W3P89-3075, Responds to NRC Re Violation Noted in Insp Rept 50-382/89-06 on Failure to Follow Procedures.Corrective Actions:Addl Actions Will Be Taken to Emphasize Mgt Desire to Have Effective,Comprehensive Torquing Program
| ML20246E239 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 07/06/1989 |
| From: | Burski R LOUISIANA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3P89-3075, NUDOCS 8907120160 | |
| Download: ML20246E239 (3) | |
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j l OUISI ANA / 317 BARONNESTREET P. O. BOX 60340
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POWER & L1GHT NEW ORLEANS, LOU 1GIANA 70160 (504)595 3100
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W3P89-3075 A4.05 QA
-July 1989 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 Violation 8906-01, Failure to Follow Procedures
References:
1.
LP6L Letter No. W3P89-3006 dated 04/27/89 from R.F. Burski to U.S. Nuclear Regulatory Commission 2.
NRC Letter dated 06/06/89 from J.L. Milhoan to J.G. Dewcase Gentlemen:
Louisiana Power & Light hereby submits the following information on the subject violation as a supplement to the response that was provided in the Reference 1 letter. This information, which is contained in Attachment 1, addresses your request expressed in the Reference 2 letter for LP&L to provide a description of the actions that will be taken to preclude further violations in the area of safety-related fastener torque requirements.
If you have any questions concerning this response, please contact T.J. Gaudet at (504) 464-3325.
cry truly yours, s
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. Burski Nnnager Nuclear Safety 6 Regulatory Affairs RFB/TJG/ssf Attachment ec: Messrs. R.D. Martin (NRC Region IV), F.J. Hebdon (NRC-NRR),
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.D.Lc Wigginton (NRC-NRR), E.L. Blake, W.M. Stevenson NRC Resident Inspectora Office 8907120160 890706 g \\
PDR ADOCK 050003S2 a
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"AN EQUAL OPPORTUNITY EMPLOYER" L
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e Attachment to
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W3P89-3075 Page 1 of 2 ATTACHMENT 1 Supplemental Response to Violation 8906-01, Example 1 Although LP&L believes that the torquing program at Waterford 3 is adequate, there is potential for improvement to preclude the recurrence of noncompliance related to torque requirements. After receiving Violation 8906-01 (Example 1), actions to prevent recurrence were initiated, but a discussion of these actions was not provided in LP&L's response to the violation.
First, a review by maintenance planners of repetitive tasks, e.g., alignment checks, was initiated to ensure that specific torque values 4
from the Vendor Manuals are included in applicable work packages. This ongoing project is being handled on a case-by-case basis as the tasks become due.
In addition, departmental meetings were used to heighten personnel awareness of the 8906-01 torquing issue.
Additional actions will be taken to emphasize mananenent's desire to have an effective, comprehensive torquing program.
To elevate the awareness of the torquing noncompliance and bring such conditions to the attention of the proper personnel, lessons learned training vill be given to maintenance personnel, including the first line supervisory level. Also, during periodic maintenance " shop" and first line supervisors' meetings, the issue of torquing compliance w111 be re-emphasized and feedback on torquing concerns will be solicited.
The upper tier torquing procedure, MM-6-011, " General Torquing and Detensioning," will be re ised and human factor engineered to increase user awareness and understandability and to reduce the chances for personnel error. Upon completion of the rewrite, training on t..e procedure will be conducted with cognizant maintenance personnel.
Finally, a review of applicable maintenance procedures will be initiated to alleviate any inconsistencies or hard spots in the area of fastener torquing.
Based on the above actions, which are scheduled for completion by December 29, 1989, LP&L is confident that recurring noncompliance in the control of safety-related fastener torque requirements will be prevented in the future.
As stated in your letter, LP&L's original response to Violation 8906-01, Example 1, neglected to address the failure to torque the coupling bolts in accordance with the Vendor Manual requirements.
Failure to reply to this part of the violation resulted from confusion in having to address two separate torquing issues that occurred during the performance of Work Authorization 01028798 and the use of Vendor Instruction Manual 457000254. The following information is being provided to supplement LP&L's original response to Violation 8906-01, Example 1.
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Attachment to
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Page 2 of 2 The alignment check that was performed on ACCW Pump 1B under Work Authorization 01028798 took place at approximately 2:00 a.m. on 2/8/89. At 1
the point in which the coupling bolts had to be tightened, the responsible mechanics _ vent to the applicable Vendor Instruction Manual (No. 457000254, "B6W Pumps") to obtain the instructions for coupling assembly. When the mechanics determined that additional instructions for Koppers fast couplings were needed but not included in the Manual, they contacted their supervisor at home to request his assistance. The supervisor, based on his knowledge of Koppers couplings, informed the mechanics that no torquing was required and instructed them to install the coupling using toolbox
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knowledge.
Subser,uently, it was learned that a later revision to the l
Koppers fast coupling instruction sheet did in fact contain requirements for torquing the coupling bolts. A Quality Notice (QN QA-89-078) was then generated on 3/3/89 to initiate corrective action for this condition.
In response to the QN, it was determined that the lack of precise torquing of
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the coupling bolts had no detrimental effect on the operation of the i
coupling. The purpose for bolt torquing is strictly to avoid overstressing l
the bolt as was confirmed by the vendor.
Koppers Insta'lation and Alignment Instuction Sheet 1900-01, which includes the torquing requirement (Note: The earlier revision, Sheet 1900, did not include the torquing requirement), has since been incorporated into Vendor Instruction Manual 457000254. Incorporation of this document into other appliccble Manuals is in progress.
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