W3P89-0064, Responds to Violations Noted in Insp Rept 50-382/89-03. Corrective Actions:Rev 6 to Procedure OP-903-053,allowing Individual Testing of Three Fire Pumps & Continuous Running of Motor Driven Fire Pump During Testing Approved
| ML20236D927 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/20/1989 |
| From: | Burski R LOUISIANA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3P89-0064, NUDOCS 8903230361 | |
| Download: ML20236D927 (4) | |
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'k P O W E R & L I G H TLouisiANA / 3i7e4nonneSrneer.
- p. O. sox e0340 NEW ORLEANS. LOUISlANA 70160 (504) 595-3100 NO$irsYN)
March 20, 1989 W3P89-0064 A4.05 QA U.S. Nuclear Regulatory Commission l
ATTN: Document Control Desk Washington, D.C. 20555 I
Subject:
Waterford 3 SES i
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 T.J. Gaudet at (504) 464-3325.
Very truly yours, R.F. Burski Manager Nuclear Safety & Regulatory Affairs RFB:TJG:ssf i
Attachment l
cc:
R.D. Martin, NRC Region IV J.A. Calvo, NRC-NRR D.L. Wigginton, NRC-NRR NRC Resident Inspectors Office E.L. Blake W.M. Stevenson i
i 8903230361 890320
{'DH ADOCK 05000382 0
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"AN EQUAL OPPORTUNITY EMPLOYER"
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'J.G. Dewease, R.P.,Barkhurst, T.F. Gerrets, F.J. Drummond, J.J. Zabritski, N.S.lCarns, D.F. Packer,.P.V. Prasankumar,
.J.R. McGaha, M.J. Meisner, G.E. Wuller, G.E. Wilson,'L.W. Laughlin, W.A. Cross, G.W. Muench,-R.T. Lally,-Jr., G.M. Davis, Y.Z.-Sirmon-Records. Center,-Administrative Support,, Licensing Library, Site j
Licensing Support File
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Attachment to W3P89-0064 Page 1 of 3 ATTACIRIENT 1 LP&L Response to the Violation Identified in Appendix A_
of Inspection Report 89-03 l
VIOLATION NO. 8903-01 Failure to Provide an Adequate Procedure Technical Specification 6.8.1.a requires that written procedures
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recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February j
1978, shall be established, implemented, and maintained covering fire q
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 driven 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 i
required the header pressure to be maintained below the reset point at which the pump could be stopped.
1 This is a Severity Level.IV violation.
RESPONSE
(1) Reason For The Violation 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 pump (MDFP) and the diesel fire pumps (DFPs). As part of the DFP 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 7.1.8) and then maintain the header pressure between 125-135 psig (Step 7.1.9).
On the dates stated in the violation, Step 7.1.8 could not be performed in sequence in that the MDFP could not be secured until after the testing of the DFPs was complete.
This was because of 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, 1988. Had this revision been promptly approved, this procedural violation would not have occurred.
The following information provides the basis for not being able to secure the MDFP.
Attachment to W3P89-0064 Page 2 of 3 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 cleaning 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 260337 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 a 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/C2/89. 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 KDFP could be stopped.
With the single exception of the run on 01/05/89, the operators performing OP-903-053 notified the shift 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 Revision 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 Management 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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.I.4 Attachment to W3P89-0064 Page 3 of 3 (3) Corrective Steps Which Will'Be Taken To Avoid Further Violations
'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 be 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.
(4) Date When Full Compliance Will Be Achieved Based on the above information, LP&L is currently in full' compliance.
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