ML20244B782

Ack Receipt of 890522 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp 50-382/89-01.Second Example in Violation 8901-05 Re Independent Verification Deleted, Based on Info Provided in Response

ML20244B782
Person / Time
Site:	Waterford
Issue date:	06/07/1989
From:	Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dewease J LOUISIANA POWER & LIGHT CO.
References
NUDOCS 8906130286
Download: ML20244B782 (2)

See also: IR 05000382/1989001

Text

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,, JUN 7 1989

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-In' Reply' Refer To:

' Docket: 50-382/89-01=

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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 May 22, 1989, in response to our letter and

Notice of Violation dated March 21, 1989. 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 compliance has been achieved and will be

maintained. Based on our review of the.information provid.ed in your response,

the second example in Violation 8901-05, involving independent verification,

is deleted.

Sincerely,

Udginal Signed Ur

" g, E Milhow

James L. Milhoan, 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: J. R. McGaha, Jr., Plant Manager

'P.O. Box B

.Killona, Louisiana 70066

RI(gf(MCPS' 'C: .

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LLouisiana' Power & Light, Company -2-

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4 Louisiana _ Power'& Light Company

ATTN: .R. F. Burski, Manager, Nuclear

,

Safety & Regulatory Affairs

317 Baronne Street

-P.O.. Box 60340

New Orleans,~ Louisiana 70160

Louisiana Power'& Light Company

ATTN: L. W. Laughlin.. Site.

.

Licensing Support Supervisors

P.O. Box B

1 Killona, Louisiana 70066

Louisiana Power & Light Company

' ATTN:".G..M. Davis, Manager, Events

Analysis Reporting & Response.

'P.O. Box B

-K111ona, Louisiana '70066 .

-

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Middle South Services.

ATTN: Mr. R..T. Lally:-

P.O. Box l61000

' New Orleans, Louisiana _70161

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Louisiana Radiation' Control Program Director

bectoDMB(IE01) r

bec distrib'.'by RIV:'

RRI. . R. D. Martin, RA

SectionChief(DRP/A) DRP ~

RPB-DRSS. MIS System

Project: Engineer.(DRP/A) RSTS Operator

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RIV File .

DRS

D. Wigginton,iNRR Project Manager (MS: .13-D-18)~

Lisa Shea, RM/ALF W. Johnson

D. Hunter

J. Gagliardo-

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LOUISIAN

POWER & LIG AHT/ 317

NEWBARONNESTREET

a P. O. BOX 60340

ORLEANS, LOUISIANA 70160 *

(504)595 3100

MEEsM

May 22, 1989

W3P89-1046

A4.05

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U.S. Nuclear Regulatory Commission

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ATTN: Document Control Desk i/

Washington, D.C. 20555 ,

!

i MAY ? A 1989 . llll -

SUBJECT: Waterford 3 SES ' - - ' '

Docket No. 50-382  !

License No. NFF-38

NRC Inspection Report- 50-382/89-01

REFERENCE: LP&L Letter W3P89-3018, dated April 20, 1989

In accordance with 10 CFR Part 2.201, Louisiana Power & Light hereby submits

in Attachment I the responses to the Violatioca identified in Appendix A of

the subject Inspection Report. LP&L requested, see referenced letter, and

the NRC granted a 30 day extension of the original response date during a

telephone conversation held on May 4,1989 between J. Gagliardo of the NRC

and R.F. Burski of LP&L. >

Plea'e

s contact me or Robert J. Murillo at (504) 595-2831 if you have any

questions concerning these responses.

Very truly yours,

.

