ML20072E209

Responds to NRC Re Violations Noted in IE Insp Rept 50-382/82-27.Corrective Actions:Procedure SIT-TP-125 Successfully Completed for Steam Generators 1 & 2.Procedures Carefully Reviewed Prior to Performance

ML20072E209
Person / Time
Site:	Waterford
Issue date:	02/23/1983
From:	Maurin L LOUISIANA POWER & LIGHT CO.
To:	Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20072E195	List: ML20072E209
References
W3I83-0054, W3I83-54, NUDOCS 8303210610
Download: ML20072E209 (4)

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LOUISIANA f 242 OuoONoe srnter POWE R & L1G HT/ P O BOX 6000 NEW ORLEANS. LOUISIANA 70174. (504) 366-2345 NONsysYN)

t. V MAURIN February 23, 1983 vee Presxient Nuclear operatens W3I83-0054 Q-3-A35.02.01 Mr. G. L. Madsen, Chief Reactor Projects Branch 1 Region IV f

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U. S. Nuc1 car Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012 s

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SUBJECT:

Uaterford SES Unit 3 USNRC Inspection Report 50-382/82-27

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Dear Mr. Madsen:

Pursuant to the provisions of 10 CFR 2.201, the following info tio regarding the violation cited by the USNRC Inspectors in the subject inspection report dated January 18, 1983 is hereby submitted:

Failure to Follow Procedures During the Steam Generator Hydrostatic Test Criterion V of 10 CFR 50, Appendix B, requires that activities affecting quality be accomplished in accordance with prescribed instructions or procedures.

1.

Procedure SIT-TP-125 " Steam Generator Ilydrostatic Test,"

Section 7.2.1.2.1 requires that a 2-inch firehose be attached to the vent rig fitting at 2MS-V668-1 (MS-101 A). The hose was to be routed to the containment sump to allow the excess water to be collected.

Contrary to the above, the 2-inch firehose was not attached to the vent rig fitting and, as a result, when Steam Generator 1 was topped off, a substantial amount of water was allowed to spray into the containment.

2.

Prior to Steam Generator 1 pressurization, Section 7.2.1.3.5 of the same procedure called for the manual vent on the temporary relief /llege gauge rig to be shut when water issued from Steam Generator 1..1.5 of Procedure SIT-TP-125 shows the manual vent (SGl) is upstream of the rupture disk.

Contrary to the above, the manual vent (SG1) was not shut but instead, vent (SG3), which is downstream of the rupture disk, was shut. The result of this action was the rupture disk ruptured and water was sprayed into the containment because it had not been valved out as intended by the procedure.

This is a Severity Level V Violation.

(Supplement II.E) (382/8227-01) 8303210610 830316 PDR ADOCK 05000382 O

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Mr. G. L. Madsen W3I83-0054 Page 2'

Response

Item 1-Section 7.2.1.2 of Secondary Hydrotest Procedure S1T-TP-125 Rev. 2 was written'to accomplish heatup of the Steam Generator secondary side water inventory to assure a generator metal temperature of greater than the minimum pressurization temperature of 100*F throughout Steam Generator pressurization.

The step requiring attachment of a two inch firehose (7.2.1.2.1) was intended to accomodate expected flow due tol thermal expansion of the generator secondary side fluid inventory during hestup from ambient to 150*F or greater, not for venting the unit during initial fill (see Section 7.2.1.1).

The note preceeding Section 7.2.1.2 required skipping Section 7.2.1.2 if the generator temperature was greater than or equal to 150*F at this point in the procedure. The Chronological Log entry of 0819 hours0.00948 days <br />0.228 hours <br />0.00135 weeks <br />3.116295e-4 months <br />, October 12, 1982, for the completed procedure SIT-TP-125 Rev. 2, indicated that Steam Generator 1 had already achieved a temperature of greater than or equal to 150*F by virtue of operating the Reactor Coolant Pumps and a heated Reactor Coolant System per procedure SIT-TP-100.

Consequently, as required by SIT-TP-125 Rev. 2, no part of Section 7.2.1.1, including Step 7.2.1.2.1 requiring attachment of a hose, was never performed.

1) Corrective Steps Which Have Been Taken and Results Achieved:

S1T-TP-125 has been successfully completed for both Steam Generator #1 and #2 therefore no immediate corrective action was deemed necessary.

2) Corrective Steps Which Will Be Taken To Avoid Further Violations:

The root cause of the violation in this case was determined to be due to failure of the procedure to adequately address all possible plant conditions which might be encountered during the test sequence. The installation of the fire hose should have been included as an initial condition in the procedure. A memo will be distributed to the Waterford 3 Startup Croup to advise the Startup Engineers to:

a) Carefully review procedures prior to-performance to ensure that procedure steps are properly sequenced.

b) Prior to commencing testing consider how changing plant conditions may affect test performance.

c) Ensure that the test procedure correctly identifies equipment (valves, breakers, pumps, etc.) to be manipulated.

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Mr. C. L.1Madsen.

'W3183-0054-

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-Additionally, the Lead.Startup Engineer or his designee will discuss the contents of the above described memo at the Waterford 3 Startup Group

-Training meeting.

3)- The Date When Full Compliance Will Be Achieved:

The memo discussed'abcve will be issued and discussed with the Startup Engineers by March 14, 1983.

Item 2 While Step 7.2.1.3.5 of SIT-TP-125 Rev. 2 calls for isolating "the manual vent valve on the tempo'rary relief /HeiseLgauge' rig", the step did 'not refer to.the valve by number nor to the applicable Attachment 8.1.5.- This may have contributed to ambiguity as to which valve was to be closed to complete the venting process.

The rupture disk was installed as part of the test apparatus as low pressure over-pressure protection for RCS cold hydro (SIT-TP-100) to provide secondary side protection in case of a primary to secondary tube leak with a full Steam Generator.- Since secondary hydro Steam Generator fill was delayed until after RCS hydro, the' temporary rupture disk was no longer of use.

Due to the close proximity of-the correct isolation valve,'SG1, flow through the temporary rupture disk (which activated, as intended, at less than 100 psig) was-isolated immediately. The amount of water escaping during the venting process was not sufficient to cause harm to permanent equipment or personnel.

1) Corrective Steps Which Have Been Taken and Results Achieved:

The valve misalignment was corrected immediately after activation of the rupture disk on October 12, 1982 and the procedure (SIT-TP-125) was successfully completed.

2) Corrective Steps Which Will Be Taken To Avoid Further Violations:

The violation in this case can be attributed to SIT-TP-125 not adequately providing specific information as to which valve on the temporary relief /

Heise gauge rig was to be isolated. As discussed in response to Item 1 above, a memo will be ie-ued to increase the Startup Engineers' attention to potential procedural ptoblems and the need to avoid them. This memo will be discussed at the V,terford 3 Startup Group training meeting.

~3) - The Date When Full Compliaice Will Be Achieved:

-The memo described will be issued and discussed with the Startup Engineers by; March 14, 1983.

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Mr. G. L. Madsen W3183-0054-Page 4' If you require further information:or discussion on this matter, please do not-' hesitate to contact me.

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L. V. Maur LVM/WAC keh cc:

E. L.~Blake, W. M. Stevenson i

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