IR 05000382/1985020

Informs That Violation Noted in Insp Rept 50-382/85-20 Re Procedure OP-03-014, Control Room Heating & Ventilating, Valid Due to Listed Reasons.Sys Should Be Evaluated to Determine When Safety Reviews Should Be Conducted

ML20209H239
Person / Time
Site:	Waterford
Issue date:	10/31/1985
From:	Martin L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Leddick R LOUISIANA POWER & LIGHT CO.
Shared Package
ML20209H244	List: IR 05000382/1985020 W3P85-1480, Responds to NRC Re Violations Noted in Insp Rept 50-382/85-20.Corrective Actions:Shift Supervisors Informed of Responsibility to Ensure That All Surveillances Satisfactorily Performed & Reviewed Prior to Making Changes
References
NUDOCS 8511110049
Download: ML20209H239 (4)

Text

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OCT 311985 -

In Reply Refer To:

Docket: 50-382/85-20 L;

Lou isiana Power & Light Company

ATTN: R. S. Leddick, Sr. Vice President Nuclear Operations 142 Delaronde Street New Orleans, Louisiana 70174 Gentlemen:

Thank-you for your letter of September 27, 1985, in response to our letter and Notice of-Violation dated August 29, 1985. We note in your response that you feel that 8520-04 should not have been classified as a violation and that you request' that the violation be withdrawn. Based on your request we have rereviewed the facts associated with the violation and have conducted-additional discussions with members of your staff and o'ur staff. We have concluded-that the violation was valid for the reasons stated belo STATEMENT OF-VIOLATION NO. 8520-04 Title 10 ofjthe Code.of. Federal Regulations, Part 50.59, requires, in part, that the , licensee shall perform and maintain a written safety:

. evaluation which provides the basis for the determination that the changes in the facility,;as described in the Safety Analysis Report (SAR), do not involve an unresolved safety questio '

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Contrary: to the. above, on June 25; 1985, the NRC inspector noted that LP&L Operating Procedure OP-03-014. " Control Room Heating and Ventilating,"

provided- the normal lineup of the emergency outside air intake valves which was different-than'the lineup described in the Final Safety Analysis L Report (FSAR).' The NRC inspector found no 'vidence that a oroper 10 CFR 50.59 review was conducted to calculate dose, rates which an operator would experience ~1f.these valves had to be manually opened from outside the 4 c7ntrol' roo L_

Th'is is aLSeverity Level'IV violation (50-382/8520-04).

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E LP&L RESPONSE:TO THE, VIOLATION-

. "Although the Emergency Outside Air Intake valve positions specified in Operating Procedure OP-03-014, Revision 1, Control Room Heating and Ventilating, differs from the normal operating mode described in the Final-Safety Analysis Report (FSAR), the valve positions addressed by this violation are described in the FSAR as the Toxic Gas Emergency Operating Mode (Figure 6.4-3). Because.this valve configuration is already H described in the FSAR, a 10 CFR 50.59 review was not required. 'However, a

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Louisiana Power & Light Company -2-safety review was performed by LP&L, the results of which revealed that

'the valve lineup described in the above violation did not constitute an unresolved-safety question. This was not a surprise since it already

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represented an operating condition allowed in the FSA LPSL feels that as a result this item should not be a violatio It is requested that

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this violation be cancelled." '

NRC REEVALUATION OF VIOLATION 8520-04

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10 CFR 50.59 authorizes licenseen to make changes to their facility, as -

described in the safety analysis report, without prior Coninission approval unless the proposed change involves a change in the Technical

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Specifications or involves an unreviewed safety. question. . In Addition, this regulation requires that the licensee maintain a record of these changes, including a written safety evaluation.which provides the bases for the detennination that the change does not involve an unreviewed safety questio As we understand it, the control room ventilation system, as described in

. the FSAR, is designed to operate in three modes. These are the normal mode and two emergency modes; high radiation mode and toxic chemical mod The system is designed to have automatic isolation with provisions for manual initiation from the control room, of filtered pressurization, recirculation and partial filtration. As a part of this design, the emergency outside air intake valves are arranged in a series / parallel configuration with each series valve powered by a different emergency power source and with one valve normally open and the other valve normally closed. Since the valves are fail-as-is, the system is protected in that the failure of an emergency power source would not preclude the ability to open the intake for control room pressurization nor to close the intake for control room isolatio Due to spurious signals on radiation and gas monitors, you have elected to

, operate.the control room ventilation system in the toxic chemical mod In this mode, all four of the series parallel emergency outside air intake valves are closed, as opposed to the normal configuration of one open/one closed as described above. This mode was established by your procedures as your new normal mede of operatio In reviewing this change in your method of operation, the NRC inspector could find no evidence that you had considered the impact of routine

. operation in the toxic chemical mode. Especially the impact of a loss of one power source during a radiation emergency where the control roo . ventilation system may need to be realigned to the pressurization / filtered / partial filtration line up. In addition, some impact could be felt.should you choose to select one or the other

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emergency outside air intake in an attempt to avoid potential

' radioactivity'at one of the widely separated intakes. Discussions with

.several licensed individuals indicated that they were not aware of the alternate power supply arrangement, and may not have been able to respond appropriatel ~

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x s , Based'on the~ above reevaluation, we have concluded that you had not, at'

y the time of the inspection, conducted a review as described in i

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. 10 CFR 50.59. In addition,ie note that, when you changed your procedure, a' decision was made that no 50.59-review was required. In our. Notice of :

. Violation, noiresponse was required based on your immediate corrective actions to revise the operating procedure and _to conduct,a 50.59. review of

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i '. .this issue after it; w'as identified by the NRC. . However,* based :on you current response, we conclude that you should evaluate your systsm for

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'. , s detennining when safety reviews:(per 10 CFR 50.59) should be conducted in

. order to avoid future occurrences. '

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VIOLATION 8520-05-

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We-have revi_ewed your reply to violation 8520-05 and find it responsive to the concerns raised in our Notice of. Violatio We.will r' eview the' implementation of your corrective actions on' the above

,  : violations during a future inspection-to determine that full compliance has-been achieved and will be maintained.

If you have any questions or additional infonnation that you feel should be considered,'please cal " original signed By:

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' L. E. MARTIN"

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r L.-E. Martin, Acting Chief

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Reactor Projects' Branch

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ATTN: G. E. Wuller, Onsite

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Licensing. Coordinator

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ATTN: 'R.-P. Barkhurst, Plant _ Manager-P. 0. - Box B -

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ATTN: 1K. : W. ' Cook, . Nuclear Support '

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and Licensing Manager- ' "

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b New Orleans;' Louisiana ~ - 70174:

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