ML20079B827

Responds to Violation Noted in Insp Rept 50-382/94-25. Corrective Actions:C/A Document Generated,Edg B Declared Inoperable & TS Action 3.8.1.1.b Entered

ML20079B827
Person / Time
Site:	Waterford
Issue date:	01/05/1995
From:	Burski R ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
W3F1-94-0232, W3F1-94-232, NUDOCS 9501090102
Download: ML20079B827 (6)

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= ENTERGY EE'*d"e ""'" """'

Kdoru. LA 70066

g Tel 504 739 6774 R. F. Burski Directtw, terAv SMey Waterforg 3 W3F1-94-0232 A4.05 '

PR January 5, 1995 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 94-25  !

Reply to Notice of Violation >

Gentlemen:

In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in ,

Attachment 1 the response to the violation identified in Appendix A of the subject Inspection Report.

If you have any questions concerning this response, please contact C.J. Thomas at (504) 739-6531.

Very truly yours, ,

ud- j1 R.F. Burski Director Nuclear Safety i

RFB/CJT/tjs ,E ,

Attachment cc:

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L.J. Callan (NRC Region IV), C.P. Patel (NRC-NRR

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R.B. McGehee, N.S. Reynolds, NRC Resident Inspectors Office 9501090102 950105 PDR ADOCK 05000392 d

Q-, PDR

Attachment to I

..- W3F1-94-0232 Page 1 of 5 l ATTACHMENT 1 ENTERGY-0PERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN i APPENDIX A 0F INSPECTION REPORT 94-25  ;

VIOLATION NO. 9425-01 10 CFR Part 50, Appendix B, Criteria XI, requires, in part, that a test 1 program be established to assure that all testing required to demonstrate -l that structures, systems, and components will perform satisfactorily in  ;

service is ioentified and performed in accordance with written test '

procedures which incorporate the requirements and acceptance limits contained in applicable design documents. The test program shall include, as appropriate, operational tests during nuclear power plant operation of .

structures, systems, and components. 1 Design Basis Document W3-DBD-Oll, Revision 0, August 1990, " Electrical Distribution (AC Portion)," specifies that safety-related functions are l performed through the Class-lE A, B, and AB electrical divisions, that the '

AB " swing" buses are designed to provide power to equipment, which is j standby to equipment on the bus to which the AB electrical bus is '

connected, and that testing provisions be provided to enable periodic evaluation of the operability and required performance of all Class-lE  !

electrical equipment.

i Technical Specification Surveillance Requirements 4.8.1.1.2.d.3a, 3b, Sa,  :

and 5b require that each emergency diesel generator be verified operable at least once per 18 months during shutdown by performing certain specified  !

tests.

Contrary to the above, Operating Procedures OP-903-069, " Emergency Diesel Post-Inspection Operability Check," Revisions 0 through 7, and OP-903-Il5 and -116, " Train A and Train B Emergency Diesel Generator / Engineering i Safety Fea ures Test," Revisions 0 through 2, did not include measures to test the AB swing electrical bus. The failure to provide a testing program j to ensure that the AB electrical components were tested to satisfy the I requirements of the design basis document and Technical Specifications could have resulted in safety-related components not functioning during accident conditions.

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Attachment to

. W3F1-94-0232 Page 2 of 5 RESPONSE  ;

-(1) Reason for the Violation

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Entergy Operations admits this violation.

On September 7, 1994, a Reactor Operator attending Senior Reactor  :

Operator (SRO) training class questioned why Surveillance Procedure )

OP-903-001, " Technical Specification Logs," requires daily verification that the undervoltage coils on the AB buses are  ;

operating satisfactorily. In response to that question, an SR0 Senior Instructor commenced a review of applicable Technical l Specifications and Surveillance Procedures. During that review, the instructor discovered that Surveillance Procedures OP-903-115 and OP-903-116 may not adequately satisfy Technical Specification (TS) i Surveillance Requirements for the Emergency Diesel Generators (EDGs). i A Root Cause Analysis Team formed to investigate this condition -

identified three factors that may have influenced the performance of ,

individuals involved with this event:

1. Misunderstanding of TS Surveillance Requirements. TS Surveillance Requirements 4.8.1.1.2.d.3b and 4.8.1.1.2.d.5b require (while simulating a loss of offsite power by itself and a loss of offsite power in conjunction with a Safety Injection  ;

Actuation Signal test signal) verification that the diesel will energize the emergency buses with permanently connected loads .

and the auto-connected emergency loads through the load sequencer. It has been suggested that these surveillance requirements exclude the 4160V Bus 3AB and 480V Bus 31AB load groups. That belief may be based on the interpretation that Bus 3AB is not a " permanently connected load." The third-of-a-kind equipment on Bus 3AB may be utilized by connecting Bus 3AB ,

to Bus 3A or 3B. The reassignment of loads on Bus 3AB requires a " dead bus" transfer. It is therefore not a normal practice ,

to transfer Bus 3AB because the momentary deenergization of the '

bus results in a temporary loss of various auxiliary components.  ;

2. Inadequate Technical Reviews. The development of or major i revision to a procedure that implements multiple TS -

surveillance requirements should receive concurrent input from various subject matter experts. During the initial development of OP-903-069 (the predecessor to OP-903-115 and OP-903-116) in 1982, some individuals may have lacked the appropriate ,

knowledge and training to detect this problem.

