W3P85-1470, Responds to NRC Re Violations Noted in Insp Rept 50-382/85-16.Corrective Actions:Offnormal Operating Procedure OP-901-022, High Activity in Component Cooling Water Sys, Modified to Reflect Isolation at High Temp

Responds to NRC Re Violations Noted in Insp Rept 50-382/85-16.Corrective Actions:Offnormal Operating Procedure OP-901-022, High Activity in Component Cooling Water Sys, Modified to Reflect Isolation at High Temp

ML20133K649
Person / Time
Site:	Waterford
Issue date:	09/03/1985
From:	Cook K LOUISIANA POWER & LIGHT CO.
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20133K641	List: IR 05000382/1985016 W3P85-1470, Responds to NRC Re Violations Noted in Insp Rept 50-382/85-16.Corrective Actions:Offnormal Operating Procedure OP-901-022, High Activity in Component Cooling Water Sys, Modified to Reflect Isolation at High Temp
References
W3P85-1470, NUDOCS 8510220227
Download: ML20133K649 (5)

Text

4 LOUISI AN A f 34a OuanONOe sinEe1 POWER & LIGHT / P O BOX 6008-

• NEW OnLEANS LOUISIANA 70174 . (5041 366 2345 NS$dvsSE September 3, 1985 W3P85-1470 A4.05 Mr. Robert D. Martin -

Regional Administrator, Region IV 9 {gggp  :

U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 J

, a ta tM i Arlington, TX 76011 'I 0; l 69 - d 985

Dear Mr. Martin:

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Subject:

Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report 85-16 Attached are the Louisiana Power & Light Company responses to Violations numbered 8516-01, 8516-02 and 8516-03 which were cited in the subject NRC Inspection Report.

These responses are submitted under affidavit as required by Section 182 of the Atomic Energy Act.of 1954, as amended.

If you have any questions on the response to the violations, please contact G.E. Wuller, Onsite Licensing, at (504) 464-3499.

Very truly yours, M L K.W. Cook Nuclear Support & Licensing Manager KWC:GEW:ses cc: NRC, Director, Office of I&E G.W. Knighton, NRC-NRR J.H. Wilson, NRC-NRR NRC Resident Inspectors Office B.W. Churchill W.M. Stevenson

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I(-/3/ 8510220227 851016

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Attachment to W3P85-1470 LP&L Response to Violations in Inspection Report No. 85-16  :

1. VIOLATION No. 8516-01 Control of Design Changes Criterion III of 10 CFR 50, Appendix B, requires that the licensee establish measures for the identification and control of design interfaces and for coordination among participating design organizations. These measures shall include the establishment of procedures among participating design organizations for the review, approval, release, distribution, and revision of documents involving design interfaces.

LP&L Administrative Procedure PE-02-006, Revision 5, " Station Modifications," paragraph 5.13.~1.4 requires that operational procedures and operational training be. completed prior to considering the modification packages fully implemented.

Contrary to the above, on April 10, 1985, the NRC inspector noted that LP&L Off-Normal Operating Procedure OP-901-022, Revision 1, "High Activity in Component Cooling Water Systems," had not been revised to reflect the modification installed under Station Modification Package (SMP) 760. This SMP changed the automatic isolation of component [

cooling water (CCW) to the reactor coolant pump (RCP) integral seal cooler from high pressure to high temperature. In addition, the modification provided the operators with the means to reopen, from the control room, a closed CCW isolation valve. This modification had been implemented by March 3, 1985.  !

This is a Severity Level IV violation (50-382/8516-01).  ;

Response To The Violation *

(1) Rea' son for Violation The lack of thoroughness for procedure review and failure to follow procedures are the reasons for the violation.

(2)- Corrective Actions Taken and Results Achieved .

I LP&L Off-Normal Operating Procedure OP-901-022, High Activity in l Component Cooling Water System, was modified to reficct the  ;

changes caused by Station Modification 760. The procedure  ;

, reflects automatic isolation to occur on high temperature. The  ;

procedure change was approved July 16, 1985. Appropriate j operations personnel have been instructed to be more thorough in j their review of procedure updates. '

4 (3) Corrective Actions That Will Be Taken i No further action is being considered.

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(4) Date When Full Compliance Will Be Achieved Compliance was achieved on July.16, 1985.