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R.F. Burski

Manager

Nuclear Safety 6 Regulatory Affairs ,

1

RFB/RJM:dc j

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cc4 k.D.$Mahtin NRC Region IV F.J.*Hebdon NRC-NRR,

D.L. Wigginton, NRC-NRR, NRC Resident Inspectors Office, E.L. Blake,

W.M. Stevenson

3w oon R If

gqg "AN EQUAL OPPORTUNITY EMPLOYER"

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Attachment One

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To LP&L Letter

W3P89-1046

Attachment One

LP&L Responses To Violations Identified In Appendix A

Of Inspection Report 50-382/89-01

A. Violation 8901-05

Failure to Follow Equipment Control Procedures

Waterford Steam Electric' Station, Unit 3, Technical Specification 6.8.1

requires that written procedures be established, implemented, and main-

tained for procedures recommended in Appendix A of Regulatory Guide

1.33, Revision 2, February 1978. Regulatory Guide 1.33, Appendix A,

paragraph 1.c, requires that administrative procedures be developed for

equipment control. The following three cases are examples of failure to

adhere to equipment control procedures.

1. Louisiana Power & Light (LP&L) Maintenance Procedure MD-1-014,

Revision 2, " Conduct of Maintenance," paragraph 5.1.5, requires that'

plant equipment such as pumps, valves, and breakers, which are

portions of systems used for power generation, will not be operated

by maintenance personnel unless specifically directed to do so by

the shift supervisor (SS)/ control room supervisor (CRS) or as a part

of an approved maintenance procedure authorized to be performed by

the SS/CRS.

Contrary to the above, on January 31, 1989, the NRC inspector

observed that a mechanical maintenance worker operated Water Chiller

Outlet Isolation Valve CHWMVAAA121B during the performance of main-

tenance work authorization (WA) 01021204 without specific direction

from the SS/CRS or authorization in an approved maintenance

procedure.

2. LP&L Administrative Procedure UNT-5-010, Revision 0, " Independent

Verification Program," paragraph 5.2.1, requires that independent

verification be performed on components, which could have been

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mispositioned during maintenance. Paragraph 5.5.2 applies inde-

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pendent verification requirements to systems listed in Attachment

6.1. This attachment identified the chilled water system as

requiring independent verification.

'

Contrary to the above, independent verification of proper.

positioning of Chilled Water System Manual Valve CHWMVAAA121B was

not performed following valve manipulation during activities

performed by WA 01021204 on January 31, 1989.

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3. LP&L Administrative Procedure UNT-5-003, Revision 7, " Clearance

Requests, Approval and Release," paragraph 3.4, states that a danger

tag, when in place, prohibits the operation of equipment or systems,

which could jeopardize personnel safety or endanger equipment.

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Attachment One

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To LP&L Letter

W3P89-1046

Contrary to the above, on January 31, 1989, the NRC inspector observed

that a mechanical maintenance worker turned the valve operating hand

wheel for Valve FS-325 while the hand wheel had a danger tag (89-103-5)

attached.

This is a Severity Level IV violation.

RESPONSE

1. LP&L's Position Regarding the Violation

LP&L admits parts 1 and 3 of violation 8901-05. The reasons for the

violation are personnel error and the lack of detailed guidance for the

operation of valves and implementation of danger tags.

LP&L denies part 2 of violation 8901-05.

Part 1 of violation 8901-05 is that of a mechanical maintenance worker

moving the Water Chiller Outlet Isolation Valve CHWMVAAA121B during the

performance of maintenance Work Authorization (WA) 01021204. Clearance

89-104 deenergized the Chilled Water Pump motor and isolated the Chilled

Water Pump inlet and outlet valves. Valve CHWMVAAA121B is the' manual

chiller outlet isolation valve. The valve was contained inside the

tag-out boundary. The valve was moved in order to lubricate the valve

operator following maintenance on the' valve which included disassembly

and rssembly of the valve, and not to verify valve lineup or operability.

Thus, since the valve was within a tagged out boundary and operated as an

integral part of a maintenance function, the maintenance personnel

erroneously judged that covement of the valve was in conformance with

maintenance procedure MD-1-014, Revision 2.

