ML20058H467
| ML20058H467 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/07/1993 |
| From: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Barkhurst R ENTERGY OPERATIONS, INC. |
| Shared Package | |
| ML20058H474 | List: |
| References | |
| EA-93-239, NUDOCS 9312130087 | |
| Download: ML20058H467 (5) | |
See also: IR 05000382/1993033
Text
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NUCLEAR REGULATORY COMMISSION
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DEC - 71993
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Docket: 50-382
License: NPF-38
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EA 93-239
Entergy Operations, Inc.
ATTN:
Ross P. Barkhurst, Vice President
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Operations, Waterford
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P.O. Box B
Killona, Louisiana 70066
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY -
$25,000 (NRC INSPECTION REPORT NO. 50-382/93-33)
This is in reference to the inspection conducted September 14 to October 7,
1993, at the Waterford Steam Electric Station, Unit-3 (Waterford-3).
This
inspection was conducted to review the circumstances surrounding the failure
of a key valve in Train A of the containment spray system to open on demand on
September 13, 1993, and to evaluate Entergy Operations, Inc.'s (Entergy
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Operations) actions in response to that occurrence. A report documenting the
results of this inspection was issued on October 26, 1993. On November 3,
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1993, you and other Entergy Operations representatives attended an enforcement
conference in the NRC's Arlington, Texas office to discuss NRC's preliminary
conclusion that potentially significant violations of NRC requirements and
plant Technical Specifications (TS) had occurred.
This conference was open to
public observation in accordance with the terms of a pilot program begun by
the NRC in July 1992.
Based on the NRC's review of information developed during the inspection and
the information that Entergy Operations provided during the enforcement
conference, the NRC has concluded that Valve CS-125A was effectively
inoperable from February 1 to September 30, 1993, because the valve would not
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have opened on an actuation signal under all accident scenarios. The
condition of this valve rendered Train A of the containment spray system
inoperable for the same period of time.
In addition, the NRC has concluded
that despite clear indications of potentially significant problems with this
valve, Entergy Operations' personnel and corrective action programs were not
effective in identifying and correcting this condition in a prompt maner, and
were not effective in February 1993 in identifying the cause of problems
associated with CS-125A and taking actions to prevent a recurrence of those
problems.
Specifically, Entergy Operations informed the NRC during the enforcement
conference that valve CS-125A had apparently failed to open on February 1,
1993, under conditions that were virtually identical to those experienced on
September 13, 1993,
i.e., the valve failed to open due to a high differential
pressure that occurred when the Train A containment spray pump was operated.
In response to the February 1 failure, mechanics apparently struck the valve
9312130087 931207
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Entergy Operations, Inc.
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body with a hammer and retested the valve with satisfactory results. Although
a Condition Identification (Cl) form was prepared, it was closed based on a
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conclusion that the valve stem required lubrication.
The valve was never
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declared inoperable nor was the unexpectedly high differential pressure across
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the valve recognized at that time.
On September 13, 1993, valve CS-125A again failed to open on demand following
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the operation of the Train A containment spray pump. Although the valve was
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initially declared inoperable, retested satisfactorily and a CI form
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completed, the NRC nonetheless questions Entergy Operations' judgement in
declaring the valve operable on that date without a complete understanding of
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the conditions under which the valve failed to operate. As indicated in the
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Licensee Event Report submitted by Entergy Operations on October 15, 1993, the
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individuals who made that decision erroneously believed that valve CS-125A
would always receive an open signal prior to the pump starting.
Based on a
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more complete analysis, Entergy Operations determined that under certain
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accident conditions, pump start and receipt of the valve open signal could
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occur simultaneously, potentially requiring the valve to open against high
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differential pressure.
Given that conclusion, Entergy Operations declared the
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valve inoperable on September 25, 1993, sought NRC relief from the TS
requirements, and on September 30, 1993, was granted an emergency TS amendment
that allowed the valve to remain open during plant operations.
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The violations in the enclosed Notice of Violation and Proposed Imposition of
Civil Penalty include:
1) a failure to assure compliance with TS 3.6.2.1
which requires that two independent containment spray systems be operable,
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with each capable of taking suction from the Refueling Water Storage Pool on a
containment spray actuation signal; and 2) a failure to comply with 10 CFR Part 50, AppencHx B, Criterion XVI, which requires, in part, that failures and
other conditions cdverse to quality be promptly identified and corrected, and
that the cause of s!qnificant conditions adverse to quality be determined and
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corrective action taken to preclude a recurrence.
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Entergy Operations identified the underlying cause of the failure of valve
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CS-125A as a system design flaw that caused air to be entrained in the piping
upstream of the valve.
Entergy Operations' analysis of the safety
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significance of this event indicates that Train B of the containment spray
system would likely have been available at all times, and that even without
containment spray altogether, it is unlikely that a Loss of Coolant Accident
would have caused a failure of the containment structure.
