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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217L0421999-10-21021 October 1999 Forwards Insp Rept 50-382/99-20 on 990815-0925 & Notice of Violation.Two Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20217N2111999-10-19019 October 1999 Forwards Insp Rept 50-382/99-14 on 990913-17 & 1004-08.No Violations Noted.Licensed Operator Requalification Program, Effective,Utilized Systems Approach to Training & Showed Continued Improvements Over Previous Insp Findings ML20217L0101999-10-18018 October 1999 Provides Update of Waterford 3 Effort for Review of Ufsar. Info Listed Includes Background Mgt Expectations,Review Status & Results,Clarifications Re Review & Conclusions ML20217L0141999-10-18018 October 1999 Submits Update to NRC Staff Re Circumstances & Plans for Submitting Certification Rept on Waterford 3 Plant Specific Simulator ML20217G7051999-10-14014 October 1999 Forwards Comments on Four of NRC RO Examination Questions for Exam Administered During Week of 991004 05000382/LER-1999-014, Forwards LER 99-014-00,providing Details of Reactor Shutdown Due to Loss of RCP Controlled bleed-off Flow.Attached Commitment Identification/Voluntary Enhancement Form Identifies All Commitments Contained in Submittal1999-10-12012 October 1999 Forwards LER 99-014-00,providing Details of Reactor Shutdown Due to Loss of RCP Controlled bleed-off Flow.Attached Commitment Identification/Voluntary Enhancement Form Identifies All Commitments Contained in Submittal ML20217D5151999-10-0707 October 1999 Forwards Application for Renewal of SRO License for C Fugate License SOP-43039-3,IAW 10CFR55.57.Without Encls ML20217C6251999-10-0505 October 1999 Informs That NRC Reviewed Util Ltr & Encl Exercise Scenario Package for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Based on Review,Nrc Determined That Exercise Appropriate to Meet Objectives ML20212J6921999-09-29029 September 1999 Forwards Insp Rept 50-382/99-18 on 990830-0902.One Noncited Violation Identified Re Failure to Follow Procedural Instructions to Ensure That Members on Fire Brigade Shift Were Qualified ML20216G2441999-09-27027 September 1999 Forwards Insp Rept 50-382/99-19 on 990830-0903.No Violations Noted 05000382/LER-1999-013, Forwards LER 99-013-00,providing Details of Exceeding TS Limits for RCS Cooldown Rates.All Commitments Contained in Submittal Are Identified on Encl Commitment Identification/ Voluntary Enhancement Form1999-09-23023 September 1999 Forwards LER 99-013-00,providing Details of Exceeding TS Limits for RCS Cooldown Rates.All Commitments Contained in Submittal Are Identified on Encl Commitment Identification/ Voluntary Enhancement Form IR 05000382/19993011999-09-21021 September 1999 Informs That NRC License Exam Previously Associated with NRC Insp Rept 50-382/99-301 Will Be Incorporated Into NRC Insp Rept 50-382/99-14 ML20212D8761999-09-16016 September 1999 Informs That on 990818,NRC Staff Completed Midcycle PPR of Waterford 3.During Assessment Period,Number of Personnel Errors Occurred,Which Demonstrated Lack of Attention to Detail by Plant Personnel.Historical Listing of Issues,Encl ML20212C2471999-09-16016 September 1999 Forwards Five Final Applications for RO Licenses for G Esquival,Jm Hearn,Md Lawson,Re Simpson & PI Wood.Written Exam & Operating Test to Be Administered,Is Requested. Encls Withheld ML20212C2391999-09-16016 September 1999 Requests Cancellation of SRO Licenses for Bn Coble,License SOP-43835,due to Job Assignment Location & CA Rodgers, License SOP-43537-1,due to Resignation from Company, Effective 990901 ML20212C5881999-09-14014 September 1999 Forwards Insp Rept 50-382/99-15 on 990719-23 with Continuing in Ofc Insp Until 0819.No Violations Noted ML20211Q4421999-09-0909 September 1999 Forwards Insp Rept 50-382/99-07 on 990601-11.Three Violations Being Treated as Noncited Violations ML20211P4121999-09-0707 September 1999 Requests NRC Staff Review & Approval of Integrated Nuclear Security Plan (Insp) & Integrated Security Training & Qualification Plan (Ist&Q), for Use by All Entergy Operations,Inc.Encl Withheld,Per 10CFR2.790(d) ML20211M8391999-09-0303 September 1999 Forwards Revised Epips,Including Rev 25 to EP-001-020,rev 24 to EP-001-030,rev 