View source for W3P89-1508, Responds to Violations Noted in Insp Rept 50-382/89-17. Corrective Actions:Operations Personnel Added Tag 89-673-11 to Clearance Request for Valve PSL-3081,verified That Valve in Normal Open Position & Hung Tag

{{Adams
| number = ML20246A743
| issue date = 08/17/1989
| title = Responds to Violations Noted in Insp Rept 50-382/89-17. Corrective Actions:Operations Personnel Added Tag 89-673-11 to Clearance Request for Valve PSL-3081,verified That Valve in Normal Open Position & Hung Tag
| 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 = W3P89-1508, NUDOCS 8908230135
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 9
}}

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                                                                              +  P. O. BOX 60340 LOUISI&AN POWER          A/
LIGHT   317  BARONNESTREET NEW ORLEANS, LOUISIANA 70160   *  (504) 595-3100 EffuiNIvsYS                                                                     W3P89-1508 A4.05 QA i                  August 17, 1989 L
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 89-17 Gentlemen:
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.
If you have any questions concerning this response, please contact T.J. Gaudet at (504) 464-3325.
Very truly yours, (A.                   j R.F. Bursk.                                                                                                   <
Manager Nuclear Safety & Regulatory Affairs RFB/TJG/pi Attachment                                                                                                 .j cc: Messrs. R.D. Martin, NRC Region IV                                                                        j F.J. Hebdon, NRC-NRR                                                                      j D.L. Wigginton, NBC-NRR                                                                   l NRC Resident Inspectors Office                                                            i E.L. Blake                                                                                I W.M. Stevenson                                                                            ;
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ATTACRMENT 1 LP&L RESPONSE TO THE VIOLATIONS IDENTIFIED IN APPENDIX A 0F INSPECTION REPORT 89-17 VIOLATION NO. 8917-03 Failure to Follow Procedures Technical Specification 6.8.1.a requires, in part, that written procedures shall be implemented as' recommended in Appendix A of Regulatory Guide 1.33,
                      ' Revision 2, February 1978.
Contrary to the above, below are two examples of where the licensee failed to follow established procedures:
: 1. Attachment 6.3 of Procedure UNT-005-003, Revision 7. " Clearance Request, Approval, and Release," states that when systems containing radioactive fluids are to be drained and vented, the drain and vent paths shall be tagged in their required position.
Contrary to the above, on June 3, 1989, Clearance No. 89-673 was incomplete in that one of the valves in the vent path to the primary sample sink, PSL-3081, was not tagged open.
: 2. Section 5.2.3 of Procedure UNT-007-005, Revision 2, " Cleanliness Control," requires unattended system openings to be covered or capped to prevent the introduction of contaminants.
Contrary to the above, on June 3, 1989, a replacement tubing assembly intended for installation in the primary sampling system was left laying on the floor unattended with no protective covering over the openings.
This is a Severity Level IV violation.

