IR 05000382/1997003

Discusses Insp Rept 50-382/97-03 Completed on 970228 & Forwards NOV & Proposed Imposition of Civil Penalty in Amount of $55,000

ML20148C310
Person / Time
Site:	Waterford
Issue date:	05/09/1997
From:	Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dugger C ENTERGY OPERATIONS, INC.
Shared Package
ML20148C314	List: IR 05000382/1997003 ML20148C320
References
50-382-97-03, 50-382-97-3, EA-97-099, EA-97-99, NUDOCS 9705150322
Download: ML20148C310 (5)

Text

c g8 MCoq UNITED STATES O( \o NUCLEAR REGULATORY COMMISSION k* $ REGloN IV t

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/g 611 RYAN PLAZA DRIVE, sulTE 400 AR LINGToN. TEXAS 760114064 EA 97-099 May 9,1997 Charles M. Dugger, Vice President Operations - Waterford Entergy Operations, Inc.

P.O. Box B Killona, Louisiana 70066 SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF civil PENALTY -

$55,000 (NRC INSPECTION REPORT 50-382/97-03)

Dear Mr. Dugger:

This refers to the predecisional enforcement conference conducted in Arlington, Texas on April 8,1997. The conference was conducted to discuss several apparent violations related to the design, testing and operation of the Waterford Steam Electric Station, Unit 3 (Waterford-3) containment cooling system. The inspection ended February 28,1997,and was documented in a report issued on March 7,1997.

Based on the information developed during the inspection and the information that Entergy Operations, Inc. (Entergy) representatives presented during the conference, the NRC has determined that violations of NRC requirements occurred. These violations are cited in the enclosed Notice of Violation and Proposed imposition of Civil Penalty. The circumstances surrounding the violations were descr%d in detail in the subject inspectinn report.

The violations involve a f ailure to assure that component cooling water flow rates through containment f an coolers (CFCs) met Technical Specification (TS) requirements (1325 gallons per minute) and design assumptions. The CFCs and the containment spray system function to reduce containment temperature and pressure in the event of a loss-of-coolant or main steam line break accident. In addition, Entergy failed to take prompt corrective action following CFC testing in August 1996 to either restore flows to design basis values (1350 gallons per minute through each CFC) or to modify the design basis documents to justify reduced flows. \;

At the conference, Entergy did not disagree with the violations, but stated: 1) that there was no safety significance to the violations and that this had been established as early as

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October 1995 when an operability evaluation supported reduced CFC flows; 2) that CFC flows, although less than assumed in design documents and less than required in the Waterford-3 TS, were always adequate to maintain containment peak pressure within design values, i.e.,less than 44 psig'; and 3) that corrective action was in progress to i

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' On April 15,1997, Entergy reported to the NRC the discovery of a problem with the '

containment spray system which, when coupled with inadequate containment fan cooler i flows, had the potential under certain 3ost-accident circumstances to cause containment l

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Entergy Operations, Inc. -2-

1 modify design documents and Waterford-3's TS to reflect the engineering conclusion that I lower flows were acceptable. We note that a revised TS was submitted to the NRC on April 11,1997.

Additional corrective actions cited at the conference included cleaning dry cooling tower tubes to increase component cooling water flow rates; performing special tests to establish post-accident flows; conducting additional design basis training for operations, maintenance, licensing and engineering personnel; and reexamining certain procedures to assure necessary design basis information was incorporated.

The NRC acknewledges Entergy's position that the actual safety significance of the violations is low. However, we note that such a conclusion was reached only after extensive engineering analysis to justify reduced CFC flows and to show that peak containment pressure would not have been exceeded in the event of an accident. In addition, Entergy missed a substantial opportunity to identify these p~roblems in October 1995, when CFC flow balance testing was conducted. Entergy did not recognize at that time that flow rates to the CFCs were not sufficient to meet TS surveillance acceptance requirements. This resulted in operation of the facility for 10 months in noncompliance with TS acceptance values for CFC flows. Therefore, the violations are considered in the aggregate as a Severity Level ll1 problem in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600.

In accordance with the Enforcement Policy, a civil penalty with a base value of $55,0002 is considered for a Severity Level ill problem. Because your facility has been the subject of escalated enforcement actions within the last 2 years,' the NRC considered whether credit was warranted for /denti// cation and Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. Although Entergy's self-assessment identified in August 1996 the potential discrepancy between test results and TS-required CFC flows, Entergy did not conclude that TS requirements had not been met (the concept of " identification" includes recognition of the problem requiring corrective action). This, coupled with the significant missed opportunity in October 1995 to make this discovery, is the basis for NRC's decision not to give Entergy credit for identification.

