ML20245C720

Summary of 890320 Meeting W/Util to Discuss Difference of Understanding on Intent & Operation of Plant,Per 890103 Order Imposing Civil Penalty Concerning 880512 Event

ML20245C720
Person / Time
Site:	Waterford
Issue date:	04/20/1989
From:	Wigginton D Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8904270357
Download: ML20245C720 (14)

Text

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!" o NUCLEAR REGULATORY COMMISSION

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o April 20,1989

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Docket No. 50-382 LICENSEE: Louisiana Power & Light Company (LP&L)

FACILITY: Waterford Steam Electric Station, Unit 3 i

SUMMARY

OF MEETING HELD ON MARCH 20, 1989 WITH THE LICENSEE TO DISCUSS DIFFERENCES OF UNDERSTANDING ON INTENT AND OPERATION OF WATERFORD The NRC staff met with the licensee on March 20, 1989 to discuss the licensee's letter dated February 1,1989 in which LP&L raised concerns about differences in understanding between the NRC and LP&L on the intent and operation of Waterford 3. The list of attendees is attached as Enclosure 1.

On January 3.1989, the NRC issued an order imposing a civil penalty concerning a May 12,-15d8 event involving the shutdown cooling at Waterford 3. On February 1,1989, the licensee responded to the order. The fine was paid and no hearing was requested which closed the enforcement action. In the response, however, the licensee raised the issue, among others, that there appears to be differences between how LP&L intends to and operates Waterford 3 and NRC's asserted understanding of how LP&L intends to and operates Waterford 3. The licensee further indicated that others in the industry shared this m% understanding.

It was these statements that prompted the NRC to call the meeting wite cP&L management. On' February 28, 1989, the Director of Enforcement addressed the LP&L February I letter and noted that the meeting would be called by the Office of Nuclear Reactor Regulation. On March 6, 1989, the meeting notice was issued.

The NRR introduction was provided by the Director, Project Directorate IV and included the following points. The Order and civil penalty is resolved and no further discussion on those matters was needed. The LP&L effort on responses to the violation and the order was good. It was noted that much of this information should have been provided at the enforcement conference early in the investigation. The commitments on the earlier event in 10M was narrow in focus and did not cover all the aspects of operation. In this regard the licensee is responsible to keep the record clear and it is not for the NRC to make assumptions on operation for the licensee. The incidents that occurred are not typical for Waterford 3 which is viewed as good in operations. It is apparent that all parties need a better understanding and more communication.

The licensee's presentation centered on three areas: procedures, corrective actions, and level measurement systems. The licensee's material for the meeting is 6ttached as Enclosure 2.

8904270357 PDR 890420 w ADOCK 05000382 k PDC 7

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2 The meeting clarified to the licensee the NRC positions stated in the Order imposing the civil penaltv and therefore resolved the issues identified in the licensees February 1,1989 letter.

/s/

David L. Wigginton, Project Manager Project Directorate - IV Division of Reactor Projects - III, IV, Y and Special Projects Office of Nuclear Reactor Regulation

Enclosures:

As stated cc w/ enclosures:

See next page DISTRIBUTION Docket File NRC PDR Local PDR J. Sniezek PD4 Reading J. Calvo D. Wigginton P. Noonan 0GC-Rockville E. Jordan B. Grimes ACRS(10)

T. Martin (Region IV) PD4 Plant File F. Hebdon

• See previous concurrences c /f PD4/LA* PD4/PM* OE* PD4/D* {},/t o I"f-PNoonan DWiggin on:bj JLieberman JCalvo 04/10/89 04/07/89 04/18/89 04/07/89 OE concurred on draft with explanatory paragraphs, however, the neeting summary was subsequently modified to close the issue hithout openly inviting a licensee response. The issues were completely discussed at the. meeting which achieved the purpose; a deta" led meeting summary would not improve relations with the licensee nor would it serve to advance public health and safety, s

2 1

In regards to procedures, the Appendix acconipanying the Order adequately I captures the NRC position. This was again discussed with the licensee. The '

licensee agreed with the NRC on prerequisites and thereby concluded it was consistent with industry practice. ,,

For corrective actions, the NRC explained that licensees are expectedjto continuously update corrective actions as additional information becomes  ;

available. However, in this case involving the enforcement action /at Waterford, l the licensee identified needed inaprovements but they were not properly implemented.

