View source for W3P86-2800, Responds to NRC Ltr Re Violations Noted in Insp Rept 50-382/86-16.Corrective Actions:Approved Flammable Liquids Cabinet Placed on +46 RAB Adjacent to MSIV Area to Allow for long-term Storage of Oil

{{Adams
| number = ML20214P072
| issue date = 11/13/1986
| title = Responds to NRC Ltr Re Violations Noted in Insp Rept 50-382/86-16.Corrective Actions:Approved Flammable Liquids Cabinet Placed on +46 RAB Adjacent to MSIV Area to Allow for long-term Storage of Oil
| 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 = W3P86-2800, NUDOCS 8612040068
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 9
}}

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 *[      e yl LOUISIANA                17 BARONNE STREET + P. O. BOX 60340 NEW ORLEANS, LOUISlANA 70160 * (504) 595 3100        /
P O W E F1 & L I G H T                                                     p
            $EE!EsYIU                                                                              -
l November 13, 1986 W3P86i2800 A4105
                                                                                       .- QA Mr. Robert D. Martin Regional Administrator, Region IV hh U.S. Nuclear Regulatory Conimission                                   v 611 Ryan Plaza Drive, Suite 1000                                              Ng 7 } %
Arlington, TX 76011                 x

==Subject:==
Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Reoort 86-16

==Dear Mr. Martin:==

Attac_hed is the Louisiana Power & Light Company (LP&L) response to Violation Nos. 8616-02, 8616-03 and 8616-05 which were cited in the subject NRC Inspection Report.
7 If you have any questions on the responses, please contact G.E. Wuller, Onsite Licensing, at (504) 464-3499.
Very truly yours, K.W. Cook Nuclear Support & Licensing Manager KWC:KLB:ssf cc: NRC, Director, Office of I&E G.W. Knighton, NRC-NRR J.H. Uilson, NRC-NRR NRC Resident Inspectors Office B.W. Churchill W.M. Stevensen 8612040068 861113 PDR G
ADOCK 05000382 ppg                                 /- cy 0 t
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h-                                    "AN EQUAL OPPORTUNITY EMPLOYER"

ATTACHMENT to W3P86-2800 Sheet 1 off 8 LP&L RESPONSE TO VIOLATION NOS. 8616-02, 8616-03 and 8616-05 VIOLATION NO. 8616-02 Technical Specification (TS) 6.8.1.f. requires that written procedures covering the. implementation of the fire protection program be established and' implemented. fFP-1-017, Revision 2, " Transient Combustibles and Hazardous-Materials," is a procedure that implements a portion of the fire-protection program. Sections.6.1.18 and 6.3 of FP-1-017 require that combustible liquids shall be placed in. safety cans and stored in designated cabinets when not in use.
                   ' Contrary to the above, on August 19, 1986, six safety cans, each partially full of combustible liquid, were found unattended in areas containing
                   - safety-related equipment.
                   .This is a Severity Level IV violation.
RESPONSE TO VIOLATION (1) ~ Reason for the Violation Appendix R to 10CFR50, Section K.1 and-2 mandates a licensee.to maintain in effect administrative controls to: (1) Govern the handling and limitation of the use of ordinary combustible materials, combustible and. flammable- gases and liquids.... and (2) Prohibit the
: storage of combustibles in safety-related areas or establish designated storage areas with appropriate fire protection..:Waterford 3 complies with this requirement by way of implementation of FP-1-017, Transient Combustibles and Hazardous Materials.- Specifically, section 6.3.2 states, " Approved safety cans (not exceeding 5 gallon capacity or 2 gallon capacity for Class I liquids) shall be used.for storing.
                          -transporting and dispensing quantities of flammable and combustible (to include lubricating oils) liquids in buildings"... Section 6.3.3
                         'goes on to say,."When not in use, safety cans containing flammable'and
: combustible liquids shall be stored in an approved flammable liquids storage cabinet"...
Due to a significant oil leak on the Main Steam Isolation Valves (MSIV) it became necessary to temporarily maintain a small quantity of Fyrquel lubricating oil adjacent to the MSIV skid. Fyrquel has a flashpoint of >>455'F and is therefore classified as a Class IIIB combustible liquid per NFPA-30, Flammable and combustible liquids code. The addition of this oil in the area constitutes a minor fire hazard at best. In fact, Roof Area E has an area of 3,216 fez , with an asgumption of 86 full 5 gallon 2
cans of lube oil yielding a total of 4.65E BTU or 1.44E BTU /FT this would produce a fire duration of less than 2 minutes for total consumption by fire. Therefore, the danger of safety-related equipment was negligible.
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ATTACHMENT to W3P86-2800 Sheet 2 of 8
                 .(2) Corrective Action That Has Been Taken As a conservative means of corrective action an approved flammable liquids cabinet has been placed on the +46 RAB adjacent to the MSIV area so as'to allow for the long-term storage of oil in.the area-should expeditious oil addition become necessary. In the past the rate of consumption of the oil could more accurately be described as usage rather than storage.. In which case, a safety can would be the required method or container.
(3) Corrective Action That Will Be Taken No additional action is felt necessary in that the addition of the flammable liquids cabinet will serve as extra conservatism in providing verbatim compliance with the requirements of FP-1-017.
(4) Date When Full Compliance Will Be Achieved Waterford 3 is in full compliance at the present time.

