View source for W3P89-3006, Responds to Violations Noted in Insp Rept 50-382/89-06. Corrective Actions:Maint & Operations Depts Generated Quality Notices to Formally Address & Resolve Concern/ Deficiency

{{Adams
| number = ML20245H454
| issue date = 04/27/1989
| title = Responds to Violations Noted in Insp Rept 50-382/89-06. Corrective Actions:Maint & Operations Depts Generated Quality Notices to Formally Address & Resolve Concern/ Deficiency
| 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 = W3P89-3006, NUDOCS 8905030402
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 6
}}

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1 P. O. BOX 60340 LO UISI POWER      ANHT
                                                             & LiG   A / 317 NEW BARONNE ORLEANS, LOUISIANA STREET 70160   e (504)595-3100
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1 April 27,1989                                              I l
l W3P89-3006               4' A4.05 QA U.S. Nuclear Regulatory Commission ATTN: Docurrent Control Desk Washington, D.C. 20555

==Subject:==
Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report 89-06 Gentlemen:
In accordance with 10 CFR Part 2.201, Louisiana Power & Light hereby submits in Attachment 1 the response to the Violation identified in Appe., dix 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,
                                                                                             .T R.F...Burski Manahr Nuclear Safety & Regulatory Affairs RFB:TJG:ssf Attachment cc:  R.D. Martin, NRC Region IV J.A. Calvo, NRC-NRR D.L. Wigginton, NRC-NRR NRC Resident Inspectors Office E.L. Blake W.M. Stevenson NS100237C 8905030402 890427                          "AN EQUAL OPPORTUNITY EMPLOYER"                                   I PDR                  ADOCK 05000382                                                                     i Q
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Attachment to W3P89-3006 Page 1 of 5 ATTACHMENT 1 LP&Ljiesponse to the Violation Identified in Appendix A of Inspection Report 89-06 VIOLATION NO. 8906-01 Failure to Follow Procedures 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 instructions, procedures, or drawings.                                            ;
Contrary to the above, three examples of failure to adhere to procedures are delineated below:
: 1. Work Authorization 01028798 required the B auxiliary component cooling water (ACCW) pump coupling to be reassembled per B&W Pumps Instruction Manual 457000254.
Contrary to the torquing requirements included in and referenced by B&W Pumps Instruction Manual 457000254, the torquing requirements were not adherett to when the coupling was reassembled on February 16, 1989,
: 2. Procedure UNT-5-003, Revision 7, " Clearance Request, Approval, and Release," requires release and removal of a red danger tag before operating the attached valve.
Contrary to the above, on February 15, 1989, a maintenance technician operated danger tagged Valve CVC-189 A/B (Charging Pump A/B drain line).
: 3. Step 12 of Attachment 10.3 to Procedure OP-903-011, Revision 4, "High Pressure Safety Injection Pump Reservice Operability Check," requires placing the B low pressure safety injection (LPSI) pump switch to                                      1 "0FF" prior to performing a test start of the A/B high pressure safety
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injection (HPSI) pump.                                                                                '
Contrary to the above, on February 4, 1989, operating personnel did                                   !
not place the B LPSI pump switch to "0FF" prior to a test start of the A/B HPSI pump.
This is a Severity Level IV violation.                                                                     ,
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===RESPONSE===
(1) Reason For The Violation Example 1 The root cause for example 1 of this violation was an inadequate work instruction. Work Authorization (WA) 01028798 was generated to perform an alignment check on ACCW Pump 1B. The steps necessary to accomplish this task were delineated in the Mechanical Maintenance Attachment Work Signoff Sheet which was included in the WA package.        ,
As required by Step 5 of the Work Signoff Sheet, the pump coupling was     i disassembled in accordance with Maintenance Procedure MM-06-004,
                     " Shaft Coupling Alignment And Belt Tensioning," and Vendor Instruction Manual 457000254, "B&W Pumps". In Step 6 of the Work Signoff Sheet, Maintenance personnel were required to perform an alignment check per MM-06-004 and realign the pump coupling if required. When performing the check, mechanics found the pump alignment to be out of specification. Consequently, pump realignment became necessary. To realign the pump the pump motor base bolts had to be loosened. After properly aligning the pump, the base bolts had to be retightened.
Because the Work Signoff Sheet did not list any torquing requirements, the bolts were not tightened to any specific torque value. This action was in direct conflict with Vendor Instruction Manual 457000254 which states that torque values for motor base bolts are from 280 to 300 foot pounds.
Example 2 The root cause for example 2 of the violation was personnel error in failing to follow Plant Administrative Procedure UNT-5-003 due to a miscommunication between the Nuclear . Auxiliary Operator (NAO) and the Control Room Superviscr (CRS). UNT-5-003 provides the controls necessary to safely remove and restore equipment and/or systems from service to protect personnel and prevent equipment damage. Steps 5.9.3 through 5.9.6 of UNT-5-003 identify the proper sequence for partial release of danger tags (tags which when in place prohibit the operation of equipment or systems that could jeopardize personnel safety or endanger equipment).
While performing maintenance on the A/B Charging Pump under WA 01032239, operation of some header drain valves (CVC-189 A/B and CVC-193 A/B) became necessary in order to drain the pump. The NA0 in the field contacted the Control Room to obtain verbal authorization to partially remove the tags and reposition the drain valves. The CRS, who misunderstood the request and did not realize that the valves had been danger tagged, verbally authorized the repositioning of the f                    valves. Under the supervision of the NAO, the valves were then l                    operated by Maintenance personnel. These actions were in direct conflict with UNT-5-003.
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      ,                                                                       Attachment to 6                                                                         W3P89-3006        i Page 3 of 5       l 1
Example 3 The root cause for example 3 of this violation was personnel error due to a failure to follow Surveillance Procedure OP-903-011. OP-903-011 provides the instructions for verifying the operability and valve alignment of HPSI Pump A/B each time it is placed in or taken out of          j service in place of HPSI Pump A or B (as required by Technical Specification Surveillance Requirement 4.5.2.1).       On 2/4/89, Operations personnel performed OP-903-011 to allow substitution of            ,
HPSI Pump A/B for HPSI Pump B.      This action was accomplished through      !
the use of Attachment 10.3 to OP-903-011 (Revision 4), "HPSI Pump AB Replacing HPSI Pump B Data Sheet." As indicated in Step 12 of Attachment 10.3 (currently Step 17 in Revision 5 to OP-903-011), the          '
control switch for LPSI Pump B is to be momentarily turned to "0FF".
This action avoids an unnecessary start of LPJI Pump B while testing HPSI Pump A/B. Once HPSI Pump A/B testing is complete, the control switch for LPSI Pump B is restored to " NEUTRAL" for automatic                )
operation. On this particular occasion, Operations personnel violated         {
Step 12 of Attachment 10.3 by leaving the LPSI Pump B control switch in " NEUTRAL". Consequently, LPSI Pump B inadvertently started aftet the test signal was actuated.
(2) Corrective Steps That Have Been Taken And The Results Achieved                i Example 1                                                                     1 On 2/22/89, the Maintenance Department generated a quality notice (QN QA-89-059) to formally address and resolve the concern. Based on an evaluation of the maximum torque value that would have resulted from the incorrect tightening of the base bolts, maintenance Engineer 1rg determined that bolt / stud damage had not occurred, Consequently, at Maintenance Engineering's recommendation, the motor base bolts were released and then retorqued properly to 280 foot pounds per the Vendor Instruction Manual. The torquing was witnessed by Operations Quality Assurance.
To prevent recurrence of a similar event, the Mechanical Maintenance Attachment Work Signoff Sheet, which appears as a generic attachment to repetitive WAs that are generated to perform this task, has been revised. Step 6 of the Work Signoff Eheet now requites the followingt     j
                         - Perform alignment check per MM-06-004 and
                         - Realign if required and Torque motor bolts 280 to 300 ft./lbs.
Example 2 On 2/16/89, the Operations Department generated a quality notice (QN QA-89-049) to formally address and resolve the deficiency. The NA0 who was responsible for this deficiency was counselled. On 2/17/89, the Operations Superintendent issued a letter (LP&L Letter W3089-0025) to Operations personnel to reemphasize the policies on danger tags and valve operation. The letter specifically stated the following:        1)
Only operators shall operate valves; 2) Danger tagged valves shall not NS100237C

