IR 05000382/1989026
| ML19332E721 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/06/1989 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Dewease J LOUISIANA POWER & LIGHT CO. |
| References | |
| NUDOCS 8912120025 | |
| Download: ML19332E721 (3) | |
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DEC 61151'
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In Reply Refer To:
Docket: 50-382/89-26'
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~ Louisiana Power & Light Company L.
ATTN:
J. G. Dewease Senior Vice President
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Nuclear Operations
317 Baronne Street
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New Orleans, Louisiana 70160 j
Gentlemen:
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Thank you for your letter'of Novenber 20,1989.. in response to our letter
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E and Notice of Violation dated October 20,=1989. We have reviewed your reply
and find it responsive to the concerns raised in our Notice of Violation. We
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will review the implementation of your. corrective actions during a, future
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inspection to determine that full compliance has been achieved and will be maintained.
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Sincerely,
/s/
Samuel J. Collins, Director Division of Reactor Projects
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CC:
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Louisiana Power & Light Company ATTN:
R. P. Barkhurst, Vice President Nuclear Operations e
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P.O. Box B
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K111ona, Louisiana 70066 Louisiana Power & Light Company ATTN:
J. R. McGaha, Jr., Plant Manager P.O. Box B K111ona, Louisiana 70066
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Louisiana Power & Light Company-2
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Louisiana Power & Light Company
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ATTN:
L. W. Laughlin, Site
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Licensing Support Supervisor
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P.O.' Box B-K111ona, Louisiana 70066 l
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Louisiana Power f. Light Company
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ATTN:
G. M. Davis, Manager, Events
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Analysis Reporting & Response
P.O. Box B
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Killona, Louisiana 70066
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Monroe & Leman i
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M ATTN:
W. Malcolm Stevenson, Esq.
201 St. Charles Avenue, Seite 3300
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New Orleans, Louisiana. 70170-3300
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Shaw, Pittman, Potts & Trowbridae ATTN: Mr. E. Blake
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2300 N Street, NW Washington,-D.C. 20037 s
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Middle South Services, Inc.
ATTN:
Ralph T. Lally, Manager i
of Quality Assurance
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P.O. Box 61000
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New Orleans, Louisiana 70161
Chainnan Louisiana Public Service Comission
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One American Place, Suite 1630
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Baton Rouge, Louisiana 70825-1697 Louisiana Power &' Light Company
l ATTN:
R. F. Burski, Manager, lluclear Safety and Regulatory Affairs l
317 Baronne Street L
New Orleans, Louisiana 70112 i
Department of Envirnnmental Quality
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ATTN: William H. Spell, Administrator Nuclear Energy Division
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P.O. Box 14690 l
l Baton Rouge, Louisiana 70898 L-President, Police Jury St. Charles Parish Hahnv111e, Louisiana 70057
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Louisiana Power & Light Company-3-
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l Mr. William A. Cross Bethesda Licensing Office'
3 Metro Center.
Suite 610
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A Bethesda, Maryland 20814 l
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U.S. Nuclear Regulatory Commission l
ATTN: Resident Inspector-
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P.0c Box 822
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K111ona.. Louisiana 70066
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U.S. Nuclear Regulatory Commission.
ATTN:
Regional Administrator, Region 31Y i
611 Ryan Plaza Drive, Suite 1000
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Arlington, Texas 76011
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bectoDMB(IE01)
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R. D. Martin Resident inspector'
SectionChief(DRP/A)-
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DRSS-FRPS MIS System
Project Engineer (DRP/A)
RSTS Operator-
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RIV File
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13-D-18)
Lisa Shea, RM/ALF D. Wigginton -NRR Project Manager (MS:
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LOUISI AN A / 3ir sAaossestater e.O.soxs0340 POWER & LIGHT NEW ORLEANS, LOUISlANA 70160 (504) $953100
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W3P89-2131 A4.05 QA r. ~
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November 20, 1989
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U.S. Nuclear Regulatory Commission
ATTN: Document Control Desk Washington, D.C.
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Subject: Waterford 3 SES Docket No. 504382 License No. NPT-38 WRC Inspection Report 89-26 Centlement In accordance with 10 CFR Part 2.201, Louisiana Power & Light hereby submits in Attachment 1 the response to the Violation identified in Appendix A of the subject Inspection Report.
If you have any questions concerning these responses, please contact L.W. Laughlin at (504) 464-3499.
