ML20236S499

Notice of Violation from Insp on 870916-1015.Violation Noted:Failure to Follow Listed Procedures,Failure to Meet Tech Spec Action Statements & Fire Protection Problems

ML20236S499
Person / Time
Site:	Waterford
Issue date:	11/23/1987
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20236S498	List: IR 05000382/1987022 ML20236S496 ML20236S499
References
50-382-87-22, NUDOCS 8711250206
Download: ML20236S499 (3)

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APPENDIX A NOTICE OF VIOLATION Louisiana Power & Light Company Docket: 50-382 Waterford Steam Electric Station, Unit 3 License: NPF-38 During an NRC inspection conducted September 16 through October 15, 1987, three violations of NRC requirements were identified. The first violation involved failure to follow procedures. The second violation was a failure to meet technical specification action statements. The third violation concerned fire protection problems. In accordance with the " General Statement of Polic Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix, Cthe(1987)y and violations are listed below:

A. Failure to Maintain Procedural Adherence and Attention to Detail Criterion V of Appendix B to 10 CFR Part 50 and the approved Quality Assurance Plan for Waterford 3, require that activities affecting quality be prescribed by documented instructions, procedures, or drawings. Three examples of failure to adhere to procedures are delineated below:

1. Procedure UNT-7-005, Revision 2, " Cleanliness Control," requires closure inspections to be performed "immediately prior to" system or component closure. I Contrary to the above, the crank case cover for Charging Pump "B", a l safety-related component, was installed on October 1, 1987, but the cleanliness inspection was conducted on September 30, 1987.

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2. Procedure OP-10-001, Revision 9 " General Plant Operations," states in a note that, during cooldown, the last reactor coolant pump should i not be stopped until the hydrogen content of the reactor coolant system is less than or equal to 5 cc/kg.

Contrary to the above, on September 21, 1987, the last reactor coolant pump was stopped prior to the hydrogen content reaching 5 cc/kg.

3. Procedure OP-100-001, Revision 4, " Duties and Responsibilities of Operators on Duty," specifies that procedure steps may be deleted as not applicable with approval of the shift supervisor.

Contrary to the above, or September 29, 1987, Step 8.2.8 of Surveillance Procedure OP-903-111, Revision 0, " Containment Air Lock Door Seal Leakage Test," was marked "NA" by the test engineer without approval of the shift supervisor.

This is a Severity Level IV violation. (Supplements)(382/8722-01) 8711250206 071123 gDR ADOCK 05000392 PDR

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B. Failure to Meet Technical Specification Action Statements-Technical Specification 3.0.1 requires, in part, compliance with action statements associated with limiting conditions for operation. There are  !

two examples listed below where this TS was not met:

.1. Technical Specification 3.3.3.11.b requires, in part, that when the.

main condenser evacuation noble gas activity monitor is inoperable, grab samples shall be taken at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, q Contrary to the above, on October 14, 1987, while the main condenser l' evacuation noble gas activity monitor was out of service, grab samples were taken at 5:05 a.m. and 8:35 p.m., which is more than .

1.25 times the 12-hour interval prescribed. '

2. Technical Specification 3.3.3.11.b also requires, in part, that when the waste gas holdup system explosive gas monitoring system is i inoperable, hydrogen grab samples shall be taken at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and oxygen grab samples shall be taken at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. These samples are required to be taken from the on-service gas decay tank.

Contrary to the above, while_the waste gas holding system explosive monitoring system was inoperable, the required grab samples were taken from an off-service tank (A) instead of the on-service tank (C) from 1:48 p.m. on October 3, 1987, through 9:00 a.m. on October 5, 1987.

This is a Severity Level IV violation. (Supplement I)(382/8722-04)

C. Fire Protection Program Technical Specification (TS) 6.8.1 requires, in part, that written procedures be established, implemented, and maintained for fire protection i program implementation. The following are three examples of failure to 4 implement fire prevention procedures:

1. Fire Protection Procedure FP-1-015, Revision 3, " Fire Protection System Impairments," requires that all impairments to fire doors be documented.

Contrary to the above, Fire Door D-47 was impaired by a scaffold clamp so that it would not close on September 22, 1987, and this was not documented as a fire door impairment. Also, on September 23, 1987, Fire Doors D-136, D-163, and D-165 were found unlatched but were not documented as being impaired.

2. Fire Protection Procedure FP-1-017, Revision 4, " Transient Combustibles and Hazardous Materials" requires that safety cans, if unattended, be stored in a flammable liquid storage cabinet. j i

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Contrary to the above, on October 6,1986, five cans of "Fyrquel", a flammable liquid,'were found unattended and not stored in a flammable liquid storage at various locations in the main steam and feed isolation valve rooms.

3. Fire Protection Procedure FP-1-013', Revision 3, " Fire Protection Program Plan," prohibits smoking in nondesignated areas such as the Emergency Feedwater Pump A room and the stairwell leading to the main steam and feed isolation valve room.

Contrary to the above, on October 6,1987, cigarette butts were found in each of these' areas.

This is a Severity Level IV violation. (Supplements)(382/8722-02)

Pursuant to the provisions of 10 CFR 2.201, Louisiana Power & Light Company is hereby required to submit a written statement or explanation to this Office within 30 days of the date of the letter transmitting this Notice. This reply, should include for each violation: (1) the reason for the violations if admitted, (2) the corrective steps that have been taken and the results achieved. (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.

Dated at Arlington, Texas, this 23rd day of November 1987.

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