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2. VIOLATION NO. 8516-02 Failure to Follow Procedure Criterion V of 10 CFR 50, Appendix B, requires in part that activities affecting quality be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

LP&L Operating Procedure OP-7-001, Revision 4, " Boron Management System," paragraph 6.24.7 requires that when the boric acid concentrator temperature decreases to 200*F, as indicated on MC-ITIC-6381A(B), close the steam chest vent valve, BM 435 A(B) by using manual adjustment knob on Vent Valve Controller BM-ITIC-6403A(B).

Contrary to the above, af ter shutting down the boric acid concentrator (BAC) on March 29, 1985, the auxiliary operator failed to close boron management valve BM 435 A(B). This valve is only opened during periods of BMC operation to allow venting of noncondensable gases from the BAC steam chest to the radioactive system collection header. On April 3, 1985, a flow transient in the chemical volume control system (CVCS) letdown line caused a pressure spike downstream of the letdown orifice valves. CVCS relief valve CVC 115 opened as required reducing the pressure below the CVC 115 set point; however, the valve failed to properly insert resulting in approximately I gpm reactor coolant system (RCS) leakage to the radioactive system collection header. The header was physically aligned to one of the holdup tanks. The existing backpressure in the tank forced the RCS leakage into the BAC steam chest. The contaminated water then flowed to the gland seal leakoff tank (condensate return unit) and back into the condenser.

From the condenser, the contaminated condensate made its way into the polisher and steam generator via the normal secondary steam flow path.

This is a Severity IV violation (50-382/8516-02).

Response To The Violation (1) Reason for Violation Operator error in failure to follow procedure is the reason for the violation.

(2) Corrective Actions Taken and Results Achieved Station Modification No. 461 was implemented on August 7, 1985.

This modificatien removed the cross connection between the Boric Acid Concentrator Auxiliary Steam and the Holdup Tank Relief Header.

(3) Corrective Actions Which Will Be Taken An Operations Department Standing Instruction was generated to emphasize the need for proper use of procedures.

(4) Date When Full Compliance Will Be Achieved i

No further action is contemplated.

3. VIOLATION NO. 8516-03 i Fire Protection Criterion V of 10 CFR 50, Appendix B requires, in part, that activities affecting quality be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

LP&L Fire Protection Procedure FP-1-015. Revision 1 " Fire Protection System Impairments," paragraph 4.2, required that the shift supervisor / control room supervisor (SS/CRS) evaluate the fire impairment impact of Technical Specification and insure that applicable ACTION statements are complied with. In addition, the SS/

CRS is required to complete a fire protection impairment form and note the same in index log. Paragraph 3.2 of this procedure defines an impairment as "any condition that inhibits a fire appliance from properly performing its design function due to failure of components or deviations from the design position." ,

Contrary to the above, on May 15, 1985, the NRC inspector noted that fire door (D-221) to Boric Acid Concentrator Room B had been removed from service and that no evidence of a completed fire appliance  ;

impairment form or that the operability of the fire detector on at least one side of the inoperable assembly had been verified.

This is a Severity Level IV violation (50-382/8516-03)

Response To The Violation (1) Reason for Violation Failure to strictly adhere to procedural steps is the reason for the violation.

(2) Corrective Action Taken and Results Achieved I t

The shift supervisor / control room supervisor were unaware of Door I 221 being impaired prior to notification by the inspector. As soon as the inspector notified them, the control room perscnnel ,

evaluated the fire impairment. Also, the Operations l Superintendent instructed operations personnel to be more cognizant of fire doors and the subsequent impairment upon  ;

removal from service.  !

(3) Corrective Action That Will Be Taken No further actions are contemplated.

(4) Date When Full Compliance Will Be Achieved All actions are complete.

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W3P85-1470 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 R.M. Nelson, being duly sworn, hereby deposes and says that he is Licensing Manager-Nuclear of Louisiana Power & Light Company; that he is-duly authorized to sign and file with the Nuclear Regulatory Commission the attached response to the Notice of Violation, Appendix A for NRC Inspection Report 85-16; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.

L 0 R.6 Nelson W "

Licensing Manager-Nuclear STATE OF LOUISIANA )

) ss PARISH OF ST. CHARLES)

Subscribed and sworn to before me,,p Notary Public and 2 'or Jhe Parish and State above named this &# day of ,_._ M (4 ,. / % ,

1985. #'

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~MotaryPublic(J -

My Commission expires h .

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