ML20059E795
| ML20059E795 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 10/27/1993 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-93-0192, W3F1-93-192, NUDOCS 9311030352 | |
| Download: ML20059E795 (4) | |
Text
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-Yi Entergy Operations,Inc.
== ENTERGY eo t*
8 Kiloro, LA 70066 Tet 504 '39 0774 R. F. Burski Duector.
PAxkw Sate 4y Vht Wd 3 t
W3F1-93-0192-A4.05:
- PR October 27, 1993 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 93-25 Reply to Notice of Violation Gentlemen:
In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in the response to the violation _-identified in Appendix A of the.
subject Inspection Report.
If you have any questions concerning this response, please contact' T.S. Becker at (504) 739-6693.
Very truly yours, t
gg& ~ '
R.F. Burski~
Director Nuclear Safety RFB/TSB/ssf Attachment cc: '
J.L'. MilhoanL (NRC Region:IV), D.L. Wigginton_ (NRC-NRR),
R.B. McGehee,' N.S.- Reynolds, NRC Resident Inspectors Office -
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'9311030352-931027--..
U' PDR: ADOCK 05000382
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W3F1-93-0192 Page 1 of 3 ATTACHMENT 1 ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN APPENDIX A 0F INSPECTION REPORT 93-25 VIOLATION N0. 9325-01 Criterion V of Appendix B,10CFR Part 50, states, in part, that activities affecting quality shall be prescribed by documented procedures and shall be accomplished in accordance with these procedures.
Waterford 2 Procedure UNT-005-002, " Administrative Procedure Condition Identifications," Revision 10, state.s, in Section 4.1.1, that Waterford-3 employees are responsible for " reporting and identifying abnormal conditions upon observation and initiating a condition identification to obtain resolution.
Conditions adverse to quality shall also be further identified as a Nonconformance Condition Identification (NCI)."
Contrary to the above, the licensee failed to. identify and initiate Nonconformance Condition Identifications for the ASME Section III pressurizer safety valves exceeding the i 1 percent tolerance specified in the Technical Specifications in December 1986, April 1988, January 1991, and June 1992. The licensee also failed to identify and initiate Nonconformance Condition Identifications for the main steam safety valves when their as-found set pressures exceeded the 1 percent tolerance specified in the Technical Specifications in November 1986, April 1988, September 1989, and March 1991.
RESPONSE
(1)
Reason for the Violation Entergy Operations, Inc. admits this violation and believes that the root cause is personnel error in that the required procedure was not-followed. Administrative Procedure UNT-005-002, " Condition Identification," requires that a Condition' Identification (CI) be.
generated for any test'that fails because of_an equipment deficiency or a nonconforming anomalous condition.
Further, the procedure requires that a Nonconformance Condition Identification (NCI)..be generated if a deficiency exists which represents a condition adverse to quality. When the pressurizer safety and main steam. safety valves were discovered to have lift setpoints outside'of the Technical.
Specification required tolerance, a NCI should have been generated in accordance with the guidance of UNT-005-002.
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Attachment to W3F1-93-0192 4-Page 2 of.3 Deficiencies in two other procedures were a contributing cause of this event. Maintenance Procedures MM-007-004, " Pressurizer Safety Valve Test," and MM-007-015, "Trevitest of Main Steam Safety Valves,"
both provide guidance regarding actions to be taken if any acceptance criterion is exceeded, if any condition is identified that could prevent fulfillment of safety valve functional requirements, or if any valve parameter is found to be out of tolerance based on test r
results.
Eontrary to the upper-tier requirements of Site Directive W2.501, " Corrective Action," and UNT-005-002, neither maintenance procedure requires that these problems be documented on a Corrective Action Program document (Condition Report or NCI).
In both cases, the procedures direct that corrective actions and explanations be documented in the " remarks" section of the test performance record.
t The net effect of this procedure guidance was to allow corrective action to be taken for a condition adverse to quality without documenting the adverse condition in the Corrective Action Program.
(2)
Corrective Steos That Have Been Taken and the Results Achieved Condition Reports 93-52 and 93-53 were generated in order to formally document the pressurizer safety and main steam safety valve as-found test failures in the Corrective Action program.
Although the as-found test failures were not properly documented, Waterford 3, in concert with the industry, has been proactive in resolving identified concerns with main steam and pressurizer safety valve setpoints, especially in the area of setpoint drift. Waterford 3 will continue to pursue the resolution of and implement necessary corrective actions for identified industry concerns associated with main steam and pressurizer safety valve setpoints.
In addition, the failure data for the pressurizer safety valves was entered into NPRDS to enhance the industry data base regarding these
-l valves.
(3)
Corrective Steps Which Will Be Taken to Avoid Further Violations This violation was a' result of a failure to enter an adverse i
condition into the Corrective Action Program. As such, a review of the Corrective Action Program _will be performed and enhancements made as necessary.
MM-007-004 and MM-007-015 will be revised to reflect those enhancements.
In addition, other procedures which are used to
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perform surveillance type testing will be reviewed for possible inclusion of. the Corrective Action Program enhancements.
