ML20062M067
| ML20062M067 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/28/1993 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-93-0373, W3F1-93-373, NUDOCS 9401050602 | |
| Download: ML20062M067 (5) | |
Text
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%W.c 3 W3F1-93-0373 A4.05 PR I
December 28, 1993 U.S. Nuclear Regulatory Commission ATIN:
Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report 93-32 Reply to Notice of Violation Gentlemen:
In accordance with 10 CFR 2.201, Entergy Operations, Inc. hereby submits in l the response to the violation identified in the subject Inspection Report.
If you have any questions concerning this response, please contact B.R. Loetzerich at (504) 739-6636.
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Very truly yours, b
gp.
'urski Director o
Nuclear Safety RFB/BRL/ssf h[
Attachment cc:
J.L. Milhoan (NRC Region IV), D.L. Wigginton (NRC-NRR),
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R.B. McGehee, N.S. Reynolds, NRC Resident Inspectors -Office 9401050602 931228 F
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. Attachment to W3F1-93-0373 Page 1 of 4-ATTACHMENT 1
.l ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN INSPECTION REPORT 93-32 VIOLATION NO. 9332-01 Technical Specification 6.8.1 requires, in part, that written procedures be established, implemented, and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2. February 1978.
Section 1 of' Appendix A of Regulatory Guide 1.33 requires safety-related-activities to be covered by written procedures, which includes maintenance of the ultimate heat sink.
System Operation Procedure OP-003-004,. Revision 6, " Condensate Makeup",
requires that the recirculation header isolation valve, CMU-1131, be closed after transferring water from the demineralized water storage tank to the
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condensate storage tank.
Contrary to the above, on August 17, 1993, Valve CMU-ll31 was opened' and left.in the open position until October 19, 1993. As a result of this misalignment, the automatic makeup system for the safety-related wet cooling tower basins did not function as designed, allowing the level of-the basins to decrease to a point below the Technical Specification j
required minimum level.
This is a Severity Level IV violation.
(Supplement I) (382/9332-01) i
RESPONSE
(1)
Reason for the Violation Entergy Operations Inc. admits this violation and believes that the-root cause is failure to follow procedure in that isolation valve CMU-ll31 was allowed to remain deviated open instead of. closed.. Step 8.11.8.3 of procedure OP-003-004, " Condensate Makeup", requires / hat t
CMU-ll31 be shut after the Condensate. Storage Tank-(CST) has'been filled to the desired level and the Condensate-Transfer Pump (CTP).
l has been secured from operation.
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' Attachment to m
W3F1-93-0373 Pa'ge.2 of 4 On August 17, 1993, Operations initiated a Locked Valve / Breaker Deviation Sheet per procedure OP-100-009, " Control of Valves and' Breakers", to maintain CTP to CST recirculation isolation' valve CMU-1131 open instead of locked closed. With the valve open, the' CTP can pump water from the Demineralized Water Storage Tank (DWST) to the CST.
This operation is accomplished p'er_ OP-003-004 and is the normal method for filling the CST.
CMU-ll31 was deviated open from August 17 to October 19, 1993, because the high temperatures associated with that period necessitated that the CST be filled frequently.
The. CST supplies.
makeup water to numerous secondary systems and must be filled every other day for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> fill duration to meet the dependent system requirements during periods of high temperature. The practice of leaving CMU-ll31 deviated open each time the CST was filled-t encouraged the development of a mindset within.0perations that the deviation was acceptable because of frequent makeup requirements.
On the morning of October 19, 1993, Operations completed a water transfer evolution from the DWST to the CST per OP-003-004 with one exception. After the CST reached the desired level (95% full) and the CTP was secured from operation, Operations-did not close CMU-1131 as required by that procedure.
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Auxiliary Component Cooling Water (ACCW) pumps "A" and "B" were then started to remove heat from the Component Cooling Water (CCW) system.
Each ACCW pump takes suction from its respective Wet Cooling TowerL i
(WCT) water basin and discharges to a heat exchanger where the CCW is cooled. The ACCW returns to the WCT water. basin by dischargin'g spray :
below the WCT fans where heat is dissipated'to the atmosphere by.
evaporation.
