View source for W3P87-2243, Responds to Violations Noted in Insp Rept 50-382/87-22. Corrective Actions:Personnel Counseled,Mechanics Required to re-read Procedure UNT-7-005 in Entirety & Plant Operators Required to Review Operations & Maint Directive 16

{{Adams
| number = ML20238C939
| issue date = 12/23/1987
| title = Responds to Violations Noted in Insp Rept 50-382/87-22. Corrective Actions:Personnel Counseled,Mechanics Required to re-read Procedure UNT-7-005 in Entirety & Plant Operators Required to Review Operations & Maint Directive 16
| author name = Cook K
| author affiliation = LOUISIANA POWER &amp; LIGHT CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF ADMINISTRATION &amp; RESOURCES MANAGEMENT (ARM)
| docket = 05000382
| license number = 
| contact person = 
| document report number = W3P87-2243, NUDOCS 8801040005
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 10
}}

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* 9 l                           LOUISI                                     P. O. BOX 60340 POWE R &ANA     / 317BARONNESTREET
* LIGHT     NEW ORLEANS, LOUISIANA 70160  *      (504)595-3100 l'         UTIlkiNIYSiEM December 23, 1987
   ,                                                                                       W3P87-2243 A4.05 QA U.S. Nuclear Regulctory Commission ATTN: Document Control Desk Washington, D.C. 20555

==Subject:==
Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report 87-22 Attached are the Louisiana Power & Light Company (LP&L) responses to the violations identified in Inspection Report No. 87-22.
If you have any questions on the response, please contact G.E. Wuller, Operational Licensing, at (504) 464-3499.
Very truly yours, K.W. Cook Nuclear Safety and Regulatory Affairs Manager KWC:GEW:ssf Attachment cc:    R.D. Martin, NRC Region IV J.A. Calvo, NRC-NRR J.H. Wilson, NRC-NRR NRC Resident Inspectors Office W.M. Stevenson E.L. Blake 8801040005 871223                                                                                                        )
PDR     ADOCK 05000302                                                                                                   I O                        DCD I
I 8'AN EQUAL OPPORTUNITY EMPLOYER"

Attachment to
.                                                                         W3P87-2243 Page 1 of 9 LP&L Responses to Violations of Inspection Report No. 87-22 VIOLATION NO. 8722-01 Failure'to Maintain Procedural Adherence and Attention to Detail Criterion V of Appendix B to 10 CFR Part 50 and the approved Quality Assurance Plan for Waterford 3, require that activities affecting quality be prescribed by documented inctructione, procedures, or drawings. Three examples of failure to adhere to procedures are delineated below:
: 1. Procedure UNT-7-005, Revision 2, " Cleanliness Control," requires closure inspections to be performed "immediately prior to" system or component closure.
Contrary to the above, the crank case cover for Charging Pump "B", a safety-related component, was installed on October 1, 1987, but the cleanliness inspection was conducted on September 30, 1987.
: 2. Procedure OP-10-001, Revision 9 " General Plant Operations," states in a note that, during cooldown, the last reactor coolant pump should not be stopped until the hydrogen content of the reactor coolant system is less than or equal to 5 cc/kg.
Contrary to the above, on September 21, 1987, the last reactor coolant pump was stopped prior to the hydrogen content reaching 5 cc/kg.
: 3. Procedure OP-100-001, Revision 4, " Duties and Responsibilities of Operators on Duty," specifies that procedure steps may be deleted as not applicable with approval of the shift supervisor.
Contrary to the above, on September 29, 1987, Step 8.2.8 of Survefilance Procedure OP-903-111, Revision 0, " Containment Air Lock Door Seal Leakage Test," was marked    "NA" by the test engineer without approval of the shift supervisor.
This is a Severity Level IV violation.