25 to EP-001-040,rev 30 to EP-002-100,rev 22 to EP-001-010,rev 27 to EP-002-010,rev 26 to EP-002-102 & Rev 16 to EP-002-190.Listed Proprietary Revs to Epips,Encl ML20211L3681999-09-0202 September 1999 Forwards Five Preliminary Applications for Reactor Operator Licenses for Individuals Listed,Iaw 10CFR55.31.Encls Withheld ML20211K9741999-09-0101 September 1999 Forwards Insp Rept 50-382/99-16 on 990704-0814.Two Severity Level IV Violations Identified & Being Treated as Noncited Violations,Consistent with App C of Enforcement Policy 05000382/LER-1999-011, Forwards LER 99-011-00,providing Details of Reactor Shutdown Due to Loss of Controlled bleed-off Flow.All Commitments Contained in Submittal Identified on Attached Commitment Identification/Voluntary Enhancement Form1999-08-31031 August 1999 Forwards LER 99-011-00,providing Details of Reactor Shutdown Due to Loss of Controlled bleed-off Flow.All Commitments Contained in Submittal Identified on Attached Commitment Identification/Voluntary Enhancement Form ML20211M3641999-08-30030 August 1999 Forwards Written Examination,Operating Tests & Supporting Ref Matl Identified in Attachment 2 of ES-210,in Response to NRC .Encl Withheld ML20211G5751999-08-27027 August 1999 Forwards RAI Re IPEEE Submittal.Please Provide RAI within 60 Days of Receipt of Ltr,Per Util Response to GL 88-20,suppl 4 ML20211E3281999-08-26026 August 1999 Forwards fitness-for-duty Performance Data for Period of 990101-0630,IAW 10CFR26.71(d).Ltr Does Not Contain Commitments 05000382/LER-1999-009, Forwards LER 99-009-00 Re Discovery of Condition of Noncompliance with App R Involving Inadequate Separation of Essential Cables Routed in Fire Area RAB-30 in Rab. Compensatory Measures Were Established Immediately1999-08-26026 August 1999 Forwards LER 99-009-00 Re Discovery of Condition of Noncompliance with App R Involving Inadequate Separation of Essential Cables Routed in Fire Area RAB-30 in Rab. Compensatory Measures Were Established Immediately 05000382/LER-1999-010, Forwards LER 99-010-00,providing Details of Inadequate Pumping Capacity in Dry Cooling Tower Area.All Commitments Contained in Submittal Are Identified on Attached Commitment Identification Voluntary Enhancement Form1999-08-26026 August 1999 Forwards LER 99-010-00,providing Details of Inadequate Pumping Capacity in Dry Cooling Tower Area.All Commitments Contained in Submittal Are Identified on Attached Commitment Identification Voluntary Enhancement Form ML20211F5421999-08-24024 August 1999 Forwards Proposed marked-up TS Page Xviii, Index Administrative Controls, Correcting Page Number Re TS Change Request NPF-38-220.Editorial Changes for TS Change NPF-38-221 Discussed ML20211F3561999-08-24024 August 1999 Forwards CTS Pages & TS Proposed marked-up Pages for Insertion Into TS Change Request NPF-38-207 Re Efas, Originally Submitted on 980702.Original NSHC Determination Continues to Be Applicable ML20211F4611999-08-24024 August 1999 Informs That NRC Reviewed Ltr & Encl Objectives for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Exercise Objectives Appropriate to Meet Emergency Plan Requirements ML20211G1731999-08-23023 August 1999 Informs That Info Submitted in ,B&W Rept 51-1234900-00,will Be Withheld from Public Disclosure,Per 10CFR2.790 ML20211C5101999-08-19019 August 1999 Forwards Certified Copies of Liability Insurance Policy Endorsements Issued in First Half of 1999 for Each Entergy Operations,Inc Nuclear Unit,Per 10CFR140.15 ML20210T9791999-08-18018 August 1999 Discusses Which Responded to Reconsideration of Violation Denial (EA 98-022) Enforcement Action Detailed in .Concludes That Violation Occurred as Stated ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210S0561999-08-12012 August 1999 Submits Voluntary Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for NRC Fys 2000 & 2001 for Waterford 3 ML20210Q6161999-08-12012 August 1999 Forwards Corrected Copy of Monthly Operating Rept for July 1999 for Waterford 3.Original Rept,Submitted with ,Contained Typos ML20217F2661999-08-12012 August 1999 Forwards Copy of 1999 Waterford 3 Biennial Exercise Package to Be Performed Using Waterford 3 CR Simulator ML20210R9231999-08-11011 August 1999 Forwards Insp Rept 50-382/99-10 on 