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While the NRC agrees that the safety significance is mitigated by the
redundancy in the containment spray system and the design margins for various
systems and structures associated with maintaining containment integrity, the
failure of licensee personnel to be sensitive to problems that threatened the
operability of a safety system, and the consequences of that failure,
i.e.,
the inoperability of the containment spray Train A, are a matter of
significant regulatory concern.
Based on the regulatory and safety
significance that the NRC attaches to these violations, they have been
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Entergy Operations, Inc.
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classified in the a
'egate as a Severity 1.evel III problem in accordance with
the " General Str
, of Policy and Proceuure for NRC Enforcement Actions,"
(Enforcement Po.
10 CFR Part 2, Appendix C, Supplement I, 0.1 and C.2.(a).
NRC recognizes that Entergy Operations has initiated broad corrective action
to resolve the hardware-related problems indicated by this event and to
resolve apparent weaknesses in its corrective action programs. Among the
latter corrective actions are: 1) plans to conduct training, some of which has
already been completed, to emphasize corrective action program goals, define
individual responsibilities, discuss management expectations, and clarify
entry requirements for the carrective action program; and 2) the formation of
a condition review board, which will review all condition reports (CRs) and
CIs.
To emphasize the importance of assuring the effectiveness and proper
functioning of Entergy Operations' programs for identifying, documenting and
resolving malfunctions in safety-related systems and components, I have been
authorized after consultation with the Director, Office of Enforcement, and
the Deputy Executive Director for Nuclear Reactor Regulation, Regional
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Operations and Research, to issue the enclosed Notice of Violation and
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Proposed Imposition of Civil Penalty (Notice) in the amount of $25,000 for the
Severity Level III problem described above.
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The base value of a civil penalty for a Severity Level III problem is $50,000.
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The civil penalty adjustment factors in the Enforcement Policy were considered
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and resulted in a net decrease of $25,000. This determination was based on
the following considerations: 1) The failure of valve CS-125A was self-
disclosing, but Entergy Operations performed a thorough evaluation which
resulted in the idcntification of underlying violations (minus 25%); 2)
Enteroy Operations' corrective actions following the identification of the
violatiens were prompt and comprehensive (minus 50%); and 3) Entergy
Operations had earlier opportunities to have identified the problems with
valve CS-125A and prevented the TS violation from occurring (plus 75%).
The
remaining civil penalty adjustment factors were considered but no further
adjustments were considered appropriate.
In presenting its perspective on the enforcement. implications of these
violations at the enforcement conference, Entergy Operations indicated that
enforcemerit discretion may be appropriate based on the violations involving a
past design problem.
The applicable section of the Enforcement Policy,
Section VII.B.4, applies only when such conditions are discovered by a
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licensee as the result of a voluntary, formal initiative, .such as a Safety
System Functional Inspection.
In this case, the discovery of the underlying
design problems was prompted by the September 13, 1993 failure of valve
CS-125A to function.
Thus, the criteria in Section VII.B.4 were not met.
Entergy Operations is required to respond to this letter and should follow the
instructions specified in the enclosed Notice when preparing its response.
In
its response, Entergy Operations should docunant the specific actions taken
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Entergy Operations, Inc.
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and any additional actions it plans to prevent recurrence. After reviewing
Entergy Operations' response to this Notice, including its proposed corrective
actions and the results of future inspections, the NRC will determine whether
further NRC enforcement action is necessary to ensure compliance with NRC
regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of
this letter and its enclosure will be placed in the NRC Public Document Room.
The responses directed by this letter and the enclosed Notice are not subject
to the clearance procedures of the Office of Management and Budget as required
by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
Sincerely,
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- Regional Adm.n s ator
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Enclosure:
Notice of Violation and Proposed Imposition
of Civil Penalty
cc w/ Enclosure:
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
Wise, Carter, Child & Caraway
ATTN: Robert B. McGehee, Esq.
P.O. Box 651
Jackson, Mississippi
39205
Entergy Operanons, Inc.
ATTN:
D. F. Packer, General
Manager Plant Operations
P.O. Box B
Killona, Louisiana 70066
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Entergy Operations, Inc.
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Entergy Operations, Inc.
ATTN:
L. W. Laughlin
Licensing Manager
P.O. Box B
Killona, Louisiana 70066
Chairman
Louisiana Public Service Commission
One American Place, Suite 1630
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Baton Rouge, Louisiana 70825-1697
Entergy Operations, Inc.
ATTN:
R. F. Burski, Director
Nuclear Safety
P.O. Box B
Killona, Louisiana 70066
Hall Bohlinger, Administrator
Radiation Protection Division
P.O. Box 82135
Baton 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
Suite 610
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Bethesda, Maryland 20814
Winston & Strawn
ATTN: Nicholas S. Reynolds, Esq.
1400 L Street, N.W.
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Washington, D.C.
20005-3502
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