ML20153D427

Notice of Violation from Insp on 880618-0731.Violation Noted:Failure to Issue LERs Identifying Conditions Found on 870402,0819,1021 & 880711,failure to Ack Annunciator Alarms on 880205 & 08-10 & Violation of 10CFR50,App B,Criterion V

ML20153D427
Person / Time
Site:	Waterford
Issue date:	08/25/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20153D424	List: ML20153D419 ML20153D427 ML20153D431
References
50-382-88-19, NUDOCS 8809020200
Download: ML20153D427 (3)

Text

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I g APPENDIX A NOTICE OF VIOLATION Louisiana Power & l.ight Company Docket: 50-382 Waterford Steam Electric Station, Unit 3 Operating License: HPF-38 i

During an NRC inspection conducted June Id through July 31, 1988, four [

violations of NRC requirements were identified. The first violation involved  ;

failure to submit 10 CFR 50.73 reports to the NRC. The second and third violations involved failures to follow procedures. The feurth violation involved failure to perform special processes with appropriately qualified .

personnel. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violations i are listed below:

A. 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 event.

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'c 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 plant.

Contrary to the above, the staff identified four examples where the licensee failed to comply:

1. Until April 18, 1988, the licensee failed to issu2 an LER 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 plant.

2. Until April 18, 1988, the licensee failed to issue an LER identifying conditions discovered on August 19, 1987, where Gas Decay Tank sampling was not performed as required by TS Table 3.3-13. As a result, the plant was in a condition prohibited by the TS.

3. Until April 18, 1988, the licensee failed to issue an LER identifying conditions discovered on October 21, 1987, where Containmer.t Atmosphere Purge Isolation Valves CAP-103 and CAP-205 had exceeded the stroke time periodicity specified by TS 4.0.2 and 4.0.5. As a result, the plant was in t, condition prohibited by the TS.

8809020200 DR e80825 ADOCN C5000392 PDC

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4. Unti' luly 11, 1983, the licensee failed to issue an LER identifying cc"& discovered on May 17, 1988, where Snubber MSR-1352 was

~ ning from a shutAn cooling line that was required to be r TS 3.7.8 ant ,9.8.2 while the plant was being refueled.

.- , the plant was in a conditien prohibited by the TS.

This . tty Level IV violation. (SupplementI)(382/8819-01)

8. Failure to Follow Procedures Technical Spccification 6.8.1.a requires, in part, the implementation of proceoures covering activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2 including the procedures for abnormal, off-normal, or alcrm conditions.

The licensee's Operating Procedure OP-4-020, Revision 0, "Bypasses and Inoperable Status Indication Systems," requires monitoring of safety equipment statut by way of computer and requires operator acknowledgement of annunciator alarms and evaluation of systems that have been computed to be inoperable.

Contrary to the above, the inspectors observed alarming annunciators in the control room which had not been acknowledged on February 5 and 9,1988.

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 procedure.

This is a Severity Level V violation. (SupplementI)(382/8819-02)

C. Failure to Follow Procedures Criterion V of Appendix B to 10 CFR Part 50 requires, in part, activities affecting quality to be accomplished in accordance with instructions, procedures, or drawings.

The licensee's Work Authori::atioa WA-01020904 required the motor-driven firewater pump to be reassembled in accordance with Technical Manual 457000514, Volume 2.

Contrary to the above, the applicable section of this 13chnical manual, entitled "Repair Instruction, Type A Centrifugal Pumps," was not followed.

Step 3-2.f provided instructions to cover the top side of the casing gasket witn a mixture of graphite and oil," Steps 3-2.f and 3-2.h provided instructions to "rotate shaft by hand to check that it runs free," and Step 3-2.g provided instructions to "insert the glands and set the nuts finger tight - DO NOT USE A WRENCH." None of the above steps were performed as required during the performance of Work Authorization WA-01020904.

This is a Severity Level IV violation. (Supplenwnt I) (382/8819-03) 11

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D. Failure to Perform Special Process with Appropriately Qualified Personnel 10 CFR 50, Appendix B, Criterion IX, requires, in part, that measures shall be established to assure that special processes are accomplished by qualified personnel.

The licensee's Nuclear Operations Management Manual,Section V, Chapter 9 Revision 3, lists the installation of fire seals as a'special process.

Contrary to the above, the licensee preserited a list cor.taining names of personnel who have performed the installation of fire seals but were not qualified in that they received no formal training and they had no previous experience in the process of fire seal installation.

This is a Severity Level IV violation. (SupplementI)(382/8819-05)

Pursuant to the provisions of 10 CFR 2.201, Louisiana Power and Light is hereby required to submit to this office within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply, including for each violation: (1) the reason for the violation 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 time.

Dated at Ar11agton, Texas, this f 5 d day of d , 1988