IR 05000382/1988019

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

ML20235M657
Person / Time
Site:	Waterford
Issue date:	02/21/1989
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dewease J LOUISIANA POWER & LIGHT CO.
References
NUDOCS 8902280352
Download: ML20235M657 (2)

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.InReply.Referio:. .

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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 (

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O ADOCK 05000382 PDC

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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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• 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{'

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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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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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recurrence of this type of violation should be prevented in the

' future. (4) Date When Full Compliance Will Be Achieved LP&L is currently in full' complianc l l

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