Part 2 of violation 8901-05 specifies that operations personnel did not

independently verify the proper valve position of valve CHWMVAAA121B

following valve operation performed by personnel in accordance with WA

01021204. LP&L procedure UNT-5-010, Revision 0, allows the~ proper valve

position to be verified by either independent verification or a functional

' test. The Chilled Water loop B, which contains valve CHWMVAAA121B, flow

rate and temperature were verified to be < 42*F at a flow rate of >

500gpa in accordance with T.S. surveillance 4.7.12.1 prior to returning

the Chilled Water train B to operable status. The temperature was 40'F

at a flow rate of 510 gpm. These results were recorded in the station

,

log. Valve CHWNVAAA121B is located upstream of the flow element for

essential Chiller B. Low flow in loop B would have occurred had valve j

CHWMVAAA121B not been properly positioned. Thus, any misalignment of -

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valve CHWMVAAA121B would have been identified and corrected.

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Attachment One

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To LP&L Letter

W3P89-1046

Part 3 of violation 8901-05 specifies a third instance of failure to

follow equipment control procedures where a mechanical maintenance worker

turned the valve operating handwheel for valve FS-325 which had a danger

tag attached.

Earlier in the filter changeout for the Fuel Pool Purification system,

problems were experienced draining the filter. An operator was summoned

to provide help. The operator performed a valve lineup verification,

with the exception of the filter drain valve, and found no other problems.

After discussion with the Control Room and Health Physics personnel, the

decision was made to pull the filter element and then locally verify the

position of the drain valve. It was believed that the remote operator

might have become disconnected because no other cause could be determined

that would prevent draining the filter. Thus, a maintenance person, who

performed the filter changeout, verified the position of the filter drain

valve, FS-325, following the changeout by rotating the remote operator

handwheel in the closed direction while another mechanic locally verified

that the valve handwheel turned in the closed direction.

Subsequently, operations personnel determined that back pressure from

the Equipment Drain Tank (EDT), which the Fuel Pool Purification Filter

drains to, was retarding the draining. The operator involved in this '

event thus explained to maintenance personnel that the EDT backpressure

had been the reason that the filter had not drained. The operator

recalls he then told maintenance personnel there was no need to check

the position of the filter drain valve locally as had been previously

agreed upon. Maintenance personnel did not have a clear understanding

of the discussion and therefore still believed the drain valve in question

needed to be checked locally. Following the work, maintenance personnel

therefore checked the valve as previously described.

Maintenance personnel thus erroneously believed verification of the

position of the filter drain valve was in accordance with procedure

UNT-5-003.

2. LP&L Actions Taken and Results Achieved

Part 1

The maintenance personnel involved in part 1 of violation 8901-05 have

been counselled by maintenance management. The counselling emphasized

the need for strict adherence to procedures, careful review and under-

standing of procedures, and communications with cognizant personnel

and management regarding perceived questionable procedural steps. The

counselling also entailed a review of applicable procedures for operation

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of plant equipment.

The plant manager issued a memorandum which clearly states that no one

i except operations personnel shall operate a valve unless specifically

I authorized by an approved plant procedure or WA signed by the shift or

control room supervisor. The memorandum was distributed to site personnel

at safety meetings.

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Attachment One

To LP&L Letter

W3P89-1046

Part 3

A meeting was held February 1, 1989, to gain an understanding of the

events which led to the operation of a component with a danger tag by

maintenance personnel following the changeout of the Fuel Pool

Purification filter element on January 31, 1989. The meeting was chaired

by the_ Event Analysis, Reporting, and Response Manager and Maintenance

Superintendent. Maintenance, Health Physics, and Rad Waste personnel

involved with the filter changeout were in attendance along with their-

supervisors. The events surrounding the filter changeout were

discussed in detail. A time line, causal factor chart, was developed to

analyze the event. The February 1,1989 meeting provided the forum for

establishing a clear understanding of the root cause and for appraising

cognizant personnel of the need for strict adherence to, careful review

of, and understanding of procedures.

The previously mentioned memorandum also clearly states that no one shall

operate a component with a danger tag until the danger tag is properly

cleared in accordance with UNT-5-003. Additionally, the memorandum

emphasizes the importance of the requirement by stating that repositioning

of danger tagged components.is grounds for termination.

3. Future Actions To Be Taken

Part 1

LP&L will revise applicable maintenance controlling procedures to

incorporate requirements on the movement of valves while performing

maintenance activities and guidance on independent verification of valve

position following maintenance. The revision will convey that main-

tenance personnel may move a valve within a tagged out boundary provided

the movement is performed as an integral part of the maintenance on that

valve and the valve movement is authorized procedurally or by a WA.

