W3P89-2127, Forwards Supplemental Info Re Util 890817 Response to Violations Noted in Insp Rept 50-382/89-17,per 891023 Request.Change to Operating Procedure OP-600-007 Approved to Address Actions Necessary to Be Taken by Operator

Forwards Supplemental Info Re Util 890817 Response to Violations Noted in Insp Rept 50-382/89-17,per 891023 Request.Change to Operating Procedure OP-600-007 Approved to Address Actions Necessary to Be Taken by Operator

ML19332D093
Person / Time
Site:	Waterford
Issue date:	11/22/1989
From:	Burski R LOUISIANA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
W3P89-2127, NUDOCS 8911300007
Download: ML19332D093 (4)

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If POWER & LIGHT 1 NEW ORLEANS, LOUISIANA 70100 (504) $95 3100 NW EU E

W3P89-2127 I

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November 22, 1989.

l U.S. Nuclear Regulatory Commission ATTN Document Control Desk-Washing;sn, D.C.

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Subject:

Waterford 3 SES

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Docket No. 50-382-

l License No. NPF-3B NRC Inspsetion Report 89-17, Supplemental Response i

Gentlement Louisiana Power & Light (LP&L) hereby. submits in Attachment 1 the i

supplemental information requested in your letter of October 23, 1989 with regard to two of the Violations (8917-03 and 8917-06) cited in the subject-Inspection Report..LP&L previously responded to the Violations on August

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17, 1989 in LP&L Letter No. W3P89-1508.

If you have any questiona concerning this information, please contact T.J. Gaudet at (504) 464-3438.

Very truly yours, k'

)(odage

/ ucle r, Safety & Regulatory Affairs V'

RFB/TJG/pi cc Messrs R.D. Martin, NRC Region IV F.J. Hebdon, NRC-NRR D.L. Wigginton, NRC-NRR t

' NRC Residr=t Inspectors Office E.L. Blake W.M. Stevenson r

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PDC

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I "AN EGUAL OPPORTUNITY EMPLOYER" 1

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s. # 3 Attachment to W3P89-2127

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Page 1 of 3 t

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SUPPLEMENTAL INFORMATION FOR VIOLATIONS 8917-03 AND 8917-06 VIOLATION No. 8917-03 jl'L g

NRC REQUEST-t In Violation 382/8917-03 Example 1. UNT-005-003 was revised to make it

' clear'that when vent or drain paths are_ required to be danger tagged, only L"

the valves moved out of their normal position must be tagged. NRC believes

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-it prudent that if the tag-out of a vent or drain path is intended.to l

pr protect personnel or equipment, i.e., preventing a hydraulic lock, buildup L

of fluid, or to vent off a section of piping down stream of a potentially i

(or actually) leaking isolation boundary, then all of the valves in the

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' vent or drain path should be tagged. Please respond to this concern.

l F-LP&L SUPPLEMENTAL RESPONSE L

t LP&L's policy on tagging requires the following j

1)

-isolation boundary valves to be tagged;

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2) actual vent _or drain isolation valves'to be tagged, i.e.,

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.f path that breeches the system; t-3) repositioned valve < within the isolation boundary to be

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tagged

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Operations personnel to review the tagout for adequacy; and h

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'the " holder" of.the tagout to walk it down and review it for adequacy.

I LP&L's policy does not require the tagging of valves within the isclation boundary that_are not repositioned. LP&L believes these controls to be-l sufficient to-accomplish the goal of personnel and equipment protection and that unnecessary hardships with no additional margin of safety would be incurred if additional valves were required to be tagged. However, LP&L will ensure that verbiage in UNT-005-003 is cufficient guidance for l

comprehensive tagging, e.g., to address preventing hydraulic locks, personnel safety, leaking isolation valves, proper venting...

O LP&L acknowledges that because this position may still differ from that of i

the NRC, full resolution of this issue may not be achieved by this supplemental' response alone. Consequently, LP&L feels that it would be

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better to discuss.the matter further during an LP&L/NRC conference call.

Consequently, responsible Waterford 3 persornel will be contacting members of the'NRC Region IV staff in the first week of December, 1989.

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Attachment to j

W3P89-2127 Page 2 of 3 f

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I VIOLATION NO. 8917-06 NRC REQUEST p;

1 In Violation 382/8917-06, Examples 1 and 2, we noted that corrective action taken to revise the emergency diesel generator operating and annunciator L

response procedures, OP-009-002 and OP-600-007 respectively, was f,

incomplete. OP-009-002 failed to show what the identit'ication numbers and L

required positions were for the duplex filter and strainer selector valves.

The revision to OP-600-007 did not address the operator response and plant effect when the fuel oil filters become clogged. In addition, the

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corrective actions taken to avoid further violations applied specifically j

to the immediate problem but did not address'any actions taken to assure i

that other procedures were not ambiguous with regard to strainers, filters, L

and other selector valves. Please provide a e,upplemental response addressing actions you will take to avoid further violations.

LP6L Supplemental Response After further review, LP6L concludes that the initial response provided for i

1 Examples 1 and 2 of Violation 8917-06 was marginal because the corrective actions taken may.have been insufficient to prevent further violations in-l the same area. Consequently, the following additional actions are being

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taken to ensure this goal is achieved.

I LP6L responded to Example 1~of the violation by making a change to Operating Procedure OP-009-002, " Emergency Diesel Generator," to ensure l

that the initial lineup for EDG fuel oil strainers and filters would be i

I verified.. When this change was made it was believed that because of vendor manual guidance, it was not necessary to: include identification numbers and definitive handle positions. Ilowever, after further review, it is believed that this information should be procedurally enhanced. As of 11/09/89, the inlet and outlet valves for fuel oil filters and strainers have been added to the standby. valve lineups for both trains of the EDG, which is provided in Attachments 11.1 and 11.2 of OP-009-002.

In response to Example 2 of the violation, LP6L approved a change to Operating Procedure OP-600-007, " Annunciator Response for Emergency Diesci Generator A or B Local Panel." The change addressed actions necessary to I

be taken by the operator in response to a clogged fuel oil duplex strainer.

However, due to an inadvertent oversight, a similar change was not made to include the actions necessary to be taken by the operator in response to a clogged fuel oil duplex filter. Accordingly, on 09/08/89, a change to OP-600-007 was approved to add the necessary information.

Subsequent to this change, as part of the Operations Procedure Upgrade effort, OP-600-007 was. totally reformatted and human factor engineered.

Specific to this issue, the information provided for the " Fuel Oil Strainer or Filter High i

Differential Press" Annunciator, which previously had been provided on two l

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oc Attachment to W3P89-2127 Page 3 of 3 i

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separate sheets (one for filters and cae for strainers), has been F,

consolidated, enhanced and arranged-in a format consistent with other-i annunciator response procedures.

Because LP&L initially considered this violation as an isolated incident.

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'it was felt that a review of related procedures with regard to other duplex

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-strainers and filters was not necessary. Upon further review, LP&L l

s b'elieves that this type of review'is necessary to fully ensure that related if procedures do contain the necessary vendor manual information. This l

review is scheduled to be completed by 11/30/89. at which time procedure f

[t changes will be initiated if warranted.

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I Based on-these actions, LP&L is confident that recurring deficiencies in

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the area of strainers, filters and other selector valves will be prevented in the future..

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