ML20079B839
| ML20079B839 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 01/05/1995 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-94-0233, W3F1-94-233, NUDOCS 9501090110 | |
| Download: ML20079B839 (7) | |
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===ENTERGY EUls"*'"
l Kifiona, LA 700fA TeJ 504 739 6774 R. F. Burski
- trectcs, Nrticut $dicti Waterba 3 W3F1-94-0233 A4.05 PR l
January 5, 1995 U.S. Nuclear Regulatory Commission l
ATTN: Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 l
License No. NPF-38 NRC Inspection Report 94-20 Reply to Notice of Violation i
l l
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 David Litolff at (504) 739-6693.
l Very truly yours, I
, h','
a I
R.F. Burski Director Nuclear Safety f
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RFB/DFL/tjs Attachment
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cc:
L.J. Callan (NRC Region IV), C.P. Patel (NRC-NRR),
l R.B. McGehee, N.S. Reynolds, NRC Resident Inspectors Office 9501090110 950105 PDR ADOCK 05000382 Q-PDR
_________________i_____________________________-_____________ _.. _ _
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Attechment.to.
W3F1-94-0233 Page 1 of 6 i
f ATTACHMENT 1 i
ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN APPENDIX A 0F INSPECTION REPORT 94-20 VIOLATION NO. 9420-03 During an NRC inspection conducted between October 2 and November l
12, 1994, one violation of NRC requirements was identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:
i A.
10 CFR Part 50, Appendix B, Criteria XVI, " Corrective Actions," requires, in part, that measures be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and i
equipment, and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to l
quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition..The identification of the significant condition
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adverse to quality, the cause of the condition, and the j
corrective action taken shall be documented and reported to appropriate levels of management.
1.
Contrary to the above, the licensee failed to correct deficiencies involving erratic flow indications from the component cooling water, containment spray, and low pressure safety injection system flow transmitters. Specifically, the resolutions of Problem Evaluation /Infonnation Requests 61439 and 61340 were assigned to a Station Modification Request (MIS 035) that did not exist and was not implemented.
2.
Contrary to the above, the licensee failed to develop corrective actions for seismic concerns identified while l
performing an Individual Plant Examination of External Events walkdown of the control room during Refueling Outage 6.
This is a severity Level IV violation (Supplement 1) (382/9420-03).
Attachment to i
Page 2 of 6 j
, RESPONSE TO EXAMPLE 1 0F THE VIOLATIQN (1)
Reason for the Violation Entergy Operations Inc. admits this violation and believes that the root cause was inappropriate action in that the system engineer failed to initiate effective corrective action documentation or otherwise ensure the implementation of corrective actions for a condition involving the erratic operation of flow transmitters. A contributing cause was inadequate administrative controls in that this condition was considered to be below the threshold of the Corrective Action Program in 1990 and, therefore, no formal mechanism existed to ensure that identified actions were tracked to completion.
On December 4,1989, Problem Evaluation /Information Request (PEIR) 61340 identified a problem with containment fan cooler Component Cooling Water (CCW) flow transmitters, CC-IFT-7570A1, A2, B1, and B2, involving the migration of air into the lines. The PEIR requested an i
evaluation from Plant Engineering for a long term fix.
Plant Engineering responded by stating that Station Modification Request
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(SMR) MIS-035 had been initiated to resolve this and similar proble ns. On April 24, 1990, PEIR 61439 was initiated to identify a similar problem of air migration into lines associated with Safety i
Injection flow loop, SI-IF-1306B. This PEIR also requested an evaluation and Plant Engineering responded with the same action identified in the response to PEIR 61340.
On November 1, 1994, Condition Report (CR) 94-1014 was written to document a problem with a flow transmitter in the Containment Spray i
(CS) System, CS-IFI-7122B. The concern identified was that when the pump runs, air is allowed to migrate upward in the sensing lines due to the transmitter being above an orifice. This CR also mentions that a similar problem with the other trans;nitters located in the same area was identified on PEIR 61439.
Further investigation revealed that the responding system engineer to PElR's 61340 and i
61439 did generate SMR MIS-035 to correct the conditions, however the SMR was not approved for implementation by the SMR Review Committee.
.I As such, the PEIR's were closed per their responses and no long term actions were ever taken to address the conditions with the various flow transmitters.
The PEIR procedure which existed at the time, NOAP-018, stated that the PEIR is not to be used as the initiating document for addressing conditions adverse to quality.
It also stated that initiating documentation such as Condition Identifications (CI's) or Quality Notices (QN's) should specifically be referenced by the PEIR.
PEIR 61340 referenced Work Authorizations (WA's) #01039566 and #01039567
p Attachment to W3F1-94-0233 Page 3 of 6 which had associated CI's. However, work under these WA's only corrected the immediate conditions and were closed.
Long term i
solutions were not addressed by these CI/WA's. The responsible engineer failed to initiate effective corrective action documentation-to track the corrective actions and ensure implementation.
It should be noted that the subject flow transmitters, while in safety-related systems, only provide Control Room indication of flow in their respective systems and not any control functions.
For this reason, the identified conditions were considered to be below the threshold for formal corrective action documentation in 1990. As a result, no long-term corrective actions for the condition were implemented or, alternatively, justification to not implement the actions was not properly documented.
(2)
Corrective Steps That Have Been Taken and the Results Achieved Waterford 3 is confident that a problem such as this - an adverse condition being identified in the field and corrective measures not being tracked to completion - would not occur under the currently implemented Corrective Action Program. The Corrective Action Program has undergone significant change since 1990, including the lowering of the threshold for documenting conditions to include all conditions adverse to quality, plant reliability concerns, nonconforming conditions, and industrial safety concerns. Under the current process all discovered conditions, including this one, are required to be documented on Condition Reports.
