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| {{Adams | | {{Adams |
| | number = ML20153D431 | | | number = ML20235M657 |
| | issue date = 08/19/1988 | | | issue date = 02/21/1989 |
| | title = Insp Rept 50-382/88-19 on 880618-0731.Violations Noted. Major Areas Inspected:Enforcement Followup on Quality Verification Function Insp,Monthly Maint Observation, Allegation Followup & Operational Safety Verification | | | title = Ack Receipt of 880926 & 890126 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp 50-382/88-19. Implementation of Corrective Actions Will Be Reviewed During Future Insp to Determine If Compliance Achieved |
| | author name = Chamberlain D, Michaud P, Smith W, Staker T | | | author name = Callan L |
| | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) | | | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| | addressee name = | | | addressee name = Dewease J |
| | addressee affiliation = | | | addressee affiliation = LOUISIANA POWER & LIGHT CO. |
| | docket = 05000382 | | | docket = 05000382 |
| | license number = | | | license number = |
| | contact person = | | | contact person = |
| | document report number = 50-382-88-19, IEB-88-005, IEB-88-5, NUDOCS 8809020201 | | | document report number = NUDOCS 8902280352 |
| | package number = ML20153D424
| | | document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE |
| | document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | | | page count = 2 |
| | page count = 19 | |
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| e -, U. S. NUCLEAR REGULATORY COMISSION '
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| , .4 REGION IV
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| NRC Inspection Report: 50-382/88-19 License: 'NPF-38 I' Docket: 50-382 .
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| Licensee: Louisiana Power & Light Company (LP&L) , .
| | .InReply.Referio:. . |
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| 142 Delaronde Street New Orleans, Louisiana 70174 ,
| | FEB 21 E 1 Docket:. 50-382/88-19 ^ |
| " | | Louisiana Power,S Light Compan o ATTN: ;J. G. Dewease, Senior Vice President - |
| . | | Nuclear Operations 317 Baronne Street ; |
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| | New Orleans, Louisiana 70160 . |
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| | . Gentlemen:. |
| Facility Name: Waterford Steam Electric Station, Unit 3 Inspection At: Taft: Louisiana s
| | Thank 'you for 'your letters of September 26, 1988, and January 26, 1989,; |
| Inspection Conducted: June 18 through July 31, 1988 <
| | ;in response to our letters.and Notice of. Violation dated August 25, 1988,'and LDecember 20, 1988. We have reviewed your supplemental response to Violations 382/8819-01 and 382/8819-02-and found it contained the additional information that was requested. We now consider it responsive'.to the concerns |
| Inspectors: .- 8 &
| | . raised in our Notice of Violation dated August 25, 1988. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine |
| W. F. Smith, Senior Resident Inspector Date 7-1-6s T. R. St4ke?, lesident Inspector Date We 7-2 2 -28 P. W. Michaud, Res'i ant Inspector, Region IV Date
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| | Sincerely, Onginal Sigxd By: |
| Approved: C , &llT/00 D. D/LTainberlain, Chief, Project Section A Date !
| | L J. CALLAN L. J. Callan, Director Division of Reactor Projects cc: |
| Division of Reactor Projects i
| | Louisiana Power & Light Company ATTN: R. P. Barkhurst, Vice President |
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| | Nuclear Operations P.O. Box B K111ona, Louisiana 70066 Louisiana Power & Light Company ATTN: N. S. Carns, Plant Manager P.O. Box B Killona, Louisiana 70066 |
| | . Louisiana Power & Light Company ATTN: R. F. Burski, Manager, Nuclear Safety & Regulatory Affairs 317 Baronne Street P.O. Box 60340 New Orleans, Louisiana 70160 RIV:DRP/A Ah W D:Db ATHowell;df C:DRP/Ahk'n DDChamberlai LJCallan 2/gi/89 2/pl/89 2/d/89 ( |
| | 8902280352 890221 . |
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| | O ADOCK 05000382 PDC |
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| Inspection Summary Inspection Conducted June 18 through July 31, 1988 (Report 50-382/88-19)
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| Areas Inspected: Routine, unannounced inspection consisting of:
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| TI) enforcement followup on quality verification function inspection, (2) monthly maintenance observation, (3) allegation followup, (4) operational safety verification, (5) monthly surveillance observation, (6) followup of previously identified items, (7) followup of NRC Bulletin 88-05, (8) licensee event report followup (9) onsite followup of events, and (10) plant statu Results:
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| Within the areas inspected, four violations were identifie The first violation involved four failures to submit Licensee Event Reports within the I 30 days required by 10 CFR 50.73 (paragraph 2). The second and third violations involved failures to follow operating and maintenance procedures respectively (paragraphs 2 & 3). The fourth violation involved failure to .
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| perform s)ecial processes using appropriately qualified personnel (paragrapi4). There is one new unresolved item in paragraph 3 regarding the possibility of unacceptable delays in correcting undersized power cable .
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| ~3 DETAILS Persons Contacted Principal Licensee Employees R. P. Barkhurst, Vice President. Nuclear Operations
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| *N. S. Carns., Plant Manager,' Nuclear P. V. Prasankumar, Assistant Plant Manager, Technical Support D. F. Packer, Assistant Plant Manager, Operations and Maintenance J. J. Zabritski,flanager of Operations Quality Assurance J. R. McGaha, Manager of Nuclear Operations Engineering W. T. Labonte, Radiation Protection Superintendent D. E. Baker, Manager of Nuclear Operations' Support and Assessments
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| *A. L. Holder, Fire Protection and Safety Department itead
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| *L. W. Laughlin, Site Licensing Support Supervisor D. W. Vinci, Maintenance Superintendent
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| *N. E. Howard, Trending Compliance & Response Supervisor A. F. Burski, Manager of Nuclear Safety and Regulatory Affairs R. S. Starkey, Operations Superintendent G. M. Woodard, Manager of Events Analysis Reporting & Responses J. Sleger, Jr. , Nuclear Safety Review Manager
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| *Present at exit utervie In addition to the above personnel, the NRC inspectors held discussions with various operations, engineering, technical su) port, maintenance, quality assurance, and administrative members of t1e licensee's staf . Enforcement Followup on Quality Verification Function Inspection (25578)
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| During the period of February 1 through February 12, 1988, the NRC staff conducted NRC headquarters-directed quality verification function inspections under the guidance of Temporary Instruction 2515/78. The Inspection Report (50-382/88-200) was issued on June 2, 1988. Enclosure 1 of the report identified several potential enforcement findings. The NRC Region IV staff has the responsibility to issue the appropriate Notices of Violation for items requiring enforcement action. The items are listed below: Item 1.a: Failure to report a valid actuation of the broad range toxicgasdetectionsystempursuantto10CFR50'3(a)(2)(iii),which requires a 30-day report when an external condition poses a threat to the safety of the nuclear power plant or significantly hampers site personnel. Neither of these criteria were met when the actuation occurred, therefore, the Region IV staff determined the item did not have to be reported, There will be no enforcement action on this ite Item 1.b: Failure to report being outside of the design basis of the plant due to nitrogen pressure indicator taps being located on the
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| Main Steam Isolation Valves (MSIVs) such that pressure could not be monitored when the MSIVs were ope The Region IV staff considered the licensee correct in not reporting this condition because the design basis of the installation did not include being able to monitor this parameter. This was further supported by the monitors not being listed in the Technical Specifications. The staff noted that LP&L did move the sensing line so that nitrogen pressure could be checked, and that the information was provided to the licensee's operational assessment group for dissemination to the nuclear industry. There will be no enforcement action on this ite c. Item 1.b: Nonreporting of a failure to meet safety to nonsafety electr leal distribution separation criteri The licensee subsequently reported the event in LER 87-029, dated April 18, 198 Failure to report this event within 30 days of the discovery date, which D CFRwas April 2,(1987,)is 50.73(a)(2) contrary ii)(b which statestothat the requirements of submit the licensee shall a 30-day report identifying any event or condition of the nuclear power plant, including its principal safety barriers, being in a condition that was outside the design basis of the plant. This is the first example of where the licensee failed to submit a report required by 10 CFR 50.73 and is an apparent violation (382/8819-01).
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| d. Item 1.c: Failure to report an event where sampling and analysis of the gas decay tank was not performed in accordance with the action requirements of Technical Specification (TS) Table 3.3-13. The apparent basis for nonreporting was that the 25 percent surveillance extension permitted by TS 4.0.2 was not exceeded. This assertion was incorrect. TS Action Statements are not under the purview of Surveillance Section 4.0.2. LP&L control room personnel appeared to be aware of this limitation all along. The licensee published LER 87-030 on April 18, 1988, in response to the NRC concern but improperly identified the LER as "vcluntary" instead of pursuant to 10 CFR 50.73(a)(2)(1)(B), which requires a 30-day report of any operation or condition prohibited by the plant's Technical Specifications. It will be necessary for the licensee to revise the LER cover sheet to indicate that it is not a voluntary report. Since the event date was August 19, 1987, this is the second example of the licensee's failure to submit a report required by 10 CFR 50.73 and is part of apparent violation 382/8819-0 Item 1.c: Failure to report a missed surveillance. The licensee failed to perform stroke testing of Containment Atmosphere Purgr Valve CAP-205 within the required interval in accordance with TS 4.0.5. This was discovered on October 21, 1987. The licensee's basis of nonreporting was that the action statements which ~rcquired that the penetration be isolated was unwittingly satisfied by otM r valves. Although this mitigated the safety significance of the event, it did not eliminate the fact that TS surveillance requireme.its were not met. The licensee published LER 87-031, dated April 18, 1988, in response to the NRC concern but improperly
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| identified the LER as "voluntary" instead of pursuant to 10CFR50.73(a)(2)(1). It will be necessary for the licensee to revise the LER cover sheet to indicate that it is not a voluntary report. This is the third example of the licensee's failure to submit a 30-day report as required by 10 CFR 50.73 and is part of apparent violation 382/8819-0 Item 1.d: Failure to report a wiring error that occurred during a routine relay replacement. The relay was related to the automatic start of a switchgear ventilation recirculation fan with an ESF actuation. The fan had redundant controls as well as the other train being available. The licensee did not consider that the errue alone fu could have structures or prevented systems asthe fulfillment described in 10ofCFR the 50.73 safety (a)nction (2)(v). of safety Therefore, the licensee did not report the incident. The Region IV staff agrees and will take no enforcement action on this ite Enforcement action related to reporting of emergency diesel generator valid and nonvalid failures has been taken in NRC Inspection Report 50-382/88-08, While in the control room, the inspection team observed standing signals, which had not been acknowledged at various times during the inspection, including February 5 and 9, 1988. Further, the inspectors observed signal actuations at about 1:00 p.m. on February 8 (annunciator No. 6, Trains A and B - Containment Isolation) and at about 3:20 p.m. on February 10 (annunciator N Trains A, B, and AB - Emergency Feedwater). On neither occasion was the signal acknowledged as specified by procedure. This is contrary to Technical Specification 6.8.1.a which requires the implementation of procedures covering activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, including the procedures for abnormal, off-normal, or alarm conditions. Operating Procedure OP-4-020, Revision 0, "Bypassed and Inoperable Status Indication System " requires the monitoring of safety equipment status by way of computer and requires operator acknowledgement and evaluation of systems that have been computed to be inoperable. This is an apparent violation (382/8819-02). Monthly Maintena_nce Observation (62703)
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| The below listed station maintenance activities affecting safety-related systems and components were observed and documentation reviewed to ascertcin that the activities were conducted in accordance with approved procedures, technical specifications, and appropriate industry codes or standards, Work Authorization 9900021 The NRC ins)ector observed the performance of hardness examinations on tie inlet and outlet flanges for component cooling water system Valves CC-8083AB, CC-8085AB, CC-8244AB, and CC-8246AB. These flanges were part of the recently
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| installed piping used to connect a temporary chiller to the containment coolers during long duration outages. The flanges were examined in response to NRC Bulletin 88-05, "Nonconforming Materials Supplied by Piping Supplies, Inc., at Folre , New Jersey, and West Jersey Manufacturing Company at Williamst w.i, New Jersey." Testing was performed with an Equotip hardness tuter. Two of the eight flanges tested had satisfactory hardness measurements but six were unsatisfactory. After consulting the NUMARC and the Equotip vendor, the licensee decided the following:
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| (1) The acceptance criteria would be reduced from a hardness corresponding to 70,000 pounds per square inch strength (70 KSI)
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| to that which corresponds to 66 KS (2) The test surface would have to be prepared using 120 grit flapper wheels only (60 grit was previously used) in order to get accurate measurement (3) The hardness test sample size for each flange would be increased from four to five with the highest and lowest readings discarded before averaging the reading (4) Acceptance criteria for the variation in readings was provided by the hardness tester vendo If all readings in a sample did not meet this criteria, testing would be performed at a new locatio After the appropriate procedure changes, all eight flanges were retested satisfactoril The NRC inspectors also observed the hardness testing of Essential Service Chilled Water Flanges 3AC-2208, 3AC-2218, and 3AC-222 The flanges did not meet the specified minimum hardness corresponding to 66 KSI. The lowest reading corresponded to 63.3 KSI. The licensee promptly performed an analysis which determined that the flanges were suitable for their present applicatio This is a low pressure, low energy system. The inspector reviewed the completed work package, including the analysis and a justification for continued operation, and no problems were note b. Work Authorization WA-0102090 The NRC inspector witnessed portions of the overhaul of the motor-driven firewater pump during the week of July 18, 1988. The inspector reviewed the work authorization to determine if it contained adequate instructions, references, and hold points. The inspector also verified that Quality Assurance, Maintenance Administrative Supervisor, and Shift Supervisor reviews and approvals were received prior to starting work. The inspector verified the materials to be used met the appropriate specifications and had the proper documentation. Some packing material was upgraded 3 for use in this application in accordance with licensee Procedure UNT-07-021, Revision 6, "Spare Parts Equivalency Evaluation
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| Report / Parts Quality Level Determination." The NRC inspector reviewed this procedure and the evaluation for the packing material in this application and found this acceptabl Three instances of procedural noncompliance were observed during the pump reassembly. Work Authorization 01020904 referenced Technical Manual 457000514 Volume 2, "Type A Centrifugal Pumps," for instructions for pump reassembly. The manual contained FMC Corporation, Peerless Pump Division, Bulletin No. 2880551, "Repair Instructions, Type A Centrifugal Pumps." Step 3-2.f of this document provided instructions which stated, "Cover the top side of the casing gasket with a mixture of graphite and oil." The NRC inspector noted that this step was not performed prior to the pump casing assembl Steps 3-2.f and 3-2.h provided instructions which stated, "Rotate shaft by hand to check that it runs free," after the casing reassembly and after the packing gland reassembly. These rotational checks were not performed. Step 3-2.g provides instructions which state, "Insert the glands and set the nuts finger tight-00 NOT USE A WRENCH." The NRC inspector observed the packing rings inserted with the use of a wrenc The instances above did not represent a significant degradation of the work product but rather indicated a lack of sensitivity to procedural compliance. This lack of adherence to procedural requirements is an apparent violation of NRC regulations (382/8819-03).
