ML20245A530

Ack Receipt of 890320 Response to Violations Noted in Insp Rept 50-382/89-03

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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In Reply Refer To: I

Cocket: 50-382/89-03 1

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Louisiana Power & Light Company I

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ATTN: J. G. Dewease, Senior Vice President

Nuclear Operations

317 Baronne Street

New Orleans, Louisiana 70160 j

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Gentlemen: J

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 I

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find it responsive to the concerns raised in our Notice of Violation. We will i

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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. l

Sincerely, l

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Origins l Signed By:

1. L. J. CALLAN  !

L. J. Callan, Director

Division.of Reactor Prcjacts ,

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Louisiana Power & Light Company

ATTN: R. P. Barkhurst, Vice President

Nuclear Operations

P.O. Box B

Killona, Louisiana 70066 1

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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 -2-

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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 i

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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:

RRI R. D. Martin, RA

Section Chief (DRP/A) DRP l

RPB-DR$5 MIS System

Project Engineer (DRP/A) RSTS Operator

RIV File DRS

D. Wigginton, NRR Project Manager (MS: 13-D-18) Lisa Shea, RM/ALF

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LOUISIANA / mainoNussraest

P O W E R & l. I G H T

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NEWoRLEANS.LoulSIANA 70160 * (504)596 3100

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March 20. 1989

W3P89-0064

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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

l 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

E.L. Blake

W.M. Stevenson

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W3P89-0064

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 j

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. )

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 l

7.1.8) and then maintain the header pressure between 125-135 psig '

(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  !

until after the testing of the DFPs was complete. This was because of 4

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 l

occurred.

The following info rmation provides the basis for not being able to

secure the MDFP.

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W3P89-0064

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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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W3P89-0064

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(3) Corrective Steps Which Will Be Taken To Avoid Further Violations l

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  ;

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needing immediate corrective action will ba implemented in a timely

manner. Personnel also understand that temporary changes to

procedures. are available to effect immediate correction of procedural

deficiencies. This action should prevent a recurrence of this type of .

violation in the future. J

(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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