IR 05000382/1996013

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp 50-382/96-13.Corrective Actions Will Be Examined During Future Insp

ML20134B131
Person / Time
Site:	Waterford
Issue date:	01/24/1997
From:	Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Sellman M ENTERGY OPERATIONS, INC.
References
NUDOCS 9701290293
Download: ML20134B131 (5)

Text

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h UNITED STATES i*. t""'%g[ t NUCLEAR REGULATORY COMMISSION fl 1). FIEGloN iv h6[8c

.t 611 RY AN PLAZA DRIVE, SUITE 400 AR LINGToN, TEXAS 760118064

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JAN 241997 Michael B. Sellman, Vice President Operations - Waterford Entergy Operations, In P.O. Box B Killona, Louisiana 70066 ,

SUBJECT: NRC INSPECTION REPORT 50-382/96-13 Thank you for your letter of January 21,1997,in response to our letter and Notice of Violation dated December 19,1996. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the ,

implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine

Sincerely,

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r J. E. Dyer, Director ,

Division of Reactor Projects l

Docket No.: 50-382 License No.: NPF-38

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cc:

Executive Vice President and ,

Chief Operating Officer Entergy Operations, In ;

t P.O. Box 31995 Jackson, Mississippi 39286-1995 .

i Vice President, Operations Support Entergy Operations, In P.O. Box 31995 j Jackson, Mississippi 39286 1995  :

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9701290293 970129 '

PDR ADOCK 05000382 G PDR

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Entergy Operations, In .

Wise, Carter, Child & Caraway ' l'

P.O. Box 651 Jackson, Mississippi 39205 General Manager, Plant Operations

Waterford 3 SES

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Entergy Operations, In P.O. Box B Killona, Louisiana 70066

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Manager - Licensing Marager Waterford 3 SES c . Entergy Operations, In ;

P.O. Box B

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Killona, Louisiana 70066 ,

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Chairman Louisiana Public Service Commission

One American Place, Suite 1630 '

Baton Rouge, Louisiana 70825-1697 ,

Director Nuclear Safety l Waterford 3 SES Entergy Operations, Inc.

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P.O. Box B Killona, Louisiana 70066 William H. Spell, Administrator >

Louisiana Radiation Protection Division

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P.O. Box 82135 Baton Rouge, Louisiana 70884-2135  ;

Parish President St. Charles Parish P.O. Box 302

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Hahnville, Louisiana 70057 Mr. William A. Cross Bethesda Licensing Office I

3 Metro Center-

. Suite 610

. Bethesda, Maryland ' 20814 i

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l Winston & Strawn l 1400 L Street, !

Washington, D.C. 20005-3502

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L. J. Callan Resident inspector DRP Director DRS-PSB Branch Chief (DRP/D) MIS System Project Engineer (DRP/D) RIV File Branch Chief (DRP/TSS) Leah Tremper (OC/LFDCB, MS: TWFN 9E10)

DOCUMENT NAME: R:\_WAT\WT613 AK.LAK To receive copy of document, indicate in box: "C** = Copy without enclosures "E" = Copy with enclosures "N" = No copy PE:DRP/Dn 3 , f) C:DRP/D, , Q D:DRP l l GAPic.k;cnB PHHarreWP$N JEDyer M 01/)M/97 01/p /97 V 01/2.f /97 OFFICIAL RECORD COPY

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a Entergy Operations, In M 2A E bec to DMB (IE01)

bec distrib, by RIV:

L. J. Callan Resident inspector DRP Director DRS-PSB Branch Chief (DRP/D) MIS System Project Engineer (DRP/D) RIV File Branch Chief (DRP/TSS) Leah Tremper (OC/LFDCB, MS: TWFN 9E10)

DOCUiviENT NAME: R:\_WAT\WT613AK.LAK To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy PE:DRP/Dni,3 C:DRP/D,3 9, D:DRP GAPic,k;crF PHHarrellPS JEDyer M 01/)M/97 0 I/g /97 V 01/1f /97 OFFICIAL RECORD COPY

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W3F1-97-0002 A4.05 PR January 21,1997 ed22 '

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 50-382/96-13 l

Reply to Notice of Violation Gentlemen:

In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in Attachment 1 the response to the violations identified in Enclosure 1 of the subject inspection Repor j Waterford 3 acknowledges the three concerns expressed in the cover letter to the inspection report: (1) operators failed to follow procedures regard!ng configuration control, (2) operators failed to recognize that the wet cooling tower fans were rendered inoperable during a maintenance activity and failed to enter appropriate Technical Specification (TS) Limiting Conditions for Operation, and (3) review of the Inservice Test (IST) program did not identify the need to perform testing on the dry cooling tower isolation valves which are required to be repositioned during the design basis tornado even )

