ML20154P980: Difference between revisions
StriderTol (talk | contribs) (StriderTol Bot insert) |
StriderTol (talk | contribs) (StriderTol Bot change) |
||
Line 1: | Line 1: | ||
{{Adams | |||
| number = ML20154P980 | |||
| issue date = 09/26/1988 | |||
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/88-13 | |||
| author name = Callan L | |||
| author affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR) | |||
| addressee name = Dewease J | |||
| addressee affiliation = LOUISIANA POWER & LIGHT CO. | |||
| docket = 05000382 | |||
| license number = | |||
| contact person = | |||
| document report number = NUDOCS 8810030259 | |||
| title reference date = 08-17-1988 | |||
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE | |||
| page count = 2 | |||
}} | |||
See also: [[see also::IR 05000382/1988013]] | |||
=Text= | |||
{{#Wiki_filter:, | |||
. '. | |||
. | |||
. | |||
SEP 26 Il2 | |||
In Reply Refer To: | |||
Docket: 50-382/88-13 | |||
Louisiana Power & Light Company | |||
ATTN: J. G. Dewease, Senior Vice President | |||
Nuclear Operations | |||
317 Baronne Street | |||
New Orleans, Louisiana 70160 | |||
Gentlemen: | |||
Thank you for your letter of August 17, 1988, in response to our letter and | |||
Notice of Violation dated July 18, 1988. We have reviewed your reply and find | |||
it responsive to the concerns raised in our Notice of Violation. We will review | |||
the implementation of your corrective actions during a future inspection to | |||
determine that full cortpliance has been achieved and will be maintained. | |||
Sincerely. | |||
Onginal Sgad Sp | |||
l'. J: CALLAN | |||
L. J. Callan, Director | |||
Division of Reactor Projects | |||
cc: | |||
Louisiana Power & Light Iompany | |||
ATTN: G. E. Wuller, Ons ite | |||
Licensing Coordinator | |||
P.O. Box B | |||
Killona, Louisiana 70066 | |||
Louisiana Power & Light Company | |||
ATTH: N. S. Carns, Plant Manager | |||
P.O. Box B | |||
Killona, Louisiana 70066 | |||
Middle South Services | |||
ATTN: Mr. R. T. Lally | |||
P.O. Box 61000 | |||
New Orleans, Louisiana 70161 | |||
c[j | |||
hb | |||
D:PSA 0:DRP['@ | |||
RIV:PSA | |||
ATHowell;d DDChanberlain LJC llan | |||
9/14/88 9/23/88 9 4 /88 [ | |||
' l | |||
esiooaoas, oe0926 | |||
PDR ADOCK 05000302 | |||
O PNU | |||
__ | |||
:. , | |||
' | |||
l ' | |||
* | |||
. | |||
Louisiana Power & Light Company -2- | |||
Louisiana Power & Light Company | |||
ATTN: R. F. Burski, Acting Manager | |||
Nuclear Safety and Regulatory | |||
Affairs | |||
317 Baronne Street | |||
P.O. Box 60340 | |||
New Orleans, Louisiana 70160 | |||
Louisiana Radiation Control Program Director | |||
bectoDMB(IE01) | |||
bec distrib. by RIV: | |||
RRI R. D. Martin, RA | |||
SectionChief(DRP/A) DRP | |||
RPB-DRSS MIS System | |||
Project Engineer, DRP/A RSTS Operator | |||
RIV File D. Wigginton, NRR Project Manager | |||
DRS Lisa Shea, RM/ALF | |||
l | |||
l | |||
l | |||
t | |||
- | |||
_ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ ___ | |||
* . ,, | |||
l/b@MSI M4 tb | |||
~ | |||
' | |||
' | |||
, | |||
E @[E DW/Lif% | |||
AUG l 91983 | |||
LOUISI | |||
POWE R & ANA | |||
LIGH /T 3irsanosses7sest | |||
. p. o. sox so34o | |||
NEW ORLEANS. LOUISIANA 70160 * (504) 595-31M | |||
h | |||
N30!?sM | |||
August 17, 1988 W3P88-1270 | |||
A4.05 | |||
QA | |||
U.S. Nuclear Regulatory Comission | |||
ATTN: Document Control Desk | |||
Washington, D.C. 20555 | |||
Subj ect: Waterford 3 SES | |||
Docket No. 50-382 | |||
License No. NPF-38 | |||
NRC Inspection Report 88-13 | |||
In accordance with 10CFR Part 2.201, Louisiana Power & Light hereby submits | |||
in Attachment I the responses to the Violations identified in Appendix A of | |||
the subject Inspection Report. | |||
If you have any questions concerning these responses, please contact | |||
L.W. Laughlin, Site Licensing Support, at (504) 464-3499. | |||
Very truly yours, | |||
yd | |||
R.F. ski | |||
Manager | |||
Nuclear Safety & Regulatory Affairs | |||
RFB:TJG:ssf | |||
Attachment | |||
ec: * 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 | |||
n o kon d K t 1 L | |||
=9 v qu u' I Q) '-- I ~+- | |||
bO0 | |||
VW | |||
"AN EQUAL OPPORTUNITY EMPLOYER" | |||
sceSE V3% | |||
_ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ | |||
'* . | |||
,, | |||
. | |||
. | |||
. | |||
Attachment to | |||
. | |||
W3P88-1270 | |||
Page 1 of 7 | |||
ATTACHMENT 1 | |||
LP&L Responses to Violations Identified in Appendix A | |||
of Inspection Report 88-13 | |||
A. VIOLATION NO. 8813-01 | |||
Inadequate Maintenance Work Instructions | |||
Technical Specification 6.8.1.a requires written procedures to be esta- | |||
blished, implemented, and maintained covering the applicable procedures | |||
recommended in Appendix A of Regulatory Guide 1.33, Revision 2. February | |||
1978. | |||
Regulatory Guide 1.33 requires procedures appropriate to the circums'tances | |||
for performing maintenance on safety-related equipment. | |||
Procedure UNT-7-005, Revision 2 "Cleanliness Control," is an approved | |||
procedure that requires cleanliness control requirements to be established | |||
when opening emergency diesel generator air systems. | |||