===RESPONSE===
(1) Reason for the Violation Example 1:
The cause of this failure to adhere to the procedure was poor communication between the Maintenance craft personnel and the Maintenance first line supervisor. On September 30, 1987 the Charging Pump "B" crankcase wcs inspected and accepted for cleanliness by a Quality Control Inspector during restoration from corrective maintenance. During the pump closure process, the mechanics recognized that the cover gasket was improperly sized for the

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  .                                                                                                                                           W3P87-2243 Page 2 of 9 (1) Reason for the Violation (Continued)
Example 1: (Continued) application. Work was suspended to resolve the problem. On October 1, 1987, when work was restarted, the workers apparently misunderstood the verbal direction provided by their supervisor in that they completed the crankcase closure process without QC presence to re-witness cleanliness. The workers assumed that the previous day's clean 16 ess witness was sufficient and still valid because the cover had been temporarily in place during the interim. Upon being questioned about the closure process by a resident inspector, the workars notified their supervisor. On October 1, 1987, the supervisor noted the discrepancy in the dates on the cleanliness control forms.
He subsequently initiated additional werk instructions to have the crankcase cover removed and another QC inspection performed. The reinspection was completed on October 4,                        1987.
Example 2:
This procedure failure example occurred because the operators interpreted the procedural " note" to be advisory in nature and not a mandatory step in the procedure. After discussions with the Shift Supervisor, it was decided that the last Reactor Coolant Pump could be secured prior to reaching a hydrogen concentration of 5 cc/kg. The basis for this decision was that experience had previously demonstrated the hydrogen concentration would drop below 5 cc/kg once shutdown cooling was initiated. This method was discussed earliergin the day with Plant Management who concurred with securing the last' pump so that dilution would reduce the concentration below 5 cc/kg.
It was felt that this decision was corroborated by plant procedure OP-10-001, General Plant Operations, which states in part "the steps in this procedure may be performed out of sequence at the discretion of the SS/CRS." Also, plant procedure UNT-4-009, Control, Distribution, Handling, and Use of POM Procedurar, states in part:
[" Procedures and instructions are prepared assuming normal plant conditions unless specified otherwise and delineate the various operatirr and maintenance steps in an orderly sequence. Normally                                                                                                                                      i procedures and instructions shall be followed and performed in the sequence in which they are written. In certain cases where steps                                                                                                                                      !
are performed out of sequence, particular attention should be paid to ensuring that initial conditions, precautions and limitations notes, and the intent of the procedure are met.                                                                                                                                    Any individual desiring to perform a procedure or a portion of a procedure out of sequence, shall first check with his supervisor.
Typical examples of performing steps out of sequence are; valve or electrical lineups, general operating procedures where numbers of items are being started or placed in a condition of readiness, Emergency Plan Notification and Communications, etc.
NOTE:  If there is any question concerning the use of procedures or instructions, consultation with one's supervisor is warranted, and if a procedure change is deemed necesse- i* should be processed in accordance with the requireme ._                                                                  "NT-1-003, POM Procedure Development, Review and Appr                          ., Change Tnd Revision and Deletion."]