Part 3

LP&L will also revise maintenance procedures MD-01-014 to incorporate

the guidance in the plant manager memorandum and attachment.

4. Date When Full Compliance Will Be Achieved

LP&L will be in full compliance by June 30, 1989.

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Attachment One

To LP&L Letter

W3P89-1046

B. Violation 8901-06

Failure to Follow Maintenance Procedure

Waterford Steam Electric Station, Unit 3, Technical Specification 6.8.1

requires that written procedures be established, implemented, and

maintained for procedures recommended in Appendix A of Regulatory Guide

1.33, Revision 2, February 1978. Regulatory Guide 1.33, Appendix A,

paragraph 9.e, requires general procedures to be developed for control

of maintenance, repair, replacement, and, modification work.

LP&L Maintenance Procedure MD-1-014, Revision 2, " Conduct of Main-

tenance," paragraph 5.1.2, requires that strict compliance with

approved procedures and work instructions is mandatory.

WA 01006815 required performance of preventive maintenance on 4160 volt

Switchgear 3B-3S in accordance with Maintenance Procedure ME-4-121,

Revision 3, "4.16-KV Switchgear." Paragraph 8.1.24 of this procedure

required torquing of all limit switches, auxiliary switches, and switch

tie-bolts. Paragraph 8.1.31 of this procedure required verification of

torque of all exposed electrical connections including the switchgear

grounding connections. Attachments to the procedure provided

appropriate torque values.

Contrary to the above, during the performance of WA 01006815 during the

1988 refueling outage, the paragraphs of Maintenance Procedure ME-4-121,

Revision 3, which addresses torquing, were not performed. These paragraphs

were marked "N/A" and explanatory notes were added indicating that no

loose connections were found, so torquing was not required. No torque

wrenches were listed as having been used on this job.

This is a Severity Level IV violation.

RESPONSE

1. LP&L's Position Regarding the Violation:

LP&L admits the violation. The violation is attributed to personnel

error. A contributing factor is inconsistencies in maintenance

procedures.

Maintenance procedures ME-4-101 for 6.9 KV switchgear and ME-4-141 for

480 V switchgear are procedures that are similar to ME-4-121 for 4.16 KV

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switchgear. These two procedures allow maintenance personnel to designate

a step "NA" if the step or condition is not appropriate for conditions at

the time of performance of the maintenance activity. The individual

concerned had previously performed. maintenance in accordance with

maintenance procedure ME-4-141 and mentally confused the "NA" provision -

allowed under procedure ME-4-141 with procedure ME-4-121.

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Attachment One

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To LP&L Letter

W3P89-1046

2. LP&L Actions Taken and Results Achieved

The individual concerned has been counselled by the cognizant Maintenance

Assistant Superintendent regarding the need for strict adherence with

procedures, careful review and understanding of procedures, and communi-

cation with cognizant personnel and management regarding perceived

questionable procedural steps. Additionally, the cognizant Maintenance

Assistant Superintendent has reviewed procedures ME-4-141, ME-4-101,

ME-4-121 with the concerned individual to assure the procedures are fully

understood.

A formal engineering evaluation, PEIR 61143, has been performed to

evaluate the safety significance and operability of the 3B-3S 4160 volt

switchgear.

The evaluation concluded that the operability and safety of the 3B-3S

4160 volt switchgear were not adversely affected by the entry of N/A on

steps 8.1.24 and 8.1.31 of procedure ME-04-121. Step 8.1.24 had been

previously added to the procedure to addrest problems solely applicable

to the elevating mechauism. Therefore, the intent of this step was to

check only the switches and tie bolts for the elevating mechanism which

have no function in breaker operation once the breaker is racked in.

Verification of the positive interlock of the closing circuit is required

in accordance with procedure OP-100-010, Attachment 6.3, before the breaker

is declared operable, resulting in an independent verification of breaker l

operability. Step 8.1.31 was considered N/A because no electrical  ;

connections were disconnected. The insulated bus connections were tested

with infrared scanning under full load conditions prior to the outage to

ensure electrical continuity. There is no need to evaluate the other

safety related switchgear since the above mentioned work was performed

only for 3B-3S 4160 volt switchgear.

