ML20005E563
| ML20005E563 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/22/1989 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Dewease J LOUISIANA POWER & LIGHT CO. |
| References | |
| NUDOCS 9001080141 | |
| Download: ML20005E563 (3) | |
See also: IR 05000382/1989017
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In Reply Refer To:
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Docket:
50-382/89-17
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Louisiana Power. & Light Company
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-ATTN:- J. G. Dewease, Senior Vice President
Nuclear Operations
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~317 Baronne Street
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New Orleans, Louisiana 70160
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Gentlemen:
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. Thank you for your letters of August 17 and November 22, 1989, in response'
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to our letters'and Notice of Violation dated July 18, 1989. We have reviewed
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'your supplemental response and find it responsive to the concerns raised in our
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Notice of Violation.- We will review the implementation of your corrective
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, actions during a future inspection to determine that full compliance has been
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achieved and will be maintained.
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Sincerel
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Samuel J. Collins, Director
Division of Reactor Projects
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Louisiana. Power & Light Company
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- ATTN:
R. P. Barkhurst, Vice President-
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Nuclear ~0perations
P.O.-Box B
Killona, Louisiana 70066-
Louisiana Power & Light Company
ATTN:
J. R. McGaha, Jr., Plant Manager
P;0.. Box B
Killona, Louisiana 70066
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Louisiana Power & Light Company
ATTN:- L.-W..Laughlin, Site
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-Licensing Support Supervisor
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Killona Louisiana
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Louisiana Power & Light Company
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ATTN:-
G. M. Davis, Manager Events
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,' Analysis Reporting & Response
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P.O. Box B
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. K111ona. Loutsianx 70066
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. Monroe & Leman .
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ATTN: W.'Malcolm Stevenson, Esq.
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- 201;St. Charles Avenue, Suite.3300
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New Orleans,4 Louisiana. 70170-3300
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Shaw, Pittman, Potts 8.Trowbridge
ATTN:
Mr. E. Blake
2300 N Street, NW .20037
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Washington, D.C.
Middle: South Services. Inc.-
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' ATTN:,' Ralph T. Lally. Manager
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of Quality Assurance
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P.O.: Box 61000
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- New Orleans, Louisianai70161 -
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Chairman '.
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- Louisiana Public~ Service Commission.
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- 0ne'American Place, Suite 1630
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Baton Rouge, Louisiana 70825-1697
Louisiana-Power & Light, Company
' ATTN:
R. F. Burski, Manager. Nuclear
Safety and: Regulatory Affairs
~ 317-Baronne Street
New-Orleans, Louisiana 70112
Department of Environmental Quality >
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ATTN: William H. Spell, Administrator
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Nuclear Energy Division .
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_ P.O. Box 14690
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Baton Rouge, Louisiana '70898
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President . Police Jury
St. Charles Parish
Hahnville. Louisiana 70057
Mr. William A. Cross
- Bethesda' Licensing Office
' 3 Metro Center
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Suite 610
Bethesda . Maryland 20814
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U.S.' Nuclear Regulatory Commission
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P.O. Box 822'
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' ATTN: . Resident' Inspector
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U.S. Nuclear Regulatory Commission
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ATTN:
Regional Administrator Region IV
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' 611 Ryan Plaza Drive. Suite 1000
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R. D.' Martin
Resident Inspector
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' Project Engineer' (DRP/A) .
RSTS Operator
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D. Wigginton, NRR Project Manager (MS:
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(604)606 3100
POWER & LIGHT
NEW ORLEANS, LOUl81ANA 70100
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November 22, 1989
U.S. Nuclear Regulatory Connaission
ATTN
Document Control Desk
. Washington. D.C.
20555
Subject: Waterford-3 SES
Docket No. 50-382
License No. NPF-38
NRC Inspection Report 89-17. Supplemental Response
Genticaent
Louisiana Power & Light (LP&L) hereby submits in Attachment 1 the
supplemental information requested in your letter of Octo'oer 23. 1989 with
regard to two of the Violations (8917-03 and 8917-06) cited in the subject
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Inspection Report. LP&L previously responded to the Violations on August
17, 1989 in LP&L Letter No. W3P89-1508.
If you have.any questions concerning this information, please contact
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-T.J. Gaudet at (504) 464-3438.
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Very truly yours.
Bur
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Safety & Regulatory Affairs
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cc: Messrs
A.D. Martin, NRC Region IV
F.J. Hebdon, NRC-NRR
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D.L. Wigginton, NRC-NRR
NRC Resident Inspectors Office
E.L. Blake
W.M. Stevenson
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"AN EOUAL OPPORTUNITV EMPLOYER"
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Attachment to
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Page 1 of 3
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ATTACHMENT 1
SUPPLEMENTAL INFORMATION FOR VIOLATIONS 8917-03 AND 8917-06
VIOLATION NO. 8917-03
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NRC REQUEST
In Violation 382/8917-03, Example 1. UNT-005-003 was revised to make it
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clear that when vetit or drain paths are required to be danger tagged, only
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
protect personnel or equipment, i.e. , preventing a hydraulic lock, buildup
of fluid, or to vent off a section of piping down stream of a potentially
(or actually) leaking isolation boundary, then all of the valves in the
vent or drain path should be tagged. Please respond to this concern.
LP&L E,UPPLEMENTAL RESPONSE
LP&L's policy on tagging requires the followingtg
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isolation boundary valves to be tagged;
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actual vent or drain isolation valves to be tagged,
i.e., any
path that breeches the system;
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repositioned valves within the isolation boundary to be
tagged;
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Operations personnel to review the tagout for adequacy; and
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the " holder" of the tagout to walk it down and review it for
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adequacy.
LP&L's policy does not require the tagging of valves within the isolation
boundary that are not repositioned. LP&L believes these controls to be
sufficient to s complish the goal of personnel and equipment protection and
tha't unnecessary hardships with no additional margin of safety would be
incurred if additional valves were required to be tagged. However, LP&L
will ensure tbst verbiage in UNT-005-003 is sufficient guidance for
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comprehensive tagging, e.g., to address preventing hydraulic locks,
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personnel safety, leaking isolation valves, proper venting...
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LP&L acknowledges that because this position may still differ from that of
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the NRC, full resolution of this issue may not be achieved by this
supplemental response alone. Consequently, LP&L feels that it would be
better to discuss the matter further during an LP&L/NRC conference call.
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Consequently, responsible Waterford 3 personnel will be contacting members
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of the NRC Region IV staff in the first week of December,1989.
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Attachment to
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Page 2 of 3
VIOLATION NO. 8917-06
NRC REQUEST
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in Violation 382/8917-06, Examples 1 and 2, we noted that corrective action
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taken to revise the emergency diesel generator operating and annunciator
response procedures OP-009-002 and OP-600-007 respectively, was
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incomplete. OP-009-002 failed to show what the identification numbers and
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
corrective actions taken to avoid further violations applied specifically
to the _immediate problem but did not address any actions taken to assure
that other procedures were not ambiguous with regard to strainers, filters,
and other selector valves. Please provide a supplemental response
addressing actions you will take to avoid further violations.
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LP&L Supplemental Response
After further review, LP&L concludes that the ini.tial response provided for
Examples ! and 2 of Violation 8917-06 was marginal because the corrective
actions taken may have been insufficient to prevent further violations in
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the same area. Consequently, the following additional actions are being
taken to ensure this goal is achieved.
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LP&L responded to Example 1 of the violation by making a change to
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Operating Procedure OP-009-002, " Emergency Diesel Generator," to ensure
that the initial lineup for EDG fuel oil strainers and filters would be
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. However, af ter 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
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in Attachments 11.1 and 11.2 of OP-009-002.
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In response to Example 2 of the violation LP&L approved a change to
Operating Procedure OP-600-007 " Annunciator Response for Emergency Diesel
Generator A or B Local Panel." The change addressed actions necessary to
be taken by the operator in response to a ciegged 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 ef f ort, 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
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Differential Press" Annunciator, which previously had been provided on two
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Attachment to
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Page 3 of 3
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separate sheets (one for filters and one for strainers), has been
consolidated, enhanced and arranged in a format consistent with other
annunciator response procedures.
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Because LP&L initially considered this violation as an_ isolated incident,
it was felt that a review of related procedures with regard to other duplex
strainers and filters was not necessary. Upon further review, LP&L
believes that this type of review is necessary to fully ensure that related
procedures do contain the necessary vendor manual information. This
review is scheduled to be completed by 11/30/89, at which time procedure
changes will be initiated if warranted.
Based on these actions, LP&L is confident that recurring deficiencies in
tha area of strainers, filters and other selector valves will be prevented
in the future.
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