ML19327B428

Responds to NRC Notice of Violation Noted in Insp Rept 50-382/89-16.Corrective Actions:Procedures Upgraded Per Operations Writers Guide OP-100-013 to Ensure That Technically Accurate & Properly Human Factor Engineered

ML19327B428
Person / Time
Site:	Waterford
Issue date:	10/26/1989
From:	Burski R LOUISIANA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
W3P89-1581, NUDOCS 8910310164
Download: ML19327B428 (5)

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! October 26, 1989  ;

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'U.S. Nuclear Regulatory Commission ATTN Document Control Desk

,i Washington, D.C. 20555 t E

Subject:

Waterford 3 SES .

Docket No. 50-382

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License No. NPF-38 NRC Inspection Report 89-16  !

Gentlement  !

In accordance with 10 CFR Part 2.201, Louisiana Power & Light hereby }

submits in Attachment I the response to the Violation identified in i

' Appendix A of the subject inspection Report.  ;

f If you have any questions concerning this response, please contact

• T.J. Gaudet at (504) 464-3325. 'i i

Very truly yours, ,

i O.fwl

.. e R'.F. B sk Manager l' Nuclear Safety & Regulatory Affairs RFB/TJG/pi l Attachment ce s- Messrs: R.D. Martin. NRC Region IV l

, F.J. Hebdon NRC-NRR D.L. Wiggiaton, NRC-NRR  :

NRC Resident Inspectors Office  ;

E.L. Blake j W.M. Stevenson i

I L 8910310164 091026 l PDR ADOCK 05000302 l G PNU i f i 9

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Attachment to b - W3P89-1581 Fage 1 of 4 i  !

i b ATTACHMENT 1 ,

l b LP&L RESPONSE TO THE VIOLATION IDENT.FIED IN APPENDIX A OF INSPECTION REPORT 89-16 l

[ .1 V101ATION NO. 8916-02  !

i Inadequate Abnormal Procedures ,

i Technical Specification 6.8.1 requires, in part, that procedures shall be t established and implemented covering . . . a. the applicable procedures recommended in Appendix A of Regulatory Guide 1.33. Revision 2, February .

1978. ,

Appendix A of Regulatory Guide (RG) 1.33, Section 5 states, in part, that procedures for safety-related activities should be established which address. expected abnormal and alarm conditions corresponding to the alarm '

annunciators. Section 5 further states that each safety-related annunciator should have its own written procedure, which should normally contain (1) the meaning of the annunciator, (2) the source of the signal, ,

i (3) the immediate action that is to cccur automatically, (4) the immediate operation action, and (5) the long-range actions. l Waterford-3 FSAR, Section 13.5.2.1.(d), " Typical Off-Normal Procedures " i stated that the off-normal procedures would include the "120V AC Vital  ;

instrument Systcm Bus Out of Service" and the " Safety-Related AC Power Distribution System Bus Out of Service." ,

Contrary to the above.

1. Procedure OP-901-054, " Loss of a Vital 120V AC Instrument Channel," r Revision 2 failed to include all of the expected conditions and actions that occurred automatically, and some of the immediate and long-term actions for the operators.  !

2. An adequate written procedure had not been provided addressing the loss of a vital 4160 volt AC electrical bus. ,

'This is a Severity Level TV violation.  !

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o' i Attachment to i" W3P89-1581 i

. Page 2 of 4 l Y

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Response

t LP&L admits the violation for the conditions stated above. Although LP&L I believed that the loss of a vital 120 volt AC instument channel and the l loss of a vital 4160 volt AC electrical bus had been adequately addressed i in existing plant procedures, the guidance provided for such conditions was not sufficiently coordinated in an off-normal procedure to ensure that the RG 1.33 requirements were being met.

1 (1) Reason for the Violation Item 1 [

l The root cause for Item 1 of the violation was improper human factor F engineering of Procedure OP-901-054. LP&L believes that the overall  !

content of procedure OP-901-054 is adequate (as was supported by the  ;

inspector on Yage 6 of the Inspection Report)1 however, the procedure did not contain all credible conditions for each criterion stipulated in Section 5 of Appendix A to RG 1.33. {

Because of the complexity involved with the loss of a vital 120V AC ,

instrument bus and due to the numerous actions (automatic and

• operator) that have to be addressed during such an event, some of the  !

expected conditions and subsequent actions were included in other l procedures which serve to complement OP-901-054. However, no i correlation between procedures was made to ensure that the upper tier procedure (OP-901-054) addressed all situations. A separate off-normal procedure (OP-901-011) is provided to ensure that the  ;

monitored limiting conditions for operation of the core operating limit supervisory system (COLSS) are maintained. Although "COLSS Out of Service" is an expected annunciator resulting from a loss of vital AC 120 volt bus 3MC-S and the subsequent actions for it are addressed  !

in OP-901-011, no reference to the procedure is made in OP-901-054.  !