===RESPONSE===
                      -(1) Reason For the Violation                                                                      k Example 1 The root cause of Example 1 of this violation was a procedure inadequacy. The information contained in Item 6 of Attachnent 6.3 to UNT-005-003 (as stated above) lacked sufficient detail to determine which valves applied to the tagging requirement.                                           ;
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l Attachment to W3P89-1508 Page 2 of 8 The purpose of Procedure UNT-005-003 is to protect personnel and prevent equipment damage by providing the controls necessary to safely remove and restore ~ equipment and/or systems from service. On 6/2/89, a clearance request (89-673) was generated (in accordance with UNT-005-003) in preparation for the replacement of Primary Sampling System tubing located between outside Containment Isolation Valve PSL-304 and Primary Sample Sink Valve PSL-306. A section of the tubing was being replaced under Work Authorization WA 01038288 due to leakage. The vent path for the job was the normal flow path to the sample sink. Applicable isolation boundary valves within the vent path were listed on Clearance 89-673 and subsequently tagged in their required position. However, Primary Sample Sink Valve PSL-3081 was in the vent path but was not included in the clearance. Operations personnel believed that the statement contained in Item 6 of Attachment 6.3 applied only to valves in the vent path that had to be placed in a position other than their normal position. Consequently, PSL-3081, which is a normally open valve and was required to remain open for the venting, was not tagged open.
Example 2 The root cause of Example 2 of this violation was also a procedure inadequacy. UNT-007-005 failed to include specific provisions for the cleaning and stcrage of parts that are to be installed on applicable systems to maintain their required level of cleanliness.
A section of Primary Sampling System tubing was being replaced under WA 01038288 due to leakege. In accordance with UNT-007-005, a Cleanliness Control Form was generated to maintain controls during the tubing replacement effort. Mechanical Maintenance personnel obtained material from the warehouse and fabricated a replacement part                         ;
consisting of a piece of rcainless steel tubing and a socket wcld coupling. The fabricated part was then taken to the work area and staged there for installation.
Section 5.2.3 of UNT-007-005 addresses measures that should be considered when setting up a work area. These measures have been understood to apply to the systein being worked on and its surroundings and not specifically to replacement parts.     (NOTE: The only reference made to parts is in Item 5.2.3.6 which addresses the delivery of the parts to the work area.) Consequently, the fabricated part received no special cleaning prior to installation and the openings were not covered to prevent entry of foreign materials. Cleanliness control measures were, however, applied to the sample line tubing that was being removed and the surrounding work area.
(2) Corrective Steps Which Have Been Taken and the Results Achieved Example 1 On 6/3/89, Operations personnel added Tag 89-673-11 to the clearance                  {

Attachment to W3P89-1508 Page 3 of 8 request for Valve PSL-3081, verified that the valve was in its normally open position and hung the tag.
On 6/4/89, Operations personnel issued a quality notice (QN QA-89-136) to formally address and track corrective actions for this deficiency.
EUpon investigation of the QN, it was determined that Operations personnel were in fact meeting the intent of UNT-005-003 because the statement contained in item 6 of Attachment 6.3 is directed toward vents and drains which are placed in other than their normal position.
To clarify this position and ensure that the intent of this statement will be met consistently in the future, a revision to UNT-005-003 was approved on S/2/89.
Example 2 Cleanliness integrity of the Primary Sampling System was ensured by flushing out the line subsequent to the installation of the fabricated part.
(3) Corrective Steps Which Will be Taken to Avoid Further Violations Example 1 Based on the information provided above, LP&L is confident that the necessary corrective actions have barn implemented to avoid further violations.
Example 2 UNT-007-005 will be revised to reflect the pre-cleaning and storage of parts prior to their installation.
(4) Date When Full Compliance Will be Achieved Example 1 LP&L is currently in full compliance.
Example 2 UNT-007-005 will be revised by October 16, 1989, at which time LP&L will be in full compliance.
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Attachment to W3P89-1508 Page 4 of 8 VIOLATION NO. 8917-06 Inadequate Procedures Technical Specification 6.8.1.a rquires, in part, that written procedurcs shall be established and maintained as recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Contrary to the above, below are three exampics of where the ifcensee failed to adequately establish and maintain procedures:
: 1. Operating Procedure OP-009-002, Revision 10. " Emergency Diesel Generator," failed to include controls over the status of the three-way outlet valves on the fuel oil filters and strainers, EGF-1222 A(B) and EGF-1228 A(B).
: 2. Operating Procedure OP-600-007, Revision 2, " Annunciator Response for Emergency Diesel Generator A or B Local Panel," contained an inappropriate operator response in Attachment 8.27 by not including instructions to shift the duplex fuel oil strainers or filters to
                   'the clean side when a high differential pressure indicates possible clogging, as described in the vendor technical manual (45700-1225, Volume I).
: 3. Upon implementing a design drawing revision, which changed the required standby position for Component Coeling Water System Valves CC-80310B r.nd CC-8062, Operating Procedure OP-002-003,
                    " Component Cooling Water System," was not changed to reflect the new position.
This is a Severity Level IV violation.

