View source for W3P86-0072, Responds to Violations Noted in Insp Rept 50-382/86-05.Util Disagrees W/Validity of Violation 8605-01.Station Mod 818 Not safety-related & Tech Spec 6.8.1 Does Not Apply

{{Adams
| number = ML20207F579
| issue date = 05/02/1986
| title = Responds to Violations Noted in Insp Rept 50-382/86-05.Util Disagrees W/Validity of Violation 8605-01.Station Mod 818 Not safety-related & Tech Spec 6.8.1 Does Not Apply
| author name = Cook K
| author affiliation = LOUISIANA POWER &amp; LIGHT CO.
| addressee name = Martin R
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION IV)
| docket = 05000382
| license number = 
| contact person = 
| document report number = W3P86-0072, W3P86-72, NUDOCS 8607220570
| package number = ML20207F566
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 3
}}

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8 P. O. BOX 60340 LOUISI&ANA POWER       L1GHT/ 317NEW BARONNESTREET
* ORLEANS, LOUISIANA 70160 + (504) 595-3100
      $TiukNhrsi[M May 2, 1986 W3P86-0072 A4.05 QA Mr. Robert 9. Martin Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000
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==Subject:==
Waterford 3 SES                                                        j j/;
Docket No. 50-382                            lgj @                         l License No. NPF-38                                                         I NRC Inspection Report 86-05

==Dear Mr. Martin:==

Attached is the Louisiana Power & Light Company (LP&L) response to Violation No. 8605-01 which was cited in the subject NRC Inspection Report.
If you have any questions on the response, please contact G.E. Wuller, Onsite Licensing, at (504) 464-3499.
Very truly yours, 6
K.W. Cook Nuclear Support & Licensing Manager KWC:KLB:ssf                                                                                  l Attachment i
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 8607220570 860716 PDR O       ADOCK 05000382 PDR "AN EQUAL OPPORTUNITY EMPLOYER"

. .'                                                                  ATTACHMENT to W3P86-0072 Sheet 1 of 2 LP&L RESPONSE TO VIOLATION NO. 8605-01 VIOLATION NO. 8605-01 Failure to Use an Adequate Radiation Worker Permit (RWP) and Failure to Use an Approved Test Procedure.
Technical Specification (TS) 6.8.1 requires in part that written procedures be established and implemented for testing of safety-related equipment and for those applicable areas recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Appendix A of Regulatory Guide 1.33, Revision 2 requires procedures for issuance of Radiation Work Permits. Administrative Procedure HP-1-110, Revision 5, " Radiation Work Permits," is the procedure the licensee uses to prescribe the proper implementation and it requires performance of appropriate radiological surveys and specification of appropriate radiation safety precaution.
: 1. Contrary to the above, HP-1-110 was not properly implemented for RWP 86000101 in that the radiological surveys and precautions taken were inadequate for the scope of the work performed.
: 2. Contrary to the above, procedures were not established for testing of safety-related equipment in that testing was performed as part of Station Modification 818 without an approved procedure.
This is a Severity Level IV violation.

===RESPONSE===
LP&L does not believe that a violation occurred. Station Modification 818 is not a safety-related modification, therefore, Technical Specification 6.8.1 does not apply to testing of this equipment. The event as described in the NRC Inspection Report 86-05 is inaccurate.
Based upon the inspection procedure done after the event, it has been determined that the Gas Decay Tank C Sample Line and the Gas Surge Tank Sample Line were crossed. This line cross occurred prior to implementing SM 818. The line cross caused the system to be over-pressurized (beyond 70 psig) which in turn caused the sample pump diaphram to fail. This failure allowed the release to the panel room area and in turn to the plant stack via the HVAC system.
Instrumentation & Control Maintenance personnel were working under Condition Identification and Work Authorization (CIWA) 21068 which allowed troubleshooting of the entire system.      There has been no
          " official" testing performed, only troubleshooting with recorded results. The completed system had been checked prior to attempting any sampling and was deemed safe and ready to proceed with further evaluation and troubleshooting. Therefore no additional " approved procedures" were required.
I&C personnel were allowed to proceed with troubleshooting of the system on the second day due to the belief that the release which occurred on the first day had been caused by an improper valve lineup

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       . .,                                                                                                ATTACHMENT
       .                                                                                                   to W3P86-0072 Sheet 2 of 2 which discharged the sample flow to the Plant Stack instead of returning it to the Gas Surge Header. Health. Physics notified appropriate I&C personnel of the event and its apparent cause, and impressed upon them the need to inform the Control Room prior to resuming work on the system. RWP 8600101 was adequate based upon the radiological conditions at the jobsite, therefore there was no reason at that time to terminate it.
I&C personnel located a leak on a soleniod valve, repaired it, and then notified the Control Room of their intention to start the system.
Upon doing so it became immediately -apparent to them that there was a problem, whereupon I&C personnel secured the system. Health Physics and Operations then concurrently determined that work should be halted on SM 818 and RWP 86000101 was terminated.
In summary, LP&L does not believe that a violation occurred. The provisions of Technical Specification 6.8.1.C do not apply to this system. RWP 85000101 was adequate for the designated scope of work and therefore was in accordance with procedurc HP-1-110, Radiation Work Permits. The Radiation Work Permit could not have prevented the release from occurring. Once it was apparent that something was wrong I              with the system and not the valve Ifneup, the job was stopped and an evaluation was made which determined the root cause of the problem.
4 The two releases occurred on February 12 and 13, 1986.
1 i)         Tech Spec 3.11.2.1 - Maximum instantaneous release rate 2/12/86             148 mrem /yr.                        30% of Tech Spec limit 2/13/86               11 mrem /yr.                        2% of Tech Spec limit                               -
: 11) Tech Spec 3.11.2.2 - Quarterly Air Doses 2/12/86       Gamma       4.5E-4 mrad                    0.009% of quarterly limit Beta        6.6E-4 mrad                    0.007% of quarterly limit 2/13/86       Camma       4.5E-6 mrad                    9E-5% of quarterly limit                             .
Beta        6.6E-6 mrad                    7E-5% of quarterly limit NOTE: Air doses for the first quarter of 1986 were as follows:
Gamma       0.496 mrad                     9.9% of quarterly limit Beta        1,29 mrad                      12.9% of quarterly limit These does rates and doses have been calculated in accordance with the methodology and parameters in the Offsite Dose Calculation Manual. As noted above, the contribution of the two inadvertent releases is negligible with respect to quarterly doses. Instantaneous release rates were well under Tech Spec limits.
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