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| c. Work Authorization 01022087. The NRC inspectors monitored the licensee's efforts to repair the AB Essential Services Chilled Water System Chiller. This chiller is a "swing" unit which can serve as a backup to either the A or B chiller. The AB chiller is not normally in operation and does not corre under the purview of the technical specifications, unless it is being used in place of the A or B chiller in that respective essential services chilled water loo The problems with the AB chiller may have been caused or aided by the fact that it was not run on a routine basis. This indicates that its availability may be questionable if lef t out of service for extended time periods. The licensee is evaluating the preventive maintenance and reliability aspects of the AB chiller and intends to do more work during the next inspection period. The inspectors will continue to mor.itor licensee activity on this uni d. Work Authorization 01005480. The NRC inspector observed the replacement of the wiring and conduit in an auxiliary control panel to the "A" Shield Building Ventilation System Heater Control
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| : Panel (EHC-51(3A-5A)). The installed wire was observed to be brittle
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| and discolored. No problems were noted during the installatio During work package documentation review, the NRC inspector observed that the wire and conduit were being replaced in response to i Nonconformance Condition Identification Work
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| Authorization (CIWA) 016612, dated March 24, 198 The
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| nonconformance was written after determining that the installed wire (No.12 AWG) was not adequate for the load requirements and No. 8 AWG wire was the minimum required size. In March 1985, licensee personnel observed that this undersized wiring was discolored and brittl It was also noted that a backup contactor in the "B" Train Heater Control Panel (EHC(3B-5B)) was overheating during operatio This indicated that proper contact was not being made and/or a high contact resistance condition existed. The engineering evaluation in CIWA 016612 required immediate action to replace the backup contactor to avoid further damage and immediate expediting of replacement power cables. The backup contactor was replaced in January 1986 (approximately nine months later). The power cables for the "A" Train Heater were not replaced until July 1988, almost two and one half years later. The NRC inspector requested that the licensee provide additional information on the basis for the delays in correcting these nonconformances. Determination of the causes for the delays and of the safety significance of this issue shall be the
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| subject of an Unresolved Item (382/8819-04). Allegation Followup (92701)
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| The NRC inspector performed a review to determine the safety significance of the following concerns and to ensure that appropriate corrective action was take (Closed) Concern 4-87-A-0030 The following issues on fire wrap of cable installations were identified by a concerned individual:
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| been (1) The individual adequately did not consider addressed his concerns by the licensee's QualityasTea having(The Quality Team is a licensee organization that provides a confidential means by which employee safety and quality concerns -
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| can bs. received, investigated, and acted upon as appropriat Exiting employees and contractors are encouraged to check out through the Quality Team. If they do not, a fonn letter is sent to their forwarding address thus mail or by telephone "hot line.")providing the opportunity by (2) At the time these concerns were received by the NRC, the individual stated that he had been unjustly terminated because of his previous concerns. (It is understood by the staff from discussions with the individual that this is no longer an issue and thus will not be addressed in this report.)
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| (3) The LP&L insulation inspector is not doing a correct or adequate jo The NRC inspectors reviewed the practices and policies of the LP&L Quality Team on July 29, 1988. It appeared that the Quality Team was
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| | Louisiana Pcwer.& Light. Company -2-Louisiana Power & Light Company 1 |
| | ~ ATTN: L. W. Laughlin, Site ; |
| | Licensing Support Superviso P.O. Box B |
| | + Killona, Louisiana 70066 Louisiana Power & Light Company ATTN: G. M. Davis, Manager, Events ' |
| | Analysis Reporting & Response P.O. Box B Killona, Louisiana 70066 |
| | ' Middle South Services ATTN:- Mr. R. T. Lally ; |
| | P.O. Box 61000 New Orleans, Louisiana 70161 Louisiana Radiation Control Program Director bectoDMB(IE01) |
| | bec distrib. by RIV: |
| | RRI R. D. Martin, RA SectionChief(DRP/A) DRP RPB-DRSS MIS System Project Engineer, DRP/A RSTS Operator RIV File DRS(2) |
| | D. Wigginton, NRR Project Manager.(MS: 13-D-18) Lisa Shea, RH/ALF |
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| carrying out their charter as required by company policies and procedures. The inspector noted, however, that the followup closure letters sent to the individuals are very short and somewhat crypti Comparison of sample letters with the activity files indicated that disposition letters sent to individuals do not fully represent what action was taken and to what extent. The licensee's representative stated that it is LP&L's policy to avoid detailed technical discussion in the responses. The inspector acknowledged this as LP&L's prerogative. The brief notifications may be the cause for some individuals concluding that little or no action was taken on their concerns. Their only recourse is to take the concerns to the NR This appears to resolve Item (1) above. The staff intends to take no further action on thi The inspector reviewed Quality Team files related to fire wrap and
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| fire seals in 1987 and 1988. The concerns appeared to have been
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| adequately addressed with the exception of one area. In one file, there was concern that fire wrap was not being properly installed; that people were leaving trash and debris in cable trays and wrapping trash along with the cables. A letter to the Assistant Plant Manager, Technical Services, dated March 5, 1987, was in the Quality :
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| Team file requesting action in response to the concern. No response was in the file nor could the Quality Team Supervisor produce an appropriate disposition. The Quality Team Supervisor comitted to provide an answer for the inspector. On August 2, 1988, the inspector was provided with the response, which was dated August 1, 1988. The letter stat?d that there was a delay in the response because a 100 percent surveillance of fire wrap was underway. On January 12, 1988, the surveillance was completed, and any deficiencies discovered were repaired and reinspecte The inspectors reviewed documentation of completed fire wrap and fire seals. There was no indication that the LP&L insulation inspectors were failing to follow the procedural requirements of inspection and verifying correct work in these areas. The inspectors also reviewed a sampling of completed fire seal surveillances. It appeared that roughly five percent of the results were unsatisfactory and thus requiring repairs due to expected wear and tear from people working in the areas. There was not a preponderance of evidence that would lead the inspectors to the conclusion that improper inspection activities existed, thus Item (3) could not be substantiated, (Clused) Concern 4-88-A-0032 The following issues on fire seal installation / rework were identified by a concerned individua (1) Ropes were left protruding from fire barrier seals after rework.
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| (2) Quality Assurance inspectors did not always verify the required dimensions (two inches around the periphery) of the void before it was filled with repair material and sealed during fire seal rework operation (3) Fire seal installation / rework was being performed by t.nqualified individual (4) Quality Control inspectors were completing signoffs in the fire seal installation procedure accepting fire seals that were not installe The NRC inspector observed a fire seal and found a cable pull rope protruding from the seal. The licensee later stated during discussions that there is no degradation due to cable pull ropes protruding from fire seals. Additionally, the licensee provided copies of Southwest Research Institute Reports 01-8305-058A and 01-8305-058B which supported this. The inspector concluded that Item (1) above was not a valid cor.cer The NRC inspector reviewed Procedure ME-13-100, Revision 6 "Fire Barrier Installation and Rework," and observed that a quality hold point to verify the removal of two inches (minimum) of material around repair areas was sequenced before the void was filled. The inspector also noted that a recent change was incorporated into the procedure to change the sequence of this hold point from after filling the void to prior to filling. Licensee personnel stated that this procedure change was issued after a concern nad been raised by an individual performing fire seal repair wor NRC inspector discussed the sequence of perfomance of this verilication with a Quality Assurance inspector who had been responsible for performing these inspections. The Quality Assurance inspector stated that verification of removal of two inches of material was always performed prior to filling the void. The results of thw NRC inspector's review of documentation indicated that although the hold point in ME-13-100 had been listed out of sequence, it would have to have been performed prior to installation of the seal material otherwise the Quality Assurance inspector could not have accomplished the action. The inspector found no reason to pursue the matter further short of removing seals to see if the two-inch requirement was met. There was insufficient evidence to require such actio The licensee's corrective action to change ME-13-100 to the proper sequence appeared adequate to preclude future questions in this are Item (2) above is therefore resolve The NRC inspector discussed training requirements for fire seal repair personnel with the licensee. Tra1oing records were then reviewed to ascertain the qualifications of individuals involved in fire seal repair. The inspector noted thet the licensee has not implemented a training course on fire seal installation /rewt,r Personnel performing these repairs were contractors, and | |
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| | * P. O. BOX 60340 LOUISI& AN POWER A / 317NEW L1GHT BARONNE STREET ORLEANS, LOUISIANA 70160 * |
| | | (504) 595-3100 U1 ONIVSNU January 26, 1989 W3P89-0011 A4.05 QA U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 9{' |
| qualifications were determined by a licensee department head based on previous training and work experience. Some of the people installing fire seals, however, had no record of prior work experience nor any formal training in fire seal installation, thus they should not have been considered qualifie Failure to perfonn this special process with appropriately qualified personnel is contrary to the requireaents of 10 CFR 50, Appendix B, Criterion IX, which states (in part) that measures shall be established to assure that special ersonnel. This is an processes apparent are accomplished violation by qualified (382/8819-05). Item p(3) above is apparently substantiate ME-13-100, Paragraph 3.2, states, "Maintenance personnel directly supervising installation or rework activities in accordance with this rocedure shall have su::cessfully completed the training program p(either B&B Training Program or LP&L Training Program or applicable instruments) covering Cable Wrap Protective System or Penetration Seals, Fire Barriers, and Water Seals." The wording does not appear to implement adequate measures to ensure people who are supervising, inspecting, and performing fire seal work will be properly qualified.
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| The licensee identified this in LP&L Quality Assurance Audit SA-88-010.1, "Control of Special Processes," dated April 28, 1988. The audit was performed during the period February 19 thrcugh March 18, 1C88. Quality Notice QA-88-036, of March 9, 1988, identified the deficiency for processing under the licensee's corrective action progra The licensee's fire seal installation / rework program did require acceptance by Quality Control (QC) inspectors after work completio In addition, third-party inspections were performed prior to returning the seals to an operable status in accordance with surveillance procedures. These inspections were performed by experienced parsonnel in the electrical maintenance department. The NRC inspector reviewed inspection documentation and discussed the inspection results with the department supervisor responsible for the third party inspections. No significant problems were identified to indicate a lack of QC inspections during fire seal installation Item (4) above does not appear to be a valid concer Specific actions taken pursuant to apparent violation 382/8819-05 will be documented in a future inspection repor . Operational Safety Verification (71707, 71709, & 71881) _
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| The objectives of this inspect'on are (1) to ensure that this facility is being operated sately and in conformance with regulatory requirements, (2) to ensure that the licensee's management controls are effectively discharging the licensee's responsibilities for continued safe operation, (3) to assure that selected activities of the licensee's radiological protection programs are implemented in conformance with plant policies and
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| | Washington, D.C. 20555 l g3l@ |
| | Subject: Waterford 3 SES ,, |
| | Docket No. 50-382 License No. NPF-38 Violations 8819-01 and 8819-02, Supplemental Information References: LP&L Letter No. W3P88-1800 dated 09/26/88 from R.F. Burski i to U.S. Nuclear Regulatory Commission NRC letter dated 12/20/88 from L.J. Callan to J.G. Dewease Gentlemen: |
| | Louisiana Power & Light hereby submits the following information on the subject violations as a supplement to the responses that were provided in Reference This information, which is contained in Attachment 1, addresses the concerns expressed in Reference 2 vith regard to the lack of including, in the original responses, the corrective steps taken to avoid further violation Also being provided, in Attachment 2, is a revised copy of the original responses for Violations 8819-01 and 8819-02. You will note that a revision bar has been placed in the margin to indicate the area where the supplemental information has been adde If you have any questions concerning these responses, please contact T.J. Gaudet at (504) 464-3325. N Ver uly yours, |
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| | R . Burski nager uclear Safety & Regulatory Affairs l |
| | ! RFB:TJG:ssf Attachments cc: R.D. Martin, J.A. Calvo, D.L. Wigginton, NRC Resident Inspectors Office, E.L. Blaka, W.M. Stevenson I |
| | o c7 no n o ni <( , __ "AN EQUAL OPPORTUNITY EMPLOYER" |
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| procedures and in compliance with regulatory requirements, and (4) to inspect the licensee's compliance with the approved physical security pla The NRC inspector attended the quarterly ALARA committee meeting held on June 27, 1988, and noted that the licensee's ALARA program appears to be effective in reducing Man-Rem expenditure as evidenced by the following: The licensee estimates that 5-10 Man-Rem were saved by use of improved reactor head shielding during the recent refueling operation, New aluminum foreign material exclusion covers versus steam generator nozzle dams for a cleanliness boundary during tube inspections reduced installation / removal time by a factor of ten. This resulted in significant Man-Rem saving In addition, when nozzle dam installation was required, mockup training appeared to be effective because exposure rates were reduced by a factor of four from the previous refueling outag The licensee's contaminated area reduction program has been effective resulting in a contaminated area reductior. from 13 percent to 2.4 percent of plant area (outside of containment).
