View source for W3P85-0825, Responds to Violations Noted in Insp Rept 50-382/84-42. Corrective Actions:Documented Engineering Evaluations Initiated to Establish Engineering Basis for Decisions Made at Original Dates of Procurement

{{Adams
| number = ML20215M719
| issue date = 04/10/1985
| title = Responds to Violations Noted in Insp Rept 50-382/84-42. Corrective Actions:Documented Engineering Evaluations Initiated to Establish Engineering Basis for Decisions Made at Original Dates of Procurement
| author name = Cook K
| author affiliation = LOUISIANA POWER &amp; LIGHT CO.
| addressee name = Martin R
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION IV)
| docket = 05000382
| license number = 
| contact person = 
| document report number = W3P85-0825, W3P85-825, NUDOCS 8611030195
| package number = ML20215M710
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 5
}}

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POWER & LIGHT / New cateANa toVI.IANA    70174-6000     9 (504)388-2345
         $1Ul$SYS                             April 10, 1985                  W3P85-0825 3-A1.01.04 A4.05 Mr. Robert D. Martin Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 3ggggg%
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Arlington, TX 76011 iI    APR I 2 005

==Dear Mr. Martin:==

                                                                  .                        h

==Subject:==
Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report 84-42

==Reference:==
Telcon - G.E. Wuller (LP&L) to W.A. Crossman (NRC - Region IV) dated March 29, 1985 Attached is the Louisiana Power and Light Company response to Violation No.
8442-01 which is cited in the subject NRC Inspection Report. By the referenced telephone communication, LP&L requested and was granted an extension to April 10 for submittal of the response to violation No.
8442-01.
This response is submitted under affidavit as required by Section 182 of the Atomic Energy Act of 1954, as amended.
                                       ~
If you have any questions on the violation response, please contact G.E. Wuller, Onsite Licensing, at (504) 464-3499.
Very truly yours, 8611030195 861027                            $      0 % q 4 L; PDR     ADOCK 05000382 o                    PDR                  K.W. Cook Nuclear Support & Licensing Manager KWC:GEW:sms cc:   NRC. Director, Office of IAE G.W. "nighton, NRC-NRR D.M. Crutchfield, NRC-NRR NRC Resident Inspectors Office INPO Records Center (J.T. Wheelock)
E.L. Blake W.M. Stevenson E-OQ3/K

3                                                                         W3P85-0825 Page 1 of 3 ATTACHMENT LP&L RESPONSE TO VIOLATION 8442-01 VIOLATION NO. 8442-01 Licensee Procedures for Procurement of Spare Parts for Safety-Reinted Applications 10 CFR Part 50, Appendix B, Criterion V, requires, " 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. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily acconplished."
Contrary to the above, the licensee did not have (1) procedures which assured the retention and timely retrieval of required procurement documentation for spare and replacement parts used in safety-related applications, (2) procedures to assure that design control includes purging or modification of spare and repair parts covered by design changes, and (3) procedures to assure that spare parts which affect the safety function of safety-related component, system, or structure are not downgraded to nonsafety-related, This is a Severity Level IV Violation.    (50-382/8442-01)
RESPONSE TO VIOLATION ITEM (1)
Corrective Steps Taken and Results Achieved A review of the seventeen procurement packagea cited in the NRC Inspection Report No. 84-42 shows that each package contained records adequate to meat the requirements of the current LP&L procedures with the exception of documented engineering evaluations necessary to establish appropriate quality requirements for spare and replacement parts. As a result, nine documented engineering evaluations were initiated to establish, at this time, an engineering basis for the decisions made at the original dates of procurement. The remaining eight procurement packages were in accordance with original requirements and no engineering evaluations are necessary. Eight of the nine engineering evaluations have been completed and the associated items found acceptable for their intended use.
Corrective Steps Which Will Be Taken Existing procedures have been reviewed to ensure proper disposition of all procurement related documentation generated or accepted during the procurement of spare or replacement parts. As a result, minor

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      +   . 4 Page 2 of 3 procedure revisions are deemed necessary to ensure that completed engineering evaluations are included in affected procurement record packages. Additionally,-the procedure used to collect and verify completeness of each procurement record package prior to entry into the records management system requires updating to reflect recent documentation changes in procurement and stores requisition related procedures.
Date When Full Compliance Will Be Achieved Procedures requiring revision will be complete by April 30, 1985. The remaining engineering evaluation will be completed by May 31, 1985.
ITEM (2)
Corrective Steps Taken and Results Achieved The current LP&L station modification procedure (PE-2-006) takes into consideration the effect of design changes on active procurements and stocked items. No further corrective action is deemed necessary and full compliance is achieved.
ITEM (3)
Corrective Steps Taken and Results Achieved Eight of the seventeen procurement packages cited were not down-graded and were procured based on the original procurement document requirements. The nine that were downgraded were the basis for initiating nine Spare Parts Equivalency Evaluation Reports (SPEERs) to re-establish their acceptability for their intended use. Eight of the nine SPEERs have been completed and the related items found acceptable.
Corrective Steps Which Will Be Taken The procedures have been revised to require the initiation of a SPEER anytime the appropriate technical and quality requirements of original items cannot be determined based on review of the original or previous procurement documents in order to ensure spare and replacement parts are of equal or better design / quality then the original supplied items. When required, a SPEER ensures the performance of an engineering evaluation to establish appropriate technical and quality requirements for such items. This evaluation may conclude that:
(1) the item is safety related and is not of " commercial (quality) grade"; (2) the item is safety related and of " commercial (quality) grade"; or (3) the item is not safety related. Procurement documents are then developed accordingly.

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_s Page 3 of 3 An engineering evaluation is required when items in stock are identified with a quality classification less than the quality classification of the major component in which an item is to be installed in the plant. In the Requisition On Stores (ROS) process a Part Quality Determination (PQD) form is required to be completed by a qualified engineer any time this condition exists. Additionally, procedures do not allow the downgrading of a Requisition On Stores (ROS) form nor the upgrading of items for dedication-in safety related applications without an' approved PQD. The PQD provides appropriate
              - instructions to accomplish either downgrading of the ROS or upgrading of individual items. If through the PQD form no determination can be   I made, then a SPEER must be initiated in order to establish appropriate l technical and quality requirements.
Date Rhen Full Compliance Will Be Achieved Full compliance on procedure revisions has been achieved. The remaining engineering evaluation will be completed by May 31, 1985.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of                                       )
                                                                 )
Louisiana Power & Light Corrpany                       ) Docket No. 50-382 Waterford 3 Steam Electric Station                     )
AFFIDAVIT R.M. Nelson, being duly sworn, hereby deposes and says that he is Licensing Manager - Nuclear of Louisiana Power & Light Company; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached response to the Violation No. 8442-01; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.
s kC W 31elsdn Licensing Manager - Nuclear STATE OF LOUISIANA    )
                                ) ss PARISH OF ST, CHARLES)
Subscribed and sworn to before me, a Notary Public in and for the Parish and State above named this      //2'2%       day of       An . */            ,
1985.                                                    'T JA?        nmde
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My Commission expires a h e/es /-[                          .}}