Contrary to the above, on May 11, 1988, control air valves were manipu- | |||
lated, the starter system disconnected, and the start air system actuated | |||
using work instructions that were not appropriate in that they did not | |||
include these tasks and they did not require the implementation of clean- | |||
linese controls. | |||
This is a Severity Level IV violation. | |||
RESPONSE | |||
LP&L acknowledges that this incident was a Violation of the guidelines | |||
of Regulatory Guide 1.33 in that the work instructions for replacing | |||
control air interface check valve EGA-421B were not detailed enough | |||
relative to the circumstances. | |||
(1) Reason For The Violation | |||
The requirements for dispositioning a condition as "Troubleshoot" | |||
when the failure mechanism or the reason for a degraded condition | |||
cannot be detected easily are provided in Plant Operations Admini- | |||
strative Procedure UNT-05-015. "Work Authorization Preparation and | |||
Implementation". Since specific guidance for determining where to | |||
differentiate between troubleshooting and rework is not provided in | |||
the procedure, a conscientious decision has to be made by maintenance | |||
personnel when in the field performing routine maintenance under a | |||
specific work authorization. Because troubleshooting involves a | |||
logical sequence of events which is determined by the outcome of a | |||
NS90035D | |||
,_ _ _ _ _ _ . | |||
* | |||
- | |||
., | |||
.. . | |||
. | |||
. | |||
Attachment to | |||
W3P88-1270 | |||
Page 2 of 7 | |||
previous step or action, specific troubleshooting instructions are | |||
difficult to write in the planning process. In this incident, the | |||
extent of work after valve replacement was not known or defined at , | |||
the time, so a statement to troubleshoot was included on the work | |||
authorization in accordance with UNT-05-015. | |||
The responsibilities and criteria for cleaning fluid systems and | |||
associated components are provided in Plant Administrative Procedure | |||
UNT-07-005, "Cleanliness Control". This procedure, which is based on | |||
the guidance provided in Regulatory Guide 1.37 (Quality Assurance | |||
Requirements for Cleaning of Fluid Systems and Associated Components | |||
of Water-Cooled Nuclear Power Plants) and ANSI N45.2.1-1973 (Cleaning | |||
of Fluid Systems and Associated Components for Nuclear Power Plants) | |||
is written primarily to address fluid systems. Although the diesel | |||
generator air system is listed as a Class "C" cleanliness system in | |||
the attachment of UNT-07-005, the procedure does not realistically | |||
address maintaining cleanliness in such an instrument and control | |||
system. The inspection criteria detailed in the procedure are not | |||
adequate for an instrument systems of such a small size Therefore, | |||
maintenance personnel had the impression that the procedure did | |||
not apply, as was the case cited in this inspection. | |||
(2) Corrective Actions That Have Been Taken | |||
Since the occurrence of this incident, a Maintenance Directive (No. | |||
28) entitled, "Troubleshooting" was developed to provide guidance on | |||
writing troubleshoot instructions and establishing limitations on | |||
what can and cannot be done in the field on work authoritations | |||
dispositioned as "Troubleshoot". The directive instructs Maintenance | |||
personnel to contact their supervisor for clarification if it becomes | |||
questionable as to whether or not a certain activity is allowed under | |||
troubleshoot authority. The directive also points out that trouble- | |||
shooting does not allow deviation from procedural requirements and | |||
that complete and accurate documentation of all steps and actions | |||
taken as well as observations noted is imperative. | |||
With regard to cleanliness control during maintenance on instrument | |||
and control tubing and air lines, Instrument and Control Planners | |||
have been trained and instructed to include Cleanliness Control Forms | |||
(Attachment 6.1 of UNT-07-005) into the work authorization packages | |||
whenever breaking a system boundary. | |||
(3) Corrective Actions To Be Taken | |||
UNT-07-005 will be revised to include responsibilities for establi- ' | |||
shing and maintaining adequate cleanliness controls when performing | |||
maintenance activities on instrument and control tubing. | |||
Although not specifically part of the corrective actions for this | |||
violation, it is worthwhile to note that beginning in September, | |||
NS90035D | |||
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . __ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - ______________ | |||
. | |||
.. . | |||
. | |||
Attachment to | |||
W3P88-1270 | |||
Page 3 of 7 | |||
1988, a pilot program entitled "Operation ZERO Deviations" will | |||
be implemented at Waterford 3 in the areas of Operations, Mainte- | |||
nance, Security, Heslth Physics and Chemistry. The intent of this | |||
program is to emphasize procedure and work instruction compliance and | |||
to instill in employees the importance of stopping work when neces- | |||
