ML20245A530
| ML20245A530 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 04/12/1989 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Dewease J LOUISIANA POWER & LIGHT CO. |
| References | |
| NUDOCS 8904250255 | |
| Download: ML20245A530 (2) | |
See also: IR 05000382/1989003
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APR I 2 m
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In Reply Refer To:
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Cocket: 50-382/89-03
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Louisiana Power & Light Company
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ATTN:
J. G. Dewease, Senior Vice President
Nuclear Operations
317 Baronne Street
New Orleans, Louisiana 70160
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Gentlemen:
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Thank you for your letter of March 20, 1989, in resporse to our letter and
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Notice of Violation dated February 17, 1989. We have reviewed your reply and
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find it responsive to the concerns raised in our Notice of Violation. We will
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review the implement.ation of your corrective actions during a future inspection
to detennine that full compliance has been achieved and will be maintained.
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Sincerely,
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Origins l Signed By:
L. J. CALLAN
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L. J. Callan, Director
Division.of Reactor Prcjacts
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CC:
Louisiana Power & Light Company
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ATTN:
R. P. Barkhurst, Vice President
Nuclear Operations
P.O. Box B
Killona, Louisiana 70066
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Louisiana Power & Light Company
ATTN:
N. S. Carns, Plant Manager
P.O. Box B
Killona, Louisiane 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
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Louisiana Power & Light Company
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Louisiana Power & Light Company
ATTN:
L. W. Laughlin, Site
Licensing Support Supervisor
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
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P.O. Box 61000
New Orleans, Louisiana 70161
Louisiana Radiation Control Program Director
bec to DMB (IE01)
bec distrib. by RIV:
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R. D. Martin, RA
Section Chief (DRP/A)
RPB-DR$5
MIS System
Project Engineer (DRP/A)
RSTS Operator
RIV File
D. Wigginton, NRR Project Manager (MS:
13-D-18)
Lisa Shea, RM/ALF
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LOUISIANA / mainoNussraest
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P O W E R & l. I G H T
NEWoRLEANS.LoulSIANA 70160 * (504)596 3100
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$0?NfrsVU
March 20. 1989
A4.05
U.S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Washington, D.C. 20555
Subj ect: Waterford 3 SES
Docket No. 50-382
License No. NPF-38
NRC Inspection Report 89-03
Gentlemen:
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 this response, please contact
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T.J. Gaudet at (504) 464-3325.
Very truly yours,
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R.F. Burski
Manager
Nuclear Safety & Regulatory Affairs
RFB:TJG:ssf
Attachment
cc:
R.D. Martin, NRC Region IV
J.A. Calvo, NRC-NRR
D.L. Wigginton, NRC-NRR
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debuRum6 dent-Inspectors. 0ffice
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E.L. Blake
W.M. Stevenson
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Attachment to
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Page 1 of 3
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ATTACHMENT 1
LP&L Response to the Violation Identified in Appendix A
of Inspection Report 89-03
VIOLATION NO. 8903-01
Failure to Provide an Adequate Procedure
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Technzcal Specification 6.8.1.a requires that written procedures
recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February
197G. shall be established, implemented, and maintained covering fire
protection system functional tests.
Procedure OP-903-053, Revision 5 " Fire Protection System Pump Operability
Test," Step 7.1.8, instructs the operator to shut off the motor driven fire
pump after starting the first diesel engine d. riven fire pump.
Contrary to the above, on December 8,1988, January 5,1989, and January
26, 1989, Step 7.1.8 could not be implemented as written in that the motor
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driven fire pump could not be shut off at that point. The procedure
required the header pressure to be maintained below the reset point at
which the pump could be stopped.
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This is a Severity Level IV violation.
RESPONSE
(1) Reason For The Violation
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The root cause of this violation is a failure by operations personnel
to promptly change a step contained in Surveillance Procedure
OP-903-053.
Procedure OP-903-053 provides the necessary guidelines at
Waterford 3 for verifying the operability of the motor driven fire
pumi (HDFP) and the diesel fire pumps (DFPs).