990719-23.Violations Noted.Nrc Has Determined That One Severity Level IV Violation of NRC Requirements Occurred ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams 05000382/LER-1999-008, Forwards LER 99-008-00,re Failure to Perform Testing of ESF Filtration Units Per TS Srs.Commitments Made by Util Also Encl1999-07-29029 July 1999 Forwards LER 99-008-00,re Failure to Perform Testing of ESF Filtration Units Per TS Srs.Commitments Made by Util Also Encl ML20210H4291999-07-29029 July 1999 Forwards Response to NRC Rai,Associated with TS Change Request NPF-38-208,proposing to Replace Ref to Supplement 1 with Ref to Supplement 2 of Calculative Methods for CE Small Break LOCA Evaluation Model, in ACs Section of TSs ML20210F9451999-07-27027 July 1999 Forwards Proprietary & non-proprietary Version of Rev 29 to EPIP EP-002-100, Technical Support Ctr Activation,Operation & Deactivation. Proprietary Info Withheld,Per 10CFR2.790 ML20210D3171999-07-23023 July 1999 Submits Proposal for Final Resolution of Reracking Spent Fuel Pool at Plant,Per License Amend 144,issued by NRC in .No New Commitments Are Contained in Ltr 05000382/LER-1999-007, Forwards LER 99-007-00,providing Details of Operation Outside Tornado Missile Protection Licensing Basis for turbine-driven Emergency Feedwater Pump Exhaust Stack & Steam Supply Piping.All Commitments Identified on Attached1999-07-23023 July 1999 Forwards LER 99-007-00,providing Details of Operation Outside Tornado Missile Protection Licensing Basis for turbine-driven Emergency Feedwater Pump Exhaust Stack & Steam Supply Piping.All Commitments Identified on Attached ML20210D8701999-07-23023 July 1999 Forwards Safety Evaluation Re First 10-yr Interval Inservice Insp Plan Requests for Relief ISI-018 Through ISI-020 for Entergy Operations,Inc,Unit 3 ML20210B1521999-07-15015 July 1999 Forwards Insp Rept 50-382/99-13 on 990523-0703.Three Violations Being Treated as Noncited Violations ML20209G9771999-07-13013 July 1999 Forwards Objectives & Guidelines for Waterford 3 Emergency Preparedness Exercise Scheduled for 991013.List of Objectives cross-referenced Where Applicable to Relevant Sections of NUREG-0654 IR 05000382/19990081999-07-12012 July 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/99-08 Issued on 990503 ML20209E5231999-07-0909 July 1999 Informs That as Result of NRC Review of Util Responses to GL-92-01,rev 1 & Suppl 1,staff Revised Info in Reactor Vessel Integrity Database & Releasing Database as Rvid Version 2.This Closes Staff Efforts Re TAC MA0583 ML20209D4051999-07-0707 July 1999 Forwards Revised TS Pages to Replace Attachment C,Entirely in Original TS Change Request NPF-38-207,per 990519 Discussion with C Patel of Nrc.Changes to Action 20 Delete Word Requirement & Revise Word Modes to Mode 1999-09-09
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20217L0421999-10-21021 October 1999 Forwards Insp Rept 50-382/99-20 on 990815-0925 & Notice of Violation.Two Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20217N2111999-10-19019 October 1999 Forwards Insp Rept 50-382/99-14 on 990913-17 & 1004-08.No Violations Noted.Licensed Operator Requalification Program, Effective,Utilized Systems Approach to Training & Showed Continued Improvements Over Previous Insp Findings ML20217C6251999-10-0505 October 1999 Informs That NRC Reviewed Util Ltr & Encl Exercise Scenario Package for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Based on Review,Nrc Determined That Exercise Appropriate to Meet Objectives ML20212J6921999-09-29029 September 1999 Forwards Insp Rept 50-382/99-18 on 990830-0902.One Noncited Violation Identified Re Failure to Follow Procedural Instructions to Ensure That Members on Fire Brigade Shift Were Qualified ML20216G2441999-09-27027 September 1999 Forwards Insp Rept 50-382/99-19 on 990830-0903.No Violations Noted IR 05000382/19993011999-09-21021 September 1999 Informs That NRC License Exam Previously Associated with NRC Insp Rept 50-382/99-301 Will Be Incorporated Into NRC Insp Rept 50-382/99-14 ML20212D8761999-09-16016 September 1999 Informs That on 990818,NRC Staff Completed Midcycle PPR of Waterford 3.During Assessment Period,Number of Personnel Errors Occurred,Which Demonstrated Lack of Attention to Detail by Plant