sary as opposed to deviating from a procedure or instruction. This | |||
program emphasizes management concern and efforts toward reducing | |||
unauthorized procedure and work instruction deficiencies. | |||
(4) Date When Full Compliance Will Be Achieved | |||
UNT-07-005 will be revised by September 30, 1988. | |||
B. VIOLATION 8813-02 | |||
Failure To Implement Quality Assurance Procedures | |||
Criterion II of Appendix B to 10 CFR Part 50 states, in part, that a | |||
quality assurance program shall be documented in procedures and carried | |||
out in accordance with those procedures. | |||
Quality Assurance Program Procedure QAP-012, Revision 6, "Corrective | |||
Action," requires initiation of a Quality Notice when conditions adverse | |||
to quality are identified. | |||
Contrary to the above, Quality Assurance Inspection Report 88-012, dated | |||
April 21, 1988, noted that several wires of hydrogen analyzer "A" had been | |||
landed at the wrong terminal points and accepted by quality assurance | |||
inspectors during the replacement of the hydrogen analyzer. No Quality | |||
Notice had been initiated on this condition which is adverse to quality as | |||
of June 15, 1988, when the NRC inspector reviewed the work documentation. | |||
This is a Severity Level IV violation. | |||
RESPONSE | |||
LP&L acknowledges that this incident was a violation of criterion II | |||
of Appendix B to 10CFR50 in that a Quality Notice (QN) should have been | |||
issued in accordance with Quality Assurance Procedure QAP-012. "Corrective | |||
Action" since a condition adverse to quality (incorrect wire terminations | |||
that damaged equipment) existed. | |||
(1) Reason For The Violation | |||
Prior to April 20, 1988, terminations were made and verified by | |||
QA Inspection to the Hydrogen Analyzer Sequencer Module. On April | |||
20, 1988, during the performance of functional testing, damage to a | |||
NS90035D | |||
- _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ | |||
. . | |||
, | |||
.. . | |||
. | |||
Attachment to | |||
W3P88-1270 | |||
Page 4 of 7 | |||
transistor on a different module occurred. Upon troubleshooting, an | |||
I&C technician found wires on the Hydrogen Analyzer Sequencer Module | |||
to be incorrectly terminated. Subsequently, on April 21, 1988, the | |||
following sequence of events took place: the work instructions were | |||
revised to correctly terminate the Sequencer Module, the work was | |||
completed per the revised work instructions and Quality Assurance | |||
verified the rework and reterminations. | |||
On April 22, 1988, the QA inspector learned from a cognizant member | |||
of the Nuclear Operations Engineering Department that a design | |||
construction package change (DCPC) was going to be issued to address | |||
the wiring error. Based on the premise that the work instruction was | |||
revised, the errors were corrected, a DCPC was to be issued and the | |||
overall concerns were documented in Inspection / Observation Report | |||
88-012,'which was dated April 21, 1988 but signed off by the inspec- | |||
tor on April 22, 1988, the inspector believed that no further a'tions e | |||
were warranted. Consequently, a QN was not issued by Quality | |||
Assurance. | |||
(2) Corrective Actions That Have Been Taken | |||
Two QNs were issued on June 17, 1988 to document the errors made | |||
during the implementation of SH 983. QN QA-88-075 was issued to | |||
Operations QA for the inspection error and QN QA-88-080 was issued to | |||
Nuclear Operations Engineering and Construction for the incorrect | |||
wiring of the hydrogen analyzers. Corrective action taken by QA has | |||
resulted in an emphasis by the Quality Inspection organization on | |||
attention to detail involving inspections. | |||
A training session on attention to details was presented to inspec- | |||
tors on August 8, 1988. Inspectors were cautioned as to the | |||
importance of recognizing, reviewing and understanding the inspection | |||
requirements imposed on the work document. Inspectors were also | |||
reminded to complete all the necessary steps when performing an | |||
inspection. In addition, the ese of inspection observation reports | |||
has been discontinued as a means of problem identification. | |||
(3) Corrective Actions To Be_Taken , | |||
1 | |||
Quality Assurance personnel will undergo lessons Learned Training. | |||
Emphasis will be placed on the importance of paying attention to | |||
detail and utilizing the corrective action systems that are currently | |||
in place. | |||
(4) Date When Full Compliance Will Be Achieved | |||
Lessons Learned Training will be completed by September 30, 1988. | |||
NS90035D | |||
.- .- - -_ . - - . _- . | |||
* | |||
. . . , | |||
. | |||
. . | |||
. | |||
* | |||
Attachment to | |||
W3P88-1270 l | |||
: Page 5 of 7 | |||
~ | |||
C. VIOLATION 8813-03 | |||
Failure To Identify And Correct Deficiencies | |||
l | |||
Criterion XVI of Appendix B to 10 CFR Part 50 states, in part, that | |||
measures shall be established to assure that conditions adverse to i | |||
quality, such as deficiencies, are promptly identified and corrected, | |||
