View source for W3P89-3024, Responds to Violations Noted in Insp Rept 50-382/89-07. Corrective Actions:Nuclear Operations Engineering Procedure Re Safety Evaluations Will Be Revised to Require Plant Operations Review Committee Review of 10CFR50.59 Evaluation

{{Adams
| number = ML20247N612
| issue date = 05/31/1989
| title = Responds to Violations Noted in Insp Rept 50-382/89-07. Corrective Actions:Nuclear Operations Engineering Procedure Re Safety Evaluations Will Be Revised to Require Plant Operations Review Committee Review of 10CFR50.59 Evaluation
| author name = Burski R
| author affiliation = LOUISIANA POWER &amp; LIGHT CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000382
| license number = 
| contact person = 
| document report number = W3P89-3024, NUDOCS 8906050402
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 9
}}

=Text=
{{#Wiki_filter:__- _ . .
l %, '
et 9'
s P. O. BOX 60340 LOUISIANA POWER    & LIGHT / 317NEW BARONNESTREET
* ORLEANS, LOUISIANA 70160 +    (504)595-3100 buSiNIvsb May 31, 1989 W3P89-3024 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 89-07, Gentlemen:
In accordar_ce with 10 CFR Part 2.201, Louisiana Power & Light hereby submits in Attachment 1 the responses to the Violations identified in Appendix A of the subject Inspection Report.
If you have any questions concerning these responses, please contact T.J. Gaudet at (504) 464-3325.
Very truly yours, R.F. Burski Manager Nuclear Safety & Regulatory Affairs RFB:TJG:ssf 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 gRo6050402 890531               '
G           ADOCK 05000382                                                                              l PNV poi
                                             ''AN EQUAL OPPORTUNITY EMPLOYER"                               e g

i ,                                                                                                                                                                                                                                    .1
                                                .                                                                                                                                                     Attachment to                      i W3P89-3024                         f Page 1 of 8 ATTACHMENT 1 LP&L Responses to the Violations Identified _in Appendix A of Inspection Peport 89-07 VIOLATION NO. 3907-01 Failure of SRC to Review Safety Evaluations Waterford 3 Steam Electric Station (W3SES) Technical Specification (TS) 6.5.2.7.a requires that the 5x0 be responsible for the review of safety evaluations completed under the previsions of 10CFR50.59, to verify that an unreviewed safety question does not exist.
Contrary to the above, the NRC inspector found that the SRC had not reviewed four safety evaluations associated with Project Evaluation /
Information Request Nos. 20000, dated August 27, 1986, and 70795, dated October 8, 1986; Condition Identification / Work Authorization Nos.
255672/01017834, dated May 26, 1988; and Special Test Procedure No.
99000104-1, dated April 12, 1988.
This is a Severity Level IV violation.

===RESPONSE===
(1) Reason For The Violation Technical Specification (TS) 6.5.1.6 requires that the Plant Operations Review Committee (PORC) maintain cognizance over and responsibility for various activities including designated procedures and changes thereto that affect nuclear safety (6.5.1.6a), proposed tests and experiments that affect nuclear safety (6.5.1.6b) and proposed design changes or modifications to unit systems that affect nuclear safety (6.5.1.6d). TS 6.5.1.7b requires that PORC " render determination in writing... with regard to whether or not each item considered under Specification 6.5.1.6a through e constitutes an unreviewed safety quertion." To ensure that formal onsite reviews are conducted by PORC for the activities described in TS 6.5.1, administrative controls are provided in Procedure UNT-1-004, " Plant Operations Review Committee." As described in Section 5.4.7 of UNT-1-004 (Revision 8), the PORC determines for each item it reviews whether the item requires SRC/NRC review prior to implementation.
(Attachment 6.4 to the procedure provides a list of those items.) As described in Section 5.4.10 of UNT-1-004 (Revision 8), the items that need to be reviewed by th9 SRC but not prior to implementation must be forwarded by PORC to the SRC.                                                     (Attachmdnt 6.5 to the procedure provides a list of these items, one of which is all 10CFR50.59 safety evaluations.)

