ML20244B782
| 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
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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 .
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
A4.05
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U.S. Nuclear Regulatory Commission
@ 't
ATTN: Document Control Desk i/
Washington, D.C. 20555 ,
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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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e Attachment
~
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"
L_____
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Attachment One
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To LP&L Letter
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.
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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
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
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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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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
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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
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
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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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
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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
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
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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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To LP&L Letter
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
J
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
l
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
'
needs to be changed. I
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3 Attachment One
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To LP&L Letter
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
'
LP&L will be in full compliance by the end of refueling outage 3.
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, ' Attachment One
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To LP&L Letter
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
,
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
L **- To LP&L Letter
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
!
' 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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