W3P87-1729, Forwards Response to NRC Ltr Re Violation Noted in Insp Rept 50-382/87-11.Corrective Actions:More Detailed Test Procedure Developed to Retest Essential Chiller a Under Station Mod 615 & to Minimize Need for Drawings
| ML20236C041 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 07/24/1987 |
| From: | Cook K LOUISIANA POWER & LIGHT CO., NEW ORLEANS PUBLIC SERVICE CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| W3P87-1729, NUDOCS 8707290322 | |
| Download: ML20236C041 (3) | |
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l LOUISIANA POWER & LIGHT COMPANY e Post Ofhce Box 6008 New Orleans. Louisione 70174
. Mattac NEW ORLEANS PUBLIC SERVICE INC. Post Othee Box 60340
- New Orleens. Louisiens 70160 July 24, 1987 W3P87-1729 j
A4.05 QA l
U.S. Nuclear Regulatory Commission 4
ATTN: Document Control Desk Washington, D.C. 20555 i
Subject:
Waterford 3 SES Docket No. 50-382 3
License No. NPF-38 NRC Inspection Report 87-11 i.i Attached is the Louisiana Power and Light Company (LP&L) response to I
Violation No. 8711-01 identified in Inspection Report No. 87-11.
If you have any questions on the response, please contact G.E. Wuller, Operational Licensing, at (504) 464-3499.
Very truly yours, K.W. Cook Nuclear Safety and Regulatory Affairs Manager i
KWC:PTM:ssf i
Attachment ec:
R.D. Martin, NRC Region IV J..A. Calvo, NRC-NRR-J.H. Wilson, NRC-NRR NRC Resident Inspectors Office E.L. Blake W.M. Stevenson fhflE90322B70724 Og2 NS20659 G
p i
t "AN EQUAL OPPORTUNITY EMPLOYER"
1 Attachment to W3P87-1729 Sheet 1 of 2 LP&L Response to Violation No. 8711-01 VIOLATION NO. 8711-01 Technical Specification (TS) 6.8.1.a requires, in part, that written procedures be established and implemented for the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Paragraph 9.e of Appendix A of Regulatory Guide 1.33, Revision 2, requires, in part, " General procedures for control of maintenance, repair, replacement, and modification..." Two examples of failure to follow such procedures are listed below.
1.
Procedure PE-2-006, Revision 8, " Plant Engineering Station Modification," is an approved procedure which. implements a portion of the licensee's program to control modification work.
Paragraph 5.8.4 of Procedure PE-2-006, Revision 8, requires that modification packages include or reference written testing requirements.
Contrary to the above, on May 20, 1987, the NRC inspector observed licensee personnel performing testing on the "A" essential chiller under Station Modification 615 without an approved written test procedure.
j 2.
Procedure UNT-4-002, Revision 1, " Field Control of Technical Documents," is an approved procedure detailing the control of documents used in quality related activities. Paragraph 1.0 of Procedure UNT-4-002, Revision 1, requires the use of field controlled copies of te'chnical documents "for any quality related activity that can affect the plant" including station modification packages.
i Contrary to the above, on May 20, 1987, licensee personnel performing testing on the "A" essential chiller under Station Modification 615 were using uncontrolled wiring drawings of the essential chiller control circuitry.
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This is a Severity Level IV violation.
RESPONSE
(1) Reason For The Violation 1.
Procedure PE-2-006, Revision 8, Section 5.8.4.1 requires that modification packages include or reference written testing requirements. Depending on the complexity of the work, testing may be performed per a general test procedure or per detailed test instructions developed as part of the Station Modification Package.
In this instance, the Station Modification (SM-615) in Section VI, TESTING, recommended testing per general plant procedure ME-7-003, Control Circuit Testing & Maintenance after implementation of the changes in the Station Modification.
Testing on the "A" essential chiller was initiated in accordance with plant procedure ME-7-003.
The violation stems from the fact i
that the test procedure was not 'in-hand' at the time of test initiation. Maintenance Procedure MD-1-014, Section 5.2.13 and
i Attachment to W3P87-1729 Sheet 2 of 2
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Administrative Procedure UNT-4-009 Section 5.6.3 identify i
requirements for test procedures to be in the possession of test I
personnt.1 at the time of testing. This is considered a personnel
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error in not following plant procedures.
2.
In the course of testing the identified components, the test personnel had need to make reference to wiring diagrams in the
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Station Modification Package. 'This package was not immediately available at the test location during the test. The Action Engineer on location provided a working copy _ of the detailed drawing for reference to the testing personnel. This drawing was not controlled as required by plant procedures, however, it was the copy used to develop the controlled drawings. The
-l information on the drawings were similar, however, procedurally j
I the working copy was uncontrolled and thus in violation of plant procedures. This is considered a personnel error in not following procedures for use of controlled drawings.
For both items identified in the violation, Waterford 3 personnel
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failed to strictly follow procedures for maintenance and i
modification activities.
(2) Corrective Action That Has Been Taken
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A more detailed test procedure was developed to retest SM-615 and to minimize the need for drawings. Only controlled drawings were allowed during test performance. Work has been completed on all three chillers with satisfactory test results. QA surveillance were performed during the conduct of these tests. The electricians working on this job were counselled on their responsibilities with regard to not performing work or testing without required procedures as well as their responsibility for using field controlled copies of technical j
documents in the field.
j Additionally, a shop meeting was held the day after the event and these problems were discussed with all electricians present with emphasis on the mistakes made, how to prevent similar mistakes in the future, and the need for procedural compliance. The engineer involved and other engineers in the Engineering I&C department were counseled the day of the event on the need to adhere to procedures for proper control of drawings in the field.
j (3) Corrective Action To Be Taken The details of this event and the corresponding corrective action will be discussed with personnel in the other Maintenance and Engineering departments.
(4) Date When Full Compliar" e Will Be Achieved Testing on SM-615 was completed on June 15, 1987 and appropriate personnel counselling was performed the day after the event.
Counselling of-other maintenance and engineering personnel will be achieved by September 1, 1987.