Attachment to W3F1-93-0192 Page 3 of 3 Failure data for the main steam safety valves will be entered into the NPRDS component database.
Finally, this event and any program changes made as a result of the Corrective Action Program review will be discussed with Waterford 3 personnel.
The discussion will stress the importance of documenting conditions adverse to quality in the Corrective Action Program so that root causes may be identified and appropriate corrective action taken.
(4)
Date When Full Compliance Will Be Achieved All corrective action for this event will be complete January 26, 1994.
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r NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104 (5-92)
EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH SPECIAL REPORT THIS INFORMATION COLLECTION REQUEST: 50.0 HRS.
FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION AND K2 CORDS MANAGEMENT BRANCH (See reverse f=or required number of digits / characters for each block)
(MNBB 7714), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555-0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104),
OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.
FACILITY NAME (1) Shearon Harris Nuclear Plant-Unit #1 DOCKET NUMBER (2)
PAGE (3) 05000/400 1 OF 3 TITLE (4) 30 Day Written Follow-up Report for the loss of ten (10) used Incore Detectors (Special Nuclear Material).
FVENT DATE (S)
LER NUMBER (6)
REPORT DATE (7)
OTHER FACILITIES INVOLVED (8)
MONTH l FACILITY NAME DOCKET NUMBER SEQUENTIAL REVISION DAY YEAR YEAR MONTH DAY YEAR 05000 NUMBER NUMBER NAM DOCKET """
9 28 93 N/A 10 27 93 0 000 3
OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR S: (Check one or more) (11)
MODE (9) x 20.402(b) 20.405(c) 50.73(a)(2)(iv) 73.71(b) 20.405(a)(1)(i) 50.36(c)(1) 50.73(a)(2)(v) 73.71(c) i pgp 100%
i LEVEL (10) 20.405(a)(1)(ii) 50.36(c)(2) 50.73(a)(2)(vii)
OTHER 20.405(a)(1)(iii) 50.73(a)(2)(1) 50.73(a)(2)(vill)(A)
(Specify in a
20.405(a)(1)(iv) 50.73(a)(2)(fi) 50.73(a)(2)(viii)(B) n e 20.405(a)(1)(v) 50.73(a)(2)(iii) 50.73(a)(2)(x)
LICENSEE CONTACT FOR THIS LER (t2)
NAME TELEPHONE NUMBER (Include Area Code)
Michael Verrilli (919) 362-2303 COMPLETE ONE LtNE FOR EACH COMPONE.NT FAILURE DESCRIBED IN THIS REPORT (13)
REPO E
REPO E
CAUSE SYSTEM COMPONENT MANUFA'TURER CAUSE SYSTEM COMPONENT MANUFACTURER i
SUPPLEMENTAL REPORT EXPECTED (14)
EXPECTED MONTH DAY YEAR 0N yes, complete EXPECTED SUBMISSION DATE).
x NO DATE 1r)
ABSTRACT (Limit to 1400 spacen, i.e., approu mately 15 single-spaced typewritten lines) (16)
On September 28, 1993, during efforts to consolidate radioactive material i
for a future burial shipment, Health Physics personnel identified that ten (10) used incore detectors were not accounted for in the desiCjnated radioactive waste storage areas.
These detectors utilize a fission chamber containing enriched Uranium 235, which classifies them as Special Nuclear Material (SNM). The combined SNM weight contained in the missing detectors is approximately 0.03 grams.
An extensive search was conducted over the next four days, including a trip to the contracted low-level waste processing facility, S.E.G.
in Oak Ridge Tennessee, but the detectors were i
not found. On October 4, 1993, a meeting was conducted to ensure that all possible efforts to locate the detectors had been exhausted. A conclusion was reached that a loss of non-fuel Special Nuclear Material (SNM) ' had occurred. The root cause of this event was a lack of accountability on the part of the SNM custodian designee. This included performing a paperwork, vice physical six-month inventory, poor maintenance of SNM records and not properly marking / segregating non-fuel SNM.
There was also a lack of knowledge / training among various work groups on what non-fuel SNM means and
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it's importance. Corrective actions included assignment of a new SNM custodian designee, development of labeling for SNM to distinguish it from other radioactive material, designation of separate locked storage areas for non-fuel SNM, development of access controls and clear posting for the non-fuel SNM storage areas, and revising the SNM inventory procedure.
Additional actions will include a revision to the SNM accountability procedure and training for applicable personnel.
The most probable disposition scenario is that this material was inadvertently mixed with other low-level radwaste and was shipped to S.E.G.
in Oak Ridge Tennessee in April 1993.
NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB N0. 3150 0104 i
(5-92)
EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS.
