View source for W3P86-0077, Responds to 860416 Notice of Violation & Proposed Imposition of Civil Penalty Noted in Insp Rept 50-382/86-02.Corrective Actions:Instruction Added to Operation Night Orders & Warning Tags Hung on Manual Valves Operated by Reach Rods

{{Adams
| number = ML20197J352
| issue date = 05/16/1986
| title = Responds to 860416 Notice of Violation & Proposed Imposition of Civil Penalty Noted in Insp Rept 50-382/86-02.Corrective Actions:Instruction Added to Operation Night Orders & Warning Tags Hung on Manual Valves Operated by Reach Rods
| author name = Cook K
| author affiliation = LOUISIANA POWER &amp; LIGHT CO.
| addressee name = Taylor J
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE)
| docket = 05000382
| license number = 
| contact person = 
| document report number = EA-86-050, EA-86-50, W3P86-0077, W3P86-77, NUDOCS 8605200006
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 9
}}

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Lounsinma / 3,7eAnoNNsS1neer          . e.O.Boxe0340 NEW ORLEANS, LOUISIANA 70160 + (504) 595-3100 POWER & L1GHT                                                                   ,
       $uyksSysE                                                                                   l May 16, 1986                               W3P86-0077 A4.05 QA Mr. James M. Taylor Director, Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555

==Subject:==
Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Enforcement Action EA 86-50

==References:==
: 1. NRC Region IV letter 4/16/86 (EA 86-50), subject: Notice of Violation and Proposed Imposition of Civil Penalty (NRC Inspection Report 50-382/86-02).
: 2. NRC Inspection Report No. 86-02 via transmittal letter dated 2/27/86.

==Dear Mr. Taylor:==

Pursuant to 10CFR2.201, Louisiana Power & Light Company submits in Attachment A the responses to the violations identified as I and II in the             ,
reference 1 notice of violation.
Additionally, pursuant to 10CFR2.205, LP&L in Attachment B responds to the civil penalty associated with Violation I.       Due to extenuating circumstances and the prompt identification, correction and reporting of the violation LP&L requests mitigation of the civil penalty. LP&L has also reviewed the severity level classification of the violation and consequently requests that the violation be re-classified as Severity Level IV, i
Very truly yours, I     8605200006 860516                              . b,    /
PDR    ADOCK 05000382 PDR h,
G                                          K.W. Cook Nuclear Support & Licensing Manager KWC:GEW:ssf Attachment cc:   R.D. Martin, NRC Region IV G.W. Knighton, NRC-NRR J.H. Wilson, NRC-NRR NRC Resident Inspectors Office i
y B.W. Churchill W.M. Stevenson "AN EQUAL OPPORTUNITY EMPLOYER"
                                                                                ~

5/16/86                                                        ATTACHMENT A to W3P86-0077 Sheet 1 of 3
          ~LP&L RESPONSES TO THE VIOLATIONS IN ENFORCEMENT ACTION EA 86-50 VIOLATION I. Violation Assessed a Civil Penalty (was apparent Violation 8602-03)
Technical Specification (TS) 3.6.2.1 requires that two independent containment spray systems be OPERABLE with each spray system capable of taking suction from the RWSP on a containment spray actuation signal and automatically transferring suction to the safety injection system sump on a circulation actuation signal. This applies to MODES 1, 2, 3, and 4.
TS 3.0.4 requires that entry into an OPERATIONAL MODE or other specified condition shall not be made unless the conditions of the limiting condition for operation are met without reliance on provisions contained in the ACTION requirements.
Contrary to the above, on December 16, 1985, the plant entered Mode 3 while relying on the ACTION requirements of TS 3.6.2.1 in that Train B of the Containment Spray system was inoperable due to a closed discharge header valve (CS-111B).
This is a Severity Level III violation.
RESPONSE TO VIOLATION (1) Alleged Violation LP&L admits to the Technical Specification violation and it was reported to NRC as LER-85-055 on January 15, 1986.
(2) Reason for the Violation The error has been attributed to a disconnected reach-rod operator.
When operations personnel attempted to open the valve, they used the reach-rod and mistakenly thought the valve had been opened. Also, a typographical error in the Operations Annunciators Response procedure may have confused the operators.
(3) Corrective Actions That Have Been Taken and Results Achieved The Operations Superintendent added an instruction in the Operation Night Orders cautioning operations personnel on the shortcomings associated with reach-rods and their use for independent verification of valve lineups. In addition, operations personnel have compiled a list of manual valves which are operated by reach rods and have hung warning tags on all accessible valves to instruct plant operators to verify actual valve positions when operating the subject valves. The necessity of treating inoperable reach-rods as plant equipment requiring maintenance and initiating a CIWA to document the work is being stressed to all operations personnel.