As part of the DTP
operability test (Section 7.0 of the procedure), the operator is
required to manually start DFP (/1 (Step 7.1.7), secure the MDFP (Step
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7.1.8) and then maintain the header pressure between 125-135 psig
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(Step 7.1.9).
On the dates stated in the violation, Otep 7.1.8 could
not be performed in sequence in that the MDFP cou11 not be secured
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until after the testing of the DFPs was complete. This was because of
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repetitive equipment failures and the inclusion of an unnecessary step
(7.1.8) in the surveillance procedure. A procedure revision to change
this step (7.1.8) was initiated in November, 1986. Had this revision
been promptly approved, this procedural violation woald not have
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occurred.
The following info rmation provides the basis for not being able to
secure the MDFP.
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Page 2 'of 3
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on 12/08/88, Condition Identification (CI) 260015 was written stating
that the MDFP would not secure when the "STOP" button is pressed,-
regardless of system pressure.
Work Authorization (WA)' 01028850 was -
completed on 01/11/89 following replacement of the main contactor and
cleanies and inspection of all other associated components. An
operational test was then performed to ensure that the MDFP could be
stopped at the desired discharge pressure.
On 12/16/88, CI 260331 was written stating that during the performance
of OP-903-053, the MDFP would not secure until' header pressure was
greater than 150 psig. .Again on 01/05/89, a separate CI, 260778,'was
written stating that the MDFP started at 140 psig which prevented the
pump from being' turned off during the performance of OP-903-053. :The
setpoint document requires the pressure switch to reset by (less than)
135 psig which allows the pump to be secured. WA 01029959 for CI-
260337 was completed on 01/12/89 stating that the calibration was
completed and the root cause was corrected by electrical maintenance
under WA 01028850. CI 260778 was rejected and dispositioned as n'
duplicate of CI 260337.
The problem reappeared and on 01/26/89, CI 261163 was written stating
that during the performance of OP-903-053 the MDFP started at 138 psig
and would not secure until 152 psig. This CI also referenced CI
260337.- To correct an apparent intermittent pressure switch problem,
WA 01031617 was completed on' 02/02/89. During performance of WA-
01031617, the pressure switch for the MDFP was replaced. The
replacement pressure switch actuated correctly at 125.1 psig and reset
at 130.8 psig.
The source of the problems occurring during the performance of
OP-903-053 was attributed to a faulty pressure switch. Per OP-903-053
revision 5, the operator was allowed to raise the header pressure to
135 psig (as observed by an NRC Inspector on 12/08/88). When properly
calibrated and functioning, the pressure switch would be reset and the
MDFP could be stopped.
With the single exception of the run on 01/05/89, the operatora
performing OP-903-053 notified the shif t supervisor (SS)/ control room
supervisor (CRS) of the equipment problems. Continuing to run the
MDFP did not affect acceptance criteria, and permission was granted to
continue the surveillance.
(2) Corrective Step That Have Been Taken And The Results Achieved
Revisica 6 to Procedure OP-903-053 was approved January 30, 1989
This revision allows individual testing of the three fire pumps and
continuous running of the MDFP during testing.
The operator involved in the 01/05/89 surveillance was counselled, and
the importance of notifying ~the SS/CRS when problems are encountered
during evolutions was stressed. Operations Managesent has emphasized
to operations personnel that they are to stop evolutions in progress
and obtain necessary procedure changes when required prior to
proceeding.
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(3) Corrective Steps Which Will Be Taken To Avoid Further Violations
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When utilizing Operating Instruction 01-019-00, " Development of
Operations Procedure Administrative Group", the Assistant Operations
Superintendent will prioritize procedure changes to ensure that those
needing immediate corrective action will ba implemented in a timely
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Personnel also understand that temporary changes to
manner.
procedures. are available to effect immediate correction of procedural
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deficiencies. This action should prevent a recurrence of this type of
violation in the future.
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(4) Date When Full Compliance Will Be Achieve _d_
Based on the above information, LP&L is currently in full compliance.
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