===RESPONSE===
I (1) Reason For the Violation Examples 1 and 2 The root causes of Examples 1 and 2 of this violation are inadequate procedures. In each case, the noted procedure failed to include necessary controls fot outlet selector valves on Emergency Diesel Generator (EDG) fuel oil duplex strainers and filters.
Section 8 (Fuel System) of the EDG Vendor Technical Manual (457001225, Volume 1) states the following about the duplex fuel oil strainer feature:
The valve handle should be positioned to circulate fuel through half the strainer (two elements). A combination differential pressure alarm and indicator J'

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Attachment to-W3P89-1508 Page 5 of 8 p
l pg"                                 monitors this unit with an annunciator on the         .
control panel. LAn alarm sounds at 5~ psi differential.
When the alarm sounds, turn valve handle to the clean 4
half and service the dirty elements.
Operating Procedure OP-009-002, which provides instructions.for EDG~
operation, did not include any provisions for this vendor manual recommendation'in.the Initial Lineup Section (5.1 of OP-009-002).
Operating Procedure OP-600-007, which'provides instructions for-annunciator alarms on EDG A or B local panels, also neglected to address the recommended guidance for its affect on operator response to a fuel' oil strainer or filter high differential pressure alarm.
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                             -As a result. on 6/8/89, the handles for the outlet selector valves on fuel oil duplex strainers and filters were-found to be positioned where all elements were in service at the same' time (simplex mode),
which is contrary to the vendor's recommendation.
Example 3 The root cause of Example 3 of this violation was also a procedure inadequacy. Operating Instruction 01-019-000 did not address the timeliness of. procedure changes that require immediate corrective
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action.
01-019-000 fs utilized by the Operations Procedure' Administrative Group (OPAG) to ensure that Operations procedures are changed or revised as necessary. Upon receiving and accepting a response on 5/18/88 to a Problem Evaluation /Information Request (PEIR 60887) which necessitated a change to the valve positions for valves CC-80310B and CC-8062, a change to OP-002-003 was' requested in accordance with 0I-019-000 Revision 2. However, because the timeliness of procedure changes that require immediate corrective action had not been
                             ' addressed in 0I-019-000, the change request was placed into the Operations Procedure Tickler File for incorporation at the next                                            !
revision to OP-002-003.
                       '(2) Corrective Steps That Have Been Taken and the Results Achieved Exampics 1 and 2 on 7/9/89, a change to OP-009-002 was approved to include an initial lineup for only one set of EDG fuel oil strainers and filters. On 7/15/89 a change to OP-600-007 was approved to include a step to shift the fuel oil duplex strainer (to the clean half) upon the receipt of a fuel 011' strainer or filter high differential pressure alarm.

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e Attachment to W3P89-1508 Page 6 of 8
                       'Although not specifically part of the corrective actions for these procedure inadequacies, it is noteworthy that the Operations Department has initiated an effort to upgrade operations' procedures.
The procedures are being upgraded when necessary to ensure that they are technically accurate and properly human factor engineered (per the Operations Writer's Guide (OP-100-013).
Example 3 On 10/5/88, 01-019-000 was revised to include a provision for the review of procedure changes by the Assistant Operations Superintendent to ensure that those needing immediate corrective action will be implemented in a timely manner. Also, the Operations Procedure Tickler File.was proceduralized and better defined as part of this revision. As defined in 01-019-000 Revision 3, the Operations Procedure Tickler File is a filing system that consists of two folders for each procedure. One-folder contains procedure change requests to be implemented on the next revision of Biannual review. The second folder is a historical record that contains the reason a change or revision was performed.
On 5/2/89, OP-002-003 was revised to require both valves CC-80310B and CC-8062 to be closed for the normal position. (NOTE: In the response to PEIR 60887, it had been determined that the valves should be normally open. However, because these valves are located at a Safety Class 3 to non-nuclear safety (NNS) class break in the CCW
                       . system and they do not have remote operators, they are required to be normally closed for leak isolation in the event of a NNS piping break.
The valves were subsequently closed on 3/27/89 under RA 01034782.
This event was reported as a condition outside the plant design basis in LER-89-006 which was submitted on 4/26/89.)
(3) Corrective Steps Which Will be Taken to Avoid Further Violations Examples 1, 2 and 3 Based on the information provided above, LP&L is confident that the necessary corrective actions have been implemented to ensure that these types of deficiencies do not recur.
1 (4) Date When Full Compliance Will be Achieved Examples 1, 2 and 3 With regard to the specifics of the violation, LP&L is currently in fu11' compliance.
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Attachment to W3P89-1508 Page 7 of 8 VIOLATION NO. 8917-07 Failure to Conduct Required Reviews Technical Specification 6.5.1.6.d required, in part, that the PORC shall be responsible for the review of all proposed changes or modifications to unit systems or equipment that affect nuclear safety.
Contrary to the above, on July 11, 1988, Document Revision Notice M8800868 was issued against Piping and Instrument Drawing LOU-1564-G-160, Sheet 1, without first being reviewed by the PORC.
This is a Severity Level IV violation.