5/16/86                                                       ^ ATTACHMENT A to W3P86-0077     .
Sheet 2 of 3    -
(4) Corrective Actions That Will Be Taken The list of manual valves that are operated with reach-rods will be included in.the appropriate operations procedure along with a statement of caution in procedure 0I-10-000, "Waterford 3 Operations
                            ' Department Good Operating Practices". The annunciator title has been changed to identify the valves being monitored. A review will be conducted to determine if there are any other ambiguously titled annunciators and if any are found, they will be appropriately          ,
re-named.
                       .(5) Date When Full Compliance Will Be Achieved Full compliance with Technical Specification 3.6.2.1 was achieved on December 17, 1985.
     - - - - - . - -                                                                                       l

5/16/86                                                                                           ATTACHMENT A to W3P86-0077 Sheet 3 of 3   ,
VIOLATION II - Violation Not Assessed a Civil Penalty (was apparent Violation 8602-04).
  .                                            TS 6.8.1 requires, in part, that written procedures be established for the procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33 Revision 2, Appendix A, requires procedures for performance of maintenance on safety-related equipment. Regulatory Guide 1.33, endorses ANSI N18.7-1976 which requires (paragraph 5.3.5) that provisions be provided for conducting and recording results of required tests.
Contrary to the above, adequate written procedures were not established for the work required by Condition Identification Work Authorization 024584 in that no written requirements were specified or results recorded for the required operability test on Chiller Unit A of the Essential Chilled Water System following corrective maintenance.
This is a Severity Level IV violation.
RESPONSE TO VIOLATION (1) Alleged Violation LP&L admits to the violation.
(2) Reason for the Violation Condition Identification Work Authorization (CIWA) 024584 did not contain written requirements for recording operability testing for Chiller Unit A for the Essential Chilled Water System. However, Chiller Unit A was properly retested by observation of chilled water temperature being less than 42*F and flow being greater than 500 gpm.
This information is documented in the Control Room Log.
(3) Corrective Action That Has Been Taken Late entries to CIWA 024584 have been made to document that the proper retest of Chiller Unit A was performed.
(4) Corrective Action That Will Be Taken Plant procedure OP-100-010 Equipment Out of Service, will be revised to incorporate the provision for identifying and documenting retest requirements for safety-related equipment.
(5) Date When Full Compliance Will Be Achieved The procedure is expected to be revised and approved by June 13, 1986.
I

  *~
5/16/86                                                                  ATTACHMENT B to W3P86-0077 Sheet 1 of 5 LP&L FILING PURSUANT TO 10CFR2.205 FOR VIOLATION I OF EA 86-50 Summary Enforcement Action 86-50 proposed imposition of a civil penalty on LP&L.for violation of Technical Specification 3.0.4 which requires that entry into an operational mode shall not be made unless the limiting conditions for operation are met without reliance on provisions contained in the action statements.- Specifically, on December 16, 1985 Waterford 3 entered Mode 3 while relying on the action statement of Technical Specification 3.6.2.1 in that Train B of the Containment Spray System was inoperable due to a closed discharge header valve (CS-111B).
As noted in the violation response (see Attachment A to W3P86-0077), LP&L admits the violation. However, pursuant to 10CFR2.205 LP&L requests mitigation of the civil penalty and reduction in the severity level of the violation.
Exted4ating Circumstances to Support Mitigation Analyses of the occurrence against each of the five factors of Section V.B of 10CFR Part 2, Appendix C, supports substantial mitigation of the civil penalty, as discussed below.
: 1. Prompt Identification and Reporting The inoperability of Train B of the Containment Spray System (CSS) was promptly identified by Operations personnel and reported to the NRC under 10CFR50.73.
On December 16, 1985 Waterford 3 was commencing a plant Feat-up in preparation for power operation. At 1341, while in Mode 4, shutdown cooling was secured. At this point, the CSS is required to be operable in accordance with Technical Specification 3.6.2.1. However, because valve alignments and surveillance are required prior to declaring the CSS operable, reliance is placed upon the action statement of Technical Specification 3.6.2.1 which allows 72 hours before the CSS must be operable (note: the CSS was finally confirmed operable at 0453 the following day - a period of some 15 hours).
In performing the CSS valve lineup two valves, among others, must be opened - CS-111B, the Train B pump discharge valve, and CS-1178, the shutdown heat exchanger stop check valve. The position of both valves is indicated in the control room only via a single white alarmed annunciator (E-14 on the N annunciator panel) with the legend                                          ,
               " Containment Spray Header B Discharge Valve Closed". Thus, from the control room indication available, it would not be clear which valve could be the source of an alarm condition.
On December 16, 1985, while performing the CSS valve lineup, CS-117B was found to have a disconnected reach rod. This valve was then opened. CS-111B also had a disconnected reach rod.            In this case, however, the disconnection was not apparent to the operator, who felt