The licensee agreed that their corrective actions plan should have been adequate but the iniplementation was inadequate or inappropriate. ,/

Finally, with-regard to level' systems, the licensees submittals at the time of the enforcement made their position en level indication unclear. The licensee did not disagree with that assertion. It was noted also that the NRC has ,

accepted the licensee's current position on level indication and there is no misunderstanding at this tin.e. /

The meeting clarified to the licensee the NRC post icos stated in the Order imposing the civil penalty and therefore resolved the issues identified in the licensees February 1,1989 letter. /

/

D vid L. Wigginton, Project Manager

,' Project Directorate - IV

/ Division of Reactor Projects - III, IV, V and Special Projects

,/ Office of Nuclear Reactor Regulation

Enclosures:

As stated -

/

cc w/ enclosures: /

See next page /

/

/

/

DISTRIBUTION /

Docket File NRC PDR Local PDR J. Sniezek PD4 Reading J. Calvo D. Wigginton P. Noonan 0GC-Rockville E. Jordan B. Grimes ACRS (10)

T. Martin (RegionIV) PD4 Plant File

• See previous concurrences  !

PD4/LA*

PNoonan PD4/Pl?

DWiggint n:bj OE h JLieberman PD4/D*

JCalvo 04/10/89 04/07/89 04/p'/89 04/07/89

1 J

1 I

I The NRC staff explained that it agrees with the licensee relative to procedures and felt that the Appendix accompanying the Order adequately captures that J point. 1 k

With regard to corrective actions there may be times when there is disagreement l about the needed scope of corrective actions. In this case involving 6e 4 enforcement action at Waterford, the licensee had identified reeded ;provements; the issue was that they were not promptly implemented.

Finally,- with regard to level systems, the NRC has accepted the licensee's recent position. However, at the time of the enforcement th / licensee position was unclear in reading their procedures and submittals.

The meeting adequately resolved all the issues identifie in the licensee's  ;

February 1,1989 letter.

David . Wigginton, Project Manager .

Proje Directorate - IV I Divj ion of Reactor Projects - III, JV, V and Special Projects 1 ffice of Nuclear Reactor Regulation

Enclosures:

As stated. y cc w/ enclosures:

See next page DISTRIBilTION Docket File NRC PDR Local PDR J. Sniezek PD4 Reading J. Calvo D. Wigginton P. Noonan 0GC-Rockville E. Jordan B. Griraes ACRS (10)

T. Martin (RegjonIV) PD4 Plant File PD4/LA i PD4/PM DWigginton:bj PD4/D JCalvo OE JLieberman PNooria QE/10/89 0{/}/89 E3/ /89 04/ /89 ap py

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l The meeting clarified to the licensee the NRC positions stated in the Order i imposing the civil penalty and therefore resolved the issues identified in the-  !

licensees February 1,1989 letter. <

i i

David L. Wigginton, Project Manager  !

Project Directorate - IV Division of Reactor Projects - III, IV, V and Special Projects Office of Nuclear Reactor Regulation

Enclosures:

As stated cc w/ enclosures:

See next page

Mr. Jerrold G. Dewease Waterford 3 Louisiana Power & Light Company cc:

W. Malcolm Stevenson, Esq. Regional Administrator, Region IV Monroe & Lemar U.S. Nuclear Regulatory Commission 1432 Whitney Building Office of Executive Director for New Orleansi Louisiana 70103 Operations 611 Ryan Plaza Drive, Suite 1000 Mr. E. Blake Arlington, Texas 76011 Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW Mr. William H. Spell, Administrator Washington, D.C. 20037 Nuclear Energy Division Office of Environmental Affairs Resident Inspector /Waterford NPS Post Office Box 14690 Post Office Eox 822 Baton Rouge, Louisiana 70898 K111ona, Louisiana 70066 Mr.' Ralph T. Lally President, Police Jury Manager of Quality Assurance St. Charles Parish Middle South Services, Inc. Hahnv111e, Louisiana 70057 q Post Office Box 61000 New Orleans, Louisiana 70161

-Chairman William A. Cross Louisiana Public Service Commission Bethesda Licensing Office One American Place, Suite 1630 3 Metro Center Baton Rouge, Louisiana 70825-1697 Suite 610 Bethesda, Maryland 20814 Mr. R. F. Burski Nuclear Safety and Regulatory Affairs Manager Louisiana Power & Light Company '

317 Barcrne Street New Orleans, Louisiana 70112 l

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ENCLOSURE I MEETING ATTENDEES - OPERATION OF.WATERFORD 3 1

NARCH 20,.1989 i l

Nuclear Regulatory Commission Lousiania Power.& Light. Company J. Calvo, NRR J. G. Dewcase l D. Wigginton, NRR R. Barkhurst J. Monninger, NRR R. Barski J. Lieberman, OE fl. Carns J. Luehman, OE M. Meisner Shaw, Pittman. Potts & Trowbridge E. Blake l

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