ML20086L011
| ML20086L011 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/11/1991 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F191-0824, W3F191-824, NUDOCS 9112160021 | |
| Download: ML20086L011 (3) | |
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t n,' n W3F191-0824 A4.05 QA December 11, 1991 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 91-25 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. In addition to specific corrective actions to address the cited violation, the response also includes initiatives which are intended to address recently noted work controlissues on a broader level.
If you have any questions concerning this response, please contact T.W.' Gates at (504) 739-GGE7.
Very truly yours, ne RFB/TWG/ssf Attachment ec:
R.D. Martin, NRC Region IV -
D;L. Wigginton, NRC-NRR:
R.B. McGehee N.S. Reynolds NRC Resident Inspectors Otfice-I bl 9112160021 911211
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i Attachment to W3F191-0824 Page 1 of 2 ATTACllMENT1 ENTERGY OPERATIONS, INC. RESPONSE TO Tile VIOLATION IDENTIFIED IN ~
APPENDIX A OF INSPECTION REPORT 91-25 VIOL ATION NO. 91-025-3 Technical Specification G 8.1.a requires, in part, that written procedures shall be implemented covering activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Section 9.a states, in part, that maintenance that can affect the performance of safety-related equipment should be properly preplanned.
Administrative Procedure UNT-005-015, Revision 2, " Work Authorization Preparation and Implementation," Section 5.7.1 requires, in part, that maintenance that can affect the performance of plant equipment shall be properly preplanned.
Contrary to the above, on October 25, 1991, during painting activities on walkway structures adjacent to Wet Cooling Tower B, the failure to properly preplan painting work activities resulted in the installation of protective tarpaulins that obstructed the cooling tower principal air inlets without predetermining the degree of obstruction acceptable for continued operability of safety-related Wet Cooling Tower B cnd without informing the shift supervisor of the extent of the obstruction beIng installed.
RESPONSE
3 (1)
Reason for the Violation Entergy Operations, Inc. admits this violation and believes that the root -
cause of the event was that work control measures related to painting activities did not provide adequate guidance for assessing the effect of the -
employment of protective tarpaulins in the area of safety-related components and systems. Although the activity was discussed with the Shift Supervisor, the extent of coverage of the intakes was not communicated well. Consequently, neither he nor the painting supervisor recognized the significance of using the tarpaulins over the tower intakes.
(2)
Corrective Steps That llave Been Taken and the Results Achieved When the condition was noted, the painting in the area of the WCT's was suspended and the tarpaulins were removed. Significant Occurrence 5
Report (SOR)91-040 was written on October 25, 1991 to track the event.
Because a reportability determination-was necessary, Potential Reportable Event (PRE)91-064 was initiated on October 30,l1991 and event tracking -
transferred from the SOR to the PRE.
t
Attachment to -
e W3F191-0821 Page 2 of 2
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An engineering evaluation of this event was performed in response to the PRE (reference: Calculation EC-M01-075/RO). The evaluation concluded that, given the environmental conditions existing while the tarpaulin was in place, the WCT was operable in that it was capable of rejecting approximately 10-1 percent of the design heat load. According to the performance curves provided in the vendor manual, at the design air flowrate the wet cooling towers will reject 116 percent of the design heat load given similar environmental conditions. Ilowever, even though the engineering evaluation is based on a " worst case" blockage of the WCT air intake, it does not take credit for the fact that the vendor performance curves provided for the WCT were demonstrated to be approximately 15 percent conservative during startup testing (reference: Calculation MN(Q)-9-52/R1).
(3)
Corrective Steps Which Will Be