and that the causes be determined and corrective action taken to l | |||
preclude repetition. , | |||
i | |||
Contrary to the above, NRC inspectors identified deficiencies in l | |||
safety system operating procedures and/or component identification l | |||
labeling during ten inspections performed from February 1, 1986, | |||
through May 31, 1988. Again, on June 7, 1988, the NRC inspector ! | |||
identified procedural and component identification labeling ! | |||
deficiencies with the hydrogen analyzer system. Licensee management' l | |||
has failed to establish adequate measures to independently identify, i | |||
correct, and preclude repeated deficiencies with safety system ! | |||
procedures and component identification labeling. l | |||
This is a Severity Level IV violation. | |||
RESPONSE | |||
LP&L acknowledges that this incident was a violation of Criterion XVI ! | |||
of 10CTR Part 50, Appendix B in that adequate corrective actions have | |||
not been taken to preclude repeated deficiencies with safety system ( | |||
procedures and component identification labeling. l | |||
r | |||
(1) Reason For The Violation j | |||
Plant Administrative Procedure OP-100-004, "UNID/EQ Tagging of | |||
Plant Components", delineates the method for replacement of i | |||
Unique Identification (UNID)/ Environmentally Qualified (EQ) ! | |||
equipment tags and also provides the administrative requirements : | |||
for installation of new UNID/EQ tags. UNID tags which are hung I | |||
as part of a design change are the responsibility of the , | |||
department or group that implements the change. Since there are , | |||
no requirements to verify that tags are hung correctly or to use l | |||
controlled drawings for ensuring proper placement of tags, j | |||
inconsistencies in the hanging of UNID tags have resulted. ! | |||
(NOTE: The failure to implement the above requirements has ! | |||
resulted in the incorrect hanging of various tags on the Hydrogen L | |||
Analyzer as was stipulated in this inspection report.) | |||
! | |||
! | |||
! | |||
t | |||
I | |||
, | |||
NS90035D f | |||
, | |||
_--! | |||
_ _ _ _ _ _ _ _ _ _ _ _ _ . | |||
* . . . , | |||
, | |||
.. . | |||
. | |||
Attachment to | |||
W3P88-1270 | |||
Page 6 of 7 | |||
Additionally, for components which are identified as not having | |||
UNID numbers, the method in place for assigning a UNID to a compo- | |||
nent, ensuring the UNID tag is hung properly and notifying the | |||
cognizant work groups of this type of situation is not sufficiently | |||
integrated to ensure the elimination of the type of problem described | |||
in the violation. The current approach for addressing these items, | |||
which involves the use of several procedures by several different | |||
groups, has proven to be unreliable. This condition coupled with the | |||
lack of a formal program to identify, correct and preclude deficien- | |||
cies with safety system procedures and component identification | |||
labeling is the basis for the violation. | |||
(2) Corrective Actions That Have Been Taken | |||
In early 1988, the responsibility for trending was transferred from | |||
the QA department to the Event Analysis, Reporting and Response' | |||
(EAR &R) organization, which reports directly to the Plant Manager. | |||
In May,1988, using the QA Trending Program as a baseline, the EAR &R | |||
organization established the Nuclear Operations Trending Program. | |||
This program, which broadens the scope of that which was previously | |||
trended, provides a method for collecting, correlating and analyzing | |||
j corrective action reports in efforts to identify potentially signifi- | |||
cant trands. The Program is utilized for the review and analysis of | |||
Licensee Event Reports (LERs), KRC Reports Quality Notices, Noncon- | |||
forming Condition Identifications, Discrepancy Notices and other | |||
reports which identify incidents or occurrences to determine apparent | |||
and/or root cause. | |||
Plant Administrative Procedure UNT-6-014. "Root Cause Determination | |||
and Trending", was approved in August, 1988. The specific purposes | |||
of this procedure are to establish the requirements for the evalu- | |||
ation and investigation of an event or condition for root cause | |||
determination and to provide a method for the categorization of root | |||
causes and their trending criteria. An adverse trend will be identi- | |||
fled for recurring deficiencies. By the use of an Adverse Trend | |||
Report, an adverse trend, which will include a summary of the defi- | |||
, | |||
ciency, root causes and any recommendations, will be submitted to the | |||
' | |||
appropriate Department Head, Group Head and Assistant Plant Manager. | |||
The Department Head, with approval by the Assistant Plant Manager, | |||
will be responsible for determining the necessary corrective actions. | |||
After completion of the corrective actions, the item will be trans- | |||
mitted to EAR &R for closure. Implementation of this procedure will | |||
provide a significant enhancement to the existing trending program. | |||
P | |||
) | |||
i | |||
1 | |||
, | |||
NS90035D | |||
. _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ | |||