Each CR is assigned to a particular department for cause and corre/ tive action determinations.
The CR remains open until all corrective actions, including those to prevent recurrence, have been implemented or alternative measures to ensure completion have been taken.
If a SMR is generated as part of corrective actions under a CR, the CR would remain open until the modification was implemented in the field or until other measures had been taken to ensure the modification would be implemented.
If the SMR was rejected, the CR would document this and provide for any necessary alternative actions. The documenting of air migration concerns on CR-94-1014 supports the conclusion that conditions such as this one would not be missed under the current process.
Additionally, engineering management has emphasized the proper use of PEIR's.
Engineering personnel are aware that PEIR's may be used for information exchange only, should reference any associated CR's, and are not to be used as corrective action tracking documents.
To address the air migration concern which appears to be common to many flow transmitters, CR-94-1065 was initiated to document and enter into the corrective action program the fact that no procedural or programmatic process is in place to ensure instrumentatien tubing
Attachment to W3F1-94-0233 Page 4 of 6 is filled and vented following system maintenance. Most system operating procedures provide fill and vent methods, however system instrumentation is not ridressed following partial system outages.
(3)
Corrective Steos Which Will Be Taken to Avoid Further Violations Procedure UNT-005-003, " Clearance Requests, Approval and Release,"
L will be revised to address instrument venting during system restoration following clearance release. During system outage preparation, Scheduling / Operations coordination will review the outage isolation boundary scope and include venting as a scheduled activity wnen warranted.
Design Engineering will evaluate the ct'fect of possible air migration into the subject flow transmitters and determine if any act'ons are necessary to prevent air migration into the related instrument lines.
(4)
Date When Full Compliance Will Be Achieved The actions described above on venting instruments as a scheduled activity when warranted are currently being implemented at Waterford 3.
UNT-005-003 will be revised by March 31, 1995 to proceduralize j
these actions.
i Design Engineering will complete their evaluation on possible air migration into instrument lines and determine any necessary corrective actions by February 15, 1995.
1 RESPONSE TO EXAMPLE 2 0F THE VIOLATION (1)
Reason for the Violation Entergy Operations Inc. admits this violation and believas that the root cause was inappropriate action in that Design Engineering (DE) failed to initiate effective corrective action documentation to address seismic concerns identified in the Control Room. As a j
result, no actions were taken to correct the identified conditions.
In April, 1994, during Refueling Outage 6, Design Engineering performed Individual Plant Examination of External Events (IPEEE) walkdowns to identify specific cases where transient / temporary, non-seismic items are located in the vicinity of safety-related equipment. During these walkdowns, DE identified several " loose
Attachment to l
W3F1-94-0233 Page 5 of 6
' items" in the Control Room. A memo was written to the Technical Services Nanager on April 11, 1994 which listed the identified items and DE's recommendation to restrain or relocate the items. However,
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no formal corrective action document (i.e. Condition Report) was initiated to address the condition. At the time, the condition was believed to be below the threshold of a Condition Report because no l
specific design requirements associated with the recommendations existed. As a result, corrective actions for the identified seismic conditions were not prioritized such that they would be completed in l
a timely manner.
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l (2)
Corrective Steos That Have Been Taken and the Results Achieved j
l Training on the current corrective action process was given to plant i
personnel in June, 1994. This training emphasized the requirement that all discovered conditions adverse to quality, nonconforming l
conditions, plant reliability concerns, and industrial safety i
concerns are to be documented on Condition Reports. Waterford 3 is confident that plant personnel understand this requirement and that a
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condition such as that referenced in this violation would be i
documented on a CR. With regard to the concern of personnel awareness of corrective action program requirements, Waterford 3 feels that no additional corrective actions are necessary.
Condition Report (CR) 94-1019 was generated on November 2, 1994 to analyze the potential adverse affects of permanent and nonpermanent equipment identified by the NRC during a walkdown on October 31, j
1994.
The evaluation determined no operability concerns existed with j
the identified equipment.
As a conservative measure, the bookcase near the Core Protection Calculators, and the tool cart in the Emergency Diesel Generator Room B were removed.
Per Inter-0ffice Memo dated December 13, 1994, Design Engineering Civil requested the Fire Protection / Safety Department to inform them when any new items are stored on the Nuclear Island near safety-i related equipment.
Plant personnel are currently required, per procedure FP-001-017, to obtain approval from the Fire Protection staff prior to staging combustible or non-combustible materials anywhere in the plant.
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4 Attachment to W3F1-94-0233 i
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Page 6 of 6 (3)
Corrective Steos Which Will Be Taken to Avoid Further Violations 1
DE Civil has met with Control Room personnel to decide what loose items are needed and what items can be removed from the Control Room.
For items which must remain in the vicinity of and could impact safety-related equipment, DE Civil will issue a Work Authorization to bolt down the identified items and revise drawings to show their locations.
DE will proceduralize guidance for. designated storage areas of temporary equipment inside the Seismic Category I buildings to prevent hazardous seismic interactions. This guidance will provide assurance that the safety function of components, equipment, and systems will not be affected by temporary storage of loose items.
l DE Civil will walkdown all the designated storage areas near safety-related equipment on the Nuclear Island to identify any adverse conditions.
(4)
Date When Full Comoliance Will Be Achieved A Work Authorization will be generated by March 1, 1995 to bolt down any equipment identified necessary as mentioned above.
Guidance for designated storage areas of temporary equipment inside the Seismic Category I buildings will be proceduralized by May 1, 1995.
DE Civil will perform and complete walkdowns of the designated storage areas by April 30, 1995.
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