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| | Page 1 of'2 ATTACHMENT 1 Supplemental Information For Violations 8819-01 and 8819-02 VIOLATION NO. 8819-01: Failure To Report To NRC NRC CONCERN: No corrective action was listed to preclude future instances of failing to satisfy reporting requirement RESPONSE: As documented in LP&L Letter W3A89-0104 dated January 23, 1989, the Events Analysis Reporting and Response (EAR &R) Manager discussed the details of this violation with members of his staff to advise them of |
| | 'the importance of adhering to reporting requirements when reviewing plant event Also, subsequent to the issuance of the violation, LP&L 1) placed the NRC Resident Inspector for Waterford 3 on distribution for all Potential' Reportable Events (which includes the initial deportability determination) and 2) contacted the NRC-NRR Project Manager for Waterford 3 (and as necessary will contact in the future) when management felt it prudent to do so in situations where questions remained about reporting requirements after internal reviews had been performe It is also noteworthy of mentioning that both the Vice President-Nuclear and the Plant Manager-Nuclear has counselled the current EAR &R Manager to be more sensitive and solicitous of the deportability opinions of others and to avoid the concerns of the pas Based on the above information, LP&L feels that sufficient actions have been implemented to prevent a recurrence of a violation for failing to satisfy reporting requirement II. VIOLATION NO. 8819-02: Failure To Follow Procedure OP-4-020 NRC CONCERN: Your response did not address what was done to assure that operators will follow procedures in the futur RESPONSE: In August, 1988, the individuals responsibit for the violation were cautioned in the importance af acknowledging Bypassed and Inoperable Status Indication System indicators as well as were reminded of the importance in complying with procedures. Although this action occurred prior to the issuance of the violation response (which was issued September 26, 1988), LP&L chose not to include a discussion of it in the response since documentation to validate such action was not available. [ Note: This information was provided to the Resident Inspector on October 3, 1988]. |
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| The inspectors visited the control room on a daily basis when onsite and verified that control room staffing, operator behavior, shift turnover, adherence to technical specification limiting conditions for operation, and overall control room decorum were being conducted in accordance with NRC requirements. No prnblems were identifie Tours were conducted in various locations of the plant to observe work and operations in progress. Radiological work practices, posting of barriers, and proper use of personnel dosimetry were observed. The inspectors noted considerable effort underway to reduce areas containing surface contamination in the Reactor Auxiliary Buildin General housekeeping, condition of fire protection equipment, and physical condition of safety related equipment were inspected with particular emphasis on engineered safety feature system The inspectors verified, on a Sr.n.pling basis, that the licensee's security force was functioning in compliance with the approved physical security plan. Search equipment such as X-ray machines, metal detectors, and explosive detectors were observed to te operational. The inspectors noted that the protected area was we.Il maintained and not compromised by erosion or unauthorized openings in the area barrie No violations or deviations were idercifie ,
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| | Page 2 of 2 Subsequently, LP&L Letter W3089-0019 was issued to document the counselling of the responsible individuals. Also, in efforts to bring this matter t the attention of operations personnel and thereby ensure that this type. of' violation does not recur, a briefing on the procedure violation, to include a discussion of the corrective actions implemented, was held on January 13, 1989 during a shift supervisors' |
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| | l Based on the above information, LP&L feels confident that a recurrence of this type of violation should be prevented in the futur : |
| 13 Monthly Surveillance Observation (61726)
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| The NRC inspectors observed the below listed surveillance testing of safety-related systems and components to verify that the activities were being performed in accordance with the technical specifications. The applicable procedures were reviewed for adequacy, test instrumentation was verified to be in calibration, and test data was reviewed for accuracy and completeness. The inspectors ascertained that any deficiencies identified were properly reviewed and resolved, Procedure OP-903-032, Revision 6, "Quarterly ISI Valve Tests." On July 19, 1988, the NRC inspector observed the performance of Quarterly ISI Valve Tests on the component cooling water system by the licensee's control room operators. These surveillance tests were perfomed in accordance with Section 8.7 of Procedure OP-903-03 The NRC inspector reviewed the procedure to verify the appropriate administrative reviews and approvals were obtained prior to performing the test. The control room operators were observed using the procedure to perfom these tests in a step-by-step manne Communications between operations personnel in the control room and operators out in the plant were observed to be accurate and clea The surveillance tests were completed satisfactorily, and no problems were identified, Procedure OP-903-056, Revision 6, "Fire Protection Systems Functional Test." During the period July 26 through July 29, 1988, the inspectors witnessed portions of the annual flow capacity testing of the motor-driven and both diesel-driven fire pumps. The operators appeared to follow the procedure satisfactorily in a step-by-step manner. The motor-driven pump performed well within the acceptance criteria, which was expected because the pump had just been overhauled during the week of July 18, 1988. The diesel pumps performed marginally. The raw data indicated that the have been delivering at least 2000 gallons per minute (pumps GPM) while at may not a pump head of 100 pounds per square inch differential (psid).
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| Technical Specification (TS) 4.7.10.1.1.f.1 requires each of the pumps to deliver at least 2000 GPM at a total head of 100 psid by verifying at least three points on the pump performance curve during performance testing. Acceptance Criterion 7.2 of OP-903-056 appears to have the same requirements. The operator brought this to the attention of the system engineer who then evaluated the data using correction factors. The operator explained to the inspector that the pumps were perfoming satisfactorily based upon the engineer's calculations. The test was completed with what appeared to be marginal results. The NRC inspector decided that further review was necessar On July 30, 1988, the inspector reviewed the completed fire pump flow data that had been presented to the Shift Supervisor. Diesel Fire Pump No. 1, although it only delivered 1966.6 GPM, was running below rated speed. By applying correction factors for speed in accordance
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| | W3P89-0011 Page 1 of 7 ATTACHMENT 2 Revision 1 to the LP&L Responses for Violations 8819-01 and 8819-02 Identified in Appendix A of Inspection Report 88-19 VIOLATION NO. 8819-01 Failure To Report To NRC 10 CFR 50.73(a)(1) states, in part, that the holder of an operating license for a nuclear, power plant shall submit a Licensee Event Report (LER) for any event of the type described in this paragraph within 30 days after the discovery of the even Attachment 6.5 of LP&L Administrative Procedure UNT-6-010, Revision 4, |
| | " Event Notification and Reporting," requires, in part, an LER as described above to be submitted when there was any operation or condition prohibited by the plant's Technical Specification (TS) or if an event or condition during operation results in the nuclear power plant being in a condition that was outside the design basis of the plan Contrary to the above, the staff identified four examples where the licensee failed to comply: Until April 18, 1988, the licensee failed to issue an LER I identifying a condition found on April 2, 1987, where nonsafety electrical circuits were not separated from safety circuits using double circuit breakers in accordance with NRC Regulatory Guide 1.75 as committed in the FSAR. This was a condition that was { |
| | outside the design basis of the plan . Until April 18, 1988, the licensee failed to issue an LER l identifying conditions discovered on August 19, 1987, where Gas ! |
| | Decay Tank sampling was not performed as required by TS Table j 3.3-13. As a result, the plant was in a condition prohibited by 1 the T . Until April 18, 1988, the licensee failed to issue an LER identifying conditions discovered on October 21, 1987, where Containment Atmosphere Purge Isolation Valves CAP-103 and CAP-205 had exceeded the stroke time periodicity specified by TS 4. and 4.0.5. As a result, the plant was in a condition prohibited by the T . Until July 11, 1988, the licensee failed to issue an LER identifying conditions discovered on May 17, 1988, where Snubber SISR-1352 was found missing from a shutdown cooling line that was required to be operable per TS 3.7.8 and 3.9.8.2 while the plant was being refueled. As a result, the plant was in a condition prohibited by the T This is a Severity Level IV violati l i |
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| | ! LP&L admits this violation in that LERs for each of the above noted events should have been submitted in accordance with 10CFR50.73(a)(1) |
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| | ' plant or were prohibited by the TSs existe (1) Reason For The Violation Item 1 addresses the nonreporting of a failure to meet safety to nonsafety electrical distribution separation criteria that was identified on April 2, 1987. The baais for not submitting an LER was strictly due to an oversight on the initial deportability determination which was dated April 6, 1987. On March 23, 1988, the deportability determination was subsequently revised and LER 87-029 was issued on April 18, 1988 accordingl . Item 2 cites the failure to submit an LER within 30 days from discovery of a missed Waste Gas Decay Tank sample on August 19, 1987. It was believed, prior to expiration of the 30 day limit, that the 25% surveillance extension of Technical Specification (TS) 4.0.2 applied to TS Limiting Condition for Operation (LCO) time requirement Consequently, the event was determined to be not reportabl On April 18, 1988, a voluntary report (LER 87-030) was submitted which discussed in detail how plant staf f made the deportability determination. It has since been learned that the 25% extension of TS 4.0.2 does not apply to LCO time limit . Item 3 identified the failure to submit an LER within 30 days from discovery of missed stroke test surveillance of two Containment Atmosphere Purge (CAP) valves in accordance with TS 4.0.5. Prior to expiration of the 30 day limit, the event was determined to be not reportable. The basis for this determination was that by declaring valve CAP 205 inoperable, which necessitates classifying leakage through valves CAP 103 and CAP 104 as bypass leakage, leakage would still remain well within the allowable limi (It is important to note that CAP 103 was tested within TS 3.6. LCO time limits.) |
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| with OP-903-056, the pump would deliver at least 2000 GPM at 100 asid if running at or above rated speed. The TS was silent as to whetler the pump should deliver at least 2000 GPM at 100 psid when called upon during testing or actual need or just be proved capable of the same by applying correction factors. By taking a liberal interpretation of the TS and by applying cc,rrection factors for speed, the three Joint pump curve established by this test places the pump just above t1e 2000 GPM point at 100 psi Diesel Fire Pump No. 2 was running slightly above rated speed but delivered only 1991.5 GPH. Application of correction factors in accordance with OP-903-056 placed the pump below the 2000 GPM point at 100 psid. Although this was well within the acceptable -ange set up by ASME, Section XI, Table IWP-3100-2, which i +3 percent and-10 percent, it did not comply with the TS as written. When the inspector brought this to the attention of the Shift Supervisor, he agreed and declared the pump inoperable. Since only two of the three fire pumps must be operable at all times, this did not place the plant in a TS L niting Condition for Operation (LCO). By the strict interpretation of the acceptance criteria in 0P-903-056, the operator (assisted by the system engineer) failed to follow the procedure acceptance Section 8.8 which requires the operator to identify unsatisfactory test results and to inform the Shift Superviso Instead, the procedure was signed off as satisfactory. In light of the arrbiguities associated with the TS and the procedure, particularly when the ASME Code allows a negative tolerance of 10 percent, the staff will not issue a Notice of Violatio The licensee has comitted to obtain a TS change and clarify 0P-903-056 acceptance criteria such that the intended operability requirements of the fire pumps will be met. The Waterford 3 FSAR, Section 9.5.1.2, calls for a maximum demand of 1844 GPM. As such, the TS value could be lowered to accommodate normal pump wear and still be within the safety analysis. This shall be tracked under Open Item 382/8819-0 No violations or deviations were identifie . Followup of Previously Identified items (92701) (Closed) Unresolved Item 382/8615-03: Conflicts and inconsistencies between the Technical Specifications, FSAR, and Operating Procedure OP-10-001, Revision 6. "Cooldown to Hot Shutdown (Mode 3 to Mode 4)." These inconsista cies were related to Reactor Coolant System (RCS) Low Temperature Overpre"urization Protection (LTOP).