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ATTACHMENT to W3P86-2800 g                                                                        Sheet 3 of 8~
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:  VIOLATION NO. 8616-03'                                                        .
10 CFR 73.55(b)(3)(1) requires, in part . written security procedures "which detail the duties of guards, watchmen, and other individuals responsible for security..."
TheWaterfordL3 physical. security-hlan'implementstherequirementsof10 CFR 73.55(b)(3)(1).
               -PS-90-101, Revision 3 " Security Department Organization, Duties and
             ; Responsibilities," in part, implements the Waterford.3 physical security plan by detailing the duties and. responsibilities of security personnel including the secondary alare station console operation.(SASCO) and the
: security officer ~(S0). These duties and responsibilities include monitoring equipment on the SAS console in order to fully implement the site security program.
Contrary to the above, the duties and responsibilities specified in PS-90-101, Revision 3, were not properly implemented.in that, on August 29, 1986, the NRC inspector observed that the SAS console was not being properly monitored in that publications not related to the job are being read by.the SASCO in the SAS.
This is a Severity Level IV violation.
RESPONSE TO VIOLATION
               -(1) : Reason for the Violation LP&LLacknowledges that on August 29, 1986, the Secondary Alarm Station
                     -(SAS)' Console Operator (CO) did have unauthorized reading material on-his post, the SAS.
The Waterford 3.SES Security Force utilized a Shift Supernumary to relieve security personnel for lunch and other breaks. The supernumary is normally dispatched through the SAS to job assignments.
On August 29, 1986 the supernumary was between job assignments and went to the SAS to await further instructions. Enroute to SAS, the supernumary stopped in the mens restroom. While in the restroom, the supernumary found the sports section of the daily newspaper. He picked up the newspaper and took it with him to the SAS.
Upon arrival (approximately 0953 hours) at the SAS the supernumary started reading the newspaper. He handed part of the newspaper to the SASCO.who also read the paper. The. resident _NRC inspector observed these actions and reported same to the Shift Supervisor. The Shift Supervisor relayed this information to the Security Shift Supervisor at approximately 1000 hours.
(2) Corrective Action That Has Been Taken Immediately upon notification Security supervisory personnel were
                     ' dispatched to SAS to investigate the complaint. The supervisors

