W3P85-1480, Responds to NRC Re Violations Noted in Insp Rept 50-382/85-20.Corrective Actions:Shift Supervisors Informed of Responsibility to Ensure That All Surveillances Satisfactorily Performed & Reviewed Prior to Making Changes

Responds to NRC Re Violations Noted in Insp Rept 50-382/85-20.Corrective Actions:Shift Supervisors Informed of Responsibility to Ensure That All Surveillances Satisfactorily Performed & Reviewed Prior to Making Changes

ML20209H258
Person / Time
Site:	Waterford
Issue date:	09/27/1985
From:	Cook K LOUISIANA POWER & LIGHT CO.
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20209H244	List: IR 05000382/1985020 W3P85-1480, Responds to NRC Re Violations Noted in Insp Rept 50-382/85-20.Corrective Actions:Shift Supervisors Informed of Responsibility to Ensure That All Surveillances Satisfactorily Performed & Reviewed Prior to Making Changes
References
W3P85-1480, NUDOCS 8511110056
Download: ML20209H258 (4)

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142 DELARONDE STREET POWER & LIGHT P O. BOX 6008

• NEW ORLEANS. LOUISIANA 70174 * (5041 366-2345 UTIUTIES SYSTEM September 27, 1985 W3P85-1480 A4.05 Mr. Robert D. Martin Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Dear Mr. Martin.

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Subject:

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Docket No. 50-382 License No. NPF-38 .

- - - - h NRC Inspection Report 85-20 Attached is the Louisiana Power & Light Company responses to Violation No.

8520-04 and 8420-05 which are cited in the subject NRC Inspection Report.

The violation response is submitted under affidavit as required by Section 182 of the Atomic Energy Act of 1954, as amended.

-If'y'ou have any questions on the responses, please contact G.E. Wuller, Onsite Licensing, at (504) 464-3499.

Very truly yours, N

f AN K. . Cook Nttelear Support & Licensing Manager KWC:GEW:sms Attachments 8511110056 851031 PDR ADOCK 05000382 G PDR cc: NRC, Director, Office of I&E G.W. Knighton, NRC-NRR J.H. Wilson, NRC-NRR NRC Resident Inspectors Office B.W. Churchill W.M. Stevenson ,

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< 1 ATTACHMENT to W3P85-1480 Page 1 of 2 LP&L Response to Violation in Inspection Report No. 85-20

1. VIOLATION NO. 8520-05 Failure to Meet Operational Mode Requirements Technical Specification 4.0.4 requires that " Entry into an OPERATIONAL MODE or other specified conditions shall not be made unless the surveillance requirement (s) associated with the limiting condition for operation have been performed within the stated surveillance interval or as otherwise specified.

LP&L Operating Procedure OP-10-001, Revision 4 " General Plant Operations," requires that_when entering Mode 4 (hot shutdown) both emergency diesel generators be operable.

Contrary to the above, on June 11, 1985, Waterford 3 was in Mode 5 (cold shutdown) while performing Surveillance Procedure OP-903-069,

" Integrated Emergency Diesel Generator / Engineered Safety Features Test." As part of the above procedure, operations personnel were attempting to prove the operability of the Emergency Diesel Generator B automatic load sequence timer. However, operations personnel did not review the test data until 1545 hours0.0179 days <br />0.429 hours <br />0.00255 weeks <br />5.878725e-4 months <br /> on June 20, 1985.

Waterford entered Mode 4 (hot shutdown) at 1028 hours0.0119 days <br />0.286 hours <br />0.0017 weeks <br />3.91154e-4 months <br /> on June 20, 1985, with Emergency Diesel Generator B inoperable due to Load Block 7 being out of tolerance.

This is a Severity Level IV Violation (50-382/8520-05).

RESPONSE TO THE VIOLATION (1) Reason for the Violation The condition occurred because the data associated with the subject. surveillance procedure is voluminous and Operations Personnel did not complete the data review prior to changing modes.

(2) Corrective Steps Taken and Results Achieved The above described condition was identified by Waterford 3 Plant Operators on June 20, 1985 and was reported to the Commission pursuant to 10CFR50.73(a)(2)(1)(B) (see LER-85-025). All shift supervisors have been informed of their responsibility to ensure all relevant surveillances have been satisfactorily performed and reviewed prior to mode changes.

(3) Corrective Actions That Will Be Taken No further actions are deemed necessary.

(4) Date When Full Compliance Will Be Achieved All corrective actions were completed August 2, 1985.

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ATTACHMENT to W3P85-1480 Page 2 of 2

2. VIOLATION NO. 8520-04 Failure to Conduct a Proper 10 CFR 50.59 Review Title 10 of the Code of Federal Regulations, Part 50.59 requires, in part, that the licensee shall perform and maintain a written safety evaluation which provides the basis for the determination that the

. changes in the facility, cs described in the Safety Analysis Report (SAR), do not involve an unresolved safety question.

Contrary to'the above, on June 25, 1985, the NRC inspector noted that LP&L Operating Procedure OP-03-014. " Control Room Heating and-

-Ventilating," provided the normal lineup of the emergency outside air intake valves which was different than the lineup described in the Final Safety Analyais Report (FSAR). The NRC inspector found no evidence that a proper 10 CFR 50.59 review was conducted to calculate dose' rates which an operator would experience if these valves had to be manually opened from outside the control room.

This is a Severity Level IV violation (50-382/8520-04).

RESPONSE TO THE VIOLATION Although the' Emergency Outside Air Intake valve positions specified in

-Operating Procedure OP-03-014, Revision 1, Control Room Heating and Ventilating, differs from the normal operating mode described in the Final Safety _ Analysis Report (FSAR), the valve positions addressed by this violation are described in the FSAR as the Toxic Gas Emergency Operating Mode (Figure 6.4-3). Because this valve configuration is already described-in the FSAR, a'10 CFR.50.59 review was not required..

However, a'cafety review was performed by LP&L, the results of which revealed that the valve lineup described in the above violation did

.not constitute an unresolved safety question. 'This was not a surprise

-since it already represented an operating condition allowed in the FSAR. LP&L feels that as a result this item should not be a

-- violation. . It is requested that this violation be cancelled.

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W3P85-1480 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of )'

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Louisiana Power & Light Company ) Docket No. 50-382 Waterford 3 Steam Electric Station )

AFFIDAVIT R.M. Nelson, being duly sworn, hereby deposes and says that he is Nuclear Licensing Manager of Louisiana Power & Light Company; that he is duly authorized to sign and act on behalf of K.W. Cook, Nuclear Support &

Licensing Manager and file with the Nuclear Regulatory Commission the attached responsesfto Violation Nos. 8420-04 and 8520-05; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.

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' '\(iM. Nelson Licensing Manager-Nuclear STATE OF LOUISIANA )

) ss PARISH OF ST. CHARLES) a n an foy the Parish Subscribedandsworntobeforeme,h[NotaryPublic and State above named this 52 7 t day of #elz, _ ,

1985. Y

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