* =. , | |||
, | |||
.= '% . | |||
. | |||
. | |||
Attachment to | |||
W3P88-1270 | |||
Page 7 of 7 | |||
(3) Corrective /etions To Be Taken | |||
OP-100-004 is being revised to specifically address the repeated | |||
tagging concerns regarding improper installation of UNID tags. | |||
To alleviate inconsistencies that currently exist on two forms, | |||
the forms vill be consolidated into one. This form, the UNID Tag | |||
Replacement Form, will be used to tequest, hang and verify proper | |||
placement of UNID tags. This procedure will also be revised to | |||
require an individual, when hanging or verifying a UNID tag, to | |||
refer to the primary source document for ensuring that the tag is | |||
correctly placed. A procedural requirement will be implemented | |||
to ensure that labeling and/or tagging deficiencies found during | |||
lineups will be appropriately documented so that the necessary | |||
corrective actions will be performed. To ensure that separate | |||
procedures are not utilized by various departments, a Plant | |||
procedure will be developed to cover all aspects of UNID taggirg. | |||
Additionally, to ensure completeness of lineups in safety | |||
systems, the existing Procedure Review Checklist in | |||
Administrative Procedure OP-100-013, "Writer's Guide For - | |||
Operating Procedures", will be revised to require that | |||
valve / breaker lineups be verified with appropriate documentation. | |||
Implementation of these actions coupled with the performance of | |||
ongoing detailed system walkdowns in accordance with Administrative | |||
Procedure OP-10-001, "Duties and Responsibilities of Operators on | |||
Duty", will provide assurance that the procedures for safety related | |||
systems reflect the actual plant configuration to the maximum extent | |||
possible. | |||
The above actions will address the present violation. However, to | |||
provide additional assurance that repeated deficiencies with safety | |||
system procedures and component identification labeling are mini- | |||
mized, Management has set an objective, which is scheduled for | |||
completien by December 31, 1989, to have applicable system engineers | |||
perform walkdowns of the accessible portions of safety systems using | |||
design documentation. | |||
(4) Date When Full Compliance Will Be Achieved | |||
Procedures OP-100-004 and OP-100-013 vill be revised by | |||
September 30, 1988. | |||
Development of the new procedure for UNID tagging is scheduled | |||
for completion by 0, a mber 31, 1988. | |||
l | |||
NS90035D | |||
, | |||
}} |
Latest revision as of 21:33, 10 April 2022
ML20154P980 | |
Person / Time | |
---|---|
Site: | Waterford |
Issue date: | 09/26/1988 |
From: | Callan L Office of Nuclear Reactor Regulation |
To: | Dewease J LOUISIANA POWER & LIGHT CO. |
References | |
NUDOCS 8810030259 | |
Download: ML20154P980 (2) | |
See also: IR 05000382/1988013
Text
,
. '.
.
.
SEP 26 Il2
In Reply Refer To:
Docket: 50-382/88-13
Louisiana Power & Light Company
ATTN: J. G. Dewease, Senior Vice President
Nuclear Operations
317 Baronne Street
New Orleans, Louisiana 70160
Gentlemen:
Thank you for your letter of August 17, 1988, in response to our letter and
Notice of Violation dated July 18, 1988. We have reviewed your reply and find
it responsive to the concerns raised in our Notice of Violation. We will review
the implementation of your corrective actions during a future inspection to
determine that full cortpliance has been achieved and will be maintained.
Sincerely.
Onginal Sgad Sp
l'. J: CALLAN
L. J. Callan, Director
Division of Reactor Projects
cc:
Louisiana Power & Light Iompany
ATTN: G. E. Wuller, Ons ite
Licensing Coordinator
P.O. Box B
Killona, Louisiana 70066
Louisiana Power & Light Company
ATTH: N. S. Carns, Plant Manager
P.O. Box B
Killona, Louisiana 70066
Middle South Services
ATTN: Mr. R. T. Lally
P.O. Box 61000
New Orleans, Louisiana 70161
c[j
hb
D:PSA 0:DRP['@
RIV:PSA
ATHowell;d DDChanberlain LJC llan
9/14/88 9/23/88 9 4 /88 [
' l
esiooaoas, oe0926
PDR ADOCK 05000302
O PNU
__
- . ,
'
l '
.
Louisiana Power & Light Company -2-
Louisiana Power & Light Company
ATTN: R. F. Burski, Acting Manager
Nuclear Safety and Regulatory
Affairs
317 Baronne Street
P.O. Box 60340
New Orleans, Louisiana 70160
Louisiana Radiation Control Program Director
bectoDMB(IE01)
bec distrib. by RIV:
RRI R. D. Martin, RA
SectionChief(DRP/A) DRP
RPB-DRSS MIS System
Project Engineer, DRP/A RSTS Operator
RIV File D. Wigginton, NRR Project Manager
DRS Lisa Shea, RM/ALF
l
l
l
t
-
_ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ ___
- . ,,
l/b@MSI M4 tb
~
'
'
,
E @[E DW/Lif%
AUG l 91983
LOUISI
POWE R & ANA
LIGH /T 3irsanosses7sest
. p. o. sox so34o
NEW ORLEANS. LOUISIANA 70160 * (504) 595-31M
h
N30!?sM
August 17, 1988 W3P88-1270
A4.05
U.S. Nuclear Regulatory Comission
ATTN: Document Control Desk
Washington, D.C. 20555
Subj ect: Waterford 3 SES
Docket No. 50-382
License No. NPF-38
NRC Inspection Report 88-13
In accordance with 10CFR Part 2.201, Louisiana Power & Light hereby submits
in Attachment I the responses to the Violations identified in Appendix A of
the subject Inspection Report.
