did not exist, and the application o' grease was in accordance with the technical manuals. The technical manual for Limitorque MOV actuators specified Exxon Nebula EPO as the lubricant.
In the past, it was the policy of LP&L to exclusively specify the products of one lubricant vendor (MOBIL) on a system-wide basis.
Thus, the Mobil lubricants were evaluated and approved for use on a generic basis during Waterford 3 startup.
PEIR 70152 evaluated and approved on a generic basis several Mobil lubricants fo-use at Waterford 3.
The intent of PEIR 70152 was to evaluate the cce itions of the lubricants as they i
relate'to the operating conditio-c Waterford 3.
The evaluation was based on data available at that time.
In 1984, the application of requirements for EQ was to some extent evolving and subject to interpretation. LP&L believed the Mobilux EPO i
was qualified, lased on analysis, for use in harsh environments, and l-therefore LP&L was maintaining Mobilux EPO was an acceptable substitute l
for Exxon Nebula EPO. The PEIR, in conjunction with LP&L's position that Mobilux EPO was an acceptable alternative for Exxon Nebula EPO,
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resulted in LP&L specifying Mobilux EPO in the PLM as the lubricant for j
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certain valves outside containment.
As LP&L pursued additional qualifi-cation documentation for the Mobilux EPO, it became apparent Mobil could not provide a concrete recommendation for the use of Mobilux EPO since Exxon Nebula EPO was the only grease type tested and approved by Limitorque.
This did not necessarily mean the Mobilux EPO was not acceptable for use in a harsh environment, but that additional type testing may have been required before Mobil vould provide a concrete recommendation for the use l
of Mobilux EPO. LP&L subsequently decided that Exxon Nebula EPO would be used in all MOVs. The evolution and change in philosophy, coupled with l
the use of Mobilux EPO for certain valves outside containment, thus provided a climate foi confusion regarding the application of grease.
Nonetheless, the use of Mobilux EPO for the subject MOVa inside contain-ment was contrary to the Limitorque technical manual and PLM and therefore, was personnel error.
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Attachment One To LP&L Letter W3P89-1046 Assuring Use of Intended ase The NRC in the. inspection report cited weaknesses'in assuring the use of
.the intended-grease.
Examples were cited by the NRC where a greue other than the grease' intended was-applied or where a grease other than~the grease intended may have been used had the valve required lubrication.
l The first basis for.the NRC cited weaknesses was that the PLM specified Mobilux EPO for use in the following MOVs:
SI-MVAAA 225A, HPSI HDR A to RC Loop - 1A i
SI-MVAAA 225B, HPSI HDR B to RC Loop - 1A SI-MVt.AA 226B, HPSI HDR B to RC Loop - 1B SI-MVAAA 227B, HPSI HDR B to RC Loop - 2A l
'SI-MVAAA 228A, HPSI.HDR A to KC Loop - 2B i
SI-MVAAA 228B, HPSI HDR B to RC Loop - 2B
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UNT-5-007, Rcvision 1, requires in part that lubrication for plant equip-ment shall utilize only the lubricants listed in the PLM. Lubrication of these valves therefore may have resulted in adding Mobilux EPO rather
- than Exxon Nebula EPO which was the previously installed grease.
LP&L j:
acknowledges'the NRC cited basis.
'li The second basis for the NRC cited weaknesses is that the NRC found a copy of the PLM which was-out dated. The copy of the PLM did not have the lubrication data.for MOVs outside containment. LP&L acknowledges
'l the NRC cited basis.
The outdated PLM was apparently a controlled copy whjch was not updated.
The third basis for the NRC cited weaknesses is the finding of inconsis-
.tencies between the PLM and the lubrication checklists for three valves:
1 EFW-MVAAA-220B, MS-HVAAA-416, and BAM-MVAAA-133. The PLM for the foregoing valves specified that Mobilux EPO was the required grease. The lubrication
'l checklist forLysive EFW-MVAAA-220B documented that the grease was tan, I
the color of new Exxon Nebula EPO. Thus, since the PLM specified Mobilux
.'EPO, the potential existed for adding Mobilux EPO which was not the j
intended grease. The lubrication checklists for valves MS-MVAAA-416 and j
I BAM-MVAAA-133 documented that the grease color was other than tan.
