ML20133H078

Forwards Response to NRC Re Enforcement Action 85-10 Concerning Failure to Perform Hydrostatic Test Per Fsar.Corrective Actions:Field Change Request Initiated on 800806 to Cover Deletion of Use of High Point Vents

ML20133H078
Person / Time
Site:	Waterford
Issue date:	06/21/1985
From:	Cook K LOUISIANA POWER & LIGHT CO.
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20133H072	List: ML20133H068 W3P85-1413, Forwards Response to NRC Re Enforcement Action 85-10 Concerning Failure to Perform Hydrostatic Test Per Fsar.Corrective Actions:Field Change Request Initiated on 800806 to Cover Deletion of Use of High Point Vents
References
EA-85-010, EA-85-10, W3P85-1413, NUDOCS 8510160257
Download: ML20133H078 (3)

Text

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LOUISI ANA / 4de u-o~oe.meer . a c eox eoo.

POWER & LIGHT / NEW oALEANS LouSAPd 70174-8000 . (So4)388-9345 En$IY June 21, 1985 W3P85-1413 A4.05 Mr. Robart D. Martin Regional Administrator, Region IV U.S. Nuclear Regulatory Commission R 611 Ryan Plaza Drive, Suite 1000 q Arlington, TX 76011

Dear Mr. Martin:

%I '

Subject:

Waterford 3 SES l g

Docket No. 50-382 License No. NPF-38 hhh J NRC Notice of Deviation

Reference:

NRC letter D. 85-10 dated 5/24/85, R.D. Martin, NRC Region IV to R.S. Leddick, LP&L - transmittal of enforcement package and proposed civil penalties.

The referenced letter included in the enforcement package transmittal, a Notice of Deviation, identified in Appendix B of EA 85-10 as a failure to perform tests in accordance with FSAR commitment. Attached is the Louisiana Power and Light Company response to the deviation notice.

If you have any questions on the response to the deviation, please contact C.E. Wuller, Onsite Licensing, at (504) 464-3499.

Very truly yours, K.W. Cook Nuclear Support & Licensing Manager KWC:GEW:sms Attachment cc: NRC, Director, Office of I&E G.W. Knighton, NRC-NRR D.M. Crutchfield, NRC-NRR NRC Resident Inspectors Office INPO Records Center (J.T. Wheelock)

B.W. Churchill h

01 2 G

[C - o#/ErT

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l W3P85-1413 Page 1 of 2 1 ATTACHMENT i LP&L RESPONSE TO NOTICE OF DEVIATION EA 85-10 DEVIATION NO. EA 85-10 Failure to Perform Test in Accordance with FSAR Commitment LP&L's Final Safety Analysis Report (FSAR) requires that all hydrostatic tests conform to the requirements of ASME III, Class 2 and 3, 1974 Edition, Summer 1976 Addenda. Article NC-6000, " Testing," which requires that " vents shall be provided at all high points of the component or system in the position in which the test is to be conducted to purge air pockets while the component or system is filling."

Contrary to the above, the NRC staff's examination of 27 hydrostatic document test packages, including the applicable valve lineup sheets and isometrics, revealed that for each of the corresponding hydrostatic tests, high point vents had not been used. An examination of the hydrostatic test index revealed that FCR-lCP-19, Revision 2, deleting the use of high point vents, was issued subsequent to all the hydrostatic test having been completed.

Ref: SSER-7:A-242 RESPONSE TO DEVIATION

References:

1. NUREG-0787 Supplement 7, Safety Evaluation Report for Operation of Waterford 3 (SSER 7) dated September 1984 (pages 220 and 221 - Task: Allegation A-242).

2. LP&L letter W3P84-1805, dated 6/29/84, K.W. Cook to G.W. Knighton, NRC, subj ect: Waterford 3 FSAR Chapter 14 (copy attached).

Corrective Steps Taken and Results Achieved Field Change Request (FCR-lCP-19, Revision 2) was initiated on August 6, 1980 to fully cover the deletion of the use of high point vents in hydrostatic l tests of instrument installations. All hydrostatic testing was conducted i subsequent to the approved field change request. Reference I confirmed by NRC Staff review that "an examination of the hydrostatic test index reveals that l

all Waterford Unit 3 hydrostatic tests had been performed on dates subsequent to the issuance of the field change request (FCR), and would therefore have l

been performed in accordance with its requirements." Furthermore, reference 1 states, "---NRC considers the alternate method of venting systems through the root valve to the process line sufficient to preclude an invalidation of hydrostatic tests."