If you have any questions concerning these responses, please contact
L.W. Laughlin, Site Licensing Support, at (504) 464-3499.
Very truly yours,
yd
R.F. ski
Manager
Nuclear Safety & Regulatory Affairs
RFB:TJG:ssf
Attachment
ec: * 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
n o kon d K t 1 L
=9 v qu u' I Q) '-- I ~+-
bO0
VW
"AN EQUAL OPPORTUNITY EMPLOYER"
sceSE V3%
_ _ _ _ - _ _ _ _ _ _ _ _ _ _ _
'* .
,,
.
.
.
Attachment to
.
Page 1 of 7
ATTACHMENT 1
LP&L Responses to Violations Identified in Appendix A
of Inspection Report 88-13
A. VIOLATION NO. 8813-01
Inadequate Maintenance Work Instructions
Technical Specification 6.8.1.a requires written procedures to be esta-
blished, implemented, and maintained covering the applicable procedures
recommended in Appendix A of Regulatory Guide 1.33, Revision 2. February
1978.
Regulatory Guide 1.33 requires procedures appropriate to the circums'tances
for performing maintenance on safety-related equipment.
Procedure UNT-7-005, Revision 2 "Cleanliness Control," is an approved
procedure that requires cleanliness control requirements to be established
when opening emergency diesel generator air systems.
Contrary to the above, on May 11, 1988, control air valves were manipu-
lated, the starter system disconnected, and the start air system actuated
using work instructions that were not appropriate in that they did not
include these tasks and they did not require the implementation of clean-
linese controls.
This is a Severity Level IV violation.
RESPONSE
LP&L acknowledges that this incident was a Violation of the guidelines
of Regulatory Guide 1.33 in that the work instructions for replacing
control air interface check valve EGA-421B were not detailed enough
relative to the circumstances.
(1) Reason For The Violation
The requirements for dispositioning a condition as "Troubleshoot"
when the failure mechanism or the reason for a degraded condition
cannot be detected easily are provided in Plant Operations Admini-
strative Procedure UNT-05-015. "Work Authorization Preparation and
Implementation". Since specific guidance for determining where to
differentiate between troubleshooting and rework is not provided in
the procedure, a conscientious decision has to be made by maintenance
personnel when in the field performing routine maintenance under a
specific work authorization. Because troubleshooting involves a
logical sequence of events which is determined by the outcome of a
NS90035D
,_ _ _ _ _ _ .
-
.,
.. .
.
.
Attachment to
Page 2 of 7
previous step or action, specific troubleshooting instructions are
difficult to write in the planning process. In this incident, the
extent of work after valve replacement was not known or defined at ,
the time, so a statement to troubleshoot was included on the work
authorization in accordance with UNT-05-015.
The responsibilities and criteria for cleaning fluid systems and
associated components are provided in Plant Administrative Procedure
UNT-07-005, "Cleanliness Control". This procedure, which is based on
the guidance provided in Regulatory Guide 1.37 (Quality Assurance
Requirements for Cleaning of Fluid Systems and Associated Components
of Water-Cooled Nuclear Power Plants) and ANSI N45.2.1-1973 (Cleaning
of Fluid Systems and Associated Components for Nuclear Power Plants)
is written primarily to address fluid systems. Although the diesel
generator air system is listed as a Class "C" cleanliness system in
the attachment of UNT-07-005, the procedure does not realistically
address maintaining cleanliness in such an instrument and control
system. The inspection criteria detailed in the procedure are not
adequate for an instrument systems of such a small size Therefore,
maintenance personnel had the impression that the procedure did
not apply, as was the case cited in this inspection.
(2) Corrective Actions That Have Been Taken
Since the occurrence of this incident, a Maintenance Directive (No.
28) entitled, "Troubleshooting" was developed to provide guidance on
writing troubleshoot instructions and establishing limitations on
what can and cannot be done in the field on work authoritations
dispositioned as "Troubleshoot". The directive instructs Maintenance
personnel to contact their supervisor for clarification if it becomes
questionable as to whether or not a certain activity is allowed under
troubleshoot authority. The directive also points out that trouble-
shooting does not allow deviation from procedural requirements and
that complete and accurate documentation of all steps and actions
taken as well as observations noted is imperative.
With regard to cleanliness control during maintenance on instrument
and control tubing and air lines, Instrument and Control Planners
have been trained and instructed to include Cleanliness Control Forms
(Attachment 6.1 of UNT-07-005) into the work authorization packages
whenever breaking a system boundary.
(3) Corrective Actions To Be Taken
UNT-07-005 will be revised to include responsibilities for establi- '
shing and maintaining adequate cleanliness controls when performing
maintenance activities on instrument and control tubing.
Although not specifically part of the corrective actions for this
violation, it is worthwhile to note that beginning in September,
NS90035D
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . __ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - ______________
.
.. .
.