M A few hours later, ground isolation on a control room annunciator 1
cabinet resulted in constant audible and visible alarms. These alarms were the expected result of annunciator ground troubleshooting y
activities. However, the constant alarms on the; control room.
annunciator panel and the plant monitoring computer may have masked j
the need to perform. additional.WCT water basin level checks i
In addition, a causal factor existed in thatithe WCT basin Hi/Lo alarms annunciate when their respective basin is 97.5% full (Lo) or 99% full (Hi). The individual alarm does not indicate whether..the l
high or low. limit has been met.
Furthermore, the WCT basin Hi/Lo 1
a
' Attachment to-31 W3F1-93-0373 Page 3 of 4.
alarms annunciate frequently as a result of high levels due' to makeup, rain or water temperature increase. _This may have contributed to' desensitizing the operators to this annunciator.
That evening, an oncoming shift discovered that both WCT basins were
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less than 97% full. At that time, Operations declare ~d'both trains of Ultimate Heat Sink (VHS) inoperable and entered action'b of Technical Specification 3.7.4.
In addition, those systems affected by UHS were declared inoperable and their associated action statementsLwere
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entered. Technical Specification 3.0.3 was entered because the condition was not specifically addressed by all of the associated action requirements.
Entergy Operations Inc. believes that as a result of having CMU-1131 open, a level of approximately 60% in the DWST, and a makeup requirement for the WCT basin, that a nitrogen gas bubble became i
entrained in the DWST makeup line to the WCT water basin. This gas bubble restricted or. prevented gravity.. feed makeup from entering the WCT water basin until CMU-1131 was closed. The basis for this scenario is documented in Licensee Event Report number 93-006, which was submitted to the NRC via Entergy Operations letter number W3F1-93-0199, dated November 18, 1993.
Condition Report CR-93-190 was initiated on October 19, 1993, and'a Root Cause Investigation, RCI 93-009, was conducted for this event.
During the Root Cause Investigation, it was discovered that one Operations' shift had a potential indicator of problems with-makeup to the WCT basins, but did not formally identi.fy.the problem.
According to the RCI, the problem was incorrectly ~ associated.with inadequate pressure to gravity feed the WCT water basins. :Thus, Operations missed an opportunity to identify'this problem during a-precursor event.
1 (2)
Corrective Steps That Have Been Taken and the Results Achieved i
Immediate corrective action involved closing CMU-1131 upon-identification of the low level in the WCT water basins; As a result, the WCT water level in basin A' was rest red to. greater than p
97% full and the associated train of UHS.and those systems affected by that train were. declared operable. The~ associated Technical Specification action statements (including Technical. Specification-l 3.0.3) were exited upon declaration of the 'A' train operability.
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Shortly after, the 'B' train was. declared operable as the wet cooling tower 'B' water basin level was restored, and associated action statements were exited.
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Attachment to
.D**'
~W3F1-93-0373
'Page 4 of 4
'- (3)
Corrective Steos Which Will Be Taken to Avoid Further Violations-In addition to those corrective measures taken during the_ event, additional corrective actions will be taken to prevent _ recurrence:
1.
Shift Supervisors will brief their shifts on this event to address the specific aspects of procedural compliance, procedure use and problem identification / questioning attitude.
s 2.
Operations' Shift Logs will be revised to indicate that, at a minimum, the DWST level should be maintained higher than the piping loop in the turbine building'.
3.
Operations' will investigate alternate methods of system valve
- lineups, 4.
Operations will develop a Case Study on this event-that stresses procedural compliance expectations.
5.
Plant configuration changes will be implemented _that provides WCT water basin low level alarms as an input to the PMC.
Additionally, the WCT Basin Hi alarms will be removed from the control room annunciator panel.
(4)
Date When Full Compliance Will Be Achieved Corrective actions 1, 2 and 3 listed in.Section 3 above.will be completed by December 31, 1993.. Corrective action.4 listed above will be completed by January 31, 1994.
The last corrective action listed above has already been initiated as a design _ change structured to reduce annunciators in the control. room, and will be completed I
prior to commencing Cycle 7 operation.
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