The reference 2 letter (copy attached) clarified the LP&L position regarding the use of high point vente in hydrostatic testing and committed to amend the i FSAR in accordance with the 100FR50.71(e) requirements. The FSAR change will reflect that venting of systems during hydrostatic testing was performed in accordance with the requirements of ASME Boiler and Pressure Vessel Code,Section III, Article NC-6211 (Summer 1981 Addenda).

1 l

W3P85-1413 Page 2 of 2 Corrective Steps To Avoid Commitment Deviations A Nuclear Operations Executive Directive (ED-027, Regulatory Commitments Management) was issued to establish the policy and provide guidance for the effective processing of regulatory commitments. Additionally, the Nuclear Services Procedure NSP-102 is implemented to provide documented reviews and approval, including concurrence with safety evaluations, for revisions to licensing documents such as the FSAR.

Completion of Action Regarding Deviation All hydrostatic testing for Waterford 3 has been completed to the satisfaction of the NRC Staff as documented in reference 1 Appropriate policy directive and procedures are in place and are being implemented to avert future commitments deviations.

The needed clarifying change to the FSAR, as specified in reference 2, relative to the deviation cited will be made per the requirements of 10CFR50.71(e).

i I

• l.OUISIANA ida cetAncNee Srneer POWER & LIG HT P O Box 600e . New ORLEANS. LCutSIANA 70174 . [5C41366-2345 NS:YsIvsE June 29, 1984 W3P84-1805 Q-3-A29.22.14 Director of Nuclear Reactor Regulation Attention: Mr. G.W. Knighton, Chief Licensing Branch No. 3 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

Waterford 3 SES Docket No. 50-382 FSAR Chapter 14

Dear Sir:

Per your request and in an effort to complete LP&L's response for Allegation 28, use of high-point vents in hydrostatic testing, attached are proposed FSAR changes which will be implemented in a future amendment in accordance with 10 CFR 50.71(e) requirements. The changes clarify that venting of systems during hydrostatic testing was performed in accordance with the requirements of ASME Boiler and Pressure Vessel Code,Section III, Article NC-6211 (Summer, 1981 Addenda).

Also, attached are proposed changes which reflect that testing of the non-safety relate.d Supplementary. Chilled Water System may not be completed prior to fuel load (this does not violate any NRC requirements).

If you have any questions please do not hesitate to call.

ry truly, h\

K. . ook

\ f g, Nuclear Support & Licensing Manager KWC/PC/pco Attachment ec: E.L. Blake, W.M. Stevenson, J.T. Collins, D.M. Crutchfield, J. Wilson, G.L. Constable r

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14'.2.12.2.30 CHILIED WATM A"" !"""LMu 3"' 5!11?D "^7Y SYsnms4 l 15 8

14.2.12.2.30.1 Objacciva To verify the proper operation of the Chilled Water =d L;;;1.cc:ce i y 4 15

_ Sill:d u rt: system .

A 8

14.2.12.2.30.2 Prerequisites 18 A. Construction activities on the systems to be tested are complace.

B. Test instrumentation is available and calibrated. l29 C. Plant systems required to support testing are operable, or temporary 5 systems are installed and operable.

29 D. Permanently installed instrumentation is operable and calibrated.

l 14.2.12.2.30.3 Test Method .

A. Verify all control logic.

B. Demonstrate that each chilled water train can be operated from its local and remote manual station. I C. Verify that each chilled water unit performs as designed and supplies chilled water at rated flow and torperature. l 15 l 8 D. Verify chilled water flow to all supplied components.

18 E. Verify that the chilled water systems respond automatically to the appropriate engineered safety features actuation signal (ESFAS). l 15 l 8 F. Verify the proper operation of all protective devices, controls, interlocks, instrumentation, and alarms, using actual or simulated l 15 inputs.

8 14.2.12.2.30.4 Acceptance Criteria Y

._., .-_... .,. __ perform 3as 1he chilled Water System 15 described in Subsection 9.2.9.

l 1

I 14.2-59 Amendment No. 29, (10/82) i l .

