IR 05000382/1985027

Insp Rept 50-382/85-27 on 850930-1004.Violations Noted: Failure to Establish & Follow Procedures for Quality Related Activities.Unresolved Item Re Provision of Work Supervisor Qualification & Training Noted

ML20137E920
Person / Time
Site:	Waterford
Issue date:	01/09/1986
From:	Boardman J, Ireland R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20137E897	List: ML20137E893 ML20137E906 ML20137E920
References
50-382-85-27, NUDOCS 8601170354
Download: ML20137E920 (7)

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APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

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NRC Inspection Report: 50-382/85-27 Operating License: NPF-26 Docket: 50-382 Licensee: Louisiana Power and Light Company (LP&L) 142 Delaronde Street New Orleans, Louisiana 70174 Facility Name: Waterford Steam Electric Station, Unit 3 Inspection At: Taft, Louisiana Inspection Conducted: September 30 through October 4, 1985 Inspector: jA . [ 8. M J Boardman, Reactor Inspector, Operations

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f Section, Reactor Safety Branch Approved: [[ Ireland, R. ~ . AM//MActing Chief, Operations

     //9/d Dat'e Section, Reactor Safety Branch

Inspection Summary Inspection Conducted September 30 through October 4, 1985 (Report 50-382/85-27) Areas Inspected: Routine, announced inspection of the licensee preventive maintenance program and nonlicensed staff training. The inspection involved 42 inspector-hours onsite by one NRC inspecto Results: Within one area inspected (preventive maintenance) two violations were identified (failure to establish and'to follow procedures for quality-related activities, paragraph 2). One new unresolved item was identified regarding provision of work supervisor qualification and training, paragraph 2.b.(3).

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DETAILS Persons Contacted Principal Licensee Employees

*R._S. Leddick, Senior Vice Pre ident, Nuclear Operations
*K. Simister, Commercial Manager R. P. Barkhurst, Plant Manager
*T. F. Gerrets, Corporate Quality Assurance (QA) Manager
:*J. Woods, 0.C Manager-
*L. L. Bass, Project Manager
*K. Brewster, OnSite Licensing Engineer
*N. L. Carns, Assistant Plant Manager, Operations and Maintenance
*T. H. Smith, Maintenance Superintendent
*P. V. Prasankumar, Technical Support Supervisor
*R. V. Seidl, Project Manager, E&NS
*F. J. Englebracht, Manager, Plant Administrative Services M. Hamilton, Plant Engineering
*A. S. Lockhart, Plant Staff
*S. Alleman, Assistant Plant Manager, Technical Services
*J. J. Zabritski, Plant Quality R. T. Burski, Manager, Engineering and Nuclear Safety
*D. Packer, Manager Training
*W. J. Baldwin, Vendor QA
*J. E. Adkins, Procurement
*J. C. Lawrence, M&S
* J. Toth, Plant Training NRC Personnel T. Flippo, Resident Inspector
* Denotes those attending the exit interview on October 4, 198 The NRC inspector also interviewed other licensee and contractor personne . Preventive Maintenance The inspection included the review of selected preventive maintenance activities, including the following areas: Preventive Maintenance Program Procedures MD-1-004, " Preventive Maintenance Scheduling," Revision 6, Change 2, dated August 16, 1985.

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 (1). The established procedural controls included scheduling and
 . classification of preventive maintenance (PM) work. The-work classification addressed preventive maintenance actions (task cards), work programs, and quality classes. Work programs and quality classes had corresponding task card colors as follows:

Work Programs Task Card Color

 * Technical Specification Related  Pink
 * Equipment Qualification (EQ) Related Yellow Quality Classes
 * Safety-related   Blue
 .* Other    Buff The review of the onsite microfilmed maintenance records associated with PM activities revealed that the task card colors could not be directly determined on the film. The provision of clear and comprehensive records of safety-related maintenance activities onsite is considered an open item pending further review during a subsequent inspection (382/8527-01).

(2) PM Scheduling for Replacement of Safety-Related Components The review of the PM scheduling prograa revealed that the program automatically added a 25 percent time extension to all PM activities. Discussions revealed that the impact of the 25 percent time extension on the component safety-related function had not been adequately considere Examples included the required replacement of safety-related Agastat relays at 10 year intervals and of Rosemount transmitter 0-rings at 5 year intervals to maintain required equipment qualit ' The automatic extension of the PM schedule for replacement of safety-related components is an open item pending further review during a subsequent inspection (382/8527-02).

b. Maintenance Procedure PE-2-014, " Equipment Environmental Qualification," Revision 2, approved September 16, 198 (1) The procedure required the following:

 * the environmental qualification (EQ) related maintenance be performed under " work program 6" - Yellow PM Task Cards;

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    * * the generation of; adequate records to demonstrate
     : maintenance'of equipment _ qualification;
    *  the EQ coordinator. review of the completed work packages
      'for adequacy;.an *  Ithe EQ; records be forwarded to project files by the EQ coordinato .
  ;(2)-1The procedure review revealed that the EQ coordinator, or-
    -another qualified individual, was not required to be involved in
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    .the EQ related PM activities at the point: safety-related, environmentally-qualified equipment was to be opened fo '

maintenance (e.g.,'Rosemount Model 1153-Transmitters - removal of cover plates for adjustments during PM activities). The procedure did not require the " work program" designation to be

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changed to "EQ Related" (" YELLOW") when appropriat The failure to establish adequate procedures to control the classification of maintenance activities in accordance with the requirements of the Technical Specifications and the QA program , is an' apparent violation (382/8527-03a).

