ML20082U040
| ML20082U040 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 09/17/1991 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-91-0478, W3F1-91-478, NUDOCS 9109190254 | |
| Download: ML20082U040 (5) | |
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ft,F.Durski Wal'l-91-0178 A1.05 QA Sept emise r 17, 1991 U.S. Nuclear itegulatory Conunission ATTN: Docuenent Control 1)esh Washlington, D.C. 20555 Subject :
Waterfor(I 3 SES De>eket No. 50-382 Lt.ense No. Ni l'-38 N!(C Inspection 1(eport 91-21 1(eply to Notice of Violations Gentlernen:
In necorcinnee with 10Cl?!(2.201, Entergy Operntjons, jne, hereby nulunits iri Attnelunent 1 the restanise to the vloint:ons identifieti in Appetulix A of the subject inspection lleport.
1" you have any (guestions coli 'erning this response, please cotttact L.lt, i.elllanc at (501) 739-033.
Very truly yours,3; 4
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Attachtuent to W 31'l 017 h Pago 1of41 ATTArilMI:NT 1 ENTI:ltriY OPElt ATIONS, INU. Iti:SPONSE TO Tile VIOL.ATIONS ll)l:NTIFil:1) IN Appl:NI)lX A Ol' INSPECTION lti:PoltT 91-21 VichATION NO. 3h2hd21.-n01 10 CFit 50, Appendix 11, Criterion XVI, " Corrective Action" requires, in part, that measures sludi be established to assure that conditions iniverse to quality, such as deficiencies and nonconforamuces, are promptly identified and corrected.
Site Directive No. W2.50), llevision 0, " Corrective Action," Section 1.7.1 requires Waterford 3 personnel to initiate the applicalle corrective netion document upon ( :scovery of a condition adverse to quality.
Quality Assurance Procedure QAP-012, Itevision 9.0, " Quality Notice," Section 5.1.1 requires any hulividual identifying a condition adverse to quality shall initiate a Quality Nottee (QN).
Contrary to the above:
- 1. On May 20,1991, an improperly configured speed gove enor withdrawn from spare parts was installed on 1:mergency l'eedwater n mp A/It, resulting in a failed test run, l.icensee personnel identifying d.e defielency failed to document this on a QN such that appropriot permanent corrective actions would be assured.
- 2. On July 10, 1991, the licensee failed to initiate a QN when it was recogniwd that a speed sensor for Emergency feedwater Pump A/Il was improperly disassembled during the fourth refueling outage. The hnproper disassembly resulted in a broken amphenol connector.
- 3. On July 15, 1991, during motor winding reshitance testing per Procedure ME-01-371, " Maintenance Procedure, Emergency Feedwater Punip Motor," a temperature conversion was incorrectly calculated. The subsequent independent ve ification did not reveal the error. A QN was not initiated until the NitC inspector brought the issue to licensee management's It t t e n t ion,
11 ESPONSE (1)
Itenson foi the Vh31ation Entergy Operations, Inc. admits this violation and believes that the root cause of this violation was failure of maintenance personnel to understand when corrective action documents should be initiated. For clarity, each of the cited examples are discussed separately.
(i) Upon receipt of the failed test run, investigations for the Emergency l'eedwater Pump A/Il governor were performed to determine the eaura and corrective actions necessary to prevent recurrence. Maintenance personnel incorrectly failed to mitiate a QN, as required by the corrective action program, believing that the elements of the corrective action were evident aiul that the issue had been adeepmtely addressed without needing to generate a QN. A QN was subsequently issued for the inchlent on August G,1991.
Attachment to W3F1-91-0178 Pago 2 of 4 I
i (11) When the amphenol connector for the emergency feedwater pump speed probo was discovered disconnected and tho speed probe damaged, a precursor trending card was completed to document the problem. The1&C planulug Supervisor was investigating the incident to determine how and when the damage had occurred. He incorrectly failed to initiato a QN to document the problem he was investigating as required by the correctivo i
action program. A QN was subsequently issued for the incident on August J
9,1991.
(111) The technichuis atu! acting supervisor involved with the independent verification error failed to realize that a QN was required by the corrective action program. The discussions relating to the need for corrective action documentation with the resident inspector were misinterpreted by the acting supervisor and technicians involved which delayed the initiation of a QN. A QN was subsequently Initiated on July 25, 1991.