Regarding the first concern, Waterford 3 has previously identified an increasing trend ;

in the number of human performance violations. Our comprehensive corrective actions to address that trend are detailed in Letter W3F1-96-0213 dated 12/13/9 We believe those correctiva actions, in concert with the actions detailed in Attachment 1, will help prevent similar violations from recurring and will improve operator attentivenes fM ; n e ! c ? io g-

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s Reply to Notice of Violation (IR 96-13)

W3F1-97-0002 Page 2

' January 21,1997

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- In addition to the corrective actions detailed in Attachment 1 for the second concern,

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we are continuing to implement corrective actions from the FOCUS plan (reference Letter W3F1-96-0130 dated 8/19/96) to improve our performance in the area of TS implementation. These actions include enhancing the procedure process, utilizing assessments as a tool to identify additional improvement opportunities, improving

. operator awareness of plant conditions prior to approving maintenance activities, and establishing specific guidance concerning the control of work and pre-job briefings to ensure proper Operations oversight. Furthermore, Waterford 3 management has placed significant focus on assuring that the culture and policy for implementing Technical Specifications are conservative from a safety standpoint and comply with

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regulatory requirements.

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Regarding the third concern, the dry cooling tower isolation valves will be added to the IST plan. Furthermore, we are developing a document that details the design basis tornado event. This document should increase the probability that similar

conditions, if they exist, are identified and correcte l

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Should you have any questions concerning this response, please contact me at (504) 739-6666 or Jeff Thomas at (504) 739-6531.

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e Very truly yours,

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, T.J. Gaudet Acting Director,

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Nuclear Safety & Regulatory Affairs TJG/GCS/tjs Attachment cc: E.W. Merschoff (NRC Region IV)

C.P. Patel (NRC-NRR)

R.B. McGehee

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N.S. Reynolds NRC Resident inspectors Office

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W3F1-97-0002 Page 1 of 8

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ATTACHMENT 1 ENTERGY OPERATIONSJNC. RESPONSE TO THE VIOLATION IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 96-13  ;

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VIOLATION NO. 9613-01 Technical Specification 6.8.1.a requires, in part, that written procedures shall be implemented covering applicable procedures recommended in Appendix A of Regulatory guide 1.33, Revision 2, February 1978. Appendix A, Section 3, requires that the licensee have procedures for operation of safety related system . Procedure OP-002-010, " Reactor Auxiliary Building HVAC and Containment Purge," Revision 11, Section 6.6, required that the airborne radioactivity removal system be secured when stopping containment purg Contrary to the above, on October 1,1996, the licensee failed to secure the I airborne radioactivity removal system after stopping containment purge. The ;

airborne rr.dioactivity removal system was not secured until observed in the l

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abnormai configuration on October 20,1996, a period of 19 day . Procedure OP-002-003, " System Operating Procedure - Component Coolino Water System," Revision 10, Section 6.0, " Normal Operations," required th i dry cooling tower fan control switches be in the AUTO positio l Contrary to the above, on October 19,1996, at 3:37 a.m., operators inadveiently placed the Dry Cooling Tower Fan 13-B control switch in the OFF pcsition. The switch remained in the OFF position until observed in the abnormal configuration at 4:40 p.m. on October 20, a period of 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> ,

! Procedure OP-903-121, " Safety Systems Quarterly IST Valves Tests,"

Revision 1, Section 7.2, " Safety injection Train B," requires that Valve Sl1398 be closed following inservice testin Contrary to the above, on November 19,1996, at 1:42 a.m., operators failed to close Valve SI-1398 following inservice testing. Valve SI-139B was not closed until operators observed the abnormal configuration at 4 p.m. on November 21,1996, a period of 62 hour7.175926e-4 days <br />0.0172 hours <br />1.025132e-4 weeks <br />2.3591e-5 months <br /> This is a Severity Level IV violation (Supplement 1), (50-382/9613-01) I

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W3F1-97-0002

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Page 2 of 8 RESPONSE (1) Reason for the Violation