===RESPONSE===
(1) Reason for the Violation The root cause of this violation was a procedural inadequacy.
A mechanism was not in place to ensure that 10CFR50.59 evaluations performed on applicable document revision notices (DRNs) were being submitted to PORC for their review.
DRN M8800868 was generated in accordance with Nuclear Operations Engineering Procedure N0EP-306, " Document Revision Notice," to change the position of Component Cooling Water (CCW) Valves CC-80310B and CC-8062 from normally closed to normally open to allow continuous flow of CCW through the Post Accident Sampling System heat exchangers. Because the DRN was implementing a change to a safety-related system as described in the FSAR, a 10CFR50.59 safety evaluation was performed in accordance with NOEP-305, " Safety Evaluations."                                 (NOTE:                                              Step 5.7.1.3 of NOEP-306 states that when a DRN affects a safety-related system, the responsible design engineer is to assure that a nuclear safety evaluation is to be performed per NOEP-305.) NOEP-305 did not require these evaluations to be submitted to PORC for their review. Consequently, based on the absence of a PORC review requirement in NOEP-305, the evaluation was not transmitted by the originator to PORC for their review.                      It should be noted that this deficiency was addressed in licensee event report LER-89-006 which was submitted on 4/26/89.                                                                                                                                                                                          I (2) Corrective Steps That Have Been Taken and the Results Achieved N0EP-305 was revised on 6/1/89 to require all 10CFR50.59 safety evaluations to be scheduled and presented to the PORC for their review.
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       .e Attachment to W3P89-1508 Page 8 of 8 DRN M8800868 and its accompanying 10CFR50.59 evaluation were reviewed by the PORC on 7/6/89. However, the DRN was not recommended for approval because it since had been superceded by DRN M8900525. This DRN, which was generated to return Valves CC-80310B and CC-8062 to their original normally closed position, was reviewed and recommended for approval by the PORC on 7/6/89.
Design Engineering personnel reviewed safety evaluations associated with the DRN process that were performed in accordance with NOEP-305 to determine which ones had not received a PORC review. Consequently, those identified were presented to and subsequently reviewed and approved by the PORC.
To clarify the PORC responsibility to review 10CFR50.59 safety evaluations from a programmatic standpoint, the following procedures have been changed:
: 1. Plant Administrative Procedure UNT-001-004, " Plant Operations Review Committee";
: 2. Plant Administrative Procedure UNT-007-022, "Special Test Procedures";
: 3. Plant Engineering Procedure PE-002-005, " Engineering Work Authorization Processing";
: 4. Plant Engineering Procedure PE-002-006, " Plant Engineering Design Change"; and
: 5. Nuclear Operations Administrative Procedure NOAP-018 " Problem Evaluation /Information Request."
Although not specifically part of the corrective actions for this violation, it is noteworthy that a Nuclear Operations Procedure (NOP-013) has been developed to describe the method for the screening and performance of 10CFR50.59 Safety Evaluations and Environmental Impact Evaluations in a comprehensive and consistent manner. Step 5.3.4 of the procedure states that the PORC shall concur with and recommend approval of all 10CFR50.59 safety evaluations as required by Section 6.5.1 of the Technical Specifications. Training on this procedure for site personnel who ordinarily perform these evaluations is expected to be completed by 12/31/89.
(3) Corrective Steps Which Will be Taken to Avoid Further Violations Based on the information provided above, LP&L is confident that the necessary correctise actions have been implemented to ensure that a violation of this type does not recur.
1 (4) Date When Full Compliance Will be Achieved l
With regard to the specifics of the violation, LP&L is currently in full compliance.
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