IR 05000401/2005031

Notice of Violation from Insp on 850401-0531

ML20133B974
Person / Time
Site:	Harris, Waterford
Issue date:	08/02/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20133B972	List: IR 05000401/2005031 ML20133B969 ML20133B987
References
50-382-85-16, NUDOCS 8508060307
Download: ML20133B974 (3)

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APPENDIX A NOTICE OF VIOLATION Louisiana Power & Light Company Docket: 50-382 Waterford Unit 3 Permit: NPF-38 During an NRC inspection conducted on April 1 through May 31, 1985, three violations of NRC requirements were identified. The violations involved failure to control design changes and failure to follow procedures. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the violations are listed below: Control of Design Changes Criterion III of 10 CFR 50, Appendix B, requires that the licensee establish measures for the identification and control of design interfaces and for coordination among participating design organizations. These measures shall include the establishment of procedures among participating design organizations for the review, approval, release, distribution, and revision of documents involving design interface LP&L Administrative Procedure PE-02-006, Revision 5, " Station Modifications," paragraph 5.13.1.4, requires that operational procedures and operational training be completed prior to considering the modification packages fully implemente Contrary to the above, on April 10, 1985, the NRC inspector noted that LP&L Off-Normal Operating Procedure OP-901-022, Revision 1, "High Activity in Component Cooling Water Systems," had not been revised to reflect the modification installed under Station Modification Package (SMP) 760. This SMP changed the automatic isolation of component cooling water (CCW) to the reactor coolant pump (RCP) integral seal cooler from high pressure to high temperature. In addition, the modification provided the operators with the means to reopen, from the control room, a closed CCW isolation valve. This modification had been implemented by March 3, 198 This is a Severity Level IV violation (50-382/8516-01). Failure to Follow Procedure Criterion V of 10 CFR 50, Appendix B, requires in part that activities affecting quality be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawing $khe2PDR

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i-2-LP&L Operating Procedure OP-7-001, Revision 4,. " Boron Management System," paragraph 6.24.7 reguires that when the boric acid concentrator temperature decreases to 200 F, as indicated on BM-ITIC- 6381A(B), close the steam chest vent valve, BM 435 A(B) by using manual adjustment knob on Vent Valve Controller BM-ITIC-6403A(B).

Contrary to the above, after shutting down the boric acid concentrator (BAC) on March 29, 1985, the auxiliary operator failed to close boron management valve BM 435 A(B). This valve is only opened during periods of BMC operation to allow venting of noncondensable gases from the BAC steam chest to the radioactive system collection header. On April 3, 1985, a flow transient in the chemical volume control system (CVCS)

letdown line caused a pressure spike downstream of the letdown orifice valves. CVCS relief valve CVC 115 opened as required reducing the pressure below the CVC 115 set point; however, the valve failed to

. properly insert resulting in approximately 1 gpm reactor coolant system (RCS) leakage to the radioactive system collection header. The header was physically aligned to one of the holdup tanks. The existing backpressure in the tank forced the RCS leakage into the BAC steam chest. The contaminated water then flowed to the gland seal leakoff tank (condensate return unit) and back into the condenser. From the condenser, the contaminated condensate made its way into the polisher and steam generator via the normal secondary system flow pat This is a Severity IV violation (50-382/8516-02). Fire Protection Criterion V of 10 CFR 50, Appendix B requires, in part, that activities affecting quality be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or

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drawing LP&L Fire Protection Procedure FP-1-015, Revision 1, " Fire Protection l

System Impairments," paragraph 4.2, required that the shift supervisor / control room supervisor (SS/CRS) evaluate the fire impairment impact of Technical Specification and insure that applicable ACTION statements are complied with. In addition, the SS/CRS is required to complete a fire protection impairment form and note the same in index

, log. Paragraph 3.2 of this procedure defines an impairment as "any condition that inhibits a fire appliance from properly performing its design function due to failure of components or deviations from the

design position."

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- Contrary to the above, on May 15, 1985, the NRC inspector noted that fire door (D-221) to Boric Acid Concentrator Room B had been removed from service and that no evidence of a completed fire appliance impairment form or that the operability of the fire detector on at least one side of the inoperable assembly had been verifie This is a Severity Level IV violation (50-382/8516-03)

Pursuant to the provisions of 10 CFR 2.201, Louisiana Power & Light Company is hereby required to submit to this Office, within 30 days of the date of the letter transmitting this Notice, a written statement of explanation in reply, including for each violation: (1) the reason for the violations if admitted, (2) the corrective steps which have been taken and the results achieved, (3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response tim Dated at Arlington, Texas, this 2d day of August,198 l

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