| | On April 18, 1988, a voluntary report (LER 87-031) was submitted which discussed in detail how plant staff made the deportability determination. It has since been understood, which was not apparent at the time of the initial deportability determination, that missed TS 4. surveillance constitute a condition prohibited by TS _ - _ - _ _ _ - _ - - |
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| Appendix 5.2B.3 of the FSAR state 5 that administrative controls necessary to provide LTOP are limited to those controls that open the shutdown cooling system isolation valves, which in turn place the shutdown cooling system relief alvr in service. The NRC inspector was concerned that there were idi ' administrative controls addressed in Section 6.3. \R. The language of licensee to be poorly worded Section 6.3.2.5.1 was dett
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| | Page 3 of 7 4. The last Item addresses the issuance of LER 88-017 on July 11, 1988, for the identification of a snubber missing from the Shutdown Cooling System that was discovered on May 17, 198 In the initial deportability determination dated May 19, 1988, the event was determined to be reportable as a condition prohibited by the TSs. The basis for this determination was the TS requirement for both Shutdown Cooling Trains to be operable when water level above the reactor pressure vessel flange is lowered below 23 feet, which occurred on May 12, 1988. Snubber SISR 1352 was not discovered as being removed (inoperable) until May 17, 198 Based on an engineering evaluation which determined that shutdown cooling system operability was not affected by the removal of the snubber, the deportability determination was subsequently revised (Revision 1) on June 2, 1988 to classify the event as not reportabl It is noteworthy to mention that a recommendation was made in the evaluation to remove snubber SISR 1352 during the next refueling outage and a modification has since been approved to do s Revision 2 to the deportability determination was issued on June 21, 1988 reclassifying the event as a reportable LER due to a condition prohibited by TS The basis for reclassifying the event as reportable was that even though SISR 1352 is not required for Shutdown' Cooling System operability, the snubber was still under the control of TS 3.7.8 thereby requiring it to be operabl Since Revision 2 to the deportability determination was dated after the expiration of 30 days from the event discovery, it was necessary to use the guidance provided in NUREG-1022, Supplement 1 (" Licensee Event Report System") to develop an adequate timeframe for drafting and approving an LER. Section 14 of NUREG-1022 states, in part, "The LER must be submitted within 30 days of discovery of the event or condition that is reportable." Accordingly, LER 88-017 was issued on July 11, 1988, which was within 30 days from Revision 2 to the event deportability determination, when the condition was discovered to be reportable. Since Section 14 of NUREG-1022 also states that "If the LER is not submitted with 30 days from the event date, explain the relationship between the event date, discovery date, and report date in the LER text", this information was explicitly provided in LER 88-01 The deportability determinations associated with this event represent a good faith interpretation of reporting regulations and guidelines by plant staff. In this particular incident, the issue of deportability was initially believed to be the operability of the Shutdown Cooling System, which was satisfactorily resolved. However, the snubber was still administrative 1y controlled by TSs which was not considered until later. |
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| and subject to misinterpretation. This section of the FSAR has since been rewritten and will be included in the 1988 revision of the FSA The other inconsistencies identified by the NRC inspector were also addressed and corrected by the revision to Section 6.3.2.5.1 of the FSAR. This item is closed, b. (Closed)OpenItem 382/8710-01: Followup on the basis for modification to core protection calculator auxiliary cabinet fan The licensee provided a copy of Field Action Request 9270-422, dated February 24, 1984, which documented Combustion Engineering's approval of modifications to the fans. The modifications included rerouting of the power cord and bypassing of the "high/ low" switch. In addition, the licensee added a precaution to the SIMS - Instrument Information Sheet for the applicable control panel (CP-22) addressing fan modifications. This item is close c. (0 pen) Open Item 382/8710-03: Followup on the licensee's actions to
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| , install and ensure adequate control of seismic restraining bolts on 480 volt switchgear breaker cabinet hoists during maintenance activities. The NRC inspector verified that the seismic restraining bolts were installed. The NRC inspector also verified that instructions to reinstall these bolts after maintenance had been incorporated into the applicable breaker maintenance procedures, t However, the instructions referenced Drawing 506760500. This drawing
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| could not be obtained by the NRC inspector from the document control center at the Waterford-3 site, which places its existence or perhaps the drawing number in question. As of the end of this inspection period, about a week had passed and the licensee had not yet provided the drawing. Consequently, this item could not be closed, d. (Closed) Open Item 382/8717-03: Followup on the licensee's '
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| | Page 4 of 7 (2) Corrective Actions That Have Been Taken All four items have been reported in the proper LER forma As documented in LP&L Letter W3A89-0104 dated January 23, 1989, the Events Analysis Reporting and Response-(EAR &R) Manager discussed the details of this violation with members of his staff to advise them of the importance of adhering to reporting requirements when reviewing plant events. Also, subsequent to the issuance of the violation, LP&L 1) placed the NRC Resident Inspector for Waterford 3 on distribution for all Potential Reportable Events (which includes the initial deportability determination) and 2) contacted the NRC-NRR Project Manager for Waterford 3 (and as necessary will contact in the future) when management felt it prudent to do so in situations where questions remained about reporting requirements after internal reviews had been performe It is also noteworthy of mentioning that both the Vice President-Nuclear and the Plant Manager-Nuclear has counselled the current EAR &R Manager to be more sensitive and solicitous of the deportability opinions of others and to avoid the concerns of the pas Based on the above information, LP&L feels that sufficient actions have been implemented to prevent a recurrence of a violation for failing to satisfy reporting requirement (3) Corrective Actions Which Will Be Taken Revisions to LER 87-030 and LER 87-031 will be submitted by October 15, 1988, to appropriately classify them as conditions prohibited by TSs. [ Note: Revisions to LER 87-030 and LEF 87-031 were actually submitted September 30, 1988 in LP&L Letter Nos. W3A88-0109 and W3A88-0110, respectively.] |
| | (4) Date When Full Compliance Will Be Achieved Based on the above information, LP&L is currently in full complianc ! |
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| pressure instrument was lef t isolated durin" maintenance. The NRC inspector verified that Procedure OP-903-02), Revision 2, "Inspection
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| | '' W3P89-0011 Page 5 of 7 B. VIOLATION NO. 8819-02 Failure To Follow Procedures Technical Specification 6.8.1.a requires, in part, the implementation of procedures covering activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, including the procedures for abnormal, off-normal, or alarm condition The licensee's Operating Procedure OP-4-020, Revision 0, " Bypassed and Inoperable Status Indication Systems," requires monitoring of safety equipment status by way of computer and requires operator acknowledgement of annunciator alarms in evaluation of systems that have been computed to be inoperabl Contrary to the above, the inspectors observed alarming annunciators l in the control room which had not been acknowledged on February 5 and 9, 198 In addition, on February 8 and 10, 1988, the inspectors observed annunciators alarm (Containment Isolation and Emergency Feedwater related, respectively) which were not acknowledged as specified by procedur This is a Severity Level V violatio RESPONSE LP&L acknowledges that a violation of TS 6.8.1.a existed when operators failed to acknowledge Bypassed and Inoperable Status Indication System indicator actuations in accordance with OP-4-02 (1) Reason For The Violation The purpose of the Bypassed and Inoperable Status Indication System (BISIS), as delineated in Operating Procedure OP-4-020, is to provide the operator with a supplemental means of identifying bypassed and inoperable safety system conditions. The system is not designed to be used in place of plant administrative procedures when determining bypassed or inoperable equipmen Nonetheless, when an operator sees that a system is computed as inoperable, his actions in accordance with OP-4-020 are to initially acknowledge the signal (by depressing the applicable pushbutton), then evaluate the status of the equipment which caused the computer to illuminate an indicator. Based on the importance of ensuring that equipment is properly operating, the more logical sequence for an operator to follow is to first determine the validity of a BISIS indicator by evaluation; then, acknowledge the indication if valid or insert an appropriate value for the point in question, log the required information on the BISIS Point Deviation Sheet (Attachment 8.5 of OP-4-020) and |
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| Handling, and Use of POM Procedures." This item is close (Closed) Open Item 382/8804-03: Followup of licensee actions on items identified during controlled area ventilation system walkdown, The NRC inspector verified that the licensee had corrected the
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| 16 (Closed)OpenItem 382/8731-02: Followup on final outcome of licensee staff reviews of vendor information packages. During the period of December 7 through December 18, 1987, the NRC conducted a Procurement / Vendor Information Audit at Waterford 3 The NRC inspectors identified cases where service bulletins issued by the emergency diesel generator vendor, Cooper-Bessemer, were not acted upon by the licensee. The specifics were corrected as reported in NRC Inspection Report 50-382/87-31, however, the licensee committed to conduct a two-phase review of a population of 769 items which had presumably been processed through the licensee's Vendor Equipment Technical Information Program (VETIP). The first phase consisted of 345 VETIP packages which the licensee determined to have a potential for significant impact on plant equipment. This was completed on a priority basis by January 5, 1988. The second phase was a review of the remaining 424 VETIP packages which was completed by March 1, 1988. A total of 208 packages required additional plant staff review, and as a result, 20 required procedure changes. Quality Notice 88-01 was written to document the failure to ensure that proper reviews of vendor infonnation packages are performed. With the exception of the Cooper-Bessemer service bulletins already identified, no significant program or procedure changes resulted from the rescreening effort. Details on the licensee's actions were documented and transmitted from LP&L to the NRC on March 19, 1988, by cover letter serial number W3P88-0040. This item is close No violations or deviations were identifie . Followup On NRC Bulletin 88-05 (92703)
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| Jersey." The licensee promptly initiated a program to carry out the i instructions in the bulletin. They determined the number of affected flanges onsite, and then initiated actions to locate and test the flange By review of procurement documents, the licensee determined that 534 of the affected flanges were potentially onsite. Records were traced to locate each flang The licensee determined that 259 flanges were currently installed in safety-related systems,138 flanges vere in the warehouse, and the remaining 137 flanges were not installed in safety-related system As flange locations were determined, the licensee perfonned hardness testing using an Equotip hardness tester to detennine whether material design strength requirements were met. Several flanges were tested onsite and then at an independent testing laboratory to verify results of the onsite testing. In addition, several flanges were destructively tested offsite to verify onsite test results. The material strength determined offsite were found to correspond with onsite measurements. At the end of this inspection period,16 flanges (in safety-related systems) were found l m
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| | Page 6 of 7 During the incidents cited in the Inspection Report, the operators, acting on plant knowledge and past experiences with invalid indications, chose to evaluate the equipment status prior to acknowledging the BISIS indicator which resulted in-the procedure violation. It is important to note that the fact that the operators were aware of the status of the monitored systems in question, that the systems were verified as being operable, was substantiated by the NRC Inspectors (as noted in Inspection Report 88-200). Also, since'the invalid indications were spurious in that the appropriate values reappeared prior to I having them inserted, no further action was required by the operato (2) Corrective Actions That Have Been Taken , |
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| | Effective August 19, 1988, Operating Procedure OP-4-020 was revised to change the sequence in which an operator responds to a BISIS indication. The current sequence, which is a more realistic and logical approach for responding to such indications, is as follows: first, when an operator sees that a system is computed as inoperable, he should evaluate the status of the equipment that caused the BISIS indication as soon as possible; then, if valid, the operator acknowledges the signal by depressing the associated pushbutton or if invalid, he generates a CI to correct the proble In August, 1988, the individuals responsible for the violation were cautioned in the importance of acknowledging Bypassed and Inoperable Status Indication System indicators as well as were reminded of the importance in complying with procedures. (LP&L Letter W3089-0019 was issued to document the counselling of the responsible individuals.) Also, in efforts to bring this matter to the attention of operations personnel and thereby ensure that this type of violation does not recur, a briefing on the procedure violation, to include a discussion of the corrective actions implemented, was held on January 13, 1989 during a shift supervisors' meetin Although not specifically part of the corrective actions completed to date for this violation, it is important to note that System Engineering performed an evaluation of the BISIS logic. The purpose of this evaluation was to identify improvements that will reduce the number of invalid indication (Note: The detailed results of this evaluation are documented in Letter W3E88-0257 dated 10/28/88.) |
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| to have lower than acceptable strength of 66 KSI. Seven of these flanges (HeatNumberG631889) were installed on the inlet to main steam relief valves ~The licensee performed an analysis, based on the lowest strength flange (58 KSI) and the highest calculated loading, and determined that these flanges met the ASME, Section III NC-3658.1, requirements and were acceptable for their intended us Five essential service chilled water system flanges and four containment atmosphere release system fbges (the lowest were at 60 KSI) were found to have lower thtn required strength of 66 KSI. These flanges were detemined to be acceptable after an analysis was performed and conformance with ASME, Section III, was verifie The licensee has identified three flanges which are located in the l containment. Two of these flanges are in the containment atmosphere i release system and one on the component cooling water return to Reactor J Coolant Pump 2A cooler. Because these flanges are in a high radiation and i
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| high temperature area, the licensee has published a justification for
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| continued operation, which states that testing can be delayed until the next forced outage without introducing a significant hazard. These are low pressure, low energy systems.
