IR 05000382/1989009

Discusses Insp Rept 50-382/89-09 on 890308-09 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000.Violation Re Failure to Follow Requirements for Testing HPSI Pump B Noted

ML20246A819
Person / Time
Site:	Waterford
Issue date:	06/28/1989
From:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dewease J LOUISIANA POWER & LIGHT CO.
Shared Package
ML20246A825	List: IR 05000382/1989009 ML20246A833
References
EA-89-069, EA-89-69, NUDOCS 8907070101
Download: ML20246A819 (4)

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UNITED STATES y% -, NUCLEAR REGULATORY COMMISSION

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<, 8 611 RYAN PLtlA DRIVE. SUITE 1000 ARLINGTON, TEXAS 76011 JUN 281989 Docket: 50-382 License: NPF-38 EA 89-69 Louisiana Power & Light Company .

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ATTN: J. G. Dewease, Senior Vice President  !

Nuclear Operations 317 Baronne Street New Orleans, Louisiana 70160 Gentlemen:

SUBJECT: MOTICE OF VIOLATION AND PROPOSED IMPOSITION OF $50,000 CIVIL PENALTY (NRC INSPECTION REPORT N0. 50-382/89-09)

This is in reference to the NRC inspection conducted from March 8-9, 1989, at the Waterford Steam Electric Station, Unit 3, located in Taft, Louisiana, and to NRC's discussion of the inspection findings with LP&L officials at an enforcement conference in Arlington, Texas, on May 8, 198 As you know, this inspection focused on surveillance testing and maintenance of the plant's "B" high pressure safety injection (HPSI) pump and on a low recirculation flow condition associated with this pump. The results of the inspection were documented in NRC inspection report No. 89-09, dated April 6, 198 During the May 8 enforcement conference, apparent violations resulting from this inspection were discussed. These included the apparent failure to test the "B" HPSI pump in accordance with the requirements of plant Technical Specification (T.S.) 4.0.5.a and the failure to perform proper maintenance on the pum NRC has concluded that LP&L's failure to follow all requirements associated with the testing of the "B" HPSI pump resulted in a significant violation of Waterford's Technical Specifications in that LP&L failed to assure the !

operability of the HPSI system, a system i.nportant to maintaining plant cooling under certain emergency conditions. Had LP&L established a surveillance testing program that met the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, a code to which you were bound in .0.5.a, the "B" HPSI pump would have been declared inoperable in November 1988, when the low recirculation flow condition was first discovered, and the cause of the condition would have been identified and corrected. Your June 7,1989 letter has been reviewed and been evaluated. The signficant regulatory issue in this case is the failure to identify a Technical Specification defined condition of inoperability and the significance of that issue remains unchanged despite your after-the-fact arguments regarding pump operability. Further, given the pre- ]

liminary findings from the internal inspection of the pump it appears that it g was merely fortuitous that more significant degradation of pump performance had not occurre {'DR ADOCK0500g2 f([ l

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Because the surveillance testing program that LP&L had in place in November

!. 1988 did not meet the necessary requirements, LP&L failed to adequately assess the low recirculation ficw condition. This failure resulted in operating the plant with an important component in a degraded condition and in violation of T.S. 3.5.2, which recuires two HPSI pumps to be operable. In fact, this condition was not adequately addressed until the NRC noted it during a maintenance inspection in late January 198 ,

l In addition, this inspection disclosed various deficiencies associated with maintenance on the "B" HPSI pump. These deficiencies included the failure to adequately use vendor supplied information, the improper installation of the HPSI pump flow orifice plate, the improper setting of the drum clearance, and '

the improper omission of slinger ring checks. The above deficiencies involved a number of less significant violations of regulatory requirements and they will be addressed in separate correspondenc The NRC has classified the violation in the enclosed Notice of Violation at Severity Level III in accord with Supplement I of the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (Enforcement Policy), as published in the Federal Register on October 13, 198 To emphasize the importance of assuring surveillance procedures have adequate acceptance criteria and promptly assessing conditions that may affect the operability of important safety systems, I have been authorized, after consulting with the Director, Office of Enforcement, eno the Deputy Executive Director for Nuclear Materials Safety, Safeguards and Operations Support, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Fifty Thousand Dollars ($50,000) for the violation described in the enclosed Notic The base amount of a Severity Level III violation is $50,000 The civil a penalty adjustment factors in Secticn V.B of the Enforcement Policy were I considered but no adjustment was made. In our view, LP&L's good past performance in the area of surveillance testing was balanced aoainst the fact that LP&L failed to identify the significance of the low recirculation flow condition on the "B" HPSI pump. Moreover, despite the fact that LP&L was reminded, in a May 20, 1988 NRC relief request denial, that the required parameters of Table IWP-3100-2 (including recirculation flow) needed to be recorded and evaluated to determine pump operability, it was not until the NRC inspector noted this in late January 1989 that acceptance criteria were adopte 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 teken and any additional actions you plan to prevent recurrence. The NRC will review your response to this Notice, including your proposed corrective actions, and the results of future inspections to determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirement )

In accordance with Section 2.790 of the NPsC'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 fy n ~;-

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The responses ' 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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hk t'O Robert D. Martin-fff Regional Administrator Enclosure:

Notice of Violation an Proposed-Imposition f-of Civil Penalty cc w/ enclosure:

Louisiana Radiation Control Program Director NRC'Public Document Room Local Public Document Room

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