View source for W3P87-1010, Forwards Response to Violation 8628-01 Noted in Insp Rept 50-382/86-28.Corrective Actions:Procedure ME-7-002 Revised to Require Removal of Any Shorting Blocks That Could Have Been Previously Installed

{{Adams
| number = ML20206R881
| issue date = 04/16/1987
| title = Forwards Response to Violation 8628-01 Noted in Insp Rept 50-382/86-28.Corrective Actions:Procedure ME-7-002 Revised to Require Removal of Any Shorting Blocks That Could Have Been Previously Installed
| author name = Cook K
| author affiliation = LOUISIANA POWER &amp; LIGHT CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF ADMINISTRATION &amp; RESOURCES MANAGEMENT (ARM)
| docket = 05000382
| license number = 
| contact person = 
| document report number = W3P87-1010, NUDOCS 8704220285
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 3
}}

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              'Louisiama POWER & LIGHT  / aize NEW noNNeS7        seere.701e0 ORLEANS, LOUISIANA  .o. eox e0340 (504)595-3100
  $EONEvsYIU April 16, 1987 W3P87-1010 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 86-28 Attached is the Louisiana Power and Light Company (LP&L) response to Violation No. 8628-01 identified in Inspection Report No. 86-28.
If you have any questions on the response, please contact G.E. Waller, Operational Licensing, at (504) 464-3499.
Very truly yours, C
fi K.W. Cook adIb .{s Nuclear Safety and Regulatory Affairs Manager KWC:KLB:ssf cc:  R.D. Martin, NRC Region IV G.W. Knighton, NRC-NRR J.H. Wilson, NRC-NRR NRC Resident Inspectors Office E.L. Blake W.M. Stevenson 8704220285 870416                                                                \
PDR   ADOCK 05000382 O                   PDR "AN EQUAL OPPORTUNITY EMPLOYER"                               j

  ..                                                                    Attachmtnt to W3P87-1010 Sheet 1 of 2 LP&L Response To Violation No. 8628-01 VIOLATION NO. 8628-01 Failure to Follow Procedures for Control of Temporary Modifications 10 CFR Part 50, Appendix B, Criterion V, requires that activities affecting quality shall be accomplished in accordance with approved procedures. ANSI N18.7-1976, to which the licensee is committed, Section 5.2.2, requires that procedures shall be followed. Licensee Procedure UNT-5-004, Revision 3, " Administrative Procedure Temporary Alteration Control," identifies                    I specific requirements for the control and restoration of temporary modifications. This procedure specifies that procedures requiring temporary modifications shall either appropriately reference UNT-5-004, or contain the specified controls for temporary modifications.
Contrary to the above, the NRC inspector on November 19, 1986, identified that licensee Procedure ME-7-002, Revision 5, " Maintenance Procedure Molded-Case Circuit Breakers and Thermal Relays," did not contain required controls for temporary removal and replacement of current limiting fuses during performance testing of the circuit breakers, nor reference UNT-5-004.
This is a Severity Level IV violation.

===RESPONSE===
(1) Reason for the Violation This violation cites procedure ME-7-002, Molded Case Circuit Breakers and Thermal Relays, "for not containing required controls for temporary alterations as specified by UNT-5-004, Temporary Alteration Control". Although ME-7-002 inadvertently omitted steps that would ensure proper restoration of equipment to its design operating
;                  condition, we do not feel that it violated UNT-5-004. UNT-5-004 is a procedure written to control temporary alterations to existing, installed, operational plant equipment. ME-7-002 is a procedure which removes a piece of equipment and bench tests it. Temporary changes, modifications, disassembly or reassembly of the equipment once removed from the plant is not considered a temporary alteration and should not fall under the requirements of UNT-5-004. Nonetheless, procedures controlling maintenance in these situations must be adequate to ensure complete and proper restoration of equipment; this is the area in which ME-7-002 was deficient.
(2) Corrective Action That Has Been Taken ME-7-002 has been revised to require removal of any shorting blocks that could have been previously installed, re-installation of fuses and independent verification of the same. The possibility that shorting devices could have been left in breakers previously tested by this procedure has also been considered. We are confident that this is not the case based on the following:
:.                                                           Attachmsnt to W3P87-1010 Sheet 2 of 2
: a. Section 8.6 (Thermal Element Time Delay Test) of ME-7-002 did contain a note requiring removal of shorting devices and           j re-installation of fuses. Section 8.6 is required each time the breaker is tested.   (Section 8.5, Instantaneous Trip Test, had no such provisions, but is only required on newly installed breakers.)
: b. To date there have been no instances of shorting devices found in breakers removed from service for maintenance.
All of the Electrical Maintenance procedures which cover circuit breaker testing (ME-3-315, ME-3-325, ME-3-327, ME-3-330, ME-4-111, ME-4-131, ME-4-143, ME-4-145, ME-4-146, ME+4-155, ME-7-100) have been reviewed and no similar deficiencies were found.
(3) Corrective Action To Be Taken No further action deemed necessary (4) Date When Full Compliance Will Be Achieved Full compliance was achieved on April 8, 1987.}}