                         ..                                                                                                                                                                              Attachment to W3P89-3024
             ;-                                                                                                                                                                                          Page 2 of 8
     ~
Contrary to Section 5.4.10 of UNT-1-004 (Revision 8), three of the four above listed evaluations (none of which were assessed to involve an unreviewed safety question) had not been1 forwarded by PORC to the SRC for their review. The root cause for not submitting the evaluations to the SRC is personnel error. With regard to the other evaluation listed (PER 20000), although a safety evaluation was performed, it was not required by TS Section 6.5.1 to be reviewed by PORC. The evaluation involved only an FSAR change as a result of the shift from a twelve month to an eighteen month fuel cycle. No physical modifications were needed and no changes to the plant design basis were required.                                                             The root cause was a failure               to have a mechanism in place to ensure that 10CFR50.59 evaluations are                                                                         being submitted as required to the SRC for their independent review.                                                                          It should be noted that the lack of receiving these evaluations was a                                                                         self identified concern made by the SRC Review Subcommittee during their review of the Annual 10CFR50.59 Report for 1988.
(2) Corrective Steps That Have Been Taken And The Results Achieved The cited evaluations have been submitted to the SRC for their independent review. The SRC has completed their review of two of the four evaluations and verified that the actions described in the two evaluations did not constitute unreviewed safety questions.
Completion of SRC reviews of the remaining two evaluations will be consistent with the schedule provided below.                                                                                                                             j Two Quality Notices (QN QA-89-122 and QN QA-89-123) have been generated to formally address and track corrective actions for the SRC's lack of receiving various safety evaluations to perform their independent reviews.
A discussion on the importance in following UNT-1-004 placing emphasis on the necessity of transmitting such information to the SRC as required was held with the individ"al currently responsible for this task.                                                  (NOTE: The individual actually responsible for failing to submit the three noted evaluations is no longer filling that position.)
(3) Corrective Steps Which Will Be Taken To Avoid Further Violations l                                                                      To ensure that a violation of this type is prevented in the future, the following will be done at a minimum:
: 1.                                   Nuclear Operations Engineering Procedure NOEP-305, " Safety Evaluations," and UNT-1-004 will be revised to require PORC review of detailed 10CFR50.59 evaluations; and 1
: 2.                                  After review by PORC, 10CFR50.59 evaluations will be included as attachments in the PORC Meeting Minutes.
Any supplemental changes necessary to support these changes would be addressed and responded to in the QNs listed above.
I L______.___.__________                                                                                                             _._.______.____._______________________._.__.._______________.________________.._.___..______________._._._.j

                     .                                                                 -Attachment to
            '.                                                                          W3P89-3024 Page 3 of 8 (4), Date When Full Compliance Will Be Achieved
                           'The.above action items will be completed by August 1, 1989 at which time LP&L will be in full compliance.
i l                                                                                                                            l I
1 i
l
       -      -                                       _   _ _ _ - _ -    _ _ __ __--_ -_ _ _ - _ _ ____-- _ __ _ _ _ ____ _ O

       .                                                                                                                                                          Attachment'to W3P89-3024 Page 4 of 8
  ~
VIOLATION NO.- 8907-02.
Failure of PORC to Meet in a Quorum and Also to Review Radioactive Releases W3SES TS 6.5.1 establishes the requirements for PORC.                                                                         Section 6.5.1.5 states that a quorum is necessary for meetings and Section 6.5.1.6.m states.
that PORC shall review any. accidental, unplanned or uncontrolled radioactive release including the evaluations, recommendations, and disposition of the corrective actions to prevent recurrence.
Contrary to the above:
(1)   " Walk-through" meetings, such as Nos. 88-101, -103, -104, -105, -108,
               -109, -111   -113, -115, -116, -118, -121, -122, -123, -125, and -126, were held in which PORC did not meet in quorum.
(2) Radioactive releases which occurred April 3 and May 23, 1988, were not reviewed'by PORC at Meetings 88-107 and -112 in regard to evaluations, recommendations, and disposition of the corrective actions to prevent recurrence.
This is a Severity Level IV violation.