Very truly yours,
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R.F. Burski Manager Nuclear Safety & Regulatory Affairs RFB/DMU/pi Attachment cet Messrs. R.D. Martin, NRC Region IV F.J. Hebdon, NRC-NRR D.L. Wigginton, NRC-NRR NRC Resident Inspectors Office E.L. Blake
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W.M. Stevenson
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"AN EDUAL OPPORTUNITY EMPLOYER" Emae%Gsiv~ '+@
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Attachment to
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W3P89-2131 Page 1 of 3
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ATTACHMENT 1 LP&L RESPONSE TO THE VIOLATION IDENTIFIED IN APPENDIX A 0F INSPECTION REPORT 89-26 VIOLATION 8926-01 INADEQUATE PROCEDURE Technical Specification 6.8.1.c requires, in part, that written procedures t
shall be established and maintained for surveillance and test activities on safety related equipment.
Technical Specification 4.0.5 requires, in part, that inservice testing of ASME Class 2 pumps shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code.
IWP-3500 of Section XI requires minimum stabilization run times for testing of pumps.
Contrary to the above Procedure OP-903-030 Revision 6. " Safety Injection Pump Operability Verification" established to implement the above requirement was inadequate in that it did not require minimum stabilization run times for testing of pumps.
This is a Severity Level IV violation.
RESPONSE (1) Reason for the Violation The root cause of this violation was personnel error. The author (s) of surveillance procedure OP-903-030, Saf ety Injection Pump Operability Verification, failed to incorporate the test durations specified in Section XI of the ASME Boiler and Pressure Code. IWP-3500 of Section XI requires the followings (1) When measurement of bearing temperature is not required, each
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pump shall be run at least 5 minutes under conditions as stable as the system permits. At the end of this time at least one measurement or observation of each of the quantities specified shall be made and
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recorded.
(2) When measurement of bearing temperature is required, each pump shall be run until the bearing temperatures (IWP-4310) stabilize, and then the quantitites specified shall be measured or observed and recorded.
A. bearing temperature shall be considered stable when three successive readings taken at 10 minutes intervals do not vary by more than 3%.
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Attachment to l
W3P89-2131 Page 2 of 3
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Contrary to item 1 above, procedure OP-903-030 did not contain the
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requirement to run the High Pressure Safety Injection Pump for at least 5 i
minutes before taking data when bearing temperature measurements are not
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required. Following a review of the other pump inservice test (IST)
procedures, it was determined that this requirement was correctly listed in those procedures.
It therefore appears that this requirement was inadvertently omitted from only OP-903-030, it is, however, reasonable to assume that, regardless of the omission, the pump was routinely run at least five minutes while preparing to take the required data.
With respect to item 2 above, OP-903-030 did specify that bearing
temperatures must stabilize before they be recorded and the procedure did correctly identify the stabilization criteria. However, the wording in the procedure did not specifically prevent the recording of IST data, i.e.,
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flow, vibration, until after bearing temperatures had stabilized. As stated, it did not ensure compliance with the requirements of IWP-3500(b).
A review of all other pump IST procedures indicated that the wording of the above requirement in each procedure was the same as that in OP-903-030.
(2) Corrective Steps That Have Been Taken and the Results Achieved Pump IST procedures, including OP-903-030, have been revised, as necessary, to incorporate the requirements of ASME Section XI, IWP-3500. The procedure revisions were approved on October 6, 1989.
(3) Corrective Steps Which Will Be Taken to Avoid Further Violations Commitment #P09422 on the Commitment Management System (CMS) lists the requirements of ASME Section XI. IWP-3500 and identifies which systems and surveillance procedures it is applicable to.
To fulfill this commitment, each procedure listed must contain the necessary steps to satisfy the commitment requirements. OP-903-030 and the remaining 6 pump IST
procedures are identified under this commitment and, as of 10/6/89, satisfy the requirements of IWP-3500.
To ensure continued compliance, UNT-1-003, REV. 11. Procedure Initiation.
Review and Approval; Change and Revision; and Deletions Section 3.2.14 requires that during a procedure revision, the technical reviewer reviews the CMS for commitments listed against that procedure. It is the reviewer's responsibility to ensure that compliance with these commitments has not been affected. Additionally, NOP-Oll, REV. O, Commitments Management System, contains a similar requirement.
Section 4.4.3 requires
" reviewing implementing document changes against the commitment report to assure the change continues to implement applicable commitments."
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I Attachment to
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Page 3 of 3
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LP&L will also review ASME Section XI, subsections IWP and IWV, to ensure no further discrepancies exist between these requirements the
Waterford 3 Pump and Valve Inservice Test Plan and corresponding IST pump and valve test procedures. This review will be complete by June 30, 1990.
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(4)
Date When Full Compliance Will Be Achieved
With regard to the specifics of this violation, LP&L is currently in full compliance.
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