Personnel.Historical Listing of Issues,Encl ML20212C5881999-09-14014 September 1999 Forwards Insp Rept 50-382/99-15 on 990719-23 with Continuing in Ofc Insp Until 0819.No Violations Noted ML20211Q4421999-09-0909 September 1999 Forwards Insp Rept 50-382/99-07 on 990601-11.Three Violations Being Treated as Noncited Violations ML20211K9741999-09-0101 September 1999 Forwards Insp Rept 50-382/99-16 on 990704-0814.Two Severity Level IV Violations Identified & Being Treated as Noncited Violations,Consistent with App C of Enforcement Policy ML20211G5751999-08-27027 August 1999 Forwards RAI Re IPEEE Submittal.Please Provide RAI within 60 Days of Receipt of Ltr,Per Util Response to GL 88-20,suppl 4 ML20211F4611999-08-24024 August 1999 Informs That NRC Reviewed Ltr & Encl Objectives for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Exercise Objectives Appropriate to Meet Emergency Plan Requirements ML20211G1731999-08-23023 August 1999 Informs That Info Submitted in ,B&W Rept 51-1234900-00,will Be Withheld from Public Disclosure,Per 10CFR2.790 ML20210T9791999-08-18018 August 1999 Discusses Which Responded to Reconsideration of Violation Denial (EA 98-022) Enforcement Action Detailed in .Concludes That Violation Occurred as Stated ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210R9231999-08-11011 August 1999 Forwards Insp Rept 50-382/99-10 on 990719-23.Violations Noted.Nrc Has Determined That One Severity Level IV Violation of NRC Requirements Occurred ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20210D8701999-07-23023 July 1999 Forwards Safety Evaluation Re First 10-yr Interval Inservice Insp Plan Requests for Relief ISI-018 Through ISI-020 for Entergy Operations,Inc,Unit 3 ML20210B1521999-07-15015 July 1999 Forwards Insp Rept 50-382/99-13 on 990523-0703.Three Violations Being Treated as Noncited Violations IR 05000382/19990081999-07-12012 July 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/99-08 Issued on 990503 ML20209E5231999-07-0909 July 1999 Informs That as Result of NRC Review of Util Responses to GL-92-01,rev 1 & Suppl 1,staff Revised Info in Reactor Vessel Integrity Database & Releasing Database as Rvid Version 2.This Closes Staff Efforts Re TAC MA0583 ML20196E6931999-06-22022 June 1999 Forwards Corrected Ltr Re Changes to Rev 19 to Emergency Plan.Original Ltr Had Error in Subject Line ML20196E0831999-06-21021 June 1999 Forwards Insp Rept 50-382/99-12 on 990524-27.No Violations Noted.Purpose of Insp Was to Conduct Assessment of Emergency Preparedness Program ML20196D9941999-06-18018 June 1999 Forwards Insp Rept 50-382/99-11 on 990524-28.No Violations Noted ML20195J8091999-06-17017 June 1999 Forwards Safety Evaulation Re First 10-yr Interval Inservice Insp Relief Request for Plant,Unit 3 ML20196C8711999-06-15015 June 1999 Discusses Insp Rept 50-382/99-08 & Forwards Notice of Violation Re Unescorted Access Which Was Mistakenly Granted to Individual Whose Background Investigation Indicated That He Had Failed Prior Drug Screening with Another Employer ML20196F3721999-06-0909 June 1999 Corrected Ltr Forwarding Rev 19 to Emergency Plan ML20195G3711999-06-0909 June 1999 Ack Receipt of Ltr Dtd 981223,which Transmitted Waterford 3 Steam Electric Station Emergency Plan,Rev 24,under Provisions of 10CFR50,App E,Section V.No Violations of 10CFR50.54(q) Identified During Review ML20207E8541999-06-0303 June 1999 Forwards SE Accepting Licensee 990114 Submittal of one-time Request for Relief from ASME B&PV Code IST Requirements for Pressurizer Safety Valves at Plant,Unit 3 ML20207G3441999-06-0303 June 1999 Forwards Insp Rept 50-382/99-09 on 990411-0522 & Notice of Violation.One Violation Identified & Being Treated as Noncited Violation C ML20207D3771999-05-27027 May 1999 Ack Receipt of 990401 & 0504 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/99-01 on 990303 ML20207A5121999-05-24024 May 1999 Refers to Which Responded to NOV & Proposed Imposition of Civil Penalty Sent by .Violations A,B & E Withdrawn & Violations C & D Changed to Severity Level IV ML20206U7851999-05-18018 May 1999 Forwards Insp Rept 50-382/99-06 on 990405-09.Three Violations of NRC Requirements Occurred & Being Treated as non-cited Violations ML20206N6961999-05-11011 May 1999 Informs That