Attachment to
Page 3 of 7
1988, a pilot program entitled "Operation ZERO Deviations" will
be implemented at Waterford 3 in the areas of Operations, Mainte-
nance, Security, Heslth Physics and Chemistry. The intent of this
program is to emphasize procedure and work instruction compliance and
to instill in employees the importance of stopping work when neces-
sary as opposed to deviating from a procedure or instruction. This
program emphasizes management concern and efforts toward reducing
unauthorized procedure and work instruction deficiencies.
(4) Date When Full Compliance Will Be Achieved
UNT-07-005 will be revised by September 30, 1988.
B. VIOLATION 8813-02
Failure To Implement Quality Assurance Procedures
Criterion II of Appendix B to 10 CFR Part 50 states, in part, that a
quality assurance program shall be documented in procedures and carried
out in accordance with those procedures.
Quality Assurance Program Procedure QAP-012, Revision 6, "Corrective
Action," requires initiation of a Quality Notice when conditions adverse
to quality are identified.
Contrary to the above, Quality Assurance Inspection Report 88-012, dated
April 21, 1988, noted that several wires of hydrogen analyzer "A" had been
landed at the wrong terminal points and accepted by quality assurance
inspectors during the replacement of the hydrogen analyzer. No Quality
Notice had been initiated on this condition which is adverse to quality as
of June 15, 1988, when the NRC inspector reviewed the work documentation.
This is a Severity Level IV violation.
RESPONSE
LP&L acknowledges that this incident was a violation of criterion II
of Appendix B to 10CFR50 in that a Quality Notice (QN) should have been
issued in accordance with Quality Assurance Procedure QAP-012. "Corrective
Action" since a condition adverse to quality (incorrect wire terminations
that damaged equipment) existed.
(1) Reason For The Violation
Prior to April 20, 1988, terminations were made and verified by
QA Inspection to the Hydrogen Analyzer Sequencer Module. On April
20, 1988, during the performance of functional testing, damage to a
NS90035D
- _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. .
,
.. .
.
Attachment to
Page 4 of 7
transistor on a different module occurred. Upon troubleshooting, an
I&C technician found wires on the Hydrogen Analyzer Sequencer Module
to be incorrectly terminated. Subsequently, on April 21, 1988, the
following sequence of events took place: the work instructions were
revised to correctly terminate the Sequencer Module, the work was
completed per the revised work instructions and Quality Assurance
verified the rework and reterminations.
On April 22, 1988, the QA inspector learned from a cognizant member
of the Nuclear Operations Engineering Department that a design
construction package change (DCPC) was going to be issued to address
the wiring error. Based on the premise that the work instruction was
revised, the errors were corrected, a DCPC was to be issued and the
overall concerns were documented in Inspection / Observation Report
88-012,'which was dated April 21, 1988 but signed off by the inspec-
tor on April 22, 1988, the inspector believed that no further a'tions e
were warranted. Consequently, a QN was not issued by Quality
Assurance.
(2) Corrective Actions That Have Been Taken
Two QNs were issued on June 17, 1988 to document the errors made
during the implementation of SH 983. QN QA-88-075 was issued to
Operations QA for the inspection error and QN QA-88-080 was issued to
Nuclear Operations Engineering and Construction for the incorrect
wiring of the hydrogen analyzers. Corrective action taken by QA has
resulted in an emphasis by the Quality Inspection organization on
attention to detail involving inspections.
A training session on attention to details was presented to inspec-
tors on August 8, 1988. Inspectors were cautioned as to the
importance of recognizing, reviewing and understanding the inspection
requirements imposed on the work document. Inspectors were also
reminded to complete all the necessary steps when performing an
inspection. In addition, the ese of inspection observation reports
has been discontinued as a means of problem identification.
(3) Corrective Actions To Be_Taken ,
1
Quality Assurance personnel will undergo lessons Learned Training.
Emphasis will be placed on the importance of paying attention to
detail and utilizing the corrective action systems that are currently
in place.
(4) Date When Full Compliance Will Be Achieved
Lessons Learned Training will be completed by September 30, 1988.
NS90035D
.- .- - -_ . - - . _- .
. . . ,
.
. .
.
Attachment to
- Page 5 of 7
~
C. VIOLATION 8813-03
Failure To Identify And Correct Deficiencies
l
Criterion XVI of Appendix B to 10 CFR Part 50 states, in part, that
measures shall be established to assure that conditions adverse to i
quality, such as deficiencies, are promptly identified and corrected,
and that the causes be determined and corrective action taken to l
preclude repetition. ,
i
Contrary to the above, NRC inspectors identified deficiencies in l
safety system operating procedures and/or component identification l
labeling during ten inspections performed from February 1, 1986,
through May 31, 1988. Again, on June 7, 1988, the NRC inspector !
identified procedural and component identification labeling !
deficiencies with the hydrogen analyzer system. Licensee management' l
has failed to establish adequate measures to independently identify, i
correct, and preclude repeated deficiencies with safety system !
procedures and component identification labeling. l
This is a Severity Level IV violation.