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* ATTAC19fENT '
c"                                                                        to W3P86-2800 Sheet 4 of 8 arrived-in.the SAS at 1004 hours. Upon arrival in the SAS, the supervisors confirmed the NRC complaint; both the-SASCO and the supernumary had part of the newspaper in their possession. Both-officers were relieved from duty and placed on suspension pending an investigation.
Disciplinary. action.was administered, as'follows:
SASCO:      Two weeks suspension-without pay.
A 90 day reduction'in pay and-grade to that of a nuclear watchperson.   (At the end of the 90 day probation period, the officer will be eligible to return to Security Officer status).
                    -SUPERNUMARY:      One week suspension without pay.
A 90 day reduction in pay and grade to that of a nuclear watchperson. Reduction suspended, and officer placed on 90 day probation.
Waterford 3 SES has a written " Security Force Disciplinary Standard".
This standard prohibits having unauthorized reading material while on duty and was in place at the time of the occurrence. Both officers had signed statements that they had read and understood the policy.
However, we reissued this disciplinary standard to contract security personnel..
            .(3) Corrective Action That Will Be Taken No futher action required.
(4).-Date When Full Compliance Will Be Achieved Action was taken immediately upon notification to Security supervisory personnel.
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                                                                                     ? ATTACHMENT to W3P86-2800 Sheet 5' of 8 -
VIOLATION NO. 8616-05 l'0CFR50,.AppendiN B,' Criterion X required, in part, that, ''A program for
                                                 ~
inspection of' activities affecting quality shall be established and executed.by;or for the organization performing the activity to verify conformance with the'_ documented instructions, procedures, and drawings for accomplishing the. activity..."
                  -Contrary to thefabove. the Louisiana Power and Light Company inspection program was not adequately executed to ensure proper installation of.
                  ;certain. components as described below:
1.:   The front and rear anchor welds for the hydrogen recombiner. power supply panel B were not installed as required by the installation drawing.
: 2.   .One of the anchor bolt nuts for the 120V nuclear instrumenta' tion static uninterruptible power supply 3MBS panel did not have the minimum. thread engagement required by installation specifications.
                  ~This is a Severity Level IV violation.
RESPONSE'TO~ VIOLATION - PART I
                  . (1) -Reason for:the Violation Nonconformance Report W3-6744 was issued on 8/19/83 by the electrical subcontractor denoting that the equipment installation checklist for the Hydrogen Recombiner Panel was not completed, and the installation could-not be reverified due to inaccessibility to the interior of the
                         -panels.
The reasons for.the violations are:      (1) the description of the noted
.                         ~ deficiency.(NCR-W3-6744) was not concise as to which particular installation. checklists were n'ot completed (2) the recommended disposition provided by the electrical contractor provided no proposed fix-to the problem so as to indicate what the deficiency was and (3) the. element of interface being significantly reduced as a result of the electrical contractor destaffing; were all contributing facters that caused the mismatch between problem description and recommended resolution, for the noted NCR.
To explain the aforementioned and how this could happ'en, the following information is provided. The noted NCR was submitted by the electrical contractor to the Architect-Engineer for logging and further processing as required by program. Per procedure, adequate supporting documentation was to accompany the NCR.       Since no checklists were submitted with the NCR, it appears that the NCR was
                         -forwarded to the Electrical Engineering Department for review and evaluation of disposition (since it was written by the electrical-subcontractor). At'the time of the evaluation, it appears that the A-E Electrical engineer understood the lack of installation                 ,
verification to mean that the internals of the cabinet could not be         i
                         . verified as completed rather that the physical mounting and attachment     l l
l s :. 7 -