SPECIAL REPORT FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION AND RECORDS MANAGEMENT BRANCH (MNBB 7714), U.S. NUCLEAR REGULATORY COMMISSION, 1
WASHINGTON, DC 20555-0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104), -0FFICE 0F MANAGEMENT AND BUDGET, WASHINGTON, DC 20503. '
FACILITY NAME (1)
DOCKET NUMBER (2)
LER NUMBER (6)
PAGE (3)
Shearon Harris Nuclear Plant YEAR SE E AL R
N Unit #1 05000/400 2 OF 3
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N/A TEXT (if more space is required, use a001tional copies of MC form 366A) (11)
DESCRIPTION OF MATERIAL INVOLVED:
The Specia] Nuclear Material involved in this event is enriched Uranium 235
.i (and decay products), which is utilized in the incore detector's fission
- chamber, The combined SNM weight of the ten missing detectors is approximately 0.03 grams.
DESCRIPTION OF CIRCUMSTANCES UNDER WHICH LOSS OCCURRED:
On September 28, 1993, during efforts to consolidate radioactive material 4
for a future burial shipment, Health Physics personnel identified that ten (10) used incore detectors were not accounted for in the designated radioactive waste storage areas.
These detectors-utilize a fission chamber containing enriched Uranium 235, which classifies them as Special Nuclear Material (SNM). The combined SNM weight contained in the missing detectors is approximately 0.03 grams.
An extensive search was conducted over the next four days, including a trip to the contracted low-level waste processing facility, S.E.G.
in Oak Ridge Tennessee, but the detectors ware not found. On October 4, 1993, a meeting was conducted to ensure that tall possible efforts to locate the detectors had been exhausted. A conclusion was reached that a loss of non-fuel Special Nuclear Material (SNM) had occurred. The root cause of this event was a lack of accountability on the part of the SNM custodian designee. This included performing a paperwork vice physical six-month inventory, poor maintenance of SNM records and not properly marking / segregating non-fuel SNM.
There was also a lack of knowledge / training among various work groups on what non-fuel SNM means and it's importance. Corrective actions included assignment of a new SNM custodian designee, development of labeling / tagging for SNM to distinguish it from other radioactive material, designation of separate locked storage areas for non-fuel SNM, development of access controls and clear posting for the non-fuel SNM storage areas, and revising the SNM inventory procedure. Additional actions will include a revision to the SNM accountability procedure and training for applicable personnel.
j DISPOSITION OF MATERIAL:
Based on a review of the above listed circumstances and sequence of events, i
the most probable disposition of the ten incore detectors is that it was inadvertently mixed with other low-level radwaste material while in storage in WPB room 144A, then shipped to SEG in April of 1993 for processing prior j
to burial.
RADIATION EXPOSURES TO INDIVIDUALS IN UNRESTRICTED AREAS:
Based on the fact that the incore detectors had low radiation levels and I
that they were handled as low-level radwaste, _no exposures to personnel in unrestricted areas occurred as a result of this event.
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1 NRC f0RM 366A (5 92))
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$RCFORM366A U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104 i
(5-92)
EXPIRES 5/31/95
~,
ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS.
FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO SPECIAL REPORT THE INFORMATION AND RECORDS MANAGEMENT BRANCH (MNBB 7714), U.S. NUCLEAR REGULATORY COMMISSION,
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WASHINGTON, DC 20555-0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150 0104),
OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.
FACILITY NAME (1)
DOCKET NUMBER (?)
LER NUMBER (6)
PAGE (3)
SEQUENTIAL REVISION Shearon-Harris Nuclear Plant YEAR Unit #1 05000/400 3 OF 3-N/A TEXT (if mcre space is required. use additional copies at W. Form 3b6A) (17)
ACTIONS TAKEN (or will be taken) TO RECOVER THE MATEPIAL:
An extensive search was conducted in all plant areas that the used incore detectors could reasonably have been placed.. A trip was also made to SEG's facility in Oak Ridge Tennessee to search the remaining radwaste material received from HNP that had not been incinerated.
Based on the conclusion that the material was processed by SEG, no further actions will be taken to locate the detectors.
PROCEDURES OR MEASURES WHICH HAVE BEEN (or will be) ADOPTED TO PREVENT RECURRENCE:
1.
A new Special Nuclear Material Custodian Designee was assigned.
2.
Labeling / tagging for non-fuel SNM has been created to ensure that it will be distinguished from other radioactive materials.
3.
Separate locked storage areas for non-fuel SNM have been designated.
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4.
Access controls and clear postings for the non-fuel SNM s'torage areas have been developed.
5.
FMP-108 (governing procedure for conducting SNM inventory) has been revised to specifically define SNM inventory requirements.
6.
Revise FMP-109 (SNM Accountability Plan / Procedure) to clearly delineate HP/Maint/ Stores /Deconners responsibilities regarding SNM.
5 This shall include the requirement for a " pre-job" briefing prior to i
SNM transfer activities and specific guidance on the completion of the transfer form.
7.
The review and approval process for SNM procedures (FMP-108 & FMP-109) has been changed to include all affected organizations.
8.
Provide training on the above listed actions for applicable personnel.
9.
Perform a follow-up review to assess the effectiveness of above corrective actions.
This condition is being reported per 10CFR20.2201(a) (ii) and 10CFR70.52 (b) to satisfy the requirement for a written follow-up report within 30 days.
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r NRC FORM 366A (5 92)
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