===RESPONSE===
LP&L believes that a Technical Specification (TS) violation did not occur in either of the above cited instances (Items (1) & (2)) and therefore has chosen to deny this violation. The basis to support this posit 1.a for each item is discussed below.
ITEM (1)
Plant Administrative Procedure UNT-1-004 (Revision 8) " Plant Operations Review Committee," provides the administrative controls to e.nsure that formal onsite reviews are conducted by the PORC for activities described in Section 6.5.1 of the Technical Specification (TS). PORC Meeting requirements are described in Section 5.2 of UNT-1-004 (Revision 8).
Sub-item 5.2.7 states that a PORC meeting shall be conducted in the following manner:
For a scheduled PORC meeting, a quorum shall be physically present at the same place; OR For an unscheduled PORC meeting, the Chairman may select one of the following methods to conduct a meeting:
A. The quorum shall be physically present at the same place; OR B. Tha quorum shall be in continuous communication during the meeting; OR

l                                                                   .
                                                                                           .                                                                                                                                                           Attachment to W3P89-3024 Page 5 of 8
                    ~
C. The members are contacted sequentially to conduct their review and vote.                                                                  If a dissenting opinion is generated by a voting PORC member, all PORC members shall be informed of such opinion before the item is forwarded to the Plant Manager - Nuclear for approval.
The approach taken by LP&L for handling PORC Meetings as described above is necessary to cover every situation that could arise. Whenever possible and in most cases, items requiring PORC review are placed on an agenda for and subsequently reviewed during a scheduled PORC Meeting. At times, however, significant circumstances arise that require PORC to perforra immediate reviews which cannot wait until the next scheduled PORC Meeting. In these instances, an unscheduled PORC Meeting must be convened as soon as possible in the most feasible manner. A gathering of PORC members at the same place (Type A) may be impossible, particularly in those situations that occur during off hours. LP&L believes that Type B (Conference Calls) and Type C Meetings (Walk-throughs) are therefore unavoidable.
LP&L has, however, acknowl9dged the Inspector's concern (noted on page 9 of the Inspection Report) with the lack of documentation of PORC review activities which does not allow verification of the items identified and followup on such. To address this concern, more detail concerning discussions held in the meeting and any necessary supporting documentation will be provided in or appended to the PORC Meeting Minutes. Additionally.
UNT-1-004 has been revised (current revision is No. 11) to better define and describe PORC activities.                                                          It is also noteworthy of mentioning that Type C PORC Meetings are currently being annotated as Walk-throughs on the PORC Meeting Minutes. LP&L feels that this action was necessary because not all of the sixteen meetings identified in Item (1) were Walk-throughs (Type C).        Some were actually Type A unscheduled meetings.
In addition, LP&L established a task force which was responsible for developing PORC sub-committees. As part of that responsibility, the task force re-evaluated PORC activities as they pertain to procedure review to ensure compliance with Technical Specification 6.5.1.6.a. Based on that review, a Flow Chart was added to UNT-1-004 to ensure that procedures receive the proper level of review.
ITEM (2)
PORC review requirements for the activity described in Section 6.5.1 of the Technical Specifications (TSs) are controlled in Section 5.3 of UNT-1-004 (Revision 8). Sub-item 5.3.1.13 states that the PORC shall be responsible for review of aay accidental, unplanned or uncontrolled radioactive release including reports covering evaluation, recommendations and disposition of the corrective action to prevent recurrence and the forwarding of these reports to the Vice President, Nuclear Operations and to the Safety Review Committee.

      ,                                                                                                                                                                   Attachment to
  .                                                                                                                                                                       W3P89-3024 Page 6 of 8
~
On July 29, 1988 during PORC Meeting No. 88-107, a cognizant individual discussed in detail the report on the release of radioactivity during Integrated Leak Rate Testing (ILRT) that occurred on May 23, 1989.
Preliminary discussions of the event were held by PORC during this particular meeting. After discussing and reviewing the pertinent information, PORC determined that the incident did not constitute an
        " unplanned" release and that the information regarding this release should be reported and discussed in the Semi-Annual Radioactive Effluent Release Report as a " planned" release that occurred through an abnormal release pathway.
On August 11, 1988 during PORC Meeting No. 88-112, a cognizant individual discussed the report issued on the unplanned and unmonitored release of radioactivity during the removal of the containment equipment hatch that occurred on April 3, 1988. Preliminary discussions on the incident, to include the root cause that had been established, the corrective actions to prevent recurrence that had been recommended and the analysis of the radiological consequences that had been developed, were held by PORC during this particular meeting. As a result, the PORC agreed that tne incident would be included in the Semi-Annual Radioactive Effluer.t Release Report as an unplanned release.
During the SRC review of the above identified radioactive release report, it was noted that there were several recommendations contained in the reports. Based on the lack of information coutained in PORC Meeting Minutes for Meeting Nos. 88-107 and 88-112, it was unclear to the SRC as to the status of these recommendations (Refereace: LP&L Letter W3P88-0328 dated 12/19/88 from the SRC Chairman to the PORC Chairman).
Subsequent to the above, on January 5, 1989 during PORC Meeting No. 89-02, PORC reviewed the two reports (as reported in the Semi-Annual Radioactive Effluent Release Report for the first half of 1988) related to the above discussed releases and approved the recommended corrective actions. To assure that these recommendations would be implemented appropriately, individuals were assigned lead responsibilities. Then on 03/15/89 a memorandum was issued by the PORC Chairman to the SRC Chairman to inform him of the status of the recommendations. With regard to the 5/23/88 incident, the memorandum stated that a TS change and an Offsite Dose Calculation Manual change would be pursued to add the ILRT depressurization pathway. With regard to the 04/03/88 incident, it stated that a new procedure (OP-08-011) was currently being developed to maintain operation of shield building ventilation during equipment hatch removal until containment purge can be initiated.                           (NOTE: This procedure was approved                                                                                               on 04/14/89.)
Although the above actions may be construed as not being timely (which in both cases involved outage related work where timeliness of corrective action did not have to be immediate), the required PORC actions (5.6.5.1, UNT-1-004, Sub-item 5.3.1.13) were performed.
In light of the above information, LP&L requests that this cited violation be reassessed.