3. Future Actions To Be Taken

LP&L will revise maintenance procedures ME-4-101, ME-4-121, and ME-4-141

to assure they are consistent regarding the provisions for designating a i

step "NA". The guidance for designating a step "NA" will be consistent '

with approved and controlled maintenance procedures, for example,

MD-1-014 and MD-1-028.

LP&L will also prepare a formal lesson plan on procedures ME-4-iO1,

ME-4-121, and ME-4-141. Maintenance personnel will receive training

on the lesson plan.

4. Date When Full Compliance Vill Be Achieved

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LP&L-will be in full compliance by October 15, 1989.

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W3P89-1046

C. Violation 8901-09

Failure to Follow Requirements of the Plant Lubrication Manual

Waterford Steam Electric Station, Unit No. 3, Technical Specification 6.8.1 requires that written procedures be established, implemented, and

maintained for procedures recommended in Appendix A of Regulatory Guide

1.33, Revision 2, February 1978. Regulatory Guide 1.33, Appendix A,

paragraph 9.a. requires, in part, that maintenance that can affect che

performance of safety-related equipment should be properly preplanned

and performed in accordance with written procedures, documented

instructions, or drawings appropriate to the circumstances.

Maintenance Procedure UNT-5-007, Revision 1, " Plant Lubrication Program,"

establishes, in part, the method for lubricating safety-related equipment.

Step 5.4.2 of UNT-5-007, Revision 1 states, in part, that " Lubrication

activities for plant equipment shall utilize only the lubricants listed

in the PLM [ Plant Lubrication Manual] unless otherwise specified on a

C1WA ..."

Contrary to the above, three environmentally qualified safety-related

motor operated valves inside the reactor building were found by the

licensee to be lubricated with an admixture of two different types of

grease in May 1988, even though the PLM only specified the use of Exxon

Nebula EP-0.

This is a Severity Level IV violation.

RESPONSE

1. LP&L's Position Regarding The Violation

LP&L admits to the violation, in that, in May 1988 three environmentally

qualified safety-related motor operated valves were found by LP&L to be

lubricated contrary to the requirements of the PLM. The reason for the

violation is personnel error.

In addition to the specifies identified in the violation, a number of

observations and weaknesses in the lube program were discussed in the

body of the inspection report. The following response addresses the

violation and these additional concerns.

There are two different aspects to this issue, the mixing of grease

with different soap bases, and assuring the application of the intended

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grease. These aspects are discussed separately.

Mixing of Grease

The mixing of grease with different soap bases is in large part attributed

to the evolution of the practice and policy for the use of grease.

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Attachment One

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To LP&L Letter

W3P89-1046 1

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PRE-88-048 documented that the grease type in the gear boxes of Limitorque

MOV actuators SI-MVAAA 332A, 332B, 401A and 401B inside containment were

found to be indeterminate during preventative maintenance that was per-

formed in May 1988. Subsequent laboratory analysis and evaluation

established that the grease for MOV actuators 331B, 332A, and 332B, had

a mixture of Mobilux and Nebula greases.

The subject MOVs were lubricated during the first refueling outage in

November 1986, and Plant Lubricating Manual (PLM) and the maintenance

work orders specified Nebula EPO for the grease. The next preventative

maintenance to check or lubricate the subject valves was due in May 1988

during the second refueling outage, at which time the type of grease in

the subject valves was found to be indeterminate. LP&L therefore be-

lieves based on a review of records, that the mixing of the greases

occurred during startup activities in 1984 and 1985 at Waterford 3.

During startup activities, the PLM did not exist, and the application of

grease was in accordance with the technical manuals. The technical

manual for Limitorque MOV actuators specified Exxon Nebula EPO as the

lubricant.

