IR 05000382/1988025

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/88-25

ML20244A921
Person / Time
Site:	Waterford
Issue date:	04/07/1989
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dewease J LOUISIANA POWER & LIGHT CO.
References
NUDOCS 8904180266
Download: ML20244A921 (2)

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In Reply Refer'To:-

-Docket: 50-382/88-25

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Louisiana Power & Light Company .

ATTN: J. G. Dewease, Senior Vice' President.-

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Nuclear. Operations 317 Baronne Street New Orleans, Louisiana 70160

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Gentlemen:. )

V Thank you for your letter of December 29, 1988, in response to our letter-and Notice of Violation dated November 29,-1988. We' have reviewed your reply and find it responsive to the concerns raised in on? Notice of Violation. We

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will review the implementation of your corrective actions during a future

' inspection to' determine that full compliance has been achieved and will be maintaine

Sincerely, Original Signed By:

E J: CALLAN L'. J. Callan, Director Division of Reactor Projects cc:

Louisiana Power & Light Company ATTN: R. P. Barkhurst, Vice President Nuclear Operations-P.O. Box B Killona, Louisiana 70066 Louisiana Power & Light Company-ATTH: N. S. Carns, Plant Manager P.O. Box B Killona, Louisiana 70066 RIV:DRP/AAd C:DRP/Atlhjd\ D:DRk ATHowell;df DDChamberlain LJCallan i

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- Lou'isiana Power '&'. Light. Company '

y-2-i Louisiana' Power & Light Company

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ATTN:: 1R2 F. ' Burski,' Manager,, Nuclear-Safety & Regulatory Affairs

.317 Baronne Street P.O.. Box 60340 New' Orleans, Louisiana ' ~ 70160 LouisiankPower&'LightCompany ATTN: 'L; W. Laughlin, Site

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. Licensing Support Supervisor

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P.O.' Box'B .

Killona, Louisiana -70066'

Louisiana: Power & Light Company; ATTN: G. M. Davis, Manager, Events

. ~ Analysis Reporting-&. Response

'P.O.. Box B: ..

K1.11ona, Louisiana 70066 '

Middle South' Services ATTN: Mr.JR. T. Lally'

P.O. Box 61000

=New Orleans; Louisiana 170161~

Louisiana Radiati~o n Control Program Director-bec to DMB (IE01) W/ enclosure bec-distrib. by RIV: w/ enclosure RRI . , . .R. Martin, RA SectionChief'.(DRP/A) DRP RPB-DRSS MIS' System Project Engineer, DRP/A RSTS Operator RIV File' .

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DRS D. 2Wigginton, NRR Project' Manager'(MS: 13-D-18) Lisa Shea, RM/ALF

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P. O. BOX 60340

.LO POWERUISI& AN L1GHTA / 317 NEWBARONNE STREET

ORLEANS, LOUISlANA 70160 * (504) 595-3100

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' U UTi!i!N sYsi$ I December 29, 1988 W3P88-1892 A4.05 QA U.S. Nuclear Regulatory Commission '

- i ATTN: Document Control Desk 'L;) . i Washington, D.C. 20555 ,

g,,5gg Subject: Waterford 3 SES ~

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

NRC Inspection Report 88-25 Gentlemen:

In accordance with 10CFR P. art 2.201, Louisiana Power & Light hereby submits in Attachment I the response to the Violation (No. 8825-02) identified in Appendix A of the subject Inspection Repor If you have any questions concerning these responses, please contact T.J. Gaudet at (504) 464-332 Very truly yours,

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R.F. Burski Manager Nuclear Safety & Regulatory Affairs

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RFB:TJG:ssf Attachment cc:@.D.. Martin,NRCRegion.I%' ,

J.A. Calvo, NRC-NRR D.L. Wigginton, NRC-NRR NRC Resident Inspectors Office E.L. Blake l W.M. Stevenson l

l-003 "AN EQUAL PPORTUNITY EMPLOYER"

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Atitachment to

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Page-1 of'2'

h ATTACHMENT 1

'LP&L Response to the Violation Identified in Appendix A'

of Inspection Report 88-25

, . . VIOLATION NO. 8825-0 >

Failure'to-Follow Procedures'

TS 6.8.1.a. requires, in part, written procedures to be implemented.fo operation of safety-related systems as recommended-in Appendix A_of'

Regulatory Guide 1.33, Revision.2, February 197 .. . . .

LP&L Administrative Procedure OP-100-009, Revision 8, " Control of-Valves. and Breakers," paragraph 5.1.2.1, requires documented control of locked valves'such as SI-2421 (Safety Injection to Loop IB Containment Isolation' Check Valve SI-242 Bypass) status. Attachment'-

6.2 of OP-100-009 requires SI-2421 to be locked close Contrary to the above, on October 25, 1988,- the NRC inspectors found SI-2421 closed but.not locked. There was no documentation allowing-this deviation from the required status nor was there any. procedure in progress that would require the valve'to be unlocked. The valve could have been unlocked as early.as' April 1988 when the last valve status-verification was performe This is a Severity Level IV violatio RESPONSE' q-LP&L admits that this violation existed in that the noted Valve (SI-2421) was not " locked closed" (retained.by some device or interlock which requires the use of a key to manually position it to some other maintained position) nor were any controls established for this deviated condition as required by Administrative Procedure OP-100-009, " Control of Valves and Breakers".

~(1) Reason For The Violation The purpose of Plant Operating Procedure OP-100-009 Is to provide t a method for controlling valves and breakers that arc important-

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to safe plant operation. In accordance with Section 5.1.3 of OP-100-009, the positions of the valves listed in Attachment of the procedure [ Note: Attachment 6.2 lists valves, including

.SI-2421, that are located in the Reactor Containment Building and are inaccessible'during Plant Modes one (1) and two (2)] are required to be verified during cold shutdowns. Consequently, in April 1988, during the early stages of the Waterford 3 second refueling outage, verification of the valves listed in Attachment 6.2 was performed (Note: At this time, Valve 2421 was verified to be in the locked closed position).

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W3P88-1892 1 Page 2 of 2- I

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Subsequent to.the above, while touring the' containment building I

during au October 21, 1988 outage, NRC inspectors found Vulve SI-2421 to be closed but not~ locked. Based on this discovery, :j operations personnel checked to see if a deviation sheet was filled out which is required by Subsection 5.1.2.1 of OP-100-009 to document this type of deviated condition. Since no record was found and because Valve SI-2421 is inaccessible during Modes 1 &

2, it is believed that the lock was inadvertently removed in May, 1988 during the latter stages of the second refueling outag The lack of having Valve SI-2421 positioned as locked closed without documentation for the deviated condition violated Procedure OP-100-009. . Consequently, the basis for this. violation is a failure to implement the controls established in OP 100-00 ,

(2) Corrective Steps Which Have Been Takan And The Results Achieved

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Operations personnel took action to ensure that Valve SI-2421 was properly placed in the locked closed position. This action was completed on October 27, 1988 during a valve lineup on the Safety '

Injection Syste J Since it was unclear as to what individual / shift was directly responsible for this violation, the Operations Superintendent,.on November 21, 1988, issued a memorandum to notify all operations personnel of the basis for the violation and to stress to them the importance in maintaining plant administrative' controls in a flawless conditio (3) Corrective Steps Which Will Be Taken To Avoid Further Violations Based on the above information, LP&L feels that the necessary steps have been taken to ensure that this type of violation does not recu (4) Date When Full Compliance Will Be Achieve LP&L is currently in full complianc j