                     .                                                                                                  Attachment to W3PR9-3024 Page 7 of 8 VIOLATION NO. 8907-03 Failure to Identify and Control Materials with Limited Shelf Life Criterion VIII of Appendix B to 10 CFR Part 50 requires that measures shall be established for identification and control of materials, parts, and components.
The Nuclear Operations Management Manual in Section V, Chapter 8, Revision 3, paragraph 3.4, requires that items having limited shelf life shall be identified and controlled to preclude the use of items whose shelf life has expired.
Contrary to the above, formal measures were not established for control of materials and equipment for which vendors had made unsolicited shelf life recommendations. For example, the Material Management Information System specified no shelf life dates for Stockcode 152-C19300 (mass flowmeter) and Stockcode 101-D53873 (0-Ring). Vendor documentation received for these items specified, however, shelf lives of 3 years and 20 years, respectively.
This is a Severity Level IV violation.

===RESPONSE===
(1) Reason For The Violation The root cause of this violation is that an overall program did not exist to ensure that shelf life controls were being applied consistently. The shelf life program had been comprised of individual group procedures, where each group had their own part of the program.
Based on a review of existing inventory that is currently being conducted, it appears as though the bulk of the items identified were received between 1981 and 1984. Contributing causes for each item found appear to vary from case to case, but in each case the data was not entered in the Waterford 3 Matertals Management Information System. Some purchase orders required the shelf life data while others did not. Furthermore,    some vendors supplied the shelf, life data while others did not.
(2) Corrective Steps That Have Been Taken And The Results Achieved A quality notice (QN QA-89-071) was issued on 3/17/89 to formally address and track corrective actions for this issue. On 3/31/89, Administrative Procedure UNT-8-015 " Shelf Life Program," was approved. This program provides:
                                    -    guidance for identifying limited shelf life items;
                                    -    a method for establishing and assigning consistent and economical shelf life expiration dates;

Attachment to' W3P89-3024 Page 8 of 8 instructions, forms end references for evaluations to extend a previously assigned shelf life, and
                                     --   instructions for dispositioning expired items and for receiving, storing, issuing, reordering and specifying limited shelf-life items.
(3) Corrective Steps Which Will Be Taken To Avoid Further Violations A review of existing inventory in stores is being done to identify and correct limited-shelf life items without shelf life controls. This review is being tracked by the Waterford 3 Commitments Management System (1D No. A16159). It should be noted that in the interim, a review of the EPRI Guideline for establishing, maintaining, and extending the shelf life capability of limited life items (NC1G-10,,
draft 5) was conducted. Based on the review of this document, there appears to be no immediate concern for items without shelf life controls because actual aging data on the items affected (which are elastomers) indicates very long shelf lives (14 to 60 years).
(4) Date When full Compliance Will Be Achieved The review of existing inventory and imposition of shelf life controls when necessary will be completed by December 31, 1989, at which time LP&L will be in full compliance.
l
_ _ _ _ - _     _ - _ _ _ _ _}}