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| No violations or deviations were identfie . Licensee Event Report (LER) Followup (92700)
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| In early June 1988, the inspector conducted a review of Potentially Reportable Event (PRE) Report 88-055 which was the licensee's internal identification that a snubber had been discovered missing from the shutdown cooling system (Safety Injection System) during maintenanc On May 17, 1988, maintenance personnel were reinstalling the shutdown cooling relief Valve SI-404A after maintenance when they noted Snubber SISR-1352 missing. The Shift Supervisor was appropriately notified, and a work authorization was initiated to promptly replace the snubber. In accordance with Technical Specification (TS) 3.7.8, the
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| absence (and thus the inoperability) of this snubber placed the shutdown
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| ; cooling system in an inoperable status for an indeterminate amount of
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| time, a condition prohibited by technical specifications. The plant was in a refueling outage, and there were times when TS 3.9.8.2 required shutdown cooling Train A to be operable. The PRE indicated that this event was not reportable because subsequent evaluation determined that the snubber could be removed permanently. The subsequent evaluation which showed the snubber was not required mitigated the consequences of the event but it did not affect the reportability of the even During an exit meeting on [[Exit meeting date::June 17, 1988]], the inspector expressed concern to plant management regarding implementation of the reporting requirements of 10 CFR 50.73. On July 11, 1988, LER 88-017 was published describing
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| the above event. This is a fourth example (see paragraph 2 of this I | | ' |
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| | (3). Corrective Actions Which Will Be Taken Based on the above information, LP&L feels confident that a |
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| report) of failure to comply with the reporting requirements of 10 CFR 50.73. This is part of apparent violation 382/8819-0 Since the issues are already identified in apparent violation 382/8819-01, the staff will not issue a second Notice of Violation citing the failure of the licensee to maintain shutdown cooling Train A operable when it was required by TS 3.9.8.2. It appears that issues and corrective actions that would normally be discussed in the response to such a violation were addressed in LER 88-017, thus no purpose would be served in the issuance of another Notice of Violation. Although the LER stated that a root cause of this event could not be detennined because it could not be ascertained when or why the snubber was disconnected, the event implies that someone removed the snubber without authority after April 8,1988, (when it was surveillance inspected in place). The inspector expressed concern that on-going licensee efforts to eliminate procedure violations (which includes doing work affecting quality without procedural controls) are not achieving satisfactory results to date. The licensee acknowledged the inspector's concerns in the procedure compliance area and discussed additional plans and programs being implemented to achieve procedure compliance. The resident inspectors will continue to monitor this are LER 88-017 is close . Onsite Followup of Events (93702) Failure of Main Feed Pump "A" During the week of July 18, 1988, the licensee noted increasing vibration on the Main Feed Pump (MFP) "A". The plant was at full power with both MFPs in service. By the end of the week, the vibration had approached approximately 8 mils displacement, which was the licensee's decision point for reducing power and securing MFP "A" for investigation and repairs. By 3:00 p.m. on July 22, 1988, power was reduced to about 65 percent. The pump was disconnected from the turbine, and the turbine was tested for vibration, with satisfactory results. The pump was then disassembled to repair an already leaking inboard seal. The licensee found the inboard pump bearing badly damaged with melted babbit, and two of the 26 socket head bolts that secured the diffuser were missing. One of the bolts was found jauned in the impeller. The bolt and the impeller were both damaged. This seemed to point toward the cause of vibration. Attempts to find the second boltimposed restrictions were unsuccessful due to by minor steam access (hot and flashing visibility ) leakage feedwater into the suction piping. Although the remaining 24 diffuser bolts were tack welded in place, two other bolts were found with the bolt heads broken off. The licensee connented that earlier revisions of the MFP technical manual did not specify a torque value for these bolts, but the current revision did, thus the bolts may have been over torqued during initial installation. The licensee replaced all
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| , 26 diffuser bolts, the pump bearings, the impeller, and the pump seal r
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| On July 26, 1988, MFP "A" was started up after completion of repair At about half speed, a metallic sound was heard in the pump, and again severe vibration of 8 to 10 mils was observed. On July 27, 1988, MFP "A" was again disassembled to determine the cause of vibration. The inboard seal was opened to look in the impeller for the bolt that could not be found. The feedwater isolation valves seated better this time allowing removal of a short section of the suction piping, and the bolt was found. The pump was reassembled, and by 6:00 a.m. on July 29, the plant was restored to full powe No violations or deviations were identifie . Plant Status (71707)
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| The plant was at full power from the beginning of the reporting period until about 3:00 p.m. on July 22, 1988. Then power was reduced to 65 percent for Main Feedwater Pump "A" repairs, and stroke testing of the main turbine throttle, governor and intercept valves. Also, while at reduced power, the monthly reactor control element assembly movement test was don On July 22, 1988, at about on low electro-hydraulic 9:25 p(. control EHC), pressur the plant experienced a turbine trip Maintenance mechanics were replacing a test solencia valve while at reduced power. A check valve used for isolation leaked due to a missing "0" ring when they attempted to remove the solenoid valve. This depressurized the EHC and the turbine tripped. The Steam Bypass Control System responded properly, and the reactor remained at power. Minimum power was about 30 percent until the plant was restored to the grid at about 9:30 a.m. on July 23, 1988, and then power was increased back to 60 to 65 percen As discussed in paragraph 10 above, by 6:00 a.m. on July 29, 1988, full power was restored and remained such as of the end of this inspection perio No violations or deviations were identifie . Exit Interview The inspection scope and findings were sunnarized on August 1,1988, with those persons indicated in paragraph 1. The licensee acknowledged the NRC inspectors' findings. The licensee did not identify as proprietary any of the material provided to or reviewed by the NRC inspectors during this inspectio
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217L0421999-10-21021 October 1999 Forwards Insp Rept 50-382/99-20 on 990815-0925 & Notice of Violation.Two Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20217N2111999-10-19019 October 1999 Forwards Insp Rept 50-382/99-14 on 990913-17 & 1004-08.No Violations Noted.Licensed Operator Requalification Program, Effective,Utilized Systems Approach to Training & Showed Continued Improvements Over Previous Insp Findings ML20217L0101999-10-18018 October 1999 Provides Update of Waterford 3 Effort for Review of Ufsar. Info Listed Includes Background Mgt Expectations,Review Status & Results,Clarifications Re Review & Conclusions ML20217L0141999-10-18018 October 1999 Submits Update to NRC Staff Re Circumstances & Plans for Submitting Certification Rept on Waterford 3 Plant Specific Simulator ML20217G7051999-10-14014 October 1999 Forwards Comments on Four of NRC RO Examination Questions for Exam Administered During Week of 991004 05000382/LER-1999-014, Forwards LER 99-014-00,providing Details of Reactor Shutdown Due to Loss of RCP Controlled bleed-off Flow.Attached Commitment Identification/Voluntary Enhancement Form Identifies All Commitments Contained in Submittal1999-10-12012 October 1999 Forwards LER 99-014-00,providing Details of Reactor Shutdown Due to Loss of RCP Controlled bleed-off Flow.Attached Commitment Identification/Voluntary Enhancement Form Identifies All Commitments Contained in Submittal ML20217D5151999-10-0707 October 1999 Forwards Application for Renewal of SRO License for C Fugate License SOP-43039-3,IAW 10CFR55.57.Without Encls ML20217C6251999-10-0505 October 1999 Informs That NRC Reviewed Util Ltr & Encl Exercise Scenario Package for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Based on Review,Nrc Determined That Exercise Appropriate to Meet Objectives ML20212J6921999-09-29029 September 1999 Forwards Insp Rept 50-382/99-18 on 990830-0902.One Noncited Violation Identified Re Failure to Follow Procedural Instructions to Ensure That Members on Fire Brigade Shift Were Qualified ML20216G2441999-09-27027 September 1999 Forwards Insp Rept 50-382/99-19 on 990830-0903.No Violations Noted 05000382/LER-1999-013, Forwards LER 99-013-00,providing Details of Exceeding TS Limits for RCS Cooldown Rates.All Commitments Contained in Submittal Are Identified on Encl Commitment Identification/ Voluntary Enhancement Form1999-09-23023 September 1999 Forwards LER 99-013-00,providing Details of Exceeding TS Limits for RCS Cooldown Rates.All Commitments Contained in Submittal Are Identified on Encl Commitment Identification/ Voluntary Enhancement Form IR 05000382/19993011999-09-21021 September 1999 Informs That NRC License Exam Previously Associated with NRC Insp Rept 50-382/99-301 Will Be Incorporated Into NRC Insp Rept 50-382/99-14 ML20212D8761999-09-16016 September 1999 Informs That on 990818,NRC Staff Completed Midcycle PPR of Waterford 3.During Assessment Period,Number of Personnel Errors Occurred,Which Demonstrated Lack of Attention to Detail by Plant Personnel.Historical Listing of Issues,Encl ML20212C2471999-09-16016 September 1999 Forwards Five Final Applications for RO Licenses for G Esquival,Jm Hearn,Md Lawson,Re Simpson & PI Wood.Written Exam & Operating Test to Be Administered,Is Requested. Encls Withheld ML20212C2391999-09-16016 September 1999 Requests Cancellation of SRO Licenses for Bn Coble,License SOP-43835,due to Job Assignment Location & CA Rodgers, License SOP-43537-1,due to Resignation from Company, Effective 990901 ML20212C5881999-09-14014 September 1999 Forwards Insp Rept 50-382/99-15 on 990719-23 with Continuing in Ofc Insp Until 0819.No Violations Noted ML20211Q4421999-09-0909 September 1999 Forwards Insp Rept 50-382/99-07 on 990601-11.Three Violations Being Treated as Noncited Violations ML20211P4121999-09-0707 September 1999 Requests NRC Staff Review & Approval of Integrated Nuclear Security Plan (Insp) & Integrated Security Training & Qualification Plan (Ist&Q), for Use by All Entergy Operations,Inc.Encl Withheld,Per 10CFR2.790(d) ML20211M8391999-09-0303 September 1999 Forwards Revised Epips,Including Rev 25 to EP-001-020,rev 24 to EP-001-030,rev 25 to EP-001-040,rev 30 to EP-002-100,rev 22 to EP-001-010,rev 27 to EP-002-010,rev 26 to EP-002-102 & Rev 16 to EP-002-190.Listed Proprietary Revs to Epips,Encl ML20211L3681999-09-0202 September 1999 Forwards Five Preliminary Applications for Reactor Operator Licenses for Individuals Listed,Iaw 10CFR55.31.Encls Withheld ML20211K9741999-09-0101 September 1999 Forwards Insp Rept 50-382/99-16 on 990704-0814.Two Severity Level IV Violations Identified & Being Treated as Noncited Violations,Consistent with App C of Enforcement Policy 05000382/LER-1999-011, Forwards LER 99-011-00,providing Details of Reactor Shutdown Due to Loss of Controlled bleed-off Flow.All Commitments Contained in Submittal Identified on Attached Commitment Identification/Voluntary Enhancement Form1999-08-31031 August 1999 Forwards LER 99-011-00,providing Details of Reactor Shutdown Due to Loss of Controlled bleed-off Flow.All Commitments Contained in Submittal Identified on Attached Commitment Identification/Voluntary Enhancement Form ML20211M3641999-08-30030 August 1999 Forwards Written Examination,Operating Tests & Supporting Ref Matl Identified in Attachment 2 of ES-210,in Response to NRC .Encl Withheld ML20211G5751999-08-27027 August 1999 Forwards RAI Re IPEEE Submittal.Please Provide RAI within 60 Days of Receipt of Ltr,Per Util Response to GL 88-20,suppl 4 ML20211E3281999-08-26026 August 1999 Forwards fitness-for-duty Performance Data for Period of 990101-0630,IAW 10CFR26.71(d).Ltr Does Not Contain Commitments 05000382/LER-1999-009, Forwards LER 99-009-00 Re Discovery of Condition of Noncompliance with App R Involving Inadequate Separation of Essential Cables Routed in Fire Area RAB-30 in Rab. Compensatory Measures Were Established Immediately1999-08-26026 August 1999 Forwards LER 99-009-00 Re Discovery of Condition of Noncompliance with App R Involving Inadequate Separation of Essential Cables Routed in Fire Area RAB-30 in Rab. Compensatory Measures Were Established Immediately 05000382/LER-1999-010, Forwards LER 99-010-00,providing Details of Inadequate Pumping Capacity in Dry Cooling Tower Area.All Commitments Contained in Submittal Are Identified on Attached