In the past, it was the policy of LP&L to exclusively specify the products

of one lubricant vendor (MOBIL) on a system-wide basis. Thus, the Mobil

lubricants were evaluated and approved for use on a generic basis during

Waterford 3 startup. PEIR /0152 evaluated and approved on a gr.neric

basis several Mobil lubricants for use at Waterford 3. The irtent of

PEIR 70152 was to evaluate the compositions of the lubricants as they

relate to the operating conditions at Waterford 3. The evalua tion was

based on data available at that time.

In 1984, the application of requirements for EQ was to some extent

evolving and subject to interpretation. LP&L believed the Mobilux EPO

was qualified, based on analysis, for use in harsh environments, and

therefore LP&L was maintaining Mobilux EPO was an acceptable substitute

for Exxon Nebula EPO. The PEIR, in conjunction with LP&L's position

that Mobilux EPO was an acceptable alternative for Exxon Nebula EPO,

resulted in LP&L specifying Mobilux EPO in the PLM as the lubricant for

certain valves outside containment. As LP&L pursued additional qualifi-

cation documentation for the Mobilux EPO, it became apparent Mobil could

not provide a concrete recommendation for the use of Mobilux EPO since

Exxon Nebula EPO was the only grease type tested and approved by Limitorque.

This did not necessarily mean the Mobilux EPO was not acceptable for use

in a harsh environment, but that additional type testing may have been

required before Mobil would provide a concrete recommendation for the use

of Mobilux EPO. LP&L subsequently decided that Exxon Nebula EPO would be

used in all MOVs. The evolution and change in philosophy, coupled with

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the use of Mobilux EPO for certain valves outside containment, thus

provided a climate for confusion regarding the application of grease.

Nonetheless, the use of Mobilux EPO for the subject MOVs inside contain-

ment was contrary to the Limitorque technical manual and PLM and therefore,

was personnel error.

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Attachment One

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To LP&L Letter

W3P89-1046

Ay u_ ring Use of Intended Grease

The NRC in the inspection report cited weaknesses in assuring the use of

the intended grease. Examples were cited by the NRC where a grease other

than the grease intended was applied or where a grease other than.the

grease intended may have been used had the valve required lubrication.

The first basis for the NRC cited weaknesses was that the PLM specified

Mobilux EPO for use in the following MOVs:

SI-MVAAA 225A, HPSI HDR A to RC Loop - 1A

SI-MVAAA 225B, HPSI HDR B to RC Loop - 1A

SI-MVAAA 226B, HPSI HDR B to RC Loop - IB

SI-HVAAA 227B, HPSI HDR B to RC. Loop - 2A

SI-MVAAA 228A,.HPSI HDR A to RC Loop - 2B

SI-MVAAA 228B, HPSI HDR B to RC Loop - 2B

UNT-5-007, Revision 1, requires in part that lubrication for plant equip-

ment shall utilize only the lubricants listed in the PLM. Lubrication of

these valves therefore may have resulted in adding Mobilux EPO rather

than Exxon Nebula EPO which was the previously installed grease. LP&L

acknowledges the NRC cited basis.

The second basis for the NRC cited weaknesses is that the NRC found a

copy of the PLM which was out dated. The copy of the FLM did not have

the lubrication data for MOVs outside' containment. LP&L acknowledges

the NRC cited basis. The outdated PLM was apparently a controlled copy

which was not updated.

The third basis for the NRC cited weaknesses is the finding of inconsis-

tencies between the PLM and the lubrication checklists for three valves:

EFW-MVAAA-220B, MS-MVAAA-416, and BAM-HVAAA-133. The PLM for the foregoing

valves specified that Mobilux EPO was the required grease. The lubrication

checklist for valve EW-MVAAA-220B documented that the grease was tan,

the color of new Exxon Nebula EPO. Thus, since the PLM specified Mobilux

EPO, the potential existed for adding Mobilux EPO which was not the

intended grease. The lubrication checklists for valves MS-MVAAA-416 and

BAM-MVAAA-133 documented that the grease color was other than tan.