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This violation was due to personnel error and inattention to detail in that operators involved with each of the occurrences failed to follow procedures and failed to closely monitor activities that were taking place on the control board. The operators are required to be cognizant of activities on all the control panels and the attention given to the control panels with the incorrect configurations was not adequate. The operations shift turnover on the plant configuration was inadequate in that configuration errors existed over several shifts and were never discussed or identified by the oncoming shifts until 19 days for example 1,36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> for example 2 and 62 hours7.175926e-4 days <br />0.0172 hours <br />1.025132e-4 weeks <br />2.3591e-5 months <br /> for example 3 of the violation. In addition, Operations supervisory personnel (Control Room Supervisor (CRS) and Shift Superintendent [SS]) did not provide adequate oversight of the activities taking place on the control panel Contributing to the failure to follow procedure OP-002-010, " Reactor Auxiliary Building HVAC and Containment Purge," to secure the airborne radioactivity removal system was an inadequate place keeping method in procedure OP-002-010. This procedure does not have sign-offs for each action step delineated. Consequently, steps in the procedure, such as those securing the airborne radioactivity system, may be overlooked due to a sign-off not being required. In addition, Operations supervisory personnel (Control Room Supervisor (CRS) and Shift Superintendent (SS) ) did not provide adequate oversight of the activities taking place on the control panels.

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Contributing to the failure to follow procedure OP-002-003, " System Operating Procedure- Component Cooling Water System," which requires the Dry Cooling Tower Fan 13-B control switch to be in Auto position was that there is no difference in light indication on the DCT fan control switch when the switch is in auto position compared with the off position. The operators rely on the position of the control knob pointer to determine the position of the control switch. In addition, Operations supervisory personnel did not provide adequate oversight of the activities taking place on the control panel Contributing to the failure to follow Section 7.2, " Safety injection Train B," of procedure OP-903-121, " Safety Systems Quarterly IST Valves Tests," was that the operators, who should have closed valve SI-139 from the control board, were involved with another activity which distracted their attention and caused them to overlook the position of valve SI-139. Even though distractions are a cue to self checking, proper self checking was not done. In addition, Operations supervisory personnel did not provide the proper work environment to minimize these distraction I

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1. . Attachrt ent to

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W3F1-9' ~-0002

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Page 3 of 8 J

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(2) Corrective Steos That Have Been Taken and the Results Achieved Condition reports 96-1639,96-1640 and 96-1847 were generated for  ;

each one of the self-identified occurrences.

! All the components were placed in their correct configuration.

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] All the operators ir.volved with the failure to restore the plant to its correct configuration have been counseled.

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l Operations Manager reinforced the operators requirement to perform thorough control board walkdown . All control room operators are required to sign a new addendum sheet to the shift log indicating completion of control board panel walkdowns.

} (3) Corrective Steos Which Will Be Taken to Avoid Further Violations The Operations Manager will issue a letter to all Shift Superintendent and Control Room Supervisors which will emphasize the importance of

! properly prioritizing tasks to avoid excessive operator work load.

- The Operations Manager will clarify to operations supervisory

personnel the expectation that licensed operators have responsibility for monitoring plant controls. The supervisory personnel will convey these expectations to the operations staf !

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, The Operations department will form a team to review and improve, if appropriate, the current method used for shift turnover. A review of the j inadequacy of reviewing shift togs will also be performe !

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, A review will be performed on normal operating procedures to ,

determine if the method for place keeping in procedures can be '

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(4) Date When Full Comoliance Will Be Achieved

Waterford 3 is in full compliance. Items 1,2, and 3 will be completed by

2/28/97 and item 4 will be completed by 7/1/9 l i'

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Paga_4.of 8 ATTACHMENT 1 ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 96-13 VIOLATION NO. 9613-03 Technical Specification 3.7.4.f requires, in part, that, with mnre than one wet cooling tower fan inoperable and the outside air temperature greater than 70 degrees F, the dry bulb temperature must be determined at least once every 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Contrary to the above, between May 5 and 9,1996, with more than one wet cooling tower fan inoperable and the outside air temperature greater than 70 degrees F, the licensee did not determine the dry bulb temperature at least once every 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> This is a Severity Level IV viclation (Supplement 1). (50-382/9613-03)

RESPONSE (1) Reason for the Violation Entergy Operations admits this violation and believes that the root cause is inadequate work controls in that the method used in the engineering evaluations was not standardized. There was no standard method or process to establish administrative controls for the format, required level of review / approval, and operations interface of the evaluation that was used to document the inoperability of the wet cooling tower fans. Guidance on the use of engineering input to evaluate work that may impact operabilty of safety related or technical specification equipment was inadequate. As a result, an

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adequate level of review of the engineerir.g evaluation was not performed and the fact that the wet cocling tower fans would be rendered inoperable whik netting was placed around the wet cooling tower basin was not clearly communicated to operations. As a result of operations not being cognizant of the wet cooling tower fans inoperability, the required actions per Technical Specification 3.7.4.f was not performe (2) Corrective Steos That Have Been Taken and the Results Achieved Condition report 96-729 was generated to document and address this

, matte . LER 96-005 Revision 0 was issued to report this occurrence.