,14 ATTACHMENT:
to W3P86-2800
                                                                                      . Sheet 16 of 8
                          'oflthe' equipment to.its foundation as indicated by the checklists.
This could.be attributed to the fact that the incomplete checklists were not-provided as.NCR attachment'so as to specifically explain the.
                 ,       ' deficiency.
P
                         'The?A -E Electrical engineer-who evaluated the NCR provided.
                          . documentation attesting.to the fact that.the internals of the cabinet had been correctly-installed as the electrical acceptance tests were.
successful. The NCR was then closed by an A-E Quality Assurance-engineer based cn1 the. documentation provided by the. electrical engineer which. supported the acceptance of the cabinet internals, electrically.
(2) Corrective Action That Has Been Taken A. Temporary Alteration Request No. 86-095 was issued on 9/4/86 to correct.the hardware deficiencies associated with the B Hydrogen Recombiner and work was completed on 9/5/86.
B. Station Modification Package (SMP) 1712 was initiated after it was determined that the seismic qualification of the Power Supply Panel B was deficient. This station modification was issued to revise.the' design-drawings to accurately reflect the as built configuration of the B panel. The update of the. drawings was complete on 10/13/86.
C. NCR-W3-6744 was annotated with SMP-1712 to-show reference to the
                                 -document which actually~provided corrective action.-
D. Nonconformance reports which were generated during the-construction phase of the project were reviewed for technical adequacy.. The scope of this review included a sampling of NCR's
                                                                ~
disportitioned and/or evaluated by the electrical engineer and those closed by the QA' Engineer who both had provided input to
                                 .NCR-V3-6744. Also NCR's submitted by the electrical contractor which showed deficiencies as a result of-missing or incomplete documentation were reviewed. 'The intent of this documentation review was to verify that no other conditions similar to this violation exists as a result of misrepresented documentation.
                                 ~There were a total of thirteen (13) NCR's dispositioned or evaluated by the Electrical engineer that were reviewed to verify the disposition or evaluation adequately addressed the nonconforming condition. In all cases, the disposition or evaluation'did adequately address problem description.
There were a total' of twenty-six (26) NCR's closed by the QA engineer that were reviewed for adequate closure. The review determined that adequate justification for closure of-the NCR's did exist.
There were also twenty-six (26) NCR's that described incomplete or missing documentation by the electrical contractor that were reviewed. Many of these NCR's were the same ones closed by the

ATTACHMENT to W3P86-2800
                                                                             . Sheet.7 of 8 QA engineer who closed NCR-W3-6744. It was noticed that these NCR's contained a more clear and concise definition of the problem and an amplified recommended disposition when compared.to the NCR.that documented the Hydrogen Recombiner deficiency. In all NCR's reviewed, it-was determined that the proposed resolution did match the deficiency and the corrective action taken was adequate.
(3) Corrective Action That Will Be Taken No further' action is deemed necessary.
(4) Date When Full Compliance Will Be Achieved A. SMP-1712 was complete on 10/13/86.
B. Physical work was complete on 9/5/86 via the Temporary Alteration Request No. 86-095.
C. Review of,the NCR's was completed on 10/24/86.
D. NCR-W3-6744 was referenced with SMP-1712 notation on 10/31/86.
E r

*jCie: j ATTACHMENT
                                                                              -to W3P86-2800 Sheet 8 of 8 VIOLATION NO.' 8616-05 Continued I RESPONSE TO VIOLATION - PART II.
(1): Reason for the'ViolationD
                  ' Based on available recosds, LP&L does not believe that the circumstances in this instance are sufficient cause for LP&L to be L.                Teited as having violated.10CFR50 Appendix B, Criterion X.. Although two'of the' anchor bolt nuts on SU.3. panel _3MB-S were found upon recent-inspection to have less than full thread engagement, there is documented evidence that- a general QA inspection was performed on the -
subject anchor bolts following rework of the panel's installation via
                                           ~
CIWA-837910, in accordance:with the applicable inspection procedure
                   - (WQC-169) . - This inspection indicated that all bolts were-tightened at the time and that the work was acceptable. The inspection report no.
15-25-1 wording was of a general nature..and did not individually.
address verification of each specific criterion of the' applicable-construction procedure (CP-697). These criteria did require that a minimum of one thread of an anchor bolt must protrude through the nut, but did not require any torquing for ASTM A307 anchor bolts.         The inspection report shows-no indication of not having met the minimum thread engagement' criterion.
            -(2) Corrective Action That Has Been~Taken LP&L has performed calculations to reconfirm the seismic integrity of the as-found installation of.the pane 1~. These calculations were based on a thorough inspection of the panel mounting, including measurement of. thread engagements, bolt' angles, and nut-to-base plate contact surface areas. Results of these calculations show that the seismic qualification for this panel is still valid.
            -(3)..-Corrective Action That Will Be Taken No further action is deemed'necessary.
(4)JDate When Full Compliance Will Be Achieved The calculations performed to reconfirm the installation was acceptable were completed on 9/10/86.
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