IR 05000382/1988013

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/88-13. Understands That Development of Nuclear Operations Procedure for Unique Identification Program Expected by 890701

ML20244B375
Person / Time
Site:	Waterford
Issue date:	04/07/1989
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dewease J LOUISIANA POWER & LIGHT CO.
References
NUDOCS 8904190164
Download: ML20244B375 (2)

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.. . APR .71989 In Reply Refer To:-

Docket: 50-382/88-13-l

Louisiana' Power & Light > Company ATTN: J. G. Dewease, Senior Vice . President

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Nuclear Operations l- 317 Baronne' Street New Orleans,' Louisiana :70160 Gentlemen:

Thank' you for your' letter. of December 30, 1988, in response to our lette ~

and Notice of. Violation dated July.18, 1988. We .have. reviewed your. reply and find acceptable your proposed eitension for the completion of the corrective action'. associated with Violation 382/8813-03. We'enderstand that the development of a nuclear operations procedure for unique identification tagging will be completed by July 1, 1989. We will review the implementation of your corrective actions.during'a future inspection to determine that full. compliance

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.has'been achieved and will be maintaine

Sincerely, Onginal Signed By:

L. J. CALLAN L. J. Callan, Director Division of Reactor Projects cc:

Louisiana Power & Light Company ATTN: R. P. Barkhurst, Vice President

_ Nuclear Operations P.O. Box B Killona, Louisiana 70066'

Louisiana Power & Light Company ATTN: N. S. Carns, Plant Manager P.O. Box B Killona, Louisiana 70066

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' Louisiana , Power' &L Light Company -

ATTN: R. F. Burski,1 Manager, Nuclear m . . . _

l Safety, & Regulatory Affairs

%., 317 Baronne. Street b' 'P.O.-Box 60340 '

!C New' Orleans ; Louisiana' 70160

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Louisiana ~ Power'& Light Company L.LW.'.Laughlin, Site-

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- Louidana' Power &; Light Company ATTN: . G. M. Davis, Manager, Events

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._ Analysis Reporting & Response

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P.O.' Box B',' .'~.

-Killona.: Louisiana 70066

' Middle South Services

' ATTN:.L M r.LR. T. Lall P.O. Box.61000'

- New ' Orleans, Louisiana 70161'

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Louisiana Radiation ' Control Program Director bec .to _ DMB (IE01). w/ enclosure

- bec distrib.iby RIV w/ enclosure:- . .

RRI- R. D.' Martin, RA-

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RPB-DRSS MIS System Project Engineer, DRP/A RSTS Operator

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RIV File DRS

'D. Wigginton, NRR Project Manager (MS: 13-D-18) Lisa Shea, RM/ALF J'

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a LOUISI POWE R & ANA LIGHT/ 317BARONNESTREET * P. O. BOX 60340 NEW ORLEANS, LOUISlANA 70160 *

(504)595 3100 N E sys $

December 30, 1988 W3P88-1895 A4.05 QA U.S. Nuclear Regulatory Commission ATTN: Document Control Desk .. ,

Washington, D.C. 20555 MG

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JAN 5 te Subject: Waterford 3 SES ,

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. Docket No. 50-382 - -"

i License No. NPF-38 . _ , .

NRC Inspection Report 88-13, Schedule Change Reference: LP&L Letter No. W3P88-1270 dated August 17, 1988 from R.F. Burski to U.S. Nuclear Regulatory Commission In the Referenced Letter, LP&L submitted the responses to the violations identified in Appendix A of NRC Inspection Report 88-13. Violation 8813-03 was cited for a failure to identify and correct deficiencies with safety system procedures and component identification labeling. As part of the response for that violation, remaining corrective actions included the revision of Operating Procedures OP-100-004, "UNID/EQ Tagging of Plant Components", and OP-100-013. " Writer's Guide For Operating Procedures" by September 30, 1988 and the development of a new plant procedure for unique identification (UNID) tagging scheduled for completion by December 31, 198 The basis for revising OP-100-004 was to specifically address the repeated tagging concerns regarding the improper installation of UNID tags. The basis for revising OP-100-013 was to ensure completeness of lineups in safety systems and to require that valve / breaker lineups be verified with appropriate documentatio Both of these actions which were completed by the scheduled date corrected the programmatic concerns with labelin The basis for developing a new procedure was to have one plant procedure that would cover various aspects of UNID tagging thereby ensuring consistency within the separate procedures that are utilized by various departments. Since August, 1988, when the response was submitted, several decisions have been made which will result in the schedule to be delayed.

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"AN EGUAL OPPORTUNITY EMPLOYER" qJ gy0DL d% ma slL2 m

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.W3P88-1895 1 . .

In September, 1988, en INPO Policy Guidance (INPO 88-009/ Good Practice OP-208) was issued on System and Component Labeling. Based on the information contained in the Policy Guidance, it was decided that the scope of the new procedure may need to be broadened and that the new procedure should be site-wide as opposed to plant-wide (i.e., make the procedure a Nuclear Operations Procedure (N0P) as opposed to a Waterford 3 Administrative Procedure (UNT)).

The responsibility for development of the NOP was then assigned to the Procurement / Programs department of the Nuclear Operations Engineering and Construction (NOE&C) Group, who is currently responsible for controlling the UNID tag database. Due to a reorganization and several personnel changes, a transition plan was developed for the NOE6C Group to establish, organize and prioritize various responsibilities for the departments within the group. Based on this plan, the current schedule for completing the new procedure is July 1, 198 Since the concerns specific to the violation have been corrected by

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revising Procedures OP-100-004 and OP-100-013 and because the original date given for completion of the new procedure was a " scheduled" completion date,: LP&L believes that the justification for the delay is warrante It is important to note that this information was discussed with and concurred by the Waterford 3 Senior Resident Inspector (W. Smith) on Wednesday, December 21, 198 Should you have any questions or comments with this schedule change, please contact T.J. Gaudet at (504) 464-332 Yours very truly,

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R.F. Burski Manager Nuclear Safety & Regulatory Affairs i

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f cc: [R.D.- Martin [ NRC Region IV J.A. Calvo, NRC-NRR D.L. Wigginton, NRC-NRR q NRC Resident Inspectors Office E.L. Blake W.h. Stevenson l

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