IR 05000382/1988013: Difference between revisions

From kanterella
Jump to navigation Jump to search
(StriderTol Bot insert)
 
(StriderTol Bot change)
Line 1: Line 1:
{{Adams
{{Adams
| number = ML20154P980
| number = ML20244B375
| issue date = 09/26/1988
| issue date = 04/07/1989
| title = Ack Receipt of 880817 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/88-13
| title = Ack Receipt of 881230 Ltr 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
| author name = Callan L
| author name = Callan L
| author affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| addressee name = Dewease J
| addressee name = Dewease J
| addressee affiliation = LOUISIANA POWER & LIGHT CO.
| addressee affiliation = LOUISIANA POWER & LIGHT CO.
Line 10: Line 10:
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = NUDOCS 8810030259
| document report number = NUDOCS 8904190164
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| page count = 2
| page count = 2
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:,
{{#Wiki_filter:. _ _ _ _
  . '.
  ; '
  .
s 6m 49 .
  .
  '
SEP 26 Il2 In Reply Refer To:
  ..    . APR .71989 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:
  : Docket: 50-382/88-13-l
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 maintaine Sincerel 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['@
Louisiana' Power & Light > Company ATTN: J. G. Dewease, Senior Vice . President
RIV:PSA ATHowell;d DDChanberlain LJC llan 9/14/88 9/23/88 9 4 /88  [
!
      ' l esiooaoas, oe0926 PDR ADOCK 05000302 O PNU
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
.
  .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
    '
RIV:DRP/A 8  C:DRP/AA D: P dd ATHowell;df  DDChamberla n LJCallan 4 y /89  4/7/89 4/q/89 7


__
l 8904190164 890407 PDR ADOCK 05000302
:.        ,
      /' >
'
f G PDC
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
      ,      _ ._ ___ _.____ ____
       ~
_
            '
    ;
  '
,
R  ,
      ,
  '
      '
      '
       '
' };. ,  ,
  *
. '?
  . :
  .
    '
f  ' Louisiana' Power & Light Company ~   -- y  ,            ,
k)
  '
  '
  ' 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
  ,
Louisiana ~ Power'& Light Company L.LW.'.Laughlin, Site-
      '
  ' ATTN:
-
  '
    . . Licensing Support Supervisor P.O. Box:BJ  <
  .Killona', Louisiana.~70066-
  '
  '
  - Louidana' Power &; Light Company ATTN: . G. M. Davis, Manager, Events
  ..
    ._ Analysis Reporting & Response
  '
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'
    ~
Louisiana Radiation ' Control Program Director bec .to _ DMB (IE01). w/ enclosure
  - bec distrib.iby RIV w/ enclosure:-        . .
RRI-        R. D.' Martin, RA-
                ' '
DRP
  .SectionChief(DRP/A)
RPB-DRSS        MIS System Project Engineer, DRP/A        RSTS Operator
      '
RIV File        DRS
  'D. Wigginton, NRR Project Manager (MS:    13-D-18)  Lisa Shea, RM/ALF J'
  '
  '
,
)
E @[E DW/Lif%
  '
AUG l 91983 LOUISI POWE R & ANA LIGH /T 3irsanosses7sest
__._E  .[_______ ____________-___m____ ____ .__.__..___..m______ _______.___________.______.______2m_  _ . ___ _ . _ _ _ -___.m__._ _ _ _ _ ____._____m__ . _ _ . _ _ _ _ _ J
    . 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 Repor If you have any questions concerning these responses, please contact L.W. Laughlin, Site Licensing Support, at (504) 464-349 Very truly yours, yd 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%


_ _ _ _ - _ _ _ _ _ _ _ _ _ _ _
__ _ _ _
'*  .
        .
  ,,
,
  .
  , e
  .
  .
Attachment to
  .
W3P88-1270 Page 1 of 7 ATTACHMENT 1 LP&L Responses to Violations Identified in Appendix A of Inspection Report 88-13 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 197 Regulatory Guide 1.33 requires procedures appropriate to the circums'tances for performing maintenance on safety-related equipmen 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 system 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 control This is a Severity Level IV violatio 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 circumstance (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
 
