W3P89-2131, Responds to NRC Ltr Re Violations Noted in Insp Rept 50-382/89-26.Corrective Action:Procedure OP-903-030 Revised to Incorporate Requirements of ASME Section XI,IWP-3500
| ML19332D499 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/20/1989 |
| From: | Burski R LOUISIANA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3P89-2131, NUDOCS 8912040056 | |
| Download: ML19332D499 (4) | |
Text
\\
i f
r i
UISIANA / sir sARoNNesTRect
- p. o. sox 60340 -
(504) 595-3100
~
POWER & L1GHT NEW ORLEANS, LOUISIANA 70160 UtkikNkvsM W3P89-2131-A4.05 i
)
QA l
r
[-
November'20, 1989 I
'U.S. Nuclear Regulatory Commission i-.
ATTNt. Document Control Desk i
~_.,.
. Washington; D.C.
20555 l
Subject:
.Waterford 3 SES Docket'No. 50-382 c.
t License No. NPF-38.
Q,-
NRC Inspection Report 89-26 t
1 i
F Gentlemen:
11 L
In accordance with 10 CFR Part 2.201, Louisiana Power & Light hereby submits in Attachment 1 the response to the. Violation identified.in 4
L Appendix A of the subject Inspection Report.
L L
.If you have any questions concerning these responses, please contact
-L.W. Laughlin at (504) 464-3499.
Very truly yours, 4
r R.F. Burski
[
.Maneger.
Nuclear Safety & Regulatory Affairs i
RFB/DMU/pi-Attachment.
cc:. Messrs. R.D. Martin, NRC Region IV i
F.J..Nebdon, NRC-NRR D.L. Wia,ginton, NPC-NRR NRC Resident Inspectors Office E.L. Blake V.M. Stevenson 891aW OO56891120 F
gDR ADOCK 05000302 1-PNU L
i 0a u
-i
'o 9 -
9 Attachment te i
W3P89-2131 Page 1 of 3
)
I
' ATTACHMENT 1 i
LP&L RESPONSE TO THE VIOLATION IDENTIFIED 1N APPENDIX A 0F INSPECTION REPORT 89-26 VIOLATION 8926-01 j
- INADEQUATE PROCEDURE i
Technical Specification 6.8.1.c requires, in part, that written procedures i
shall be established and maintained for surveillance and test activities on safety.related equipment.
l
- Technical Specification 4.0.5 requires, in part, that inservice testing of ASME Class'2 pumps shall be performed in accordance with Section XI of the ASME Boiler and Pressure vessel Code.
IWP-3500 of Section XI requires minimum. stabilization run times for testing of pumps.
Contrary to the above. Procedure OP-903-030 Revision 6. " Safety Injection Pump Operability Verification" established to implement the above requirement was-inadequate in that it did not require minimum Stabilization
-run times for_ testing of pumps.
-This is a Severity Level IV violation.
RESPONSE.
(1) Reason for the Violation The, root cause of this violation was personnel error. The author (s) of surveillance procedure OP-903-030 Safety Injection Pump Operability Verification, failed to incorporate the test durations specified in Section XI of the ASME Boiler and Pressure Code.
IWP-3500 of Section XI requires the followings (1) When measurement of bearing temperature is not required, each pump shall be run at least 5 minutes under conditions as stable as the system permits. At the end of this time at least one measurement or observation of each of the quantities specified shall be made and recorded.
(2) When measurement of bearing temperature is required, each pump shall be run until the bearing temperatures (IWP-4310) stabilize, and
-then'the quantitites specified shall be measured or observed and recorded. A bearing temperature shall be considered stable when three successive readings taken at 10 minutes intervals do not vary by more than 3%.
l-u a
Attachment to i
W3P89-2131 Page 2 of 3 f
Contrary to item 1 above, procedure OP-903-030 did not contain the i
requirement to run the High Pressure Safety Injection Pump for at least 5 minutes before taking data when bearing temperature measurements are not required. Following a review of the other pump inservice test (IST)
[
procedures, it was determined that this requirement was correctly listed in those procedures. It therefore appears that this requirement was
[
inidvertently omitted from only OP-903-030. It is, however, reasonable to assume that,'regardless of the omission, the pump was routinely run at least five minutes while preparing to take the required data.
i With respect to item 2-above, OP-903-030 did specify that bearing
-temperatures must stabilize before they be recorded and the procedure did correctly identify the stabilization criteria. However, the wording in the i
procedure did not specifically prevent the recording of IST data, i.e.,
a flow, vibration, until after bearing temperatures had stabilized. As stated, it did not ensure compliance with the requirements of IWP-3500(b).
l A review of all other pump IST procedures indicated that the wording of the above requirement in~each procedure was the same as that in OP-903-030.
j (2) Corrective Steps That Have Been Taken and the Results Achieved
[
Pump IST procedures, including OP-903-030, have been revised, as necessary, to incorporate the requirements of ASME Se.: tion XI, IWP-3500. The procedure-revisions were approved on October 6, 1989.
t (3) Corrective Steps Which Will Be Taken to Avoid Futther Viointions Commitment #P09422 on the Commitment Management System (CMS) lists the requirements of ASME Section XI.-IWP-3500 and identifies which systems and surveillance' procedures it is applicable to.
To fulfill this commitment, each procedure listed must contain the necessary steps to satisfy the commitment requirements. OP-903-030 and the remaining 6 pump IST i
. procedures are identified under this commitment and, as of 10/6/89, satisfy the requirements of IWP-3500.
To ensure continued compliance, UNT-1-003, REV. 11, Procedure Initiation.
Review and Approval; Change and Revision; and Deletions; Section 3.2.14 requires that during a procedure revision, the technical reviewer reviews the CMS for commitments listed against that procedure.
It is the reviewer's responsibility to ensure that compliance with these commitments has not been affected. Additionally, NOP-011. REV. O, Commitments Management System, contains a similar requirement.
Section 4.4.3 requires
" reviewing implementing document changes against the commitment report to assure the change continues to implement applicable commitments."
l l
6
fi$i
!n1140',
i
~q.~
t i
w L 4:
Attachment to-W3P89-2131-Page:3 of 3 LP&L will also review'ASME Section XI. : subsections t IWP and IWV. to ensure;no further discrepancies exist between these requirements, the.
Waterford 3 Pump and Valve Inservice Test Plan and corresponding IST pump-e F.
and valve test procedures. This review will be complete by June 30, 1990.
P 1(4)-
Date When' Full Compliance Will Be Achieved 5
' With regard.to the specifics-of this violation. LP&L is currently in full compliance, b,
9 f
i; s
b 4
t s
4 L.
L E
E.._',_a