IR 05000382/1997027

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/97-27

ML20199K825
Person / Time
Site:	Waterford
Issue date:	02/04/1998
From:	Harrell P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dugger C ENTERGY OPERATIONS, INC.
References
50-382-97-27, NUDOCS 9802090028
Download: ML20199K825 (5)

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g.- NUCLEAR REGULATORY COMMISSION g REcloN IV 611 RYAN PLAZA DRIVE, SulTE 400

%'tg AR LINGTON, T E XAS 76011-8064 FEB 4 1998 Charles M. Dugger, Vice President Operations -Waterford 3 Entergy Operations, Inc.

P.O. Box B Killona, Louisiana 70066 SUBJECT: NRC INSPECTION REPORT 50-382/97-27

Dear Mr. Dugger:

Thank you for your letter of February 2,1998, in response to our letter and Notice of Violation dated January 2,1998. 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 maintained.

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{ P arrell, lef r et Branch D Divi ton of Reactor Projects Docket No.: 50-382 License N;.: NPF-38 cc:

Executive Vice President and Chief Operating Officer Entergy Operations, Inc.

P.O. Box 31995 Jacxson, Mississiopi 39286-1995 Vice President, Operations Support /

Entergy Operations, Inc.

P.O. Box 31995 g

Jackson, Mississippi 3926S-1995

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9002090028 990204 PDR ADOCK 05000302 G FDR 1 --

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' Entergy Operations, Inc. - 2-Wiss, Carter, Child & Caraway P.O. Box 651 Jackson, Mississippi 3g205 General Manager, Plant Operations Waterford 3 SES Entergy Operations, Inc.

P.O. Box B Killona, Louisiana 70066 Manager- Licensing Manager Waterford 3 SES Entergy Operations, Inc.

P.O. Box B

- Xillona, Loulslano 7006L Chairman Louisiana Public Service Commission One American Place, Suite 1630

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Baton Rouge, Louisiana 70825-1697 Director, Nuclear Safety &

Regulatory Affairs-Waterford 3 SES Entergy Operations, Inc.

P.O. Box B -

Killona, Louisiana -70066'-

- William H. Spell, Administrator Loulslana Radiation Protection Division P.O. Eox 82135 Baton Rouge, Louisiana 70884-2135 Parish President :

St. Charles Parish

~ P.O. Box 302 Hahnville, Louisiana 70057 Mr. William A. Cross -

Bethesda Liesasing Office

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Entergy Operations, Inc. 3-Winston & Strawn 1400 L Street, N.W.

Washington, D.C. 20005 3502 l

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Entergy Operations, Inc. -4- FEB ~ 41998 bec distrib. by RIV.

Regional Administrator Resident inspector DRP Director DRS-PSB Branch Chief (DRP/D) MIS System '

Project Engineer (DRP/D) RIV File Branch Chief (DRP/TSS)

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Regional Administrator Res! dent Inspector DRP Director DRS PSB Branch Chief (DRP/D) MIS System l Project Engineer (DRP/D) RIV File Branch Chief (DRP/TSS)

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W3F198-0015 A4.05 PR i

February 2,1998 U.S. Nuclear Regulatory Commission

ATTN: Document Control Desk

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Washington, D.C. 20555 Subject: _ Waterford 3 SES Docket No- 50-382 License No. NPF-39 NRC Inspection Report 97-27 Reply to Notice of Violation -

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- Gentlemen:

In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in Attachment 1 the response to the violation identified in Enclosure 1 of the subject inspection Report.

If you have any questions concoming this response, please contact me at (504) 739-6242 or Tim Gaudet at (504) 739-6666.

Very truly yours, O

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E.C./Ewing Director, .

Nuclear Safety & Regulatory Affairs

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Ecc: E.W. Menschoff (NRC Region IV), C.P. Patel (NRC-NRR),

J. Smith, N.S. Reynolds, NRC Resident inspectors Office

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/ W3F1-98-0015 Pego 1 of 3 ATTACHMENT 1 ENTEDGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN!