Commitment Identification Voluntary Enhancement Form1999-08-26026 August 1999 Forwards LER 99-010-00,providing Details of Inadequate Pumping Capacity in Dry Cooling Tower Area.All Commitments Contained in Submittal Are Identified on Attached Commitment Identification Voluntary Enhancement Form ML20211F5421999-08-24024 August 1999 Forwards Proposed marked-up TS Page Xviii, Index Administrative Controls, Correcting Page Number Re TS Change Request NPF-38-220.Editorial Changes for TS Change NPF-38-221 Discussed ML20211F3561999-08-24024 August 1999 Forwards CTS Pages & TS Proposed marked-up Pages for Insertion Into TS Change Request NPF-38-207 Re Efas, Originally Submitted on 980702.Original NSHC Determination Continues to Be Applicable ML20211F4611999-08-24024 August 1999 Informs That NRC Reviewed Ltr & Encl Objectives for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Exercise Objectives Appropriate to Meet Emergency Plan Requirements ML20211G1731999-08-23023 August 1999 Informs That Info Submitted in ,B&W Rept 51-1234900-00,will Be Withheld from Public Disclosure,Per 10CFR2.790 ML20211C5101999-08-19019 August 1999 Forwards Certified Copies of Liability Insurance Policy Endorsements Issued in First Half of 1999 for Each Entergy Operations,Inc Nuclear Unit,Per 10CFR140.15 ML20210T9791999-08-18018 August 1999 Discusses Which Responded to Reconsideration of Violation Denial (EA 98-022) Enforcement Action Detailed in .Concludes That Violation Occurred as Stated ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210S0561999-08-12012 August 1999 Submits Voluntary Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for NRC Fys 2000 & 2001 for Waterford 3 ML20210Q6161999-08-12012 August 1999 Forwards Corrected Copy of Monthly Operating Rept for July 1999 for Waterford 3.Original Rept,Submitted with ,Contained Typos ML20217F2661999-08-12012 August 1999 Forwards Copy of 1999 Waterford 3 Biennial Exercise Package to Be Performed Using Waterford 3 CR Simulator ML20210R9231999-08-11011 August 1999 Forwards Insp Rept 50-382/99-10 on 990719-23.Violations Noted.Nrc Has Determined That One Severity Level IV Violation of NRC Requirements Occurred ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams 05000382/LER-1999-008, Forwards LER 99-008-00,re Failure to Perform Testing of ESF Filtration Units Per TS Srs.Commitments Made by Util Also Encl1999-07-29029 July 1999 Forwards LER 99-008-00,re Failure to Perform Testing of ESF Filtration Units Per TS Srs.Commitments Made by Util Also Encl ML20210H4291999-07-29029 July 1999 Forwards Response to NRC Rai,Associated with TS Change Request NPF-38-208,proposing to Replace Ref to Supplement 1 with Ref to Supplement 2 of Calculative Methods for CE Small Break LOCA Evaluation Model, in ACs Section of TSs ML20210F9451999-07-27027 July 1999 Forwards Proprietary & non-proprietary Version of Rev 29 to EPIP EP-002-100, Technical Support Ctr Activation,Operation & Deactivation. Proprietary Info Withheld,Per 10CFR2.790 ML20210D3171999-07-23023 July 1999 Submits Proposal for Final Resolution of Reracking Spent Fuel Pool at Plant,Per License Amend 144,issued by NRC in .No New Commitments Are Contained in Ltr 05000382/LER-1999-007, Forwards LER 99-007-00,providing Details of Operation Outside Tornado Missile Protection Licensing Basis for turbine-driven Emergency Feedwater Pump Exhaust Stack & Steam Supply Piping.All Commitments Identified on Attached1999-07-23023 July 1999 Forwards LER 99-007-00,providing Details of Operation Outside Tornado Missile Protection Licensing Basis for turbine-driven Emergency Feedwater Pump Exhaust Stack & Steam Supply Piping.All Commitments Identified on Attached ML20210D8701999-07-23023 July 1999 Forwards Safety Evaluation Re First 10-yr Interval Inservice Insp Plan Requests for Relief ISI-018 Through ISI-020 for Entergy Operations,Inc,Unit 3 ML20210B1521999-07-15015 July 1999 Forwards Insp Rept 50-382/99-13 on 990523-0703.Three Violations Being Treated as Noncited Violations ML20209G9771999-07-13013 July 1999 Forwards Objectives & Guidelines for Waterford 3 Emergency Preparedness Exercise Scheduled for 991013.List of Objectives cross-referenced Where Applicable to Relevant Sections of NUREG-0654 IR 05000382/19990081999-07-12012 July 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/99-08 Issued on 990503 ML20209E5231999-07-0909 July 1999 Informs That as Result of NRC Review of Util Responses to GL-92-01,rev 1 & Suppl 1,staff Revised Info in Reactor Vessel Integrity Database & Releasing Database as Rvid Version 2.This Closes Staff Efforts Re TAC MA0583 ML20209D4051999-07-0707 July 1999 Forwards Revised TS Pages to Replace Attachment C,Entirely in Original TS Change Request NPF-38-207,per 990519 Discussion with C Patel of Nrc.Changes to Action 20 Delete Word Requirement & Revise Word Modes to Mode 1999-09-09
[Table view] Category:NRC TO UTILITY
MONTHYEARML20058E8621990-11-0101 November 1990 Forwards Understanding of Current Status of Unimplemented GSIs at Facility,Per 900626 Response to Generic Ltr 90-04. Timely Completion of Encl GSIs Urged ML20058G1561990-10-31031 October 1990 Requests That Matl Listed in Encl 1, Ref Matl Requirements for Reactor/Senior Reactor Operator Licensing Exams, Be Furnished by 901207 for Retake of Operating Exams Scheduled for 910122 ML20058B3101990-10-23023 October 1990 Forwards Insp Rept 50-382/90-22 on 900905-1001 & Notice of Violation IR 05000382/19900231990-10-17017 October 1990 Submits Revised Schedule for Electrical Distribution Sys Functional Insp 50-382/90-23.Insp Team Will Arrive at Plant Site on 910107 ML20058B2681990-10-17017 October 1990 Informs That Util Response to Generic Ltr 90-03, Relaxation of Staff Position in Generic Ltr 83-28,Item 2.2 Part 2, 'Vendor Interface for Safety-Related Components,' Acceptable ML20058A6711990-10-16016 October 1990 Forwards Insp Rept 50-382/90-21 on 900910-14.No Violations or Deviations Noted ML20058A4771990-10-16016 October 1990 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/90-17 ML20062B6231990-10-12012 October 1990 Confirmation of Action Ltr CAL-90-06,confirming That Plant Will Not Enter Mode 2 Until NRC Confirms Actions Assuring That Adequate Safety Exists for Continued Power Operation IR 05000382/19900151990-10-11011 October 1990 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/90-15.NRC Unable to Clearly Determine Actions Intended to Address Overall Retest & Program Weaknesses ML20059N7041990-10-10010 October 1990 Ack Receipt of Util 900717 Response to NRC Bulletin 90-001, Loss of Fill-Oil in Transmitters Mfg by Rosemount ML20059K8651990-09-14014 September 1990 Forwards Interfacing Sys LOCA Insp Rept 50-382/90-200 on 900730-0810.Deficiencies in Availability of Design Calculations,Check Valve Maint & Plant Equipment Labeling Noted ML20059K3601990-09-14014 September 1990 Ack Receipt of Scenario for 1990 Emergency Preparedness Exercise ML20059D5901990-08-28028 August 1990 Forwards Insp Rept 50-382/90-17 on 900625-29.No Violations or Deviations Noted.Exercise Weakness Re Performance of Emergency Responders Noted ML20056B4841990-08-22022 August 1990 Forwards Errata to Amend 62 to License NPF-38,consisting of Revised Bases Page Re Time Intervals for Surveillance Requirements,Per 900717 Application & Generic Ltr 89-14 ML20056B2731990-08-16016 August 1990 Ack Receipt of 900720 & 0803 Ltrs Re Objectives & Guidelines for Annual Emergency Preparedness Exercise.Objectives Appear Reasonable.Exercise Scenario & Associated Matls Should Be Submitted at Least 60 Days Prior to Exercise for NRC Review ML20058P3441990-08-15015 August 1990 Advises That Although Adequate Info Provided to Justify Continued Plant Operation Until Plant Completes Final Rept Per Schedule Delineated by NRC Bulletin 88-11,adequate Bases Not Provided for 40-yr Plant Life ML20056A0301990-07-30030 July 1990 Forwards Insp Rept 50-382/90-11 on 900625-29.No Violations or Deviations Noted IR 05000382/19900021990-07-27027 July 1990 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/90-02 ML20055G7951990-07-19019 July 1990 Forwards Insp Rept 50-382/90-14 on 900625-29 & Notice of Violation.Actions Taken Re Previously Identified Insp Findings Also Examined ML20055E6501990-07-0909 July 1990 Discusses Generic Implications & Resolutions of Control Element Assembly (CEA) Failures at Maine Yankee.Waterford Unit 3 Does Not Have Old Style CEAs Installed in Reactor Core & Does Not Plan to Use Any in Future ML20055C9751990-06-26026 June 1990 Forwards Page 6a for Insertion in Insp Rept 50-382/90-09 ML20055C7781990-06-15015 June 1990 Forwards Insp Rept 50-382/90-09 on 900501-31.No Violations or Deviations Noted.One Unresolved Item Identified.Licensee Test Acceptance Criteria Did Not Appear to Account for Effect of Flow on Valve Closing Time ML20059M9171990-06-13013 June 1990 Forwards NRC Performance Indicators for First Quarter 1990. W/O Encl ML20055C4121990-03-0202 March 1990 Ack Receipt of & Check for $50,000 in Payment for Civil Penalty Imposed by NRC 900202 Order.Corrective Actions Will Be Examined During Future Insp ML20055C2991990-02-23023 February 1990 Advises That 890410 Changes to Emergency Plan,Acceptable ML20248G1871989-10-0202 October 1989 Forwards Insp Rept 50-382/89-25 on 890828-0901.No Violations or Deviations Noted ML20248C6531989-09-27027 September 1989 Forwards Insp Rept 50-382/89-23 on 890801-31.Violations Noted.Enforcement Conference Scheduled for 891011 in Region IV Ofc to Discuss Violation,Reason for Occurrence & Corrective Actions ML20248A4091989-09-26026 September 1989 Requests That Jl Pellet Be Removed from Distribution for Controlled Documents Updates & Revs ML20247Q4211989-09-22022 September 1989 Provides Results of Review of Amend to Rev 5 of Inservice Testing Program for Pumps & Valves.Amend to Rev 5 Acceptable for Implementation & That Testing Requirements Impractical for Item for Which Relief Being Granted ML20247R5681989-09-21021 September 1989 Forwards Amend 4 to Indemnity Agreement B-92,reflecting Changes to 10CFR140, Financial Protection Requirements & Indemnity Agreements, for Signature ML20247J6851989-09-15015 September 1989 Forwards Insp Rept 50-382/89-16 on 890717-21 & Notice of Violation ML20247D4781989-09-11011 September 1989 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/89-05 ML20247F2211989-09-0808 September 1989 Forwards SER Accepting Util 881007,890203,0301 & 0717 Ltrs Re Compliance W/Atws Rule 10CFR50.62 ML20247H8501989-09-0808 September 1989 Ack Receipt of 890531 & 0821 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/89-07. NRC Disagrees W/Licensee Denial of Violation.Implementation of Corrective Actions Will Be Reviewed During Future Insp ML20246P6081989-09-0606 September 1989 Forwards Summary of 890712 Meeting w/C-E Owners Group & Utils Re General Design Features of Diverse ESFAS to Be Installed,Per 10CFR50.62.Safety Evaluation on Plant Design Expected to Be Issued in Near Future ML20246N3131989-08-31031 August 1989 Ack Receipt of Re Violations Noted in Insp Rept 50-382/89-08 & 890516 Notice of Violation.Requests Supplemental Response Re Examples 1-3 of Notice ML20247A5841989-08-30030 August 1989 Forwards Summary of Region Iv/Senior Util Executive Meeting on 890818.Agenda & List of Attendees Also Encl ML20246M6491989-08-29029 August 1989 Forwards Amend 56 to License NPF-38 & Safety Evaluation. Amend Increases Frequency of Channel Calibrs from Quarterly to Monthly on Waste Gas Holdup Sys Explosive Gas Monitoring Sys ML20245J0021989-08-14014 August 1989 Confirms 890808 Conversation W/Rp Barkhurst Re Util Participation in NRC Impact Survey Scheduled for 891010 & Submits Info Re Survey ML20245L3311989-08-11011 August 1989 Forwards Insp Rept 50-382/89-22 on 890701-31 & Notice of Violation IR 05000382/19890121989-08-11011 August 1989 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/89-12.Excluding Incident 1,Violation 382/8912-02 Should Stand as Cited. Response W/Corrective Actions Requested within 30 Days ML20245J2451989-08-0909 August 1989 Advises That Requalification Exams Scheduled for Wk of 890911 Changed to Wk of 890905 to Accommodate New INPO Schedule Issued in May 1989 IR 05000382/19890051989-07-31031 July 1989 Discusses Insp Rept 50-382/89-05 on 890213-17 & Forwards Notice of Violation.No Addl Info Was Provided to Change NRC Position & Therefore Util in Violation of Requirements.Basis for NRC Determination of Violation Provided IR 05000382/19890061989-07-28028 July 1989 Ack Receipt of 890706 Supplemental Response Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/89-06 1990-09-14
