W3P87-2242, Responds to Violation 8721-01 Noted in Insp Rept 50-382/87-21.Corrective Actions:Station Info Mgt Sys Now Employed to Track Measuring & Test Equipment Nonconformance
| ML20238C937 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/30/1987 |
| From: | Drummond F LOUISIANA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| W3P87-2242, NUDOCS 8801040003 | |
| Download: ML20238C937 (3) | |
Text
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ama LOUISI AN A / 3U BARONNE STREET P. O, BOX 60340 (504)595 3100 POWER S L1G HT NEW ORLEANS, LOUISIANA 70160
+
$2i?NIrsS$
December 30, 1987 W3P87-2242 A4.05 QA U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report 87-21 Attached is the Louisiana Power & Light Company (LP&L) response to
' Violation No. 8721-01 identified in Inspection Report No. 87-21.
If you have any questions on the response, please contact G.E. Wuller, Operational Licensing, at (504) 464-3499.
Very truly yours, 7 "'
F.J. Drummond Nuclear Services Manager FJD:GEW:ssf Attachment cc:
R.D. Martin, NRC Region IV J.A. Calvo, NRC-NRR J.H. Wilson, NRC-NRR NRC Resident Inspectors Office j
W.M. Stevenson l
E.L. Blake ggo\\
8801040003 871230 PDR ADOCK 050 0382 I l 0
m "AN EQUAL OPPORTUNITY EMPLOYER"
--________-__-_-___________-__________a
i, Attachment to W3P87-2242 Page 1 of 2 LP&L Response to Violation No. 8721-01 VIOLATION NO. 8721-01 Failure to Evaluate Out-of-Calibration Test Equipment in Timely Manner 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, states, in part,
" Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected."
LP&L Procedure UNT-5-009, " Administrative Procedure Dispositioning of M&TE Nonconformances," dated October 12, 1986, paragraph 5.5. states, "The M&TE nonconformance evaluation Condition Identification and Work Authorization (CIWA) must be completed by the department within 30 days from the date of identification recorded on the originator section of the M&TE nonconformance evaluation. The 30-day limit may be exceeded in cases where retest or recalibration of equipment is necessary to evaluate the nonconformance." Paragraph 5.15 statee, "The Operations Quality Assurance department shall review the completed evaluation for acceptability and close out the M&TE nonconformance evaluation."
Contrary to the above, three out of five evaluated nonconformance CIWA's selected by the NRC inspector, were found to have exceeded the 30-day limitation imposed by paragraph 5.5, LP&L Procedure UNT-5-009, as identified above, Specific CIWA documents are as follows:
CIWA Documents Originator Date Completed CIWA 031565 March 9, 1987 September 17, 1987 CIWA 031566 March 9, 1987 May 29, 1987 CIWA 031600 March 30, 1987 May 29, 1987 This is a Severity Level IV violation.
RESPONSE
(1) Reason For The Violation UNT-05-009 "Dispositioning of M&TE Nonconformances" Section 5.5 states "The M&TE nonconformance evaluation Condition Identification Work Authorization (CINA) must be completed by the department within 30 days from the date of identification recorded on the originator section of the M&TE nonconformance evaluation." For the three CIWAs identified in the violation #8721-01, two of the three met this requirement. The specific dates for department evaluation completion are as follows:
ORIG. SECTION OF DEPARTMENT CIWA THE EVALUATION EVALUATION COMPLETED CIWA CLOSED 031565 March 4, 1987 March 9, 1987 Sept. 17, 1987 031566 March 4, 1987 May 7, 1987 May 29, 1987 031600 March 25, 1987 April 22, 1987 May 29, 1987
...v'*
Attachment to W3P87-2242 Page 2 of 2 l
l CIWA 031566 did not meet the 30 day limitation as specified'in UNT-5-009.
This CIWA was sent to Nuclear Operations Engineering on March 9, 1987.
The reason for this violation'was an inadequate tracking method used to ensure a timely record. search completion.
(2) Corrective Actions That Have Been Taken The Station Information Management. System (SIMS) is now employed in the tracking of M&TE nonconformances. Each user department is now responsible for planning the Work Authorization (WA) within that department.
A generic work authorization has been entered into SIMS to provide consistency in planning by the various departments now responsible for planning and conducting the evaluations.
SIMS reports are now issued on a weekly basis to all departments that have record search CI/WAs. This report provides a listing of near term M&TE record searches and the responsible groups required to plan / evaluate them.
The Plant Manager issued letter W3187-0151 on December 2, 1987, to the responsible managers explaining the SIMS report, the urgency of timely evaluation completion, and the sample generic work authorization used for planning. The overdue Records Search Evaluations listed in the Plant Manager's letter have been completed.
(3) Corrective Actions To Be Taken A proposed revision to UNT-5-009 gives the evaluator the ability to request an extension in time for performance of the evaluation.
The reason for the extension will be documented on the WA along with the Maintenance Superintendent's approval signature. The revision to UNT-5-009 io scheduled for approval by January 31, 1988.
(4) Date When Full Compliance Will Be Achieved Waterford 3 is in full compliance at this time.
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