ML20040G953

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

ML20040G953
Person / Time
Site:	Waterford
Issue date:	12/23/1981
From:	Mclendon G LOUISIANA POWER & LIGHT CO.
To:	Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20040G942	List: ML20040G950 ML20040G953 ML20040G959
References
W3K81-0464, W3K81-464, NUDOCS 8202160658
Download: ML20040G953 (7)

Text

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December 23, 1981 G D. McLENDON Senior Vice President W3K81-0464 Q-3-A35.02.01 Mr. G. L. Madsen, Chief, Reactor Projects Branch U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012

SUBJECT:

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

Dear Mr. Madsen:

The following additional information regarding the inf ractions 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 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.

(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 cf Station Emergency Batteries A, B, and A/B had been overfilled.

The following information is submitted:

1. Corrective Action Taken and the Results Achieved:

High battery electrolyte level was identified several months prior to the August 17, 1981, NRC Inspection when procedure ME-DC-200 was in effect. The battery fill / level requirements in this procedure were ambiguous. ME-DC-200, Rev. 0 was revised to clarify battery fill level requirements by stating to " fill to the high level mark.

Do not overfill". ME-4-201, Rev. O and ME-4-211, Rev. I were approved on March 20, 1981, and issued for use on 8202160658 820121 PDR ADOCK 05000382 G PDR

Mr. G .L Mr.d3sn, Chisf Reactor Projects Branch . April 6,-1981, thus superceding ME-DC-200. ME-4-201 and ME-4-211 provide adequate' guidance for battery electrolyte level maintencnce. Electrolyte levels are returning to normal in that nearly all cells are now within the high and low level marks during float.

2. Corrective Action to Preclude Repetition:

LP&L procedures ME-4-201 and ME-4-211 are again being revised to state that "high electrolyte levels are expected and are considered normal during and after charges'and discharges due to increased temperature and gasification".

This is to clarify the difference between an " overfilled" condition and a " normal high" condition. . Correcting the specific gravity readings for 31evel (when out of the tolerance band) will also be added.

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 evaluation 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.

l The following information is submitted:

1. Corrective Action Taken and Results Achieved:

On 9/17/81 CIWA 813010 was initiated which described the I 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.

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Mr. G. L. Madsen, Chief Reactor Projects Branch (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 tenders the quality of an item unacceptable or 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 overfilling of the battery was not identified as a nonconformance as described in UNT-1-007.

The following information is submitted:

(Cl) No QC Review of CIWA #810990

1. Corrective Action Taken and Results Achieved:

SAP-08, Rev. 3 was in use at the time that CIWA 810990 was not reviewed by QC. .This CIWA was processed in accordance-with that revision which forwarded the CIWA's to QC for review, if the resolution " requires a physical change to a plant system".

No additional corrective action is necessary because SAP-08 was revised on June 17, 1981, to state "If the CIWA is system related (and is neither a question to ESSE

[ design question} nor a construction surveillance) delivers the CIWA to Quality Control". Quality Control " Reviews CIWA per UNT-1-007 for possible nonconformance". This revision of processing CIWA's to QC constitutes full compliance.

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.

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Mr. G. L. Madsen, Chief Reactor. Projects Branch . (C2) ~ 1mproper: Review of CIWA #810775 by'LP&L QA

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1. Corrective Action ~Taken'and Results Achieved:

Station Battery 3AB-S .was placed on . equalizing ~ charge on March 19', 1981. The data record form (date March 19, 1981) identified a high electrolyte level condition thus CIWA 810775 was initiated. Quality control reviewed this CIWA on. March 27,'1981, and it was determined that a Nonconformance Report was not required based upon previous .

battery experience and the fact that CIWA 810775' stated to

" accept as is, normal gasification will lower the level".

High levels are normal during a charge due ' to the increased

temperature and gasification.

2. Corrective' Action Taken to Preclude Repetition:

Battery procedures ME-4-201 (Weekly), ME-4-211 (Quarterly) and ME-4-231 (Equalizing Charge) are being revised to differentiate between high levels resulting from charging / discharging and high levels due to overfilling.

Initiation of a CIWA for high levels due to charging /

discharging will not be required.- Full compliance will be achieved upon revision approval of these procedures.

3. Date When Full Corrective Action was Achieved:

November 30, 1981,

2. Criterion V of 10CFR50, Appendix B, states that activities af fecting quality shall be prescribed by instruction, 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.

Ebasco Care and Maintenance Instructions (CMI) for .the safety-related equipment require that motor ' space heaters be energized, that equipment be protected from damage, and that dust covers.be provided.

Contrary to the above, on September 3 and 4,1981, the NRC inspectors observed that:

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Mr. G. L. Madsen, Chief Reactor Projects Branch (a) Motor space heaters were not energized as required on:

Low Pressure Safety Injection (LPSI) A Containment Spray Pump B Charging Pump (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 that conditions are identified and corrected on a more timely basis.

3. Date When 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.

Mr.' G. L. Madsen, Chief Reactor Projects Branch 1. Corrective Action Taken and Reyjlts Achieved:

All motors will b'e inspected and dust covers replaced, as necessary.-

2. Corrective Action to Preclude Repetition:

Same as Item (a) above. Also, the monthly check, as required by Ebasco CMI'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.

Very truly yours, G. D. McLendon Senior Vice President i CDMcL: DBL:TFG:ned 4

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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 G. D. .McLendon being duly sworn, hereby deposes and says that he is Senior Vice President of Louisiana Power & Light Company; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached response (W3K81-0464)~

to the Notice of Violation identified in NRC Inspection Report 81-23; that he is f amiliar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.

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G. D. McLendon '

Senior Vice President STATE OF LOUISIANA)

) ss PARISH OF ORLEANS )

Subscribed and a r before me, Notary Puplic in and for the Parish and State above named thi . day of f r, /),y;/r m ,1981.

&"Not - ba P W ie M,Co +ssi.n.a,ir.b/ w bnT

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