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Attachment to

, , W3F1-94-0232 Page 3 of 5 That presumption may explain why Buses 3AB and 31AB were not  ;

included in the Integrated Emergency Diesel Generator / Engineer-ing Safety Features Test. However, it is not clear why the l l

originator " deleted AB equipment" from the test in response to l a reviewer's comment. It should he noted that, due to insufficient information, the team could only speculate about conditions surrounding the development of OP-903-069.  ;

3. Potential Opportunities to Identify. While 3AB testing is not~ i specifically mentioned in the following documents, a critical i review reveals that potential opportunities .to ' identify this l condition may have existed prior to September 7, 1934: A 1990 l

, Safety System Functional Inspection of the EDG System; reviews L associated with IN 91-13, " Inadequate Testing of Emergency Diesel Generators (EDGs);" and the implementation of OP-903-115 l

and OP-903-ll6. After reviewing the depth, scope and purpose  ;

of these potential opportunities, the team concluded that no  !

corrective actions related to these reviews are necessary. l Given the above, the team determined that the most probable root cause of this event is an inadequate procedure apparently due to one l or more of the following conditions. First, there may have been a possible misunderstanding of the concept of permanently connected loads as described in TS 4.8.1. Second, the originator of Revision 1 to OP-903-069 acted inappropriately by deleting the AB equipment from an earlier draft and the technical reviews for that procedure were inadequate in that they did not detect the problem.

(2) Corrective Steps That Have Been Taken and the Results Achieved Immediately following the identification of this event, a corrective action document was generated, EDG B was declared inoperable (Bus 3AB, which can receive power from either Bus 3A or 3B, but not from both simultaneously, was aligned to receive power from Bus 38 at that time) and TS Action 3.8.1.1.b was entered. Additionally, a Standing Order was issued that prohibited the alignment of any third-of-a-kind AB components.

On September 8, 1994, the feeder breaker supplying the backup power supply to the Plant Monitoring Computer (PMC) Static Uninterruptible Power Supplies (SUPS) was tagged in the open r,osition. On September 9, 1994, Waterford 3 asked the NRC to exercise enforcement discretion not to enforce compliance with TS 4.8.1.1.2.d surveillance requirements for 7 days. The discretion was needed to allow approval of an emergency TS change permitting alternate surveillance testing for AB loads. As justification, Waterford 3 utilized previous surveillance testing, operational events, and load analyses. The

- Attachment to W3F1-94-0232 Page 4 of 5 l

NRC issued enforcement discretion at 1632 hours0.0189 days <br />0.453 hours <br />0.0027 weeks <br />6.20976e-4 months <br />. Subsequently, Waterford 3 declared EDG B operable.

On September 22 and 25, 1994, tests of Component Cooling Water (CCW)

Pump AB, Chiller AB and High Pressure Safety Injection (HPSI) Pump AB were conducted. The tests subjected these components to loss of voltage (LOV) and LOV in conjunction with a Safety Injection Actuation Signal (or simulation of these signals) that would be present in the integrated test required by the Technical Specifications for EDG B. Additionally, the PMC SUPS alternate power supply was tested for shedding. The test demonstrated that these components performed satisfactorily per TS surveillance requirements.

The Shift Technical Advisors performed a review of TS 3/4.8.1 to verify that all surveillance requirements were appropriately implemented. As a result of that review, it was discovered that the surveillance requirements of TS 4.8.1.1.2.d.1 had not been satisfied.

TS 4.8.1.1.2.d.1 demonstrates operability of the EDGs by verifying the generator capability to reject a load of greater than or equal to 498 Kilowatts (HPSI pump) without exceeding specified output voltage and frequency constraints. Previous testing was deficient in that it utilized a load of approximately 230 XW. In response, Waterford 3 initiated a corrective action document, determined that the EDGs were operable, performed an engineering evaluation that confirmed the operability determination, entered TS 4.0.3, and performed the TS required surveillance test. Additionally, a Licensee Event Report, LER 94-017-00, was submitted per 10CFR50.73 detailing the event and corrective actions.

(3) fffrective Steos Which Will Be Taken to Avoid Further Violations Four corrective actions to prevent recurrence were identified:

1. OP-903-115 and OP-903-116 will be revised to appropriately implement TS Surveillance Requirements.

2. The Integrated Emergency Diesel Generator / Engineered Safety Features tests required by the Technical Specifications will be implemented prior to startup following Refuel 7.

3. TS Bases for 3/4.8.1 will be revised to clarify what is meant by " permanently connected loads."

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I Attachment to

.. .~ W3F1-94-0232 Page 5 of 5

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-Selected surveillance' procedures will be reviewed to assure

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.that.TS surveillance requirements are fully implemented. Based on the results of that review additional actions will be taken  ;

as appropriate.

(4) Date When Full Como11ance Will Be Achieved Corrective actions 1 and 2 will be completed prior to startup .

following Refuel 7. Currently, the Refuel 7 outage is planned to be  !

completed by November 3,1995. Corrective action 3 and the initial  !

review of selected surveillance procedures discussed in corrective -

action 4 will be completed by July 28, 1995.

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