IR 05000382/1988016

Discusses Insp Rept 50-382/88-16 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty

ML20207F783
Person / Time
Site:	Waterford
Issue date:	08/18/1988
From:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dewease J LOUISIANA POWER & LIGHT CO.
Shared Package
ML20207F789	List: IR 05000382/1988016 ML20207F794
References
EA-88-144, NUDOCS 8808230217
Download: ML20207F783 (4)

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N?g 4 UNITED STATES yT /; NUCLEAR REGULATORY COMMISSION

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REGloN IV k, / 611 RYAN PLAZA DRIVE. SUITE 1000 o,, ,,

ARLINGTON TEXA5 76011 NJG I 81988 Docket No.: 50-382 License No.: NPF-38 EA 88-144 Louisiana Power & Light Company ATTN: J. G. Dewease, Senior Vice President Nuclear Operations 317 Baronne Street New Orleans, Louisiana 70160 Gentlemen:

SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT 50-382/88-16)

This refers to the inspection conducted by personnel of the NRC Region IV office during the period of May 12-20, 1988, of activities authorized by NRC Operating License NPF-38 for Waterford Steam Electric Station, Unit 3. The inspection included review of the events which occurred on May 12, 1988, when problems with refueling water level instruments and ensuing low reactor coolant system (RCS) water level twice resulted in the loss of the operational train of shutdown cooling. During this inspection and subsequent followup, it was determined that certain of your activities were in violation of NRC requirements. On May 27, 1988, NRC Inspection Report 50-382/88-16 was issued which provided the details of the inspection performed May 12-20, 1988. An enforcement conference was held with members of your staff in the NRC Region IV office on June 14, 1988, to discuss the issues related to these event Violation A in the enclosed Notice of Violation and Proposed Imposition of CivilPenalty(NOV)involvesalossofcontrolofreactorvesselwaterlevelon May 12,1988, that resulted in the cavitation and subsequent loss of the operating shutdown cooling pump. The inaccurate level indication resulted from the improper installation and care of the tygon tube level instrument. It is significant that this event occurred twice on May 12, 1988, on two separate operational shifts, and is repetitious of a previous significant condition adverse to quality which occurred in July 1986 (reference Licensee Event Report 50-382/86-15). In the July 1986 event, inaccurate reactor vessel water level indication, brought about in part by tygon tube deficiencies, resulted in the vortexing, cavitation, and loss of both shutdown cooling pumps. As a result of this earlier event, Waterford-3 operations management should have 8808230217 800818 PDR G

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I CERTIFIED MAIL l RETURN RECEIPT REQUESTED . - . .. - - ... - - - - - - - -.-.. ~ . - . . - - ... :$

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i Louisiana Power & Light Company -2-r B

exercised a heightened degree of awareness crior to conducting part-loop operations on May 12, 1988, to ensure that ,ae reactor coolant drain-down procedure adequately detailed the necessary steps for correctly performing such an operation, and that plant operators were trained and briefed to properly I implement this procedure. Your implementation of corrective actions taken in :

response to the July 1986 event was not adequate in that it did not preclude '

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the May 12, 1988, event. This is a violation of Criterion XVI, Appendix B to 10 CFR 5 Further, your inadequate implementation of comitments in response to NRC Generic Letter 87-12, "Loss Of Residual Heat Removal (RHR) While The Reactor Coolant System (RCS) Is Partially Filled," contributed to your inability to preclude repetition of this significant condition adverse to quality. Generic Letter 87-12 was issued, in part, in response to the April 10, 1987, Diablo '

Canyon loss-of-RHR event to emphasize the safety significance that the NRC places on potential loss of shutdown cooling events and loss of control of reactor vessel level during part-loop operation Violation B in the enclosed NOV involves four examples of the failure to follow Waterford-3 procedures. This failure to follow procedures resulted in your conducting part-loop operations on May 12, 1988, without: (a) using the refueling water level indicator system (RWLIS) and the heated junction thermocouple (HJTC) level indicator system; (b) performing the reactor coolant drain-down procedure prerequisite of blowing down the RWLIS level detector .

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referencelegs;(c)backfillingandventingtheRWLIS;and(d) detecting,upon initial inspection, that approximately 30 feet of excess refueling level

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indication system (RLIS) hose contained entrapped air. Although the reactor coolant drain procedure was deficient, enough information was available to the operators to have prevented the loss of control of reactor vessel water level and the subsequent loss of the operational SDC pump if your operations staff had properly implemented these procedures. This is a violation of Criterion V, Appendix B to 10 CFR 50, in that you failed to follow procedures developed pursuant to this requiremen During the enforcement conference, your staff emphasized the fact that shutdown cooling was never actually lost on May 12, 1988. Although the NRC staff agrees with this conclusion, it needs to be emphasized that as a result of the failure to follow procedures on the part of the Waterford-3 staff and insufficient corrective actions for a previous event, a loss of shutdown cooling could have occurred just as it did 2 years ago. The fact that your operators continued to drain the reactor coolant system with the available water level instruments indicating significantly different reactor vessel water levels is a significant concern. The NRC staff is also concerned that the corrective actions you proposed at the enforcement conference were shortsighted insofar as they did not appear to address the broader implications associated with the potential for a sustained loss of shutdown coolin To emphasize the concern with your inadequate corrective actions to preclude repetition of 'a significant condition adverse to quality and your failure to establish and implement procedural requirements for significant comitments

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made to the NRC, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Regional Operations, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Fifty Thousand Dollars ($50,000) for the violations described in the enclosed Notice, in accordance with the "General Statement of Polic and Procedure for NRC Enforcement Actions," 10 CFR Part 2

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AppendixC(1988)y(EnforcementPolicy),theviolationsdescribedinthe enclosed Notice have been categorized in the aggregate as a Severity Level III problem. The base value of a civil penalty for a Severity Level !!! violation or problem is $50,000. The escalation and mitigation factors in the Enforcement Policy were considered and no adjustment has been deemed appropriat You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. In formalizing your corrective actions, you should address all previous comitments made to the NRC in this area and your ability to fully implement these commitments. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether more stringent enforcement action is necessary to ensure lasting corrective action in this are In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Roo The response directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by -

the Paperwork Reduction Act of 1980, Pub. L. No. 96 51

Sincerely,

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obert D. Martin Regional Administrator Enclosure:

Appendix - Notice of Yiolation and Proposed Imposition of Civil Penalty cc w/ enclosure:

(Seenextpage)

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Louisiana Power & Light Company -4-cc w/ enclosure:

Louisiana Power & Light Company '

ATTN: G. E. Wuller, Onsite Licensing Coordinator P.O. Box B Killona, Louisiana 70066 Louisiana Power & Light Company ATTN: N. S. Carns, Plant Manager P.O. Box B Killona, Louisiana 70066 Middle South Services ATTN: Mr. R. T. Lally P.O. Box 61000 New Orleans, Louisiana 70161 Louisiana Power & Light Company ATTN: R. F. Burski, Acting Manager Nuclear Safety and Regulatory Affairs 317 Baronne Street P.O. Box 60340 New Orleans, Louisiana 70160 Louisiana Radiation Control Program Director t