RESPONSE
LP&L acknowledges that this incident was a violation of Criterion XVI !
of 10CTR Part 50, Appendix B in that adequate corrective actions have
not been taken to preclude repeated deficiencies with safety system (
procedures and component identification labeling. l
r
(1) Reason For The Violation j
Plant Administrative Procedure OP-100-004, "UNID/EQ Tagging of
Plant Components", delineates the method for replacement of i
Unique Identification (UNID)/ Environmentally Qualified (EQ) !
equipment tags and also provides the administrative requirements :
for installation of new UNID/EQ tags. UNID tags which are hung I
as part of a design change are the responsibility of the ,
department or group that implements the change. Since there are ,
no requirements to verify that tags are hung correctly or to use l
controlled drawings for ensuring proper placement of tags, j
inconsistencies in the hanging of UNID tags have resulted. !
(NOTE: The failure to implement the above requirements has !
resulted in the incorrect hanging of various tags on the Hydrogen L
Analyzer as was stipulated in this inspection report.)
!
!
!
t
I
,
NS90035D f
,
_--!
_ _ _ _ _ _ _ _ _ _ _ _ _ .
- . . . ,
,
.. .
.
Attachment to
Page 6 of 7
Additionally, for components which are identified as not having
UNID numbers, the method in place for assigning a UNID to a compo-
nent, ensuring the UNID tag is hung properly and notifying the
cognizant work groups of this type of situation is not sufficiently
integrated to ensure the elimination of the type of problem described
in the violation. The current approach for addressing these items,
which involves the use of several procedures by several different
groups, has proven to be unreliable. This condition coupled with the
lack of a formal program to identify, correct and preclude deficien-
cies with safety system procedures and component identification
labeling is the basis for the violation.
(2) Corrective Actions That Have Been Taken
In early 1988, the responsibility for trending was transferred from
the QA department to the Event Analysis, Reporting and Response'
(EAR &R) organization, which reports directly to the Plant Manager.
In May,1988, using the QA Trending Program as a baseline, the EAR &R
organization established the Nuclear Operations Trending Program.
This program, which broadens the scope of that which was previously
trended, provides a method for collecting, correlating and analyzing
j corrective action reports in efforts to identify potentially signifi-
cant trands. The Program is utilized for the review and analysis of
Licensee Event Reports (LERs), KRC Reports Quality Notices, Noncon-
forming Condition Identifications, Discrepancy Notices and other
reports which identify incidents or occurrences to determine apparent
and/or root cause.
Plant Administrative Procedure UNT-6-014. "Root Cause Determination
and Trending", was approved in August, 1988. The specific purposes
of this procedure are to establish the requirements for the evalu-
ation and investigation of an event or condition for root cause
determination and to provide a method for the categorization of root
causes and their trending criteria. An adverse trend will be identi-
fled for recurring deficiencies. By the use of an Adverse Trend
Report, an adverse trend, which will include a summary of the defi-
,
ciency, root causes and any recommendations, will be submitted to the
'
appropriate Department Head, Group Head and Assistant Plant Manager.
The Department Head, with approval by the Assistant Plant Manager,
will be responsible for determining the necessary corrective actions.
After completion of the corrective actions, the item will be trans-
mitted to EAR &R for closure. Implementation of this procedure will
provide a significant enhancement to the existing trending program.
P
)
i
1
,
NS90035D
. _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _
- =. ,
,
.= '% .
.
.
Attachment to
Page 7 of 7
(3) Corrective /etions To Be Taken
OP-100-004 is being revised to specifically address the repeated
tagging concerns regarding improper installation of UNID tags.
To alleviate inconsistencies that currently exist on two forms,
the forms vill be consolidated into one. This form, the UNID Tag
Replacement Form, will be used to tequest, hang and verify proper
placement of UNID tags. This procedure will also be revised to
require an individual, when hanging or verifying a UNID tag, to
refer to the primary source document for ensuring that the tag is
correctly placed. A procedural requirement will be implemented
to ensure that labeling and/or tagging deficiencies found during
lineups will be appropriately documented so that the necessary
corrective actions will be performed. To ensure that separate
procedures are not utilized by various departments, a Plant
procedure will be developed to cover all aspects of UNID taggirg.
Additionally, to ensure completeness of lineups in safety
systems, the existing Procedure Review Checklist in
Administrative Procedure OP-100-013, "Writer's Guide For -
Operating Procedures", will be revised to require that
valve / breaker lineups be verified with appropriate documentation.
Implementation of these actions coupled with the performance of
ongoing detailed system walkdowns in accordance with Administrative
Procedure OP-10-001, "Duties and Responsibilities of Operators on
Duty", will provide assurance that the procedures for safety related
systems reflect the actual plant configuration to the maximum extent
possible.
The above actions will address the present violation. However, to
provide additional assurance that repeated deficiencies with safety
system procedures and component identification labeling are mini-
mized, Management has set an objective, which is scheduled for
completien by December 31, 1989, to have applicable system engineers
perform walkdowns of the accessible portions of safety systems using
design documentation.
(4) Date When Full Compliance Will Be Achieved
Procedures OP-100-004 and OP-100-013 vill be revised by
September 30, 1988.
Development of the new procedure for UNID tagging is scheduled
for completion by 0, a mber 31, 1988.
l
NS90035D
,