ML20040G950

Responds to NRC 811014 Ltr Re Violations Noted in IE Insp Rept 50-382/81-23.Corrective Actions:Battery Electrolyte Levels Corrected & Procedures ME-4-201 & ME-4-211 Being Revised

ML20040G950
Person / Time
Site:	Waterford
Issue date:	11/13/1981
From:	Aswell D LOUISIANA POWER & LIGHT CO.
To:	Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20040G942	List: ML20040G950 ML20040G953 ML20040G959
References
W3K-81-0410, W3K-81-410, NUDOCS 8202160652
Download: ML20040G950 (6)

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LOUISIANA 24a OuAnONOe S1nn1 sm P O W E R & L 1 G H T! P O BOX 6008

• NEW OnLEANS. LOUISIANA

• [504) 366 2345 70174 UTIUTIES SYSTEM November 13, 1981 u, ,, ,t.%,. %

W3K-81-0410 Q-3-A35.02.01 Mr. K. V. Seyfrit, Director, Region IV U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012

SUBJECT:

Waterford SES Unit 3 USNRC Inspection Report 50-382/RPT 81-23

Dear Mr. Seyfrit:

The following information regarding the infractions cited by the USNRC Inspectors in IE Inspection Report No. 50-382/Rpt. 81-23 dated October 14, 1981, is herewith submitted.

1. Criterion V of 10 CFR 50, Appendix B, states that activities af fecting quality shall be prescribed by instructions, procedures or drawings of a type appropriate to the circumstances and that these activities shall be accomplished in accordance with these instructions, procedures or drawings.

(a) " Station Battery Weekly Maintenance", ME-4-201, and " Station Battery Quarterly Maintenance", ME-4-211, require that the cells of the station batteries not be overfilled.

Contrary to the above, on August 17, 1981, the NRC inspectors observed that the cells of Station Emergency Batteries A, B and A/B had been overfilled.

The following information is submitted:

1. Corrective Action Taken and the Results Achieved:

Applicable personnel were given instructions concerning procedure requirements. Battery electrolyte levels are now within accept-able limits.

2. Corrective Action to Preclude Repetition LP&L Procedures ME-4-201 and ME-4-211 are being revised to clarify the differenc between an " overfilled" condition and a " normal KOhhohB2 PDR 1 l

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r Mr. K. V. Seyfrit, Director, Region IV high" condition. The method to be used to correct the specific gravity reading will also be added. Personnel will be trained in the application of these revised procedures.

3. Date When Full Corrective Action Was Achieved:

November 30, 1981 (b) " Station Battery Weekly Maintenance", ME-4-201, and " Station Battery Quarterly Maintenance", ME-4-211, require that minor deficiencies that can be corrected (in accordance with the above procedures), be corrected and that major deficiencies be identified on a Condition Identification Work Authorization '(CIWA) for evalua-tion and repair.

Contrary to the above, on August 17, 1981,'the NRC. inspector observed that a CIWA had not been written for the A battery.

The following information is submitted:

1. Corrective Action Taken and Results Achieved:

On 9/17/81 CIWA 813010 was initiated which described the high electrolyte level condition in battery system 3A-S.

2. Corrective Action to Preclude Repetition:

Personnel were instructed in proper documentation of deficiencies.

It was emphasized that personnel were not to assume that a deficiency had been reported when the same deficiency had been reported on a like component.

3. Date When Full Corrective Action Was Achieved:

September 10, 1981 .

(c) Startup Administrative Procedure SAP-08, " Condition Identification and Corrective Action", requires that quality Control review each CIWA per UNT-1-007, " Preparation and Processing Discrepancy Notices and Nonconformance Reports".

UNT-1-007 describes a nonconformance as a deficiency that renders the quality of an item unacceptable of indeterminate and describes a failure to follow inspection or test procedures as examples.

Contrary to the above, CIWA 810990 was not reviewed by Quality Control and CIWA 810775 was improperly reviewed in that the over-filling of the battery was not identified as a nonconformance as described in UNT-1-007.