The failure of an incore instrument channel is another expected i

! annunciator resulting from a loss of a vital 120 volt bus and is .

I I listed in OP-901-054, however, the affected indications and subsequent actions to such an alarm are addressed in a separate procedure i 0 (OP-500-009) again with no tie in to OP-901-054. Lastly, the reset of a partial engineered safety features actuation system (ESFAS) ,

actuation following restoration of power to the failed instrument bus is an additional condition that was not addressed in OP-901-054 but is r.ddressed in separate procedures (OP-903-094 and OP-903-095).

Iten 2 The root cause for Item 2 of the violation was a misinterpretation of the regulatory requirements provided in RG 1.33. Although procedural guidance for the operator in the event of a loss of a 4160 volt AC electrical bus is available, the guidance is not feasibly located in a stand alone off-normal procedure to meet the regulatory requirements of RG 1.33.

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! c-Attachment to u W3P89-1581 Page 3 of 4 RG 1.33, Section C (Regulatory Position) states that "(t)he procedures

! listed in Appendix A may be combined, separated, or deleted to conform to the applicant's procedures plan. Furthermore, as stipulated in the Notice of Violation, Section 5 of Appendix A to RG 1.33 states that each safety-related annunciator should have its own written procedure, which should normally contain... LP&L had in this instance I interpreted these guidelines to mean that various combinations of procedures could be utilized to address the loss of a vital 4160 volt AC electrical bus and that a stand alone procedure was unnecessary.

An annunciator response precedure (OP-500-xxx series) exists for each of the 14 Control Room Cabinets. Various expected conditions and the l

associated corrective sctions for the loss of a vital 4160 volt AC r electrical bus are included in these annunciator response procedures where applicab3e. Because LP&L's philosophy on annunciators is based on the operator's understanding, knowledge and training of the annunciator response procedurus, LP&L believed that adequate guidance was available for the loss of a vital 4160 volt AC electrical bus to meet the requirements of RG 1.33 and therefore, in this case, a separate off-normal procedure was not developed.

(2) Corrective Steps Which Have Been Taken and the Results Achieved Items 1 & 2 As was stated in a previous letter to the NP.C (LP&L Letter No.

W3P89-1508 datel 8/17/89), the Operations Department has initiated an effort to upgrade Operations' procedures. The procedures are being upgraded per the Operations Writer's Guide (OP-100-013) to ensure that they are technically accurate and properly human factor engineered.

This effort involves the extensive review of approximately 260 procedures by LP&L and an independent consultant who is providing human factors expertise. As of the end of September, 1989, 142 procedures (55%) have undergone this review and were upgraded accordingly. Of the remaining 118 procedures, 50% are under revision and the other 50% are undergoing technical verification.

With regard to item 1, the current schedule calls for completing the upgrade to OP 901-054, which will now require the inclusion of the i

information discussed above at a minimum, by May 1, 1990.

With regard to Item 2, the annunciator response procedures are included in the remaining procedures to be reviewed as part of the upgrade effort.

LP&L is confident however that the existing procedures, coupled with l Waterford 3 operators trained to properly assess the loss of a vita)

L 120 volt AC instrument channel and the loss of a vital 4160 volt AC i electrical bus, will be sufficient to avoid a safety concern in the ,

t interim.

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$dfL.o m -e y-7 Attachment-to i J' > _

V3P89-1581 -l Page 4 of 4 l

' I (3)L Corrective Steps Which Will Be Taken to Avoid Further Violations i

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I, Item 1 ,

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a, , LP&L believes that the necessary corrective actions as described above j

, >s will ensure that a violation of this type does not recur.  ;

l Item 2 .;

i An off-normal procedure will be developed to ensure that the essential  !

information for,a loss of a vital 4160 volt AC electrical bus is .

available in a single procedure to meet the requiremenca of RG 1.33.

(4) Date When Full Compliance Will Be Achieved i i

/' Items 1 6'2 -

The actions identified above (upgrade to OP-901-054 and development of i F ,

' a new off-normal procedure) will be completed by no later than May 1  !

1990, at which time LP&L will be in full compliance. .

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