However, a color other than tan only means the grease may not have been

Exxon Nebula EPO. LP&L collected samples of the installed grease for

valves MS-MVAAA-416 and BAM-MVAAA-133 for evaluation by the lubrication

engineer. The lubrication engineer determined that the grease could not

be positively confirmed as Exxon Nebula EPO. As a conservative measure,

LP&L removed t.he grease in valve BAM-MVAAA-133 and installed new Exxon

Nebula EPO since the valve could be taken out-of-service without affecting

plant operation. Mobilux EPO is qualified for use outside containment,

and the grease was therefore left in valve MS-MVAAA-416 since the valve

'

could not be taken out-of-service without affecting plant operation. The

NRC apparently concluded valves MS-MVAAA-416 and BAM-MVAAA-133 contained

Mobilux EPO and relied on the grease color and the fact that LP&L took

samples to make this conclusion in the inspection report. LP&L would

like to provide the following additional clarification regarding the NRC

conclusion.

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Attachment One

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l W3P89-1046

To ensure that Exxon Nebula EPO was used in all MOVs inside containment,

the lubrication checklist, in its previous form, required maintenance

personnel to verify the grease was tan in color. New Exxon Nebula EPO

is tan in color. LP&L later learned that Exxon Nebula EPO darkens with

exposure to elevated temperature, and thus Exxon Nebula EPO may look like

Mobilux EPO which is a dark brown color. The use of a tan color as an

acceptance criterion for verifying the type of grease was therefore

invalid. LP&L thus changed the lubrication checklist to its present

form, which requires that a grease sample be taken if the grease color is

other than tan. The lubrication engineer then determines if the proper

grease is installed or if the grease needs to be changed. The collection

of a sample of a grease therefore does not necessarily mean the wrong

grease is installed.

2. LP&L Actions Taken and Results Achieved

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LP&L actions and results are discussed separately relative to the mixing

of grease and assuring the use of the intended grease.

Mixing of Grease

LP&L performed an evaluation, documented in LP&L letter W3B88-0312, of )

the effect on operability of using Mobilux EPO or a mixture of Exxon

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Nebula EPO and Mobilux EPO on Limitorque valve operators located inside

containment. The evaluation concluded that neither the Mobilux EPO or

the mixture of Exxon Nebula EPO and Mobilux EPO should be detrimental to

the operation of the gear box assembly. Nonetheless the evaluation

recommended the operators containing the mixed grease be cleaned and

re-lubricated with Exxon Nebula EPO by the end of Refueling Outage 3.

The mixed lubricant in valves SI-MVAAA 331B, 332A, and 332B was removed

and was replaced with Exxon Nebula EPO in accordance with maintenance

work orders 01018074, 01001930, and 01017773. The grease in valves

SI-MVAAA 401A, 401B, and 331A were determined by analysis to be Exxon

Nebula EPO. The grease in valve 401A was removed and replaced, via

maintenance work order 01017414, with Exxon Nebula EPO prior to the

receipt of the laboratory analysis since LP&L suspected the grease could

have been Mobilux EPO.

The Plant Lubrication Manual has been revised to require the use of

Exxon Nebula EPO for all Limitorque valve operators inside and outside

containment.

UNT-5-007 has been revised to require that a sample of the grease be

taken if the grease color is not easily recognized. The lubricat;vn

engineer determines if the proper grease is installed or if the grease

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needs to be changed. I

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To LP&L Letter

W3P89-1046'

Subsequent to the NRC maintenance inspection, LP&L reviewed the records

for the application of grease of all safety related MOVs outside contain-

ment to verify that the MOVs contained Exxon Nebula EPO. Where documenta-

tion could not be found to positively verify the MOVs contained Exxon

Nebula EPO, such valves were checked in the field to verify they

contained Exxon Nebula EPO. Valves MS-MVAAA-416 and BAM-MVAAA-133 were

found to contain Mobilux EPO which is an acceptable substitute lubricant

for MOVs outside containment.

These actions are expected to preclude the mixing of grease. The NRC

has independently concluded, reference page 39 of the inspection report,

that the LP&L program for lubricating MOVs inside containment is adequate

i to prevent the recurrence of mixing greases.