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Mr. K. V. Seyfrit, Director, Region IV The following information is submitted:

(Cl) No QC Review of CIWA #810990

1. Corrective Action Taken and Results Achieved:

No corrective action is required since SAP-08, Rev. 3 which was in effect at that time required a QC review-only when the resolution required a physical change to a plant system. This problem was not considered a physical change to a plant system.

2. Corrective Action Taken to Preclude Repetition SAP-08 Rev. 4 was issued on June 17, 1981 to state that if a CIWA relates to a safety related item, a QC review is required.

3. Date When Full Corrective Action Was Achieved:

June 17, 1981 (C2) Improper Review of CIWA #810775 by LPL QC

1. Corrective Action Taken and Results' Achieved:

No corrective action is required. QC's review of CIWA 810775 on March 27, 1981 determined that a nonconformance report was not required. This determin-ation was based on prior experience with battery systems and the interpretation of what constitutes a nonconformance.

as defined.hy UNT-1-007.

2. Corrective Action Taken to Preclude Repetition N/A

3. Date When Full Corrective Action Was Achieved N/A

2. Criterion V of 10CFR50, Appendix B, states that activities affecting quality shall be prescribed by instructions, procedures or drawings of a type appropriate to the circumstances and that these activities shall be accomplished in accordance with these instructions, procedures or drawings. i <

Ebasco Care and Maintenance Instructions. (CMI) for the safety-related

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equipment require that motor space' heaters he energized,'that equipment be protected from damage and that' dust covers be provided.

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Mr. K. V. Seyfrit, Director, Region IV Contrary to the above, on September 3 and 4, 1981, the NRC inspectors observed that:

(a) Motor space heaters were not energized as required on:

Low Pressure Safety Injection (LPSI) A Containment Spray Pump B Charging Pumps (CFSS) A, B and A/B The following information is submitted:

1. Corrective Action Taken and Results Achieved:

Motor space heaters were re-energized on LPSI Pump A, Containment Spray Pump B and Charging Pumps A, B and A/B.

2. Corrective Action to Preclude Repetition:

Gulf Engineering Company has put additional personnel on inspection duties, and they have been instructed to pay close attention to CMI's to assure that equipment is properly protected, as is practical, to prevent future damage and l that conditions are identified and corrected on a more timely basis.

3. Date Vhen Full Corrective Action Was Achieved:

Full compliance was achieved on September 7, 1981.

(b) Sight glasses were broken on Charging Pumps A and B.

1. Corrective Action Taken and Results Achieved:

Broken sight glass on Charging Pumps A and B was reported on Gulf Nonconformance Report Numbers 140 and 141.

2. Corrective Action Taken to Preclude Repetition:

Same as Item (a) above.

3. Date When Full Corrective Action Will Be Achieved:

Full compliance will be achieved two weeks prior to startup to prevent further breakage, as even with increased protection and inspection, broken sight glasses have been a continuing problem.

(c) Dust covers were missing from openings on Containment Spray Pump Motor A

1. Corrective Action Taken and Results Achieved:

All motors will be inspected and dust covers replaced as necessary.

Mr. K, V. Seyfrit.

Director, Region IV 2. Corrective Action to Preclude Repetition:

Same as Item (a) above. Also, the monthly check as required by Ebasco CIll's has been increased to every two or three weeks.

3. Date When Full Corrective Action Was Achieved:

Full corrective action was achieved on September 23, 1981. l I

If you have any questions concerning this response, please let us know. '

l Yours very truly, D. L. Aswell DLA/LLB/grf l

I' I

l

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In .the Matter of )

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Louisiana Power & Light Company ) Docket No. 50-382 Waterford 3 Steam Electric Station )

AFFIDAVIT D. L. Aswell being duly sworn, hereby deposes and says that he is Vice President -

Power Production of Louisiana Power & Light Company; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached response (W3K81-0410) to the Notice of Violation identified in NRC Inspection Report 81-23; that he is familiar with the content thereof; and that the matters set forth therin are true and correct to the best of his knowledge, information and belie l NY D'. L. Aswell STATE OF LOUISIANA)

) ss PARISH OF ORLEANS )

Subscribed and sworn to before me, a Notary Public in and for the Parish and State above named this /.~t ff/ day of //////fNAM - -

,1981.

y Fub My Commission expires M

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