However, a color other than tan only means the grease may not have been Exxon Nebula EPO. LP&L collected samples of the installed grease for valves MS-MVAAA-416 and BAM-HVAAA-133 for evaluation by the lubrication engineer. The lubrication engineer determined that the grease could not I
be positively confirmed as Exxon Nebula EPO. As a conservative measure, LP&L removed the grease in valve BAM-MVAAA-133 and installed new Exun
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Nebula EPO since the valve could be taken out-of-service without affecting plant operation. Mobilux EPO is qualified for use outside containment, and the grease was therefae left in valve MS-MVAAA-416 since the valve could not be taken out-of-service without affecting plant operation. The NRC apparently concluded valves MS-MVAAA-416 and BAM-MVAAA-133 ccatained Mobilux EPO and relied on the grease color and the fact that LP&L took samples to make.this conclusion in the inspection report.
LP&L would like to provide the following additional clarification regarding the NRC conclusion.
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L Attachment One To LP&L Letter W3P89-1046 To ensure that Exxon Nebula EPO was used ir all MOVs inside containment, the lubrication checklist, in its previous arm, required maintenance personnel to verify the grease was tan in ilor.
New Exxon Nebula EPO is tan in color. LP&L later learned that.xxon Nebula EPO darkens with exposure to elevated temperature, and thri Exxon Nebula EPO may look like Mobilux EPO which is a dark browe The use of a tan color as an acceptance criterion for verifying the type of grease was therefore invalid. LP&L thus changed the lubrication checklist to its present form, which requires that a grease sample be taken if the grease color is other than tan.
The lubrication engineer then determines if the proper grease is installed or if the grease needs to be changed. The collection of a sample of a grease therefore does not necessarily mean the wrong grease is installed.
2.
LP&L Actions Taken and Results Achieved LP&L actions and results are discussed separately relative to the mixing of grease and assuring the use of the intended grease.
Mixing of Grease LP&L performed an evaluation, documented in LP&L letter W3B88-0312, of the effect on operability of using Mobilux EPO or a mixture of Exxon Nebula EPO and Mobilux EPO on Limitorque valve operators located inside containment. The evaluation concluded that neither the Mobilux EPO or the mixture of Exxon Nebula EPO and Mobilux EPO should be detrimental to the operation of the gear box assembly. Nonetheless the evaluation recommended the operators containing the mixed grease be cleaned and re-lubricated with Exxon Nebula EPO by che end of Refueling Outage 3.
The mixed lubricant in valves SI-HVAAA 331B, 332A, and 332B was removed and was replaced with Exxon Nebula EPO in accordance with maintenance work orders 01018074, 01001930, and 01017773. The grease in valves SI-MVAAA 401A, 401B, and 331A were determined by analysis to be Exxon Nebula EPO.
The grease in valve 401A was removed and replaced, via maintenance work order 01017414, with Exxon Nebula EPO prior to the receipt of the laboratory analysis since LP&L suspected the grease could have been Mobilux EPO.
The Plant Lubrication Manual has been revised to require the use of l_
Exxon Nebula EPO for all Limitorque valve operators intice and outside l'
containment.
l UNT-5-007 has been revised to require that a sample of the grease be taken if the grease color is not easily recognized. The lubrication engineer determines if the proper grease is installed or if the grease needs to be changed.
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Attachment One-To LP&L Letter W3P89-1046 Subsequent to the NRC maintenance inspection, LP&L reviewed the records for the application of grease of all safety related MOVs outside contain-ment to verify that the MOVs contained Exxon Nebula EPO. Where documenta-tion could not be found to positively verify the MOVs contained Exxon Nebula EPO, such valves were checked in the field to verify they contained Exxon Nebula EPO. Valves MS-MVAAA-416 and BAM-MVAAA-133 were found to contain Mobilux EPO which is an acceptable substitute lubricant for MOVs outside containment.
