ML20207F561
| ML20207F561 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| 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) | |
See also: IR 05000382/1986005
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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
Louisiana Radiation Control Program Director
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