5/16/86                                                          ATTACHMENT B to W3P86-0077 Sheet 2 of 5 resistance (unlike CS-Il7B) when " opening" the valve. Although CS-IllB remained closed due to the disconnected reach rod, the operator firmly believed that he had opened the valve. At 1600, based on operator completion of the CSS lineup the CSS was declared operable.
At this point, control room personnel were aware that annunciator window E-14 had not cleared. They looked for the annunciator response procedure for this window but were unable to locate it because the Column E annunciator on Panel N had been incorrectly labelled as      "F" in the procedures. Had they been able to find the E-14 procedure it would have identified CS-IllB and CS-117B as the initiating devices for the alarm. In the procedure, the possible causes for alarm were stated to be:
: 1. Improper lineup
: 2. Valve not fully on its seat
: 3. Limit switch malfunction Regardless of availability of the E-14 response procedure, the operators' attention would have been directed to first evaluate CS-117B. The reach rod for CS-117B had earlier been found disconnected, while the same operator " opening" CS-111B had found sufficient reach rod turning resistance to indicate that CS-111B had been successfully opened. The known disconnected reach rod for CS-Il7B was enough to suggest that there may be additional problems with that valve. Therefore, although not having the annunciator response procedure in hand, operations personnel over a period of several hours investigated the possibility that either CS-117B was not open or that there may be a broken limit switch associated with the valve. In the course of the investigation, the stem position of CS-117B was checked three times to verify that the valve was open.       Based on these ongoing actionc and the previous operator belief that CS-IllB had been properly opened, the shift supervisor had good reason to believe that an electrical problem was causing the alarm condition of annunciator window E-14.       Therefore, at 2042, directions were given to enter Mode 3.
It should be noted that during this shift (1500-2300) on December 16, 1985, the control room was quite busy in heating-up the plant in preparation for criticality.       Yet, the alarm at annunciator E-14 was given adequate attention (based on the information available) and the thought process followed in tracing potential causes of the alarm tracked that of the mis-labelled annunciator response procedure.
Shift turnover occurred at 2250. Having been briefed on the E-14 alarm by a control room operator who served on both shif ta, the oncoming Control Room Supervisor requested operations personnel to re-investigate the possible reasons for the alarm. At 0425 on December 17, 1985, after researching control wiring diagrams, it was discovered that CS-IllB position was also an input to E-14. Still suspecting an electrical problem, personnel were dispatched to locally      '
verify CS-IllB limit switch integrity. Upon local inspection it was