I (2)
C_opeective Steps That llave lleen Taken and the llesults Aehleved i
in all three lustances a QN was issuM to docutaent the condition adverse to quality. QN QA-91-149 was originatod on August 6,1991 for the emergency feedwater turbine governor problem. QN QA-01-153 was originated on August 9,1991 for the broken speed probe amphenal. QN QA-01-148 was originated on July 25, 1991 for the improper independent verification of calculations.
(3)
. Corrective Steps Which Will fin Taken to Avoid Further Violations A memorandum will be sent to discipline superintendents to provido additional guidance on initiation of correctivo action documents. Shop meetings will bo held to communicate to shop personnel the importance of initiating correctivo action documents and when they are required.
A correctivo action task group la currently evaluating Site Directive W2.501, " Corrective Action," to determine if the program should be streamlined or simplified. This evaluation commenced prior to the violations cited and is not considered as part of the corrective actions.
llowever, this does demonstrate the continuing effort to improve the corrective action program at Waterford 3.
(4)
Date When Full Compliance Will llo Achievod The memorandum will be issued and the shop meetings completed by September 30, 1991.
Attachment to W3F1-01-0178
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pagu 3 of 1 VIOL.ATION NO. 382/0121-003 Technical Speelfication 3.8.1.1, Action b requires, in part, with one diesel generator inoperable and the plant in Mode 1, that the lleensee demonstrate the operability of the offsite A.C. circuits by verifying correct breaker alignments and indleated power availability within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.
Contrary to the above, on June 20, 1991, with Emergency Diesel Generator A Inoperable, the 1-hour off-site elreult operability verification was not completed for nearly 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and on June 21, 1991, with Emergency Diesel Generator A Inoperable, the verification was not completed for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in one instance and for nearly G hours in a second instance.
- It ESPONSE (1)
Henson for the Violation Entergy Operations, Inc. admits this violation and belloves that the root-cause of this event is inadequate attention to detall. The control room aupervisor (CitS) properly entered Technical Specification 3.8.1.1, but did not Initiate the electrient breaker alignment chuch in order to satisfy the action requirements of Technical Speelfication 3.8.1.1, NitC Inspection Iteport 50-382/91-21 identified this event as a recurring j
problem in which past measures to prevent recurrence did not appear to l'
prevent future recurrences. This part! ular technical speelfication action has been unique in that it generally han been a problem when cascading down from support system outages, in this particular event the inoperability of the EDG cascaded from placing essential chillers out of i
service. A_ contributing cause of these events was that the procedures in place at the time did not include sufficient clarification and guldunce on entering cascading technica; speelfications.
(2)
Corrective Steps That llave Iteen Taken and the Resulta Achieved At approximately 2220 on June 21, 1991 during a review of the control room logs it was discovered that Technical Specification 3.8.1.1 action b had not been performed as_ required. At 2223 on June 21,1991, Op-903-000, Electrical Breaker Alignment check, was performed and verified that offsite AC electrical power was availablo as required by Technical Specification 3.8.1.1 action b. Licensee Event Report (LElt)91-012 dated July 22,1991 was written to report this event. The control room
- supervisor involved in this. event was debriefed. To prevent recurrence, a new procedure, " Technical Specification Compliance," Op-100-011, was issued which provides additional clarification and guidance on entering cascading tecluilcal specifications. The purpose of thin new procedure is to -
provide guidance for determining operability of technical specification i
related equipment and for ensuring that complinuce with the technical speelfications is maintained.
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Attnehment to W3F1-01-0178 l
page 4 of 4 In addition, other paveedures were revised to provide clarification and guidance. Procedure OP-002-003, "Componont Cooling Water System," was revised to add a precaution to section 3.1, and a caution to section G.5 which states if a CCW train is inoperable, then cascading technical speelfications should be entered in accordance with OP-106-14, Technical Speelfication Compliance. Procedure OP-002-004, " Chilled Water System,"
was revised to add a precaution to section 3.1, and a enution to sections 0.2, 0.3, and 0.5, requiring that if a chilled water train is inoperable, then cascading technical speelfications shall be entered in accordance with OP-100-014, Technteal Speelfication Compliance.
-LElt 91-012 and OP-100-014 were entered into the Operations Department Priority 2 Itequired lleading.
(3)-
Corrective Stetis Which Will lie Taken to Avoid Furi her Violations t
All correctivo actions for this violn'hn have been completed, y
(4)
Date_When Full Comiillance Will 11e Achieved
- Full compliance was achieved on August 16, 1991, at which timo all associated corrective actions were comploto.
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