ENCLOSURE 1 OF INSPECTION REPORT 97-27 VIOLATION NO. 9727-01 Criterion XVI of Appendix B to 10 CFR Part 50 states, in part, measures shall be established to assure that conditions adverse to quality, such as nonconformances, are promptly identified and corrected.

Procedure W2.501, " Corrective Action," Step 4.9, stated, in part, that a nonconforming condition is an adverse condition atbetir.g a safety-related system caused by a deficiency in a characteristic that renders the quality of the item indeterminate. Step 4.9.2 stated that discovery of a condition of a system or component required to be operable by Technical Specifications, which calls into question the current or past operability, is an example of a nonconforming condition.

Step 6.1.1 stated, in part, that an individual who identifies an adverse condition shall complete Sections 1,2, and 3 of Attachment I (the condition report form) in accordance with the instructions given in the attachment.

Contrary to the above, on February 24,1997, an individual, who identified an adverse condition affecting a safety-related system, failed to promptly identify a nonconformance that called into question the operability of a system required to be operable by Technical Specifications. Specifically, the individual identified an adverse condition related to the refueling water storage pool level instrumentation and did not promptly complete a condition report form.

This is a Severity Level IV violation (50-382/9727-01) (Supplement 1).

RESPONSE (1) Reason for the Violation The apparent cause of this violation is inappropriate action due to a lack of information.

On February 23,1997, an Instrumentation & Controls (l&C) Technician observed an indicated change in RWSP level when the CVAS fan started.

The indicated level increased approximately two percent. The l&C Technician notified control room personnel of the observation. At that time, personnel had a reasonable expectation that the RWSP level instruments were operable. In addition, there was no reason to believe the observed change represented a condition involving a loss of quality or functional capability or the failure to meet requirements or commitments.

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Att chm:nt to

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. Pcg3 2 of 3 Due to a questioning attitude, how. personnelinitially aware of the observation informed other personnel and attempted to obtain additional

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information. For example, Operations personnel promptly informed a Design Engineer of the observation and expected to obtain information substantiating their initial expectation. However, the Design Engineer responded that he would be surprised if the effect had been accounted for in the RAS setpoint.

At that time, a potential adverse condition existed and personnel should have generated a condition report or an engineering request to facilitate a prompt operability determination Subsequent to the at,ove information request, the l&C Technic i an informed his suporintentent who, in turn, involved others. As more people became involved and more information became available, a decision was made to initiate a condition report. Or. March 8,1997, condition report CR-97-0562 wen gonarated.

In hindsight, personnel acted inappropriately in that a nonconforming

condition existed prior to March 8,1997, and a condition report was not l generated. As a practical matter, decision making requires good information l and takes time. However, the procass used to gather that information should i

call for prompt and continuous attention to deficiencies and potential system inoperabiliti9s. Given the lack of li.ormation available on February 23,1997, personnel did not believe an adverse condition or potential nonconformance existed. As additional infctmation became available, however, it became clear an adverse condition existed and a condition report should have been previously generated.

(2) Corrective Steps That Have Been Taken and the Results Achieved 1. Condition Report 97-0562 was generated.

2. On December 10,1997, Revision 7 to Site Procedure W2.501 was implemented. This revision includes condition report threshold

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3. Management's expectations regarding the thresholds for generating condition reports and identification of problems have been communicated and reinforced to operations personnel. This activity was performed at department and SSICRS meetings and was included in written communications. Operations personnel continue to aggessively identify and document plant problems in condition reports.

4. In response to IR 97-16 dated November 24,1997, Waterford 3 identif ed the need to emphasize the importance of communicating new information that involves a potentially degraded or nonconforming condition. In consequence, cn December 17,1997, the Director, Design Engineering, issued a memorandum to all Design Engineering d

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Attachment to f .' W3F1-08-0015

Page 3 of 3 personnel providing expectations on when to write a condition report and when to involve others in the decision making process.

(3) Corrective Steos Which Will Be Taken to Avoid Further Violations

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The next cycle of Engineering Support Personnel (Ebi-) Continuing Training will include examples of when to write a condition report and when to involve others in the decision making process.

(4) Date Wher . qi Compliance Will He Achieved

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Full compliance has been achieved. The next cycle of ESP Continuing Training is scheduled for March,1998.

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