5/16/86                                                        ATTACHMENT B to W3P86-0077 Sheet 3 of 5 discovered that the reach rod to CS-111B was disconnected and that the valve was closed. CS-IllB was immediately opened at 0453, and the CSS re-declared as operable.
From initial " completion" of the CSS lineup at 1600 on December 16, to discovery of the disconnected reach rod and opening of CS-111B at 0453 on December 17, the response of the operations personnel to the alarm at E-14 was professional, timely and appropriate. While availability of the E-14 annunciator response procedure may have led to a slightly earlier identification of CS-IllB as a potential problem (i.e.
operations personnel would not have had to confirm E-14 inputs through CWDs), CS-Il7B would still have been the prime suspect of the           I annunciator alarm, and the same investigative process would have been followed. For these reasons, LP&L takes exception to the NRC statement that "... timely and appropriate response to the annunciator indication was not made."
By 0609 on December 17, 1985 the control room personnel had completed the Potentially Reportable Event form identifying that a mode change had occurred with an inoperable CSS train. The NRC Resident Inspector was briefed on the event at the earliest opportunity, and preparation of the LER required by 10CFR50.73 was initiated. The LER was submitted to the NRC via W3P86-00ll dated January 15, 1986 - within the period prescribed by 10CFR50.73.
The NRC has some question about the adequacy of the LER, noting that
                "...your subsequent review of the event was deficient in that the Licensee Event Report 382/85-55 that you submitted did not precisely describe when and how this abnormal plant condition was recognized."
It is not clear from the NRC's comment precisely what information was not contained in the LER, which should have been. The LER attributed the identification of the annunciator alarm as leading to the discovery of the disconnected reach rod on CS-IllB. LP&L agrees with the NRC that the root cause of the violation was the failure to adequately control the condition and the status of remote valve operators. For that reason, the LER placed emphasis on the disconnected reach rod and, from that point of view, provided in the LER the essential elements required by 10CFR50.73(b)(2)(ii)(A-L).
LP&L does not, however, agree that failure to follow the appropriate annunciator procedure was a root cause of the violation. As previously noted, operations personnel er untially followed the procedural steps of the relevant annuncia r response procedure.
Having the procedure available would have caly had a minimal effect on the length of time the CSS train was inoperable.
While admitting the violation and its associated root cause, LP&L feels that the actions of its operation staff were highly commendable in quickly and professionally identifying the problem of the disconnected reach rod to CS-IllB and subsequently reporting the Technical Specification violation to the NRC. On this basis, LP&L requests mitigation of the civil penalty.

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       .       5/16/86                                                        ATTACHMENT B to W3P86-0077 Sheet 4 of 5
: 2. Corrective Action to Prevent Recurrence In th violation response (see Attachment A to W3P86-0077) LP&L identified the detailed corrective action implemented as a result of discovering the violation.
Corrective action was implemented to prevent recurrence as well as longer-term in-depth actions to assure that remote operators would be considered as essential components of plant equipment. All corrective actions were implemented on LP&L's initiative, independent of the NRC's inspection activities. The actions taken were prompt and effective in preventing recurrence of a similar situation. On this basis LP&L requests mitigation of the civil penalty.
: 3. Past Performance Inappropriate mode changes due to faulty valve operation have not previously occurred at Waterford 3.
: 4. Prior Notice of Similar Event LP&L had no prior knowledge of a similar problem due to LP&L audits, or specific NRC or industry notification.
: 5. Multiple occurrences Multiple examples of the violation have not been identified during this inspection period.
Basis for Reduction in Violation Severity Level The violation has been assigned a Severity Level III (Supplement I) by the NRC. LP&L agrees that a technical violation has occurred but disagrees with the severity level assigned.
10CFR2, Appendix C, Supplement I, provides certain examples of Severity Level III violations for reactor operations. No example clearly fits the subject violation, and the inferred characteristics of a Severity Level III violation are more severe than those of the subject violation. Where one train of a significant safety system is inoperable, the exampics imply that the train must be inoperable for a period in excess of that allowed by the associated Technical Specification in order to qualify as a Severity Level III violation. The subject violation concerns non-compliance with Technical Specification 3.0.4 (mode change restrictions) so is not directly applicable. 'However, solely for the purpose of assessing the severity level of the violation, it should be noted that Technical Specification 3.6.2 allows a single CSS train to be inoperable for up to 72 hours. The prompt action on the part of LP&L personnel restored operability of CSS Train B in approximately 15 hours.
The other similar Severity Level III example involves a safety system (i.e., all redundant trains) not being able to perform its safety functions. The subject violation included the loss of one train of the CSS for a period less than the allowabic outage time (had there been no mode

    . 5/16/86                                                       ATTACHMENT B to W3P86-0077 Sheet 5 of 5 change). The redundant CSS train was available to perform its intended safety function throughout the time in question.
To place the violation in perspective, with respect to Severity Level classification, one could postulate that the plant had been in Mode 3 pri.or to CS-111B closing. For such a hypothetical case, the 72 hour action statement of Technical Specification 3.6.2 would apply. Restoring operability of CSS Train B within 15 hours would have resulted in compliance with the Technici.1 Specifications and no violation. What has been reported by LP&L is a technical violation of Technical Specification 3.0.4 which is not of appropriate safety significance to be classified as a Severity Level III violation.
The Severity Level IV examples in 10CFR2 Appendix C discuss less significant Technical Specification violations. LP&L feels that the subject violation is appropriately classified as a Severity Level IV.
Accordingly, LP&L requests that the Severity Level of the violation be reviewed and amended as appropriate.
L}}