ML20207F794

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000.Noncompliance Noted:Failure to Take Adequate Corrective Actions to Preclude Repetition of Significant Condition Adverse to Quality

ML20207F794
Person / Time
Site:	Waterford
Issue date:	08/18/1988
From:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20207F789	List: IR 05000382/1988016 ML20207F794
References
EA-88-144, NUDOCS 8808230222
Download: ML20207F794 (5)

Text

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NOTICE OF VIOLATION AND PROPOSED IMPOSITIOK 0F civil PENALTY louisiana Power & Light Company Docket: 50-382 Waterford Steam Electric Station Operating License: NPF-38 Unit 3 EA 88-144 During an NRC inspection conducted on May 12-20, 1988, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2 Appendix C (1988), the Nuclear Regulatory Commission proposes to impose a civil penalty pursuanttoSection234oftheAtomicEnergyActof1954,asamended(Act),

42 U.S.C. 2282, and 10 CFR 2.205. The particular violations and associated civil penalty are set forth below:

A. Inadequate Corrective Actions Criterion XVI of Appendix B to 10 CFR Part 50, requires, in part, that for significant conditions adverse to quality, measures shall be established to assure that the cause of the condition is determined and corrective action is taken to preclude repetition.

In July 1986, a loss of both shutdown cooling pumps occurred at Waterford-3, an event constituting a "significant condition adverse to quality." The licensee's measures established to preclude repetition of this event included specific commitments made in a September 21, 1987 responsetoGenericLetter87-12,"LossofResidualHeatRemoval(RHR)

While The Reactor Coolant System is Partially Filled." These measures as set forth in the September 21, 1987 response, included:

1. During part-loop operations, operators will utilize two independent and diverse RCS level measurement systems - the heated junction

. thermocouple (HJTC)systemandtherefuelinglevelindication system (RLIS), and that the HJTC system level indication shall be monitored continuously while draining, and frequently while the RCS is partially drained.

2.

" . . . when the reactor vessel head is not in place (or when preparing for head removal or replacement) the RCS water level is maintained several feet above the hot leg centerline. This precludes thepossibilityoflosingSDC[shutdowncooling]flowdueto vortexing."

3. "During installation, the tubing length of the RLIS was maintained to a minimum."

Contrary to the above, the licensee failed to take adequate corrective actions to preclude repetition of a significant condition adverse to quality in that, on May 12, 1988 at approximately 6:15 a.m. and again at 9:35 a.m., inaccurate reactor vessel water level indication resulted in vortexing, cavitation, and subsequent loss of the operational shutdown 8808230222 890818 PDR ADOCK 05000302 G PNV g

Notice of Violation cooling pump. These events are repetitious of the occurrence in July 1986 (reportedinLER86-15)whereaseriesofevents,includinginaccurate water level indication resulting from improper installation and care of the tygon tube instrument, resulted in vortexing, cavitation, and loss of both shutdown cooling pumps. The licensee's measures to prevent a recurrence of that condition, including the licensee's commitments in response to Generic Letter 87-12, were not fully implemented on May 12, 1988, in that the two independent means of level indication (HJTC and RLIS) were not both used when draining during part-loop operation, the RCS water level was not maintained several feet above the hot leg centerline when the reactor vessel head was not in place, and the RLIS tubing length was not maintained to a minimum when installed. Therefore, the measures were not adequate to prevent a similar condition from occurring.

B. Failure to Follow Procedures 10 CFR 50, Appendix B, Criterion V, requires, in part, that activities affecting quality be prescribed by documented instructions, procedures, or drawings. The activities shall be accomplished in accordance with these instructions, procedures, or drawings.

Pursuant to this requirement, Waterford 3 operating procedure OP-1-003, Revision 6, "Reactor Coolant System Drain Down," establishes, in part, the requirements for draining down the reactor coolant system (RCS) to the refuelingwaterStoragepool(RWSP):

lant

1. Step 6.4.8 of Procedure OP-1-003, Revision 6, states that the p(Tygon staff will, "Perform frequent cross checks of the RWLIS, RLIS Tubing), if in service, and the HJTC level indication on QSPOS, during RCS drain down."

2. Step 8.4.6 of Attachment 8.4 of Procedure OP-1-003, Revision 6, requires the blowdown of water from the pressurizer reference leg.