......m....... ,

l TADLE 14.2-1 (Cont'd)

." l 8

Subsection Title 14.2.12.2.21 Annulus Negative Pressure And Vacuum Relief Systems 14.2.12.2.22 -

Containment Combustible Cas Control System l15 14.2.12.2.23 Airborne Radioactivity Removal System 14.2.12.2.24 CEDM Cooling System 8 14.2.12.2.25 Turbine Building Ventilating System 14.2.12.2.26 Cable Vault and Switchgear Area HVAC System 12.2.12.2.27 Control Room Envelope HVAC System 14.2.12.2.28 RAB Normal Ventilation and Containment Purge Systems 15 12.2.12.2.29 Controlled Ventilation Area System hj' 14.2.12.2.30 chilled Water And LppEx:: q ChiM:d A

'J;;;; 5yee 14.2.12.2.31 RAB Miscellaneous HVAC System 14.2.12.2.32 Fuel Handling Building ventilating l15 System 14.2.12.2.33 Primary Water Storage System 8

14.2.12.2.34 Reactor Coolant System Quench Tank Subsystem 12.2.12.2.35 Pressurizer Pressure And Level Control System l15 14.2.12.2.36 Pressurizer Safety Valve 8 14.2.12.2.37 c Chemical And Volume control System l15 Charging Subsystem 8 14.2.12.2.38 Chemical And Volume Control System l15

Letdown Subsystem 8

14.2.12.2.39 Volume Control Tank Subsystem 14.2.12.2.40 Boronometer l 15 14.2-147 Amendment No. 15, (2/81)

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14.2.12.2.90 SECONDARY SYSTDi HYDROSTATIC TEST 15 14.2.12.2.90.1 Objective To hydrostatically test the secondary side of the steam generators and non-isolable piping. 8 14.2.12.2.90.2 Prerequisites A. The steam generators and main steam piping to the main steam isolation valves are filled, vented, and at the required tem- l15 perature. 8

[

B. Reactor Coolant System (RCS) is filled, vented, and at the l 15 required temperature. [ 9 C. The reactor coolant pumps are operable.

D. Test pump is available.

E. Main steam safety valves are gagged or removed.

F. Test instrumentation is available and calibrated. 29 G. Permanently installed instrumentation necessary for testing is 34

-. operable and calibrated.

"' 14.2.12.2.90.3 Test Method A. Increase RCS pressure to a value that will ensure that the 8 secondary to primary differential pressure does not exceed design value.

B. Perform the test in accordance with the ASME code.

14.2.12.2.90.4 Acceptance Criteria The Secondary System hydrostatic test meets the requirements of ASME ,

18 BoilerandPressureVesselCode,SectionIIIj(bi;w iw perlem,3 6 e. ^;46 -

phc. 4ed was dont auced;*y +o UC-61u s_ ,,gcg;pygud 14.2-109 Amendment No. 34, (1/84)

14.2.12.2.91 REACTOR COOLANT SYSTEM HYDROSTATIC TEST 14.2.12.2.91.1 Objective 8

To verify the integrity of the Reactor Coolant System (RCS) pressure boundary and associated Safety Class I piping.

14.2.12.2.91.2 Prerequisites A. The RCS is filled, vented, and at the required temperature.

B. The reactor coolant pumps are operable.

8 C. Test pump is available.

D. Primary safety valves are gagged or removed.

E. Permanently installed instrumentation necessary for testing is 34 operable and calibrated.

29 F. Test instrumentation is available and calibrated.

14.2.12.2.91.3 Test Method A. Operate reactor coolant pumps to sweep gases from the steam generator tubes. .

B. Vent the RCS and all control element drive mechanism housings. g C. Operate the reactor coolant pumps to increase the RCS temperature to that required for pressurization of RCS to test pressure.

D. Perform the test in accordance with the ASME code.

14.2.12.2.91.4 Acceptance criteria The RCS hydrostatic test meets the requi esents of ASME Boiler and Pressure Vessel Code, Section IIIJ ( Ak in .cmi* kydro sfolic. Jied we done 13 U c. 6 tti L o w , =t p gdg Oc.

acec e ] lo 14.2-110 Amendment No. 34, (1/84)

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