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20217L0421999-10-21021 October 1999 Forwards Insp Rept 50-382/99-20 on 990815-0925 & Notice of Violation.Two Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20217N2111999-10-19019 October 1999 Forwards Insp Rept 50-382/99-14 on 990913-17 & 1004-08.No Violations Noted.Licensed Operator Requalification Program, Effective,Utilized Systems Approach to Training & Showed Continued Improvements Over Previous Insp Findings ML20217C6251999-10-0505 October 1999 Informs That NRC Reviewed Util Ltr & Encl Exercise Scenario Package for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Based on Review,Nrc Determined That Exercise Appropriate to Meet Objectives ML20212J6921999-09-29029 September 1999 Forwards Insp Rept 50-382/99-18 on 990830-0902.One Noncited Violation Identified Re Failure to Follow Procedural Instructions to Ensure That Members on Fire Brigade Shift Were Qualified ML20216G2441999-09-27027 September 1999 Forwards Insp Rept 50-382/99-19 on 990830-0903.No Violations Noted IR 05000382/19993011999-09-21021 September 1999 Informs That NRC License Exam Previously Associated with NRC Insp Rept 50-382/99-301 Will Be Incorporated Into NRC Insp Rept 50-382/99-14 ML20212D8761999-09-16016 September 1999 Informs That on 990818,NRC Staff Completed Midcycle PPR of Waterford 3.During Assessment Period,Number of Personnel Errors Occurred,Which Demonstrated Lack of Attention to Detail by Plant Personnel.Historical Listing of Issues,Encl ML20212C5881999-09-14014 September 1999 Forwards Insp Rept 50-382/99-15 on 990719-23 with Continuing in Ofc Insp Until 0819.No Violations Noted ML20211Q4421999-09-0909 September 1999 Forwards Insp Rept 50-382/99-07 on 990601-11.Three Violations Being Treated as Noncited Violations ML20211K9741999-09-0101 September 1999 Forwards Insp Rept 50-382/99-16 on 990704-0814.Two Severity Level IV Violations Identified & Being Treated as Noncited Violations,Consistent with App C of Enforcement Policy ML20211G5751999-08-27027 August 1999 Forwards RAI Re IPEEE Submittal.Please Provide RAI within 60 Days of Receipt of Ltr,Per Util Response to GL 88-20,suppl 4 ML20211F4611999-08-24024 August 1999 Informs That NRC Reviewed Ltr & Encl Objectives for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Exercise Objectives Appropriate to Meet Emergency Plan Requirements ML20211G1731999-08-23023 August 1999 Informs That Info Submitted in ,B&W Rept 51-1234900-00,will Be Withheld from Public Disclosure,Per 10CFR2.790 ML20210T9791999-08-18018 August 1999 Discusses Which Responded to Reconsideration of Violation Denial (EA 98-022) Enforcement Action Detailed in .Concludes That Violation Occurred as Stated ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210R9231999-08-11011 August 1999 Forwards Insp Rept 50-382/99-10 on 990719-23.Violations Noted.Nrc Has Determined That One Severity Level IV Violation of NRC Requirements Occurred ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20210D8701999-07-23023 July 1999 Forwards Safety Evaluation Re First 10-yr Interval Inservice Insp Plan Requests for Relief ISI-018 Through ISI-020 for Entergy Operations,Inc,Unit 3 ML20210B1521999-07-15015 July 1999 Forwards Insp Rept 50-382/99-13 on 990523-0703.Three Violations Being Treated as Noncited Violations IR 05000382/19990081999-07-12012 July 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/99-08 Issued on 990503 ML20209E5231999-07-0909 July 1999 Informs That as Result of NRC Review of Util Responses to GL-92-01,rev 1 & Suppl 1,staff Revised Info in Reactor Vessel Integrity Database & Releasing Database as Rvid Version 2.This Closes Staff Efforts Re TAC MA0583 ML20196E6931999-06-22022 June 1999 Forwards Corrected Ltr Re Changes to Rev 19 to Emergency Plan.Original Ltr Had Error in Subject Line ML20196E0831999-06-21021 June 1999 Forwards Insp Rept 50-382/99-12 on 990524-27.No Violations Noted.Purpose of Insp Was to Conduct Assessment of Emergency Preparedness Program ML20196D9941999-06-18018 June 1999 Forwards Insp Rept 50-382/99-11 on 990524-28.No Violations Noted ML20195J8091999-06-17017 June 1999 Forwards Safety Evaulation Re First 10-yr Interval Inservice Insp Relief Request for Plant,Unit 3 ML20196C8711999-06-15015 June 1999 Discusses Insp Rept 50-382/99-08 & Forwards Notice of Violation Re Unescorted Access Which Was Mistakenly Granted to Individual Whose Background Investigation Indicated That He Had Failed Prior Drug Screening with Another Employer ML20196F3721999-06-0909 June 1999 Corrected Ltr Forwarding Rev 19 to Emergency Plan ML20195G3711999-06-0909 June 1999 Ack Receipt of Ltr Dtd 981223,which Transmitted Waterford 3 Steam Electric Station Emergency Plan,Rev 24,under Provisions of 10CFR50,App E,Section V.No Violations of 10CFR50.54(q) Identified During Review ML20207E8541999-06-0303 June 1999 Forwards SE Accepting Licensee 990114 Submittal of one-time Request for Relief from ASME B&PV Code IST Requirements for Pressurizer Safety Valves at Plant,Unit 3 ML20207G3441999-06-0303 June 1999 Forwards Insp Rept 50-382/99-09 on 990411-0522 & Notice of Violation.One Violation Identified & Being Treated as Noncited Violation C ML20207D3771999-05-27027 May 1999 Ack Receipt of 990401 & 0504 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/99-01 on 990303 ML20207A5121999-05-24024 May 1999 Refers to Which Responded to NOV & Proposed Imposition of Civil Penalty Sent by .Violations A,B & E Withdrawn & Violations C & D Changed to Severity Level IV ML20206U7851999-05-18018 May 1999 Forwards Insp Rept 50-382/99-06 on 990405-09.Three Violations of NRC Requirements Occurred & Being Treated as non-cited Violations ML20206N6961999-05-11011 May 1999 Informs That NRC Office of Nuclear Reactor Regulation Reorganized Effective 990328.As Part of Reorganization, Division of Licensing Project Management Created ML20206S4411999-05-10010 May 1999 Forwards Insp Rept 50-382/99-05 on 990228-0410.Three Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20206H3841999-05-0707 May 1999 Informs That on 990407,NRC Administered Generic Fundamental Exam Section of Written Operator Licensing Exam.Licensee Facility Did Not Participate in Exam,However Copy of Master Exam,With Answer Key,Encl for Info.Without Encl ML20206K0951999-05-0606 May 1999 Discusses Insp Rept 50-382/99-08 Issued 990503 Without Cover Ltr Documenting EA Number & Subject Line Indicated NOV Which Was Incorrect.Corrected Cover Ltr Encl ML20206F4701999-05-0303 May 1999 Forwards Insp Rept 50-382/99-08 on 990405-07.One Apparent Violation Re Failure to Review & Consider Derogatory Access Authorization Background Info as Required by PSP Identified & Being Considered for Escalated Enforcement Action ML20206K1211999-05-0303 May 1999 Corrected Cover Ltr Forwarding Insp Rept 50-382/99-08 on 990405-07.One Violations Noted & Being Considered for Escalated EA ML20205N7251999-04-13013 April 1999 Forwards Summary of 990408 Meeting with EOI in Jackson, Mississippi Re EOI Annual Performance Assessment of Facilities & Other Issues of Mutual Interest.List of Meeting Attendees & Licensee Presentation Slides Encl ML20205M0561999-04-0909 April 1999 Forwards Insp Rept 50-382/99-04 on 990301-19.One Violation of NRC Requirements Occurred & Being Treated as Noncited Violation,Consistent with App C of Enforcement Policy ML20205J8781999-04-0505 April 1999 Forwards Insp Rept 50-382/99-02 on 990117-0227.No Violations Noted.Inspectors Determined That Six Violations Occurred & Being Treated as Noncited Violations Consistent with App C of Enforcement Policy ML20205J0901999-04-0202 April 1999 Informs That Info Submitted by & 970313 Affidavit Will Be Withheld from Public Disclosure,Per 10CFR2.790(b) (5) ML20205A4681999-03-26026 March 1999 Forwards Insp Rept 50-382/99-03 on 990308-12.Two Violations of Radiation Protection Requirements Occurred & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20205A6141999-03-25025 March 1999 Forwards SE Accepting Request to Use Mechanical Nozzle Seal Assemblies (Mnsas) as an Alternative Repair Method,Per 10CFR50.55a(a)(3)(i) for Reactor Coolant Sys Application at Plant,Unit 3 ML20205F3311999-03-19019 March 1999 Advises of Planned Insp Effort Resulting from Plant,Unit 3 PPR Review,Which Was Completed on 990211.Performance at Plant,Unit 3 Was Acceptable ML20204E4941999-03-17017 March 1999 Discusses TSs Bases Change Re 3/4.4.1,3/4.6.1.7,3/4.6.3, 3/4.7.12 & 3/4.8.4.Forwards Affected Bases Pp B 3/4 4-1, B 3/4 6-3,B 3/4 6-4,B 3/4 7-7 & B 3/4 8-3 ML20207F1251999-03-0303 March 1999 Forwards Insp Rept 50-382/99-01 on 990125-29 & 0208-12 & Notice of Violations ML20203H8501999-02-17017 February 1999 Forwards SE Accepting Licensee 970701 Submittal of Second Ten Year ISI Program & Associated Relief Request for Plant, Unit 3.Nine Relief Requests Had Been Authorized Previously & Proposed Alternatives Remain Authorized ML20203D7211999-02-11011 February 1999 Forwards Request for Addl Info Re Licensee 970317 & 990111 Responses to GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves. Response Should Be Provided within 60 Days 1999-09-09
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FEB 21 E 1 Docket:. 50-382/88-19 ^
Louisiana Power,S Light Compan o ATTN: ;J. G. Dewease, Senior Vice President -
Nuclear Operations 317 Baronne Street ;
New Orleans, Louisiana 70160 .
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. Gentlemen:.
Thank 'you for 'your letters of September 26, 1988, and January 26, 1989,;
- in response to our letters.and Notice of. Violation dated August 25, 1988,'and LDecember 20, 1988. We have reviewed your supplemental response to Violations 382/8819-01 and 382/8819-02-and found it contained the additional information that was requested. We now consider it responsive'.to the concerns
. raised in our Notice of Violation dated August 25, 1988. We 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, Onginal Sigxd By:
L J. CALLAN L. J. Callan, Director Division of Reactor Projects cc:
Louisiana Power & Light Company ATTN: R. P. Barkhurst, Vice President
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Nuclear Operations P.O. Box B K111ona, Louisiana 70066 Louisiana Power & Light Company ATTN: N. S. Carns, Plant Manager P.O. Box B Killona, Louisiana 70066
. Louisiana Power & Light Company ATTN: R. F. Burski, Manager, Nuclear Safety & Regulatory Affairs 317 Baronne Street P.O. Box 60340 New Orleans, Louisiana 70160 RIV:DRP/A Ah W D:Db ATHowell;df C:DRP/Ahk'n DDChamberlai LJCallan 2/gi/89 2/pl/89 2/d/89 (
8902280352 890221 .
PDR
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Louisiana Pcwer.& Light. Company -2-Louisiana Power & Light Company 1
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Licensing Support Superviso P.O. Box B
+ Killona, Louisiana 70066 Louisiana Power & Light Company ATTN: G. M. Davis, Manager, Events '
Analysis Reporting & Response P.O. Box B Killona, Louisiana 70066
' Middle South Services ATTN:- Mr. R. T. Lally ;
P.O. Box 61000 New Orleans, Louisiana 70161 Louisiana Radiation Control Program Director bectoDMB(IE01)
bec distrib. by RIV:
RRI R. D. Martin, RA SectionChief(DRP/A) DRP RPB-DRSS MIS System Project Engineer, DRP/A RSTS Operator RIV File DRS(2)
D. Wigginton, NRR Project Manager.(MS: 13-D-18) Lisa Shea, RH/ALF
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(504) 595-3100 U1 ONIVSNU January 26, 1989 W3P89-0011 A4.05 QA U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 9{'
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Washington, D.C. 20555 l g3l@
Subject: Waterford 3 SES ,,
Docket No. 50-382 License No. NPF-38 Violations 8819-01 and 8819-02, Supplemental Information References: LP&L Letter No. W3P88-1800 dated 09/26/88 from R.F. Burski i to U.S. Nuclear Regulatory Commission NRC letter dated 12/20/88 from L.J. Callan to J.G. Dewease Gentlemen:
Louisiana Power & Light hereby submits the following information on the subject violations as a supplement to the responses that were provided in Reference This information, which is contained in Attachment 1, addresses the concerns expressed in Reference 2 vith regard to the lack of including, in the original responses, the corrective steps taken to avoid further violation Also being provided, in Attachment 2, is a revised copy of the original responses for Violations 8819-01 and 8819-02. You will note that a revision bar has been placed in the margin to indicate the area where the supplemental information has been adde If you have any questions concerning these responses, please contact T.J. Gaudet at (504) 464-3325. N Ver uly yours,
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R . Burski nager uclear Safety & Regulatory Affairs l
! RFB:TJG:ssf Attachments cc: R.D. Martin, J.A. Calvo, D.L. Wigginton, NRC Resident Inspectors Office, E.L. Blaka, W.M. Stevenson I
o c7 no n o ni <( , __ "AN EQUAL OPPORTUNITY EMPLOYER"
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W3P89-0011
Page 1 of'2 ATTACHMENT 1 Supplemental Information For Violations 8819-01 and 8819-02 VIOLATION NO. 8819-01: Failure To Report To NRC NRC CONCERN: No corrective action was listed to preclude future instances of failing to satisfy reporting requirement RESPONSE: As documented in LP&L Letter W3A89-0104 dated January 23, 1989, the Events Analysis Reporting and Response (EAR &R) Manager discussed the details of this violation with members of his staff to advise them of
'the importance of adhering to reporting requirements when reviewing plant event Also, subsequent to the issuance of the violation, LP&L 1) placed the NRC Resident Inspector for Waterford 3 on distribution for all Potential' Reportable Events (which includes the initial deportability determination) and 2) contacted the NRC-NRR Project Manager for Waterford 3 (and as necessary will contact in the future) when management felt it prudent to do so in situations where questions remained about reporting requirements after internal reviews had been performe It is also noteworthy of mentioning that both the Vice President-Nuclear and the Plant Manager-Nuclear has counselled the current EAR &R Manager to be more sensitive and solicitous of the deportability opinions of others and to avoid the concerns of the pas Based on the above information, LP&L feels that sufficient actions have been implemented to prevent a recurrence of a violation for failing to satisfy reporting requirement II. VIOLATION NO. 8819-02: Failure To Follow Procedure OP-4-020 NRC CONCERN: Your response did not address what was done to assure that operators will follow procedures in the futur RESPONSE: In August, 1988, the individuals responsibit for the violation were cautioned in the importance af acknowledging Bypassed and Inoperable Status Indication System indicators as well as were reminded of the importance in complying with procedures. Although this action occurred prior to the issuance of the violation response (which was issued September 26, 1988), LP&L chose not to include a discussion of it in the response since documentation to validate such action was not available. [ Note: This information was provided to the Resident Inspector on October 3, 1988].