3. Attache.cnt 8.4 of Procedure OP-1-003, Revision 6, requires, in part, a backfill and venting of the tubing in the refueling water level indicator system (RWLIS) to ensure that air is removed from the system.

4 Step 8.6.6.5 of Attachment 8.6 of Procedure OP-1-003, Revision 6, requires that the refueling level indicator of the refueling level indication system (RLIS) be inspected for any condition which could cause the refueling level indicator to give false indication.

Contrary to the above, on May 12, 1988, Procedure OP-1-003, Revision 6, was not followed in that:

1.a. During a drain-down of the RCS to the RWSP, no cross checks of reactor vessel water level were performed between the RWLIS indicators and the heated junction thermocouple (HJTC) water level

d he Notice of Violation indicator system indicators as required by Step 6.4.8 of Procedure OP-1-003, Revision 6. Further, at the time of the RCS drain-down, the HJTC water level indicator system was not operable.

1.b. During a second RCS drain-down of May 12, 1988, plant operators relied solely on reactor vessel water level indication provided by the RLIS, even though Step 6.4.8 of Procedure OP-1-003, Revision 6, requires that cross checks of the RLIS indications be made with the RWLIS indications.

2. The RWLIS level detector reference leg was apparently not blown down as required by Step 8.4.6 of Attachment 8.4 of Procedure 0P-1-003, Revision 6, in that licensee personnel detected water in the reference leg subsequent to the comencement of the RCS drain down. The discovery of water in the RWLIS detector reference leg contributed to the licensee's decision to rely solely or, the RLIS for reactor vessel water level indication.

3. RCS drain-down to part-loop was performed even though the RWLIS backfill and venting had not been performed as required by Attachment 8.4 of Procedure OP-1-003, Revision 6. Performance of the RWLIS backfill would have removed entrapped air which can cause false water level indication.

4 Even though the RLIS tubing was inspected prior to and during the RCS drain down of May 12, 1988, it was not performed in accordance with Step 8.6.6.5 of Attachment 8.6 of Procedure OP-1-003, Revision 6, in that several licensee personnel, initially, failed to detect upon inspection, that approximately 30 feet of excess RLIS hose contained entrapped air and consequently caused erroneously high RLIS reactor vessel water level indication.

Collectively, these violations have been categorized in the aggregate as a Severity Level III problem (Supplement I).

Cumulative Civil Penalty - $50,000 (assessed equally between the violations).

Pursuant to the provisions of 10 CFR 2.201, Louisiana Power & Light Company is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Comission, within 30 days of the date of this Notice. This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each lleged violation:

(1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, (3) the corrective steps that have been taken and the results achieved (4) the corrective steps that will be taken to avoid further violations,and(5)thedatewhenfullcomplit.ncewillbeachieved. If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be

Notice of Violation ta ken . Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Within the same time as provided for the response required above under 10 CFR 2.201, the Licensee may pay the civil penalty by letter addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draf t, or money order payable to the Treasurer of the United States in the amount of the civil penalty proposed above, in whole or in part by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Comission. Should the Licensee fail to answer within the time specified, an order imposing the civil penalty will be issued. Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, in whole or in part, such answer should be clearly marked as an "Answer to a Notice of Violation" and may: (1) deny the violations listed in this Notice in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalty should not be imposed. In addition to protesting the civil penalty in whole or in part, such answer may request remission or mitigation of the penalty.

In requesting mitigation of the proposed penalt Section V.B of 10 CFR Psrt 2, Appendix ,Cshould (1988)y, the five Any be addressed. factors addressed in written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. The attention of the Licensee is directed to the other provisions c,f 10 CFR 2.205, regarding the procedure for imposing a civil penalty.

Upon failure to pay any civil penalty due which subsequently has been determined in accordance with the applicable provisions of 10 CFR 2 205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282c.

The responses to the Director, Office of Enforcement, noted above (Reply to a Notice of Violation, letter with payment of civil penalty, and answer to a Notice of Violation) should be addressed to: Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, and a copy to the NRC Resident inspector, at the Water-ford 3 Steam Electric Station.

FOR TH NUCLEAR REGULATORY COMMISSION Robert D. Martin Regional Aaministrator Dated at Arlington, Texas, this ay of August 1988.

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