With respect to corrective actions, we believe that actions to resolve these problems were peak pressure to reach 44.05 psig. The problem with the containment spray system will be dispositioned separately.

2 The Enforcement Policy was revised in October 1996, such that for violations occurring or continuing after November 12,1996, the base value was increased to

$55,000. Since some of the violations that comprise this Severity Level ill problem continued after November 12,1996, the increased base value is being used.

• Two escalated actions have been issued in the last two years involving Waterford-3.

A $50,000 civil penalty (EA 96-255) was issued December 26,1996, for violations involving the inservice test program, and a $50,000 civil penalty (EA 96-025) was issued March 28,1996, for violations involving the auxiliary component cooling water system.

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delayed by Entergy's failure to recognize the TS noncompliance. However, from February

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1997, when Entergy was put on notice of NRC's conclusion regarding the intent of the CFC TS surveillance requirement, we consider Entergy's correctivo actions to be sufficiently prompt and comprehensive to warrant credit.

l Therefore, to emphasize the importance of assuring that Waterford-3 is operated in 1 accordance with TS requirements, and the importance of assuring that design assumptions

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are accurate and reflected in the operation of the facility, I have been authorized, after

consultation with the Director, Office of Enforcement, to issue the enclosed Notice of Violation and Proposed imposition of Civil Penalty (Notice) in the base amount of $55,000.

j. - You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.

) In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, ,

its enclosure, and your response will be placed in the NRC Public Document Room (PDR). l

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Sincerely, j

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W h Ellis W. Merschoff Regional Administrator

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Docket No. 50-382

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License No. NPF-38 Enclosure: Notice of Violation and i Proposed imposition of Civil Penalty

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l cc w/ Enclosure:

Executive Vice President and i Chief Operating Officer

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Entergy Operations, Inc.

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

Vice President, Operations Support Entergy Operations, Inc.

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

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l Entergy Operations, Inc. -4-i

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( Wise, Carter, Child & Caraway l P.O. Box 651 Jackson, Mississippi 39205 General Manager, Plant Operations l

l Waterford 3 SES i Entergy Operations, Inc.

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P.O. Box B Killona, Louisiana 70066 l

l Manager - Licensing Manager Waterford 3 SES 2ntergy Operations, Inc.

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P.O. Box B l Killona, Louisiana 70066 i

l l Chairman

Louisiana Public Service Commission

! One American Place, Suite 1630 Baton Rouge, Louisiana 70825-1697 Director Nuclear Safety &

Regulatory Affairs Waterford 3 SES l Entergy Operations, Inc.

P.O. Box B Killona, Louisiana 70066 i

William H. Spell, Administrator Louisiana Radiation Protection Division l P.O. Box 82135 Baton Rouge, Louisiana 70884-2135 I l

Parish President St. Charles Parish L P.O. Box 302 Hahnville, Louisiana 70057 Mr. William A. Cross Bethesda Licensing Office 3 Metro Center -

Suite 610

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Bethesda, Maryland 20814 l Winston & Strawn 1400 L Street, N.W.

Washington, D.C. 20005-3502 i

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bec w/ Enclosure (s): , ,

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PDR 14E 141,4 LPDR NUDOCS ,

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SECY EC's: Rl,Ril,Rlli CA PA (0-2G4) i EDO (0-17G21) OlG (T-5D28)

DEDO (0-17G21) OE (0-7H5)

OE:EAFile (0 7H5) 01 (0-3E4)

OGC (0-15B18) OGC (015B18)

NRR (0-12G18) NRR/ADP (0-12G18) ,

NRR PROJECT MANAGER OC/DAF (T-9E10)

OC/LFDCB (T-9E10) AEOD (T-4D18)

RA Reading File GSanborn-EAFile RIV Files MIS Coordinator PAO RSLO DRP-Harrell E-Mall DISTRIBUTION:

OEMAIL JDyer (JED2)  !

TPGwynn (TPG) WBrown (WLB)

GSanborn (GIS) GMVasquez (GMV)

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CHackney (CAM) DKunihiro (DMK1)

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DOCUMENT NAME: G:\EA\ DRAFT \EA9.7099.DFT To receive copy of document, indicate in box: "C" = Copy without enclosures *E" = Copy wg enclosures "N" = No copy EO ry(/)( C:DRP/D , h D:DRP y RC f/Qy DRA -

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