ML20207F561

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/86-05.Addl Info,Addressing Corrective Actions Re Work W/O Radiation Work Permit & Test Procedure,Required
ML20207F561
Person / Time
Site: Waterford Entergy icon.png
Issue date: 07/16/1986
From: Gagliardo J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Muench G
LOUISIANA POWER & LIGHT CO.
Shared Package
ML20207F566 List:
References
NUDOCS 8607220564
Download: ML20207F561 (3)
v • d • e


See also: IR 05000382/1986005

Text

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JUL 161996

In Reply Refer To:

Docket: 50-382/86-05

Louisiana Power & Light Company

ATTN: G. W. Muench, Director

Nuclear Operations

317 Baronne Street

P. 0. Box 60340

New Orleans, Louisiana 70160

Gentlemen:

Thank you for your letter of May 2,1986, in response to our letter and attached

Notice of Violation (N0V) dated April 2, 1986. In your response you deny that.

a violation occurred. We have reviewed your bases for denial _ and conclude that"

they do not support withdrawal of this NOV for the following reasons.

Your denial of NOV 8605-01 is based in part on the contention that Technical

Specification (TS) 6.8.1.c does not apply. Although this oppears correct, the

NOV was written against TS 6.8.1 which also includes 6._8.1.a which references

Regulatory Guide (RG) 1.33, Revision 2. Appendix A, which -in Section 7 specifies

procedures for control of radioactivity (for limiting materials released'to the

environment and limiting personnel exposure). Specifically,'Section 7.'c

addresses pressurized water reactor (PWR) gaseous effluent systems and Section 7.e

addresses radiation protection procedures including requirements for a radiation

work permit (RWP) system. It is clear that procedures are required for all ,

associated activities. Our reference to safety-related equipment in the NOV

may have been misleading, in that the term was used in a general sense. The

involved equipment is important to safety but not safety-related. The activities

in question are described as safety-related, again in the general sense, in the

first paragraph of RG 1.33, Appendix A, which applies in this case.

The first of the two releases under discussion occurred because of a design

error that resulted in cross connected systems. Your staff thought that the

release was because of an improper valve lineup and the second day of testing

was allowed because it was felt that the improper valve lineup had been

corrected. These events appear to be related to the two elements of the NOV

which were not addressed. In the first element, it seems clear that monitoring

for airborne radioactivity should be required when testing a newly installed

system containing gaseous radioactivity. Leaks in diaphragms and fittings are

very common in this type of system and such monitoring should be considered the

prudent action. Your response, as well as the applicable condition

identification work authorization (CIWA), both document the repair of various

system leaks found during installation which should have pointed out the need

to radiologically monitor the system during troubleshooting and testing. -While

your statement that the RWP could not have prevented the releases from

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occurring is true, closer radiological monitoring could have minimized the

amount of radioactivity released through the plant stack and into the work

a rea.

The second element contained in the NOV involved performance of system functional

testing without specific test procedures which is required by RG 1.33, Appendix A,

Section 7. Although we agree that limited troubleshooting checks and tests can

be performed on a CIWA, verification of full system function (in this case

sampling at various sample points) cannot be considered troubleshooting. Therefore,

we consider your contention that no " official" testing was performed as being

immaterial. The extent of system testing should have been described in sufficient

detail such that work approvals (CIWAs and RWPs) had the benefit of consideration

of expected system dynamics when approved.

Your response stated that instrumentation and control (I&C) maintenance personnel

secured the system after the second release while NRC Inspection Report 50-382/86-05

states that this was performed by operation personnel. The information contained

in the report was provided to the NRC inspector by plant personnel and although

apparently incorrect, the information has little bearing on the violation.

In responding to this NOV you did not adequately address all concerns expressed

in our previous letter and attached NOV. Specifically, you should address

corrective actions associated with performance of the work without an adequate

- RWP and test procedure as required by the NOV.

Please provide this supplemental information within 30 days of the date of this

letter.

Sincerely,

Origina! Signed By

J. E. Gag!!ardo

J. E. Gagliardo, Chief

Reactor Projects Branch

cc w/ enclosures:

Louisiana Power & Light Company Louisiana Power & Light Company

ATTN: G. E. Wuller, Onsite ATTN: R. P. Barkhurst, Plant Manager

Licensing Coordinator P. O. Box B

P. O. Box B Killona, Louisiana 70066  ;

Killona, Louisiana 70066

Middle South Services Louisiana Power & Light Company i

ATTH: Mr. R. T. Lally ATTN: K. W. Cook, Nuclear Support i

P. O. Box 6100 and Licensing Manager

New Orleans, Louisiana 70161 142 Delaronde Street

New Orleans, Louisiana 70174 l

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Louisiana Radiation Control Program Director

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Louisiana Power & Light Company -3-

bec to DMB (IE01)

bcc distrib. by RIV

RPB R. D. Martin, RA

Resident Inspector DRSP

Section Chief (RPB/C) *RIV File '

EP&RPB D. Crutchfield, NRR

MIS System RSB

RSTS Operator

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