. The temporary netting that rendered the fans inoperable was remove _ ._ _ _ . _ . . _

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, Att:chment to W3F1-97-0002 Page 5 of 8

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, 4. Operations Administrative Procedure OP-100-014," Technical Specification Compliance," has been revised to require the following: If any system, sub-system, or component becomes unable to perform its intended safety function due to surveillance, calibration, or maintenance, then declare that equipment i inoperable and enter the appropriate Tech / Spec TRM (Technical i Requirements Manual) actio If a component is thought to be Inoperable enter the appropriate Tech Spec /TRM action and initiate LCO tracking in accordance with OP-100-010," Equipment Out of Service."

l The engineering guidance should have at least two signatures on it indicating that a technical review has been performed.

1. The engineering guidance must be specifically bounded against

. any applicable Tech Specs. All engineering guidance i'

parameters must be bounded by Tech Spec parameters, and in all cases, operators will adhere to the Tech Spec The STA should perform a review of the engineering guidance and provide a recommendation to the SS concerning the adequacy of the guidance.

, 5. Plant Administrative Procedure UNT 007-053 " Engineering Work  ;

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Authorization," has been revised to specify the following: l

1 An engineering input will not be used to make operability j

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determinations for technical specifications or safety related

equipment, nor will it be used to implement configuration

change All nonconformance conditions are addressed by Corrective

, Action Site Directive, W2.50 Engineering inputs are only used to facilitate work such as

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bolting, torquing, gasketing, material condition improvements, troubleshooting and venting requirements.

$ All engineering inputs require a technical reviewer signature.

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(3) Corrective Steos Which Will Be Taken to Avoid Further Violations i l The Engineering Request process will replace the Problem j Evaluation /Information Request (PElR) for the purpose of engineering i evaluations.

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(4) Date When Full Comoliance Will Be Achieved

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Waterford 3 is currently in full compliance. The above corrective action will be 4 completed by 9/30/97.

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W3F1-97-0002 Page 7 of 8 l 6-

I ATTACHMENT 1

! ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN i ENCLO'SURE 1 OF INSPECTION REPORT 96-13 t

VIOLATION NO. 9613-04 10 CFR 50.55a(g) requires, in part, that inservice testing to verify operational readiness of pumps and valves whose function is required for safety be accomplished in accordance with Section XI of the ASME Boiler and Pressure Vessel

. Cod Contrary to the above, as of October 29,1996, the licensee failed to verify the operational readiness of certain valves whose function is required for safety in accordance with Section XI of the ASME Boiler and Pressure Vessel Cod Specifically, the licensee failed to perform testing which ensured the operational readiness of manually operated dry cooling tower isolation valves used to maintain the safety function of the ultimate heat sink during the design basis tornado even This is a Severity Level IV violation (Supplement 1). (50-382/9613-04)

RESPONSE (1) Reason for the Violation The root cause of this violation is believed to be insufficiently explicit design-basis tornado event documentation. The documentation was not specific enough to readily allow the IST plan reviewers to conclude that the Dry Cooling Tower inlet and outlet valves had a safety function and should be included in the IST program for testing. These valves were not included in the IST plan during initial IST plan development, during the IST design basis document (DBD 24) review, or during the current (although not completed)

review of all ASME Class 1,2, and 3 valve A contributing cause for this violation was that the reviewer did not examine all of the available design basis tornado event documentation during the current IST plan review process. It is believed that had the reviewer examined the calculation related to the design basis tornado event, he would have concluded that the Dry Cooling Tower inlet and outlet valves should have been in the IST pla = _ _ _ - . - . -. . -

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,a f Attachmsnt to W3F1-97-0002 e Page 8 of 8 (2) Corrective Steos That Have Been Taken and the Results Achieved The Dry Cooling Tower manual inlet and outlet valves were successfully tested per IST requirements on 12/7/9 (3) Corrective Steos Which Will Be Taken to Avoid Further Violations The Dry Cooling Tower Manual inlet and outlet valve: will be included in the IST progra . A review of the design basis tornado event will be performed and the design basis documents will be revised, as necessary, based on the results of the revie . The IST basis document will be reviewed by the appropriate design engineering disciplines in support of the development of the IST plan for the second ten interva (4) Date When Full Comoliance Will Be Achitygd Waterford 3 is in full compliance item 1 will be completed by 1/31/97, item 2 will be completed by 8/31/97 and item 3 will be completed by 12/1/9 I

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