Assuring The Use of Intended Grease

Valve BAM MVAAA-133 had the grease removed and replaced with Exxon Nebula

EPO via maintenance work order 01013828. Although no corrective action

was required for valve EFW-MVAAA-220B, the valve has been taken out of

service for other reasons. See section 3 for the planned action on valve

MS-MVAAA-416.

The PLM has been revised to specify Exxon Nebula grease for all motor

operated valves inside and outside containment. The specification of

one grease in the PLM will provide clear and unequivocal requirements

for the application of grease.

PLM 457001150, copy 029, has been located and updated.

3. Future Actions To Be Taken

LP&L will replace the grease in valve MS MVAAA-416 with Exxon Nebula EPO

during refueling outage 3.

LP&L will revise procedure UNT-5-007 to require that an evaluation be

performed, should the lubricant specification in the PLM be changed for

a particular component, to ensure the grease previously in the component

is either removed or the specified lubricant is compatible with the

existing grease.

Completion of these actions, along with the corrective action.s t'aken to

date, will provide LP&L a high level of confidence that the problem with

incompatible grease mixtures in motor operated valves has been corrected

and that incompatible grease mixtures will not be used in the future.

'4. Date When Full Compliance Will Be Achieved

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LP&L will be in full compliance by the end of refueling outage 3.

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To LP&L Letter

W3P89-1046

D. ' Violation 8901-01

Failure to Control Technical Documents as Required bv Adminir,trative

Procedure

Criterion V of Appendix B to 10 CFR 50 requires that activities

affecting quality shall be prescribed by documented instructions,

procedures, or drawings, of a type appropriate to the circumstances

and shall be accomplished in accordance with these instructions,

procedures, or drawings. LP&L Administrative Procedure UNT-4-002,

Revision 2, " Field Control of Technical Documents," requires tech-

nical documents used in the field to be " field controlled" and

specifies the administrative procedures to be used to provide field l

control of technical documents. J

Contrary to the above, maintenance data forms, used to provide 'calibra-

tion data for instrument calibration, and instrument information sheets,

containing setpoint information, were not field controlled in accordance

with Procedure UNT-4-002, Revision 2. I

There is a Severity Level IV violation.

RESPONSE

1. LP&L Position Regarding the Violation

LP&L admits the violation. The reason for the violation is a lack of

detailed procedural controls for the use of maintenance data forms and

information sheets.

Initially, the maintenance data forms and the information sheets were

issued as hard copy documents by document control in accordance with

UNT-4-002. The information sheets were stamped " field controlled," and

the maintenance data forms were appended to the information sheets. The

" field controlled" stamp applied to the package, i.e. maintenance data

forms and information sheets, and the two documents were used in the

field as one controlled document. With the implementation of SIMS, the

information sheets are now generated by SIMS, rather than document

control, and the practice of stamping the information sheets " field  ;

controlled" continued. As a result, information sheets were being l

stamped and dated as field controlled, but were not meeting all'of the .

requirements of UNT-4-002. Maintenance data forms were being handled as {

a separate document without the necessary field controls. 1

2. LP&L Actions Taken and Results Achieved

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Maintenance procedure MD-1-002, Revision 0, has been revised to require

that the maintenance data forms be field controlled as required by

procedure UNT-4-002, Revision 2. i

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Attachment One

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W3P89-1046

The information sheets contain a compendium of information for reference

like numbers for applicable EMLRACs, loop diagrams, technical manuals,

procedures, etc. Accordingly, information-sheets are no longer stamped

" field. controlled" but rather are stamped with an indication that the

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' document has been verified and must be reverified within seven days.

MD-1-002 requires the foregoing stamping practice for information sheets.

The maintenance manager issued a memorandum on February 3, 1989 to

maintenance personnel requiring that information sheets be retained as

part of the work package closure documentation.

3. Future Actions To Be Taken

A revision to maintenance procedure MD-01-002 will be made to specifi-

cally require that information sheets be retained as part of the

work package closure documentation. Maintenance personnel will-be

required to read the revision to maintenance procedure MD-01-002 when

effected.

4. Date When Full Compliance Will Be Achieved

LP&L will be in' full compliance by July 1, 1989.

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