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  ~(3) The procedure review and discussions revealed that the routine closure of a work package /PM task card included a review by the-applicable work supervisor for acceptability of maintenance of equipment qualification (EQ, IE, Seismic, etc). No documented qualification, or training, was identified during this revie This item is considered unresolved pending further review during
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a subsequent inspection (382/8527-04).

- E Review of Maintenance Activities Associated with Completed

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Safety-Related Preventive Maintenance (PM) Task Cards

  'The inspection included the review of completed PM task cards u
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  > . associated with the calibration of four safety-related Rosemount l'   Model 1153 Transmitters (Reactor Coolant System (RCS) loop pressure,
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injection tank level). The following quality deficiencies were identified: Deficiency Number Description L 1 Failure to incorporate component ,

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manufacturer's maintenance requirements for maintaining

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component qualification.

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Deficiency Number Description

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Failure to implement the manufacturer's requirements where incorporated in licensee procedures as follows: manufacturer's requirements were not followe , 2(a) Replacement of cover 0-rings not accomplished 2(b) Use of Dow Corning 55M lubricant on replacement 0-ring not

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accomplishe + ' ' 2(c) Torquing of cover to 200 inch pounds not accomplished Task Card / Procedure and Deficiency Matrix Task Card / Procedure Deficiency (1) RC ILO 001X 01/MI-3-323, Revision 2, Change 2 2(a), 2(b)

 (2) CCS1IP 515 X A 25/MI-5-503, 1 Revision 0, Change 2 (3) CP IP 6702 MC 1/MI-315, 1 Revision 2, Change 1 (4) SI IL 0321 01/MI-5-201, 1 Revision 3, Change 1 Failure to comply with requirement 1 is an apparent violation of establishing procedures for activities affecting quality as required by Waterford SES Unit 3 Technical Specification, Section 6.8.1, 10 CFR-Part 50, Appendix B, Criterion V, and FSAR Section 17. (50-382/8527-03b)
 . Failure to comply with requirements 2(a), 2(b), or 2(c), is an apparent violation of implementation of procedures for activities affecting quality as required by Waterford SES Unit 3 Technical Specification, Section 6.8.1, 10 CFR Part 60, Appendix B, Criterion V, and FSAR Section 17. (50-382/8527-05a).

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,- Failure to Perform a Spare Parts Equivalency Evaluation Request-(SPEER) A review of CIWA 15517, ROS.098960, dated February 14, 1985, revealed the following:

 ~ Material supplied (0-ring) on C1WA 15517, ROS 098960, P0 N L-A78479-P, P/N 01151-0033-0002, for Rosemount Transmitter Model 1153 (RC IP 0110) failed to have a SPEER performed prior to us The 0-ring required part number'was P/N 01153-0011-00 Licensee personnel told to the NRC inspector that, prior to issue and use, a Spere-Parts Equivalency Evaluation Request (SPEER) was not processed as required by Procedure UNT-8-042 Revision 1, or UNT-7-021, Revision 0, " Spare Parts Equivalency Evaluation."

The failure to perform a SPEER as required by procedure in accordance with the Technical Specifications and the licensee's QA

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 -program requirements is an apparent violation (382/8527-05b).

e. .Use'of Preventive Maintenance Task Cards to Perform Corrective Maintenance The inspection revealed that PM tasks having a periodicity of 3 or 5 years had been accomplished at least twice. Examples included task cards for the following PM tasks in 1985:

 * CC EBKR 3AB4S L  * SI FOL 313 A7CS The multiple accomplishment of the PM activities in excess of the normal scheduled activities indicated the possible use of the PM tasks to accomplish corrective maintenanc This matter will remain an open item pending further review during a subsequent inspection (382/8527-06). Design' Life of Safety-Related Capacitors A review of the vendor documentation provided with licensee purchase order L-08423-D stated that the power supplies provided were of limited life due to electrolytic capacitor .

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 ' The = installed Elgar Inverters (safety-related, environmentally
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  ! qualified)have45capacitorswith9yearlife,requiringreplacement to~ maintain component qualificatio Discussions with a capacitor manufacturer's aluminum electrolytic capacitor manufacturing group revealed that aluminum electrolytic capacitors have design life periods of 1000 hours to 15 years,
  ' depending upon the grade of the capacitor.(e.g. special, standard, premium, computer or military specification).

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The-licensee had no' program identifying capacitors installed in safety-related circuits where failure could be nonconservativ This will remain an open item pending further review during a subsequent inspectir;n (382/8527-07).

- Training of Nonlicensed' Staff

 .The NRC inspector began review of the licensee's training program for nonlicensed staff; however, the' requirements of the inspection plan were
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not completed. The licensee has a documented, time phased, program to obtain INPO accreditation of nonlicensed staff training. Completion of review of nonlicensed staff training will be completed during a subsequent inspectio ' No violations or deviations were identifie . Unresolved Items-Unresolved items are matters about which more'information is required in order to' ascertain whether they are acceptable items, violations, or deviations. One unresolved item disclosed during the inspection is discussed in paragraph 2.b.(3). Exit Interview The NRC inspector met with th'e licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on October 4, 198 The-NRC inspector summarized the purpose, scope and findings of the inspection. }}