These actions are expected to preclude the mixing of grease. The NRC has independently concluded, reference page 39 of the inspection report, that the LP&L program for lubricating MOVs inside containment is adequate to prevent the recurrence of miring greases.
Assuring The Use of Intended Grease Valve BAM MVAAA-133 had the grease removed and replaced with Exxon Nebula EPO via maintenance work order 01013828. Although no corrective action was required for valve EFW-HVAAA-220B, the valve has been taken out of service for other reasons. See section 3 for the planned action on valve MS-MVAAA-416.
The PLM has been revised to specify Exxon Nebula grease for all motor operated valves inside and outside containment. The specification of one grease'in the PLM will provide clear and unequivocal requirements for the application of grease.
PLM 457001150, copy 029, has been located and updated.
3.
Future Actions To Be Taken LP&L will replace the grease in valve MS MVAAA-416 with Exxon Nebula EPO during refueling outagc 3.
l LP&L will revise procedure UNT-5-007 to require that an evaluation be performed, should the lubricant specification in the PLM be changed for
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a particular component, to ensure the grease previously in the component is either removed or the specified lubricant is compatible with the
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existing grease.
IL Completion of these actions, along with the corrective actions taken to date, will provide LP&L a high level of confidence that the problem with incompatible grease mixtures in motor operated valves has been corrected and that incompatible grease mixtures will not be used in the future.
4.
Date When Full Compliance Will Be Achieved LP&L will be in full compliance by the end of refueling outage 3.
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Attachment One i
To LP&L Letter W3P89-1046 Di Violation 8901-01 Failure to Contro1' Technical Documents as Required by Administrative Procedure Criterion V of Appendix B to 10 CFR 50 requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and.shall.be accomplished in accordance with these instructions, procedures, or drawings.
LP&L Administrative Procedure UNT-4-002, Revision 2, " Field Control of Technical Documents," requires tech-nical documents used in the field to be " field controlled" and specifies the administrative procedures to be used to provide field control of technical documents.
Contrery to the above, maintenance data forms, used to provido calibra-tion data for instrument calibration, and instrument informat on sheets, containing setpoint information, were not field controlled in accordance with Procedure UNT-4-002, Revision 2.
I There is a Severity Level IV violation.
. RESPONSE 1.
LP&L Position Regarding_the Violation LP&L admits the violation.
The reason for the violation is a lack of detailed procedural controls for the use of maintenance data forms and information sheets.
Initially, the maintenance data forms and the information sheets were issued as hard copy documents by document control in accordance with UNT-4-002. The information sheets were stamped " field controlled," and the maintenance data forms were appended to the information sheets. The
" field controlled" stamp applied to the package, i.e. maintenance data forms and information sheets, and the two documents were used.in the field as one controlled document. With the implementation of SIMS, the 3'
information sheets are now generated by SIMS, rather than document control, and the practice of stamping the information sheets " field controlled" continued. As a result, information sheets were being stamped and dated as field controlled, but were not meeting all of the requirements of UNT-4-002.
Maintenance data forms were being handled as a separate document without the necessary field controls.
2.
LP&L Actions Taken and Results Achieved Maintenance procedure dD-1-002, Revision 0, has been revised to require that the maintenance data forms be field controlled as required by procedure UNT-4-002, Revision 2.
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Attachment One L
To LP&L Letter J
W3P89-1046 The information sheets contain a compendium of information for reference like numbers for applicable EMDRACs, loop diagrams, technical manuals, procedures, etc.
Accordingly, information sheets are no longer stamped
" field controlled" but rather are stamped with an indication that the document has.been verified and must be reverified within seven days.
i MD-1-002 requires the foregoing stamping practice for information sheets.
The reaintenance manager issued a memorandum on February 3,1989 to -
maintenance personnel requiring that.information sheets be retained as part of the work package closure documentation.
3.
Future Actions To Be Taken t.
A revision to maintenance procedure M0-01-002 will be made to specifi-cally require that information sheets be retained as part of the work package closure documentation. Maintenance personnel will be required to read the revision to maintenance procedure MD-01-002 when effected.
4.
Date When Full Compliance Will Be Achieved LP&L vill be in full compliance by July 1, 1989.
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