NRC Office of Nuclear Reactor Regulation Reorganized Effective 990328.As Part of Reorganization, Division of Licensing Project Management Created ML20206S4411999-05-10010 May 1999 Forwards Insp Rept 50-382/99-05 on 990228-0410.Three Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20206H3841999-05-0707 May 1999 Informs That on 990407,NRC Administered Generic Fundamental Exam Section of Written Operator Licensing Exam.Licensee Facility Did Not Participate in Exam,However Copy of Master Exam,With Answer Key,Encl for Info.Without Encl ML20206K0951999-05-0606 May 1999 Discusses Insp Rept 50-382/99-08 Issued 990503 Without Cover Ltr Documenting EA Number & Subject Line Indicated NOV Which Was Incorrect.Corrected Cover Ltr Encl ML20206F4701999-05-0303 May 1999 Forwards Insp Rept 50-382/99-08 on 990405-07.One Apparent Violation Re Failure to Review & Consider Derogatory Access Authorization Background Info as Required by PSP Identified & Being Considered for Escalated Enforcement Action ML20206K1211999-05-0303 May 1999 Corrected Cover Ltr Forwarding Insp Rept 50-382/99-08 on 990405-07.One Violations Noted & Being Considered for Escalated EA ML20205N7251999-04-13013 April 1999 Forwards Summary of 990408 Meeting with EOI in Jackson, Mississippi Re EOI Annual Performance Assessment of Facilities & Other Issues of Mutual Interest.List of Meeting Attendees & Licensee Presentation Slides Encl ML20205M0561999-04-0909 April 1999 Forwards Insp Rept 50-382/99-04 on 990301-19.One Violation of NRC Requirements Occurred & Being Treated as Noncited Violation,Consistent with App C of Enforcement Policy ML20205J8781999-04-0505 April 1999 Forwards Insp Rept 50-382/99-02 on 990117-0227.No Violations Noted.Inspectors Determined That Six Violations Occurred & Being Treated as Noncited Violations Consistent with App C of Enforcement Policy ML20205J0901999-04-0202 April 1999 Informs That Info Submitted by & 970313 Affidavit Will Be Withheld from Public Disclosure,Per 10CFR2.790(b) (5) ML20205A4681999-03-26026 March 1999 Forwards Insp Rept 50-382/99-03 on 990308-12.Two Violations of Radiation Protection Requirements Occurred & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20205A6141999-03-25025 March 1999 Forwards SE Accepting Request to Use Mechanical Nozzle Seal Assemblies (Mnsas) as an Alternative Repair Method,Per 10CFR50.55a(a)(3)(i) for Reactor Coolant Sys Application at Plant,Unit 3 ML20205F3311999-03-19019 March 1999 Advises of Planned Insp Effort Resulting from Plant,Unit 3 PPR Review,Which Was Completed on 990211.Performance at Plant,Unit 3 Was Acceptable ML20204E4941999-03-17017 March 1999 Discusses TSs Bases Change Re 3/4.4.1,3/4.6.1.7,3/4.6.3, 3/4.7.12 & 3/4.8.4.Forwards Affected Bases Pp B 3/4 4-1, B 3/4 6-3,B 3/4 6-4,B 3/4 7-7 & B 3/4 8-3 ML20207F1251999-03-0303 March 1999 Forwards Insp Rept 50-382/99-01 on 990125-29 & 0208-12 & Notice of Violations ML20203H8501999-02-17017 February 1999 Forwards SE Accepting Licensee 970701 Submittal of Second Ten Year ISI Program & Associated Relief Request for Plant, Unit 3.Nine Relief Requests Had Been Authorized Previously & Proposed Alternatives Remain Authorized ML20203D7211999-02-11011 February 1999 Forwards Request for Addl Info Re Licensee 970317 & 990111 Responses to GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves. Response Should Be Provided within 60 Days 1999-09-09
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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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f a
]i Entergy Operations, Inc. -3-
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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
]
- Docket No. 50-382
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License No. NPF-38 Enclosure: Notice of Violation and i Proposed imposition of Civil Penalty
!
l cc w/ Enclosure:
Executive Vice President and i Chief Operating Officer
"
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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( 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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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:
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