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W3P89-3006 Page 4 of 5 be operated; and 3) The tags must be released and documented as such beforehand. The letter also expressed that violation of these policies will result in disciplinary action.
Since this was the second instance of a danger tagged valve being operated contrary to procedure, the plant manager felt it prudent to issue a memorandum to Nuclear Operation's personnel reiterating the-above policies. The memorandum stated the following:
(1) Unless specifically authorized by an approved plant procedure or a WA signed by the SS/CRS, N0 one except Operations personnel shall operate a valve.
(2) N0 one shall operate a DANGER tagged component.                       !
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: a. The purpose of danger tagging equipment is to protect personnel and prevent equipment damage, i
: b. ONLY Operations Department personnel shall hang or remove Danger Tags.
: c. Once a component is positioned and Danger tagged, NO one       j shall reposition that component, until the Danger tag is properly cleared in accordance with UNT-5-003, Clearance Request, Approval, and Release.
: d. Personnel authorized to request or hold clearances shall be-trained in the use of the clearance procedure.
: e. Notify your Supervisor if you are assigned to work on a componant that has a Danger tag on it. Danger tagged components are boundary components to protect you or equipment and should not be touched.
: f. Repositioning of Danger tagged components is grounds for termination.
To ensure that this information would be brought to the attention of plant personnel, a discussion on the two events was provided during the April Waterford 3 Safety Meetings on 4/4/89 and 4/6/89.
l Example 3 After the event, LPSI Pump E ran on recirculation and was promptly secured. Because this event was reportable as an unplanned manual Engineered Safeguards Features actuation, a Licensee Event Report (LER 89-003-00) was submitted on March 3, 1989. The personnel responsible for the procedural violation were counselled by the Assistant Operations Superintendent, emphasizing a more cautious and thorough approach when following procedures. Additionally, on 2/23/89, the Operations Superintendent issued a letter (LP&L Letter W3089-0026) to Operations personnel which addressed the inadvertent start of LPSI Pump B and discussed the need to rededicate efforts toward procedural compliance.
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                                                                                       .Page 5 of 5 (6                '(3) Corrective Steps Which Will Be Taken To Avoid Further Violations
                           . Examples 1,'2, and 3 1
  ,'                         Based on the information provided above, LP&L feels confident that the necessary corrective actions have been implemented to ensure that a violation' for these types ofcprocedural deficiencies will not recur.
(4) Date When Full Compliance Will Be' Achieved P                            Examples 1, 2, and'3 LP&L is currently in. full compliance.                                                      !
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