,_ _ _ _ _ _ .
*
  -
  -
  .,
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
Attachment to W3P88-1270 Page 2 of 7 previous step or action, specific troubleshooting instructions are difficult to write in the planning proces 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-05-01 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)
JAN 5 te Subject: Waterford 3 SES    ,
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 inspectio (2) Corrective Actions That Have Been Taken Since the occurrence of this incident, a Maintenance Directive (N ) 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 imperativ 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 boundar (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 tubin 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 deficiencie (4) Date When Full Compliance Will Be Achieved UNT-07-005 will be revised by September 30, 198 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 procedure Quality Assurance Program Procedure QAP-012, Revision 6, "Corrective Action," requires initiation of a Quality Notice when conditions adverse to quality are identifie 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 documentatio This is a Severity Level IV violatio 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) existe (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
  . 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.
.    .
    ,
  ..   .
      .
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 terminate 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 retermination 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 warrante Consequently, a QN was not issued by Quality Assuranc (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 analyzer Corrective action taken by QA has resulted in an emphasis by the Quality Inspection organization on attention to detail involving inspection A training session on attention to details was presented to inspec-tors on August 8, 198 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 inspectio In addition, the ese of inspection observation reports has been discontinued as a means of problem identificatio (3) Corrective Actions To Be_Taken        ,


Quality Assurance personnel will undergo lessons Learned Trainin Emphasis will be placed on the importance of paying attention to detail and utilizing the corrective action systems that are currently in plac (4) Date When Full Compliance Will Be Achieved Lessons Learned Training will be completed by September 30, 198 NS90035D
l      <
      '
  "AN EGUAL OPPORTUNITY EMPLOYER" qJ gy0DL d% ma slL2 m
  '


  .- .- - -_ . - - . _- .
_ _ _ _ _ - - _ _ - _ _ -
*
. . . ,
  .
  .
  . .
  ~
.
Page 2
*
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 repetitio ,
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 labelin l This is a Severity Level IV violatio 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 labelin 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 chang 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 resulte !
  (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 violatio (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 Manage In May,1988, using the QA Trending Program as a baseline, the EAR &R organization established the Nuclear Operations Trending Progra 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 caus 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 deficiencie 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 Manage The Department Head, with approval by the Assistant Plant Manager, will be responsible for determining the necessary corrective action 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 progra P
-l
  )
  .W3P88-1895 1 . .
i
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
    -
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,
      .
R.F. Burski Manager Nuclear Safety & Regulatory Affairs i
RFB:TJG:ssf ,
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
l


        ,
- - _ - _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ .
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 tag 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 performe To ensure that separate procedures are not utilized by various departments, a Plant procedure will be developed to cover all aspects of UNID taggir 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 documentatio 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 possibl 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 documentatio (4) Date When Full Compliance Will Be Achieved Procedures OP-100-004 and OP-100-013 vill be revised by September 30, 198 Development of the new procedure for UNID tagging is scheduled for completion by 0, a mber 31, 1988.
 
l NS90035D
,
}}
}}

Revision as of 04:17, 23 January 2021

Ack Receipt of 881230 Ltr 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 Entergy icon.png
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)
v • d • e


Text

. _ _ _ _

'

s 6m 49 .

'

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

Docket: 50-382/88-13-l

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

!

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

.

.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

'

RIV:DRP/A 8 C:DRP/AA D: P dd ATHowell;df DDChamberla n LJCallan 4 y /89 4/7/89 4/q/89 7

l 8904190164 890407 PDR ADOCK 05000302

/' >

f G PDC

- _ _ - - _ _ _ = - - _ _ _

,

, _ ._ ___ _.____ ____

_

'

'

,

R ,

,

'

'

'

'

' };. , ,

. '?

. :

.

'

f ' Louisiana' Power & Light Company ~ -- y , ,

k)

'

' 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

,

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

'

' ATTN:

-

'

. . Licensing Support Supervisor P.O. Box:BJ <

.Killona', Louisiana.~70066-

'

'

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

..

._ Analysis Reporting & Response

'

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'

~

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

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

RRI- R. D.' Martin, RA-

' '

DRP

.SectionChief(DRP/A)

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

'

RIV File DRS

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

'

)

'

__._E .[_______ ____________-___m____ ____ .__.__..___..m______ _______.___________.______.______2m_ _ . ___ _ . _ _ _ -___.m__._ _ _ _ _ ____._____m__ . _ _ . _ _ _ _ _ J

__ _ _ _

.

,

, e

-

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

' '

JAN 5 te Subject: Waterford 3 SES ,

.

. 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.

l <

'

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

'

_ _ _ _ _ - - _ _ - _ _ -

.

~

Page 2

'

-l

.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

-

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,

.

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

RFB:TJG:ssf ,

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

l

- - _ - _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ .

Retrieved from "https://kanterella.com/w/index.php?title=IR_05000382/1988013&oldid=3107728"