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            .                                                                                                                                                                       W3P87-2243                         i Page 3 of 9 (1) Reason'for the Violation (Continued)                                                                                                                                                 j I
Example 2: (Continued)                                                                                                                                                            I Both OP-10-001 and UNT-4-009 were interpreted as providing the flexibility needed to make the decision in question. One complicating factor, however, is that the note as stated prohibits securing the last RCP before hydrogen is reduced below 5 cc/kg. This makes the applicability of the out-of-sequence rules addressed above somewhat                                                                                                               j dubious. The note is also an example of a procedure step that could                                                                                                               '
l be enhanced from a human factors standpoint.
Example 3:
This procedural deviation resulted from an interpretation of OP-100-001, Duties and Responsibilities of Operators on Duty. The Shift Technical Advisor-skipped the step in question and documented it as not applicable because that portion of the procedure would be later satisfied via OP-10-001, General Plant Operations.                                                                                                       OP-10-001 requires a check of the same interlocks as a mode constraint during plant start-up therefore satisfying the intent of OP-903-111, Containment Airlock Door Seal Leakage Test. The STA fully intended to obtain the Shift Supervisor's initials next to the N/A entry when the SS reviewed and approved the completed surveillance test document (prior to equipment operability restoration). The STA felt that this was in compliance with OP-100-001, Duties and Responsibilities of Operators on Duty, which states that " Procedure steps with requirements for a signature, initial, or data entry shall have the appropriate entry unless the specific task or data entry is not appropriate for the evaluation performed or conditions at the time of procedure performance. For these situations the operator will enter N/A (NOT APPLICABLE) in the appropriate blank or block. All N/A entries will be approved by the SS/CRS by the entry of his initial near the N/A." The contention in the procedural violation is apparently that the N/A authorization should have been obtained prior to performance of the surveillance field activities.                                                                                                                             j (2) Corrective Actions That Have Been Taken
: 1. Personnel involved in the three examples of failures to adhere to procedures have been counselled.
: 2. The mechanics in Example 1 above were required to re-read UNT-7-005, Cleanliness Control in f ts entirety.                                                                                        They new clearly understand the procedural requirements and the significance of their actions.
: 3. Plant Operators were required to review Operations & Maintenance Directive #16, Procedure Compliance, and the critical portions of OP-100-001, Duties and Responsibilities of Operators on Duty.
: 4. A series of meetings were conducted by the Plant Manager during the period September 29 through October 2, 1987, to improve procedural awareness and sensitivity of attention to detail, i
These meetings were attended by members of Plant Staff and l
supporting organizations.
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                                                                                                                                                            -W3P87-2243
                                                                                                                                                            -Page 4 of 9 (3) Corrective Action To Be Taken
: 1. OP-10-001, General Plant Operations, will be revised to enhance procedure clarity and flexibility by applying additional human factors good practices. The note addressed by the violation will be revised as part of this process. The procedure will be revised by January 31, 1988.
: 2. Procedures OP-100-001,. Duties and Responsib111 ties of Operators on Duty, and MD-1-014, Conduct of Maintenance, will be revised to clarify the guidance and requirements relevant to use, I                                                  documentation, justification, and approval of the "N/A" feature when performing operations and maintenance procedures. The-procedures will be revised by January 31, 1988.
: 3. Feedback on management efforts to improve procedural awareness and attention to dete.11 will be solicited from the Plant Advisory Groups. This feedback will be used to initiate action by Management to ensure that station personnel are aware of the importance of procedural compliance and attention to detail.
: 4. The Operations and Maintenance departments have employed the services of a Human Factors consultant to review existing plant procedures and procedure writing guidelines for the purpose.of making recommendations for enhancements. Those recommendations-will be used as input to pending revisions to Operations and Maintenance procedure writing guidelines. The guidelines will then be used to upgrade procedures as they are reviewed during the biennial review cycle. A number of Plant Procedures will be selected for expedited review and upgrading before their biennial review date. This effort should significantly reduce procedural human factors proble.as which are sometimes conducive. to causing procedure violations. The revised procedure writing guidelines will be issued by March 1, 1988.
(4) Date When Full Compliance Will Be Achieved Full com;,11ance will be achieved by March 1,1988.

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Page 5 of 9 i
VIOLATION NO. 8722-02                                                                                     !
Fire Protection Program Technical Specification (TS) 6.8.1 requires, in part, th'a t written procedures be established, implemented, and maintained for fire protection program implementation. The following are three examples of failure to ir.plement fire prevention procedures:
: 1. Fire Protection Procedure FP-1-015, Revision 3, " Fire Protection System Impairments," requires that all impairments to fire doors be documented.
Contrary to the above, Fire Door D-47 was impaired by a scaffold clamp so that it would not close on September 22, 1987, and this was not documented as a fire door impairment. Also, on September.23, 1987, Fire Doors D-136, D-163, and D-165 were found unlatched but were not documented as being impaired.
: 2. Fire Protection Procedure FP-1-017, Revision 4, " Transient Combustibles and Hazardous Materials" requires that safety cans, if unattended, be stored in a flammable liquid storage cabinet.
Contrary to the above, on October 6, 1986, five cans of "Fyrquel", a flammable liquid, were found unattended and not stored in a flammable liquid storage cabinet at various locations in the main steam and feed isolation valve rooms.
: 3. Fire Protection Procedure FP-1-013, Revision 3, " Fire Protection Program Plan," prohibits smoking in nondesignated areas such as the Emergency Feedwater Pump A room and the stairwell leading to the main steam and feed isolation valve room.
Contrary to the above, on October 6, 1987, cigarette butts were found in'each of these areas.
This is a Severity Level IV violation.

===RESPONSE===
(1) Reason for the Violation Example 1:
Plant fire doors are addressed under Technical Specification 3/4.7.11 which calls for a daily inspection to ensure that doors are closed and a semi-annual check of the closure and latch mechanism. Both of these tasks are accomplished daily by surveillance procedure PS-15-111, Fire Door Surveillance. Fire doors that were capable of being made to latch were considered operable and reliance was placed on plant personnel to ensure the doors were closed upon entry or exi+-
Following this incident it became apparent the necessary sensitivity did not exist to ensure this action was accomplished.

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Attachment to W3P87-2243 Page 6 of 9 (1) Reason for the Violation (Continued)
Example 2:
Due to an oil leak on equipment in the MSIV/MFIV area, it was necessary to maintain a small quantity of Fyrquel, a combustible liquid (class IIIB), in the area. . Corrective actions taken in August 1986, following Violation No. 8616-02, included the addition of a flammable liquids locker to the area. l' modification to this system during the first refueling eliminated the oil leakage. In an effort to limit combustibles and reduce area fireloading, the locker was removed. This along with an unacceptable level of. sensitivity led to the interim storage of oil outside a flammable liquids locker as required.
Example 3:
Smoking guidelines as set forth in LP&L inter-office correspondence W3M85-0096, dated March 5, 1985 delineated areas in the Protected Area as Designated Smoking Areas. Both the Emergency Feedwater Pump Room A and the stairwell leading to the MSIV/MFIV areas are not designated smoking areas. Therefore, this indiscretion can be attributed to lack of knowledge or lack of sensitivity thereto on the part of personnel.
(2) Corrective Actions That Have Been Taken Corrective actions for the above events were effected by the Senior Management of the station conducting plant wide employee awareness      j meetings during the week of September 28, 1987. These meetings were attended by 587 employees and covered the topic of. procedural.
awareness and attentiveness to detail. Emphasis was placed on each employee's responsibility to sensitivity to existing programs and policies. Additional corrective actions were the issuance of letter W3Y87-0219 that established the need for firewatch activities for any fire door that had a questionable latch mechanism. This would be effected via a fire protection impairment per plant procedures.
1 A flammable liquids lockers has been reinstalled to serve the area on    l
                 +46 RAB that houses the MSIV/MFIV equipment. This locker will be left in place to support this area on a long-term basis. Additionally, the plant awareness meetings cautioned all personnel on sensitivity to the use of flammables and the proper storage of safety cans.
Finally, the plant smoking and chewing policy was re-emphasized by LP&L letter W3Y87-0209, dated November 8, 1987 that was reissued and distributed to all plant personnel and issued to each vehicle entering the facility on that date to ensure the widest possible distribution.
These guidelines clearly delineate the plant's Designated Smoking Areas.

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                             .                                                                                                              W3P87-2243-Page 7 of 9'
                                       ' (3) Corrective Action To Be Taken
                                               - No additional corrective action is felt.necessary in that the application of additional administrative and physical improvements identified above are believed adequate to entablish a high. level of personnel sensitivity.
(4) Date When Full Compliance Will Be Achieved Waterford 3 is in full compliance at the present time, j

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         .                                                                                                                                  W3P87-2243 Page 8 of 9 VIOLATION NO. 8722                            Failure to Meet Technical Specification Action Statementa o
Technical Specification 3.0.1 requires, in part, compliance with action statements associated with limiting conditions for operation. There are two examples listed below where this TS was not met:
: 1. Technical Specification 3.3.3.11.b requires, in part, that when the main condenser evacuation noble gas acth ity monitor is f r. operable, grab samples shall be taken at least once per 12 hours.
Contrary to the above, on October 14, 1987, while the main condenser evacuation noble gas activity monitor was out of service, grab samples were taken at 5:05 a.m. and 8:35 p.m., which is more than 1.25 times the 12-hour interval prescribed.
: 2. Technical' Specification 3.3.3.11.b also requires, in part, that when                                                                          j the waste gas holdup system explosive gas monitoring system is inoperable, hydrogen grab samples shall be taken at least once per 8 hours and oxygen grab samples shall be taken at least once per 4 hours. These samples are required to be taken from the on-service gas decay tank.
i Contrary to the above, while the waste gas holding system explosive                                                                             !
monitoring system was inoperable, the grab samples were taken from an                                                                           !
off-service tank (A) instead of the on-service tank (C) from 1:48 p.m.                                                                          .
on October 3, 1987, through 9:00 a.m. on October 5, 1987.                                                                                      I This is a Severity Level IV violation.
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===RESPONSE===
(1) Reason for the Violation Examples 1 & 2:
The root cause of these failures to meet technical specification actions was a programmatic breakdown in administrative controls as described in LER 87-025-00.                    Tracking and management review controls were not adequate to ensure completion of surveillance within required time frames.
(2) Corrective Actions That Have Been Taken (1) Operating Instruction 01-014-00, Departmental Action Statement Notification Instructions (DASN), was revised to require the action department to hand carry the completed DASN to the Control Room where the Shift Supervisor or Control Room Supervisor signs for receipt.

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     .-                                                                                                                                 W3P87-2243 Page 9 of 9 (2) , Corrective Actions That Have Been Taken (Continued)
(2) 7The Health Physics and Chemistry technicians responsible for the                                                                              1 missed samples and their immediate supervisors were counselled by                                                                           J the Plant Manager. This' counselling emphasized personal responsibility and accountability at all levels of the organization in ensuring that Technical Sp2cification                                                                                       ,
requirements are properly met,.and the importance of promptly notifying the Shift Supervisor of-problems or deviations.                                                                                  ,
1 (3) A formal watchstation turnover sheet was implemented to enable the Shift Control Technician (lead Health Physics technician) to monitor sample requirements independently of the methods used for scheduling the analyses.
(4) These incidents were reviewed with all Health Physics and Chemistry technicians.
(5) Chemistry Procedure, CE-1-003, Reporting Chemistry Data was revised and reissued to establish a watchstation shift chemistry log and a weekly Technical Specification Surveillance Check Sheet. Completion of surveillance is reviewed and signed by the chemistry Supervisor or SS/CRS eath day.
(6) Chemistry Procedure, CE-3-305, Sampling of Ventilation and                                                                                   {
Gassous Waste Management Systems for Radioactive Effluents, was                                                                             I revised to specify the mechanism for verifying the on-service gas decay tank and to require notification to the SS/CRS of sampling activities prior to sampling and analysis.
(3) Corrective Action To Be Taken The corrective actions taken above are considered satisfactory.
Station Modification 818 which will provide continuous monitoring capability for the gaseous decay tanks is scheduled for completion by July 1988.
(4) Date When Full Compliance Will Be Achieved Waterford 3 is in full compliance at the present time.
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