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Page 2 of 2 Subsequently, LP&L Letter W3089-0019 was issued to document the counselling of the responsible individuals. Also, in efforts to bring this matter t the attention of operations personnel and thereby ensure that this type. of' violation does not recur, a briefing on the procedure violation, to include a discussion of the corrective actions implemented, was held on January 13, 1989 during a shift supervisors'
meeting.
l Based on the above information, LP&L feels confident that a recurrence of this type of violation should be prevented in the futur :
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W3P89-0011 Page 1 of 7 ATTACHMENT 2 Revision 1 to the LP&L Responses for Violations 8819-01 and 8819-02 Identified in Appendix A of Inspection Report 88-19 VIOLATION NO. 8819-01 Failure To Report To NRC 10 CFR 50.73(a)(1) states, in part, that the holder of an operating license for a nuclear, power plant shall submit a Licensee Event Report (LER) for any event of the type described in this paragraph within 30 days after the discovery of the even Attachment 6.5 of LP&L Administrative Procedure UNT-6-010, Revision 4,
" Event Notification and Reporting," requires, in part, an LER as described above to be submitted when there was any operation or condition prohibited by the plant's Technical Specification (TS) or if an event or condition during operation results in the nuclear power plant being in a condition that was outside the design basis of the plan Contrary to the above, the staff identified four examples where the licensee failed to comply: Until April 18, 1988, the licensee failed to issue an LER I identifying a condition found on April 2, 1987, where nonsafety electrical circuits were not separated from safety circuits using double circuit breakers in accordance with NRC Regulatory Guide 1.75 as committed in the FSAR. This was a condition that was {
outside the design basis of the plan . Until April 18, 1988, the licensee failed to issue an LER l identifying conditions discovered on August 19, 1987, where Gas !
Decay Tank sampling was not performed as required by TS Table j 3.3-13. As a result, the plant was in a condition prohibited by 1 the T . Until April 18, 1988, the licensee failed to issue an LER identifying conditions discovered on October 21, 1987, where Containment Atmosphere Purge Isolation Valves CAP-103 and CAP-205 had exceeded the stroke time periodicity specified by TS 4. and 4.0.5. As a result, the plant was in a condition prohibited by the T . Until July 11, 1988, the licensee failed to issue an LER identifying conditions discovered on May 17, 1988, where Snubber SISR-1352 was found missing from a shutdown cooling line that was required to be operable per TS 3.7.8 and 3.9.8.2 while the plant was being refueled. As a result, the plant was in a condition prohibited by the T This is a Severity Level IV violati l i
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Page 2 of 7 RESPONSE
! LP&L admits this violation in that LERs for each of the above noted events should have been submitted in accordance with 10CFR50.73(a)(1)
l since conditions that were either outside the design basis of the
' plant or were prohibited by the TSs existe (1) Reason For The Violation Item 1 addresses the nonreporting of a failure to meet safety to nonsafety electrical distribution separation criteria that was identified on April 2, 1987. The baais for not submitting an LER was strictly due to an oversight on the initial deportability determination which was dated April 6, 1987. On March 23, 1988, the deportability determination was subsequently revised and LER 87-029 was issued on April 18, 1988 accordingl . Item 2 cites the failure to submit an LER within 30 days from discovery of a missed Waste Gas Decay Tank sample on August 19, 1987. It was believed, prior to expiration of the 30 day limit, that the 25% surveillance extension of Technical Specification (TS) 4.0.2 applied to TS Limiting Condition for Operation (LCO) time requirement Consequently, the event was determined to be not reportabl On April 18, 1988, a voluntary report (LER 87-030) was submitted which discussed in detail how plant staf f made the deportability determination. It has since been learned that the 25% extension of TS 4.0.2 does not apply to LCO time limit . Item 3 identified the failure to submit an LER within 30 days from discovery of missed stroke test surveillance of two Containment Atmosphere Purge (CAP) valves in accordance with TS 4.0.5. Prior to expiration of the 30 day limit, the event was determined to be not reportable. The basis for this determination was that by declaring valve CAP 205 inoperable, which necessitates classifying leakage through valves CAP 103 and CAP 104 as bypass leakage, leakage would still remain well within the allowable limi (It is important to note that CAP 103 was tested within TS 3.6. LCO time limits.)
On April 18, 1988, a voluntary report (LER 87-031) was submitted which discussed in detail how plant staff made the deportability determination. It has since been understood, which was not apparent at the time of the initial deportability determination, that missed TS 4. surveillance constitute a condition prohibited by TS _ - _ - _ _ _ - _ - -
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Page 3 of 7 4. The last Item addresses the issuance of LER 88-017 on July 11, 1988, for the identification of a snubber missing from the Shutdown Cooling System that was discovered on May 17, 198 In the initial deportability determination dated May 19, 1988, the event was determined to be reportable as a condition prohibited by the TSs. The basis for this determination was the TS requirement for both Shutdown Cooling Trains to be operable when water level above the reactor pressure vessel flange is lowered below 23 feet, which occurred on May 12, 1988. Snubber SISR 1352 was not discovered as being removed (inoperable) until May 17, 198 Based on an engineering evaluation which determined that shutdown cooling system operability was not affected by the removal of the snubber, the deportability determination was subsequently revised (Revision 1) on June 2, 1988 to classify the event as not reportabl It is noteworthy to mention that a recommendation was made in the evaluation to remove snubber SISR 1352 during the next refueling outage and a modification has since been approved to do s Revision 2 to the deportability determination was issued on June 21, 1988 reclassifying the event as a reportable LER due to a condition prohibited by TS The basis for reclassifying the event as reportable was that even though SISR 1352 is not required for Shutdown' Cooling System operability, the snubber was still under the control of TS 3.7.8 thereby requiring it to be operabl Since Revision 2 to the deportability determination was dated after the expiration of 30 days from the event discovery, it was necessary to use the guidance provided in NUREG-1022, Supplement 1 (" Licensee Event Report System") to develop an adequate timeframe for drafting and approving an LER. Section 14 of NUREG-1022 states, in part, "The LER must be submitted within 30 days of discovery of the event or condition that is reportable." Accordingly, LER 88-017 was issued on July 11, 1988, which was within 30 days from Revision 2 to the event deportability determination, when the condition was discovered to be reportable. Since Section 14 of NUREG-1022 also states that "If the LER is not submitted with 30 days from the event date, explain the relationship between the event date, discovery date, and report date in the LER text", this information was explicitly provided in LER 88-01 The deportability determinations associated with this event represent a good faith interpretation of reporting regulations and guidelines by plant staff. In this particular incident, the issue of deportability was initially believed to be the operability of the Shutdown Cooling System, which was satisfactorily resolved. However, the snubber was still administrative 1y controlled by TSs which was not considered until later.
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Page 4 of 7 (2) Corrective Actions That Have Been Taken All four items have been reported in the proper LER forma As documented in LP&L Letter W3A89-0104 dated January 23, 1989, the Events Analysis Reporting and Response-(EAR &R) Manager discussed the details of this violation with members of his staff to advise them of the importance of adhering to reporting requirements when reviewing plant events. Also, subsequent to the issuance of the violation, LP&L 1) placed the NRC Resident Inspector for Waterford 3 on distribution for all Potential Reportable Events (which includes the initial deportability determination) and 2) contacted the NRC-NRR Project Manager for Waterford 3 (and as necessary will contact in the future) when management felt it prudent to do so in situations where questions remained about reporting requirements after internal reviews had been performe It is also noteworthy of mentioning that both the Vice President-Nuclear and the Plant Manager-Nuclear has counselled the current EAR &R Manager to be more sensitive and solicitous of the deportability opinions of others and to avoid the concerns of the pas Based on the above information, LP&L feels that sufficient actions have been implemented to prevent a recurrence of a violation for failing to satisfy reporting requirement (3) Corrective Actions Which Will Be Taken Revisions to LER 87-030 and LER 87-031 will be submitted by October 15, 1988, to appropriately classify them as conditions prohibited by TSs. [ Note: Revisions to LER 87-030 and LEF 87-031 were actually submitted September 30, 1988 in LP&L Letter Nos. W3A88-0109 and W3A88-0110, respectively.]
(4) Date When Full Compliance Will Be Achieved Based on the above information, LP&L is currently in full complianc !
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W3P89-0011 Page 5 of 7 B. VIOLATION NO. 8819-02 Failure To Follow Procedures Technical Specification 6.8.1.a requires, in part, the implementation of procedures covering activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, including the procedures for abnormal, off-normal, or alarm condition The licensee's Operating Procedure OP-4-020, Revision 0, " Bypassed and Inoperable Status Indication Systems," requires monitoring of safety equipment status by way of computer and requires operator acknowledgement of annunciator alarms in evaluation of systems that have been computed to be inoperabl Contrary to the above, the inspectors observed alarming annunciators l in the control room which had not been acknowledged on February 5 and 9, 198 In addition, on February 8 and 10, 1988, the inspectors observed annunciators alarm (Containment Isolation and Emergency Feedwater related, respectively) which were not acknowledged as specified by procedur This is a Severity Level V violatio RESPONSE LP&L acknowledges that a violation of TS 6.8.1.a existed when operators failed to acknowledge Bypassed and Inoperable Status Indication System indicator actuations in accordance with OP-4-02 (1) Reason For The Violation The purpose of the Bypassed and Inoperable Status Indication System (BISIS), as delineated in Operating Procedure OP-4-020, is to provide the operator with a supplemental means of identifying bypassed and inoperable safety system conditions. The system is not designed to be used in place of plant administrative procedures when determining bypassed or inoperable equipmen Nonetheless, when an operator sees that a system is computed as inoperable, his actions in accordance with OP-4-020 are to initially acknowledge the signal (by depressing the applicable pushbutton), then evaluate the status of the equipment which caused the computer to illuminate an indicator. Based on the importance of ensuring that equipment is properly operating, the more logical sequence for an operator to follow is to first determine the validity of a BISIS indicator by evaluation; then, acknowledge the indication if valid or insert an appropriate value for the point in question, log the required information on the BISIS Point Deviation Sheet (Attachment 8.5 of OP-4-020) and
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generate a condition identification (CI) accordingly if invali l l
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Page 6 of 7 During the incidents cited in the Inspection Report, the operators, acting on plant knowledge and past experiences with invalid indications, chose to evaluate the equipment status prior to acknowledging the BISIS indicator which resulted in-the procedure violation. It is important to note that the fact that the operators were aware of the status of the monitored systems in question, that the systems were verified as being operable, was substantiated by the NRC Inspectors (as noted in Inspection Report 88-200). Also, since'the invalid indications were spurious in that the appropriate values reappeared prior to I having them inserted, no further action was required by the operato (2) Corrective Actions That Have Been Taken ,
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Effective August 19, 1988, Operating Procedure OP-4-020 was revised to change the sequence in which an operator responds to a BISIS indication. The current sequence, which is a more realistic and logical approach for responding to such indications, is as follows: first, when an operator sees that a system is computed as inoperable, he should evaluate the status of the equipment that caused the BISIS indication as soon as possible; then, if valid, the operator acknowledges the signal by depressing the associated pushbutton or if invalid, he generates a CI to correct the proble In August, 1988, the individuals responsible for the violation were cautioned in the importance of acknowledging Bypassed and Inoperable Status Indication System indicators as well as were reminded of the importance in complying with procedures. (LP&L Letter W3089-0019 was issued to document the counselling of the responsible individuals.) Also, in efforts to bring this matter to the attention of operations personnel and thereby ensure that this type of violation does not recur, a briefing on the procedure violation, to include a discussion of the corrective actions implemented, was held on January 13, 1989 during a shift supervisors' meetin Although not specifically part of the corrective actions completed to date for this violation, it is important to note that System Engineering performed an evaluation of the BISIS logic. The purpose of this evaluation was to identify improvements that will reduce the number of invalid indication (Note: The detailed results of this evaluation are documented in Letter W3E88-0257 dated 10/28/88.)
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(3). Corrective Actions Which Will Be Taken Based on the above information, LP&L feels confident that a
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' future. (4) Date When Full Compliance Will Be Achieved LP&L is currently in full' complianc l l
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