IR 05000382/1993025
| ML20059L299 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/12/1993 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Barkhurst R ENTERGY OPERATIONS, INC. |
| References | |
| NUDOCS 9311170008 | |
| Download: ML20059L299 (4) | |
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L i 2 !O93 Docket: 50-382 License: NPF-38 Entergy Operations, Inc.
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ATTN: Ross P. Barkhurst, Vice President i
Operations, Waterford P.O. Box B Killona, Louisiana 70066 SUBJECT:
NRC INSPECTION REPORT 50-382/93-25
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Thank you for your letter of October 27, 1993, in response to our letter and Notice of Violation dated September 28, 1993. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We
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will review the implementation of your corrective actions during a future
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inspection to determine that full compliance has been achieved and will be
maintained.
Sincerely,
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.dollins, Director Division of Reactor Safety cc:
Entergy Operations, Inc.
ATTN: Harry W. Keiser, Executive Vice President & Chief Operating Officer P.O. Box 31995 Jackson, Mississippi 39286-1995
Entergy Operations, Inc.
ATTN: Jerrold G. Dewease, Vice President Operations Support P.O. Box 31995 Jackson, Mississippi 39286
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9311170008 931112" PDR ADOCK 05000382 G
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Wise, Carter, Child & Caraway ATTN: Robert B. McGehee, Esq.
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P.O. Box 651
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Jackson, Mississippi 39205
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Entergy Operations, Inc.
ATTN:
D. F. Packer, General
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Hanager Plant Operations i
P.O. Box B
- i Killona, Louisiana 70066 Entergy Operations, Inc.
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L. W.-Laughlin t
Licensing Manager
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P.O. Box B l
Killona, Louisiana 70066 j
Chairman Louisiana Public Service Commission
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One American Place, Suite 1630 -
Baton Rouge, Louisiana 70825-1697 i
Entergy Operations, Inc.
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R. F. Burski, Director
Nuclear Safety-j o
P.O. Box B Killona, Louisiana 70066
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Hall Bohlinger, Administrator j
Radiation Protection Division
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P.O. Box 82135 l
Bato.: Rouge, Louisiana 70884-2135 Parish President St. Charles Parish P.O. Box 302
Hahnville, Louisiana 70057
Mr. William A. Cross
Bethesda Licensing Office 3 Metro Center i
Suite 610
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Bethesda, Maryland 20814 Winston & Strawn i
ATTN:
Nicholas S. Reynolds, Esq.
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1400 L Street, N.W.
Washington, D.C.
20005-3502 j
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Entergy Operations,-Inc.
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bEc to ~'B (IE01) -- DRS and DRP bcc distrib. by RIV:
J. L. Milhoan Resident Inspector Section Chief (DRP/D)
Lisa Shea, RM/ALF, MS: MNBB 4503 MIS System DRSS-FIPS RIV File Project Engineer (DRP/D)
Section Chief (DRP/TSS)
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October 27, 1993 f
_ REG!OfGr U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C. 20555 Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report 93-25 Reply to Notice of Violation Gentlemen:
In accordance with IOCFR2.201, Entergy Operations, Inc. hereby submits in Attachment I 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.S. Becker at (504) 739-6693.
Very truly yours,
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R.F. Burski Director Nuclear Safety (,37449 3 s ' i.:J J,cn
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RFB/TSB/ssf Attachment cc:
.J.L. Milhoan (NRC Region IV), D.L. Wigginton (NRC-NRR),
R.B. McGehee, N.S. Reynolds, NRC Resident Inspectors Office f
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Page 1 of 3 ATTACHMENT 1 ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN APPENDIX A 0F INSPECTION REPORT 93-25 VIOLATION NO. 9325-01 Criterion V of Appendix B, 10CFR Part 50, states, in part, that activities affecting quality shall be prescribed by documented procedures and shall be accomplished in accordance with these procedures.
Waterford 2 Procedure UNT-005-002, " Administrative Procedure Condition Identifications," Revision 10, states, in Section 4.1.1, that Waterford-3 employees are responsible for " reporting and identifying abnormal conditions upon observation and initiating a condition identification to obtain resolution.
Conditions adverse to quality shall also be further identified as a Nonconformance Condition Identification (NCI)."
Contrary to the above, the licensee failed to identify and initiate Nonconformance Condition Identifications for the ASME Section III pressurizer safety valves exceeding the 1 percent tolerance specified in the Technical Specifications in December 1986, April 1988, January 1991, and June 1992. The licensee also failed to identify and initiate Nonconformance Condition Identifications for the main steam safety valves when their as-found set pressures exceeded the 1 percent tolerance specified in the Technical Specifications in November 1986, April 1988, September 1989, and March 1991.
RESPONSE (1)
Reason for the Violation Entergy Operations, Inc. admits this violation and believes that the root cause is personnel error in that the required procedure was not followed.
Administrative Proceduro UNT-005-002, " Condition Identification," requires that a Condition Identification (CI) be generated for any test that fails because of an equipment deficiency or a nonconforming anomalous condition.
Further, the procedure requires that a Nonconformance Condition Identification (NCI) be generated if a deficiency exists which represents a condition adverse to quality. When the pressurizer safety and main steam safety valves were discovered to have lift setpoints outside of the Technical Specification required tolerance, a NCI should have been generated in accordance with the guidance of UNT-005-002.
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Deficiencies in two other procedures were a contributing cause of this event. Maintenance Procedures MM-007-004, " Pressurizer Safety Valve Test," and MM-007-015, "Trevitest of Main Steam Safety Valves,"
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both provide guidance regarding actions to be taken if any acceptance criterion is exceeded, if any condition is identified that could q
prevent fulfillment of safety valve functional requirements, or if
any valve parameter is found to be out of tolerance based on test results.
Contrary to the upper-tier requirements of Site Directive W2.501, " Corrective Action," and UNT-005-002, neither maintenance l
procedure requires that these problems be documented 'on a Corrective
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Action Program document (Condition Report or NCI).
In both cases,
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the procedures direct that corrective actions and explanations be documented in the " remarks" section of the test performance record.
The net effect of this procedure guidance was to allow corrective action to be taken for a cond" ;n adverse to quality without i
documenting the adverse condit.an in the Corrective Action Program.
(2)
Corrective Steos That Have Been Taken and the Results Achieved Condition Reports 93-52 and 93-53 were generated in order to formally document the pressurizer safety and main steam safety valve as-found test failures in the Corrective Action program. Although the as-found test failures were not properly documented, Waterford 3, in concert with the industry, has been proactive in resolving identified
concerns with main steam and pressurizer safety valve setpoints,
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especihlly in the area of setpoint drift. Waterford 3 will continue to pursue the resolution of and implement necessary corrective actions for identified industry concerns associated with main steam
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and pressurizer safety valve setpoints.
In addition, the failure data for the pressurizer safety valves was
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entered into NPRDS to enhance the industry data base regarding these valves.
(3)
Corrective Steps Which Will Be Taken to Avoid Further Violations This violation was a result of a failure to enter an adverse
condition into the Corrective Action Program. As such, a review of
the Corrective Action Program will be performed and enhancements made as necessary.
MM-007-004 and MM-007-015 will be revised to reflect those enhancements.
In addition, other procedures which are used to perform surveillance type testing will be reviewed for possible
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inclusion of the Corrective Action Program enhancements.
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Page 3 of 3 Failure data for the. main steam safety valves will be entered into
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the NPRDS component database.
l, Finally, this event and any program changes made as a result of the Corrective Action Program review will be discussed with Waterford 3 personnel.
The discussion will stress the importance of documenting conditions adverse to quality in the Corrective Action Program so that root causes may be identified and appropriate corrective action taken.
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(4)
Date When Full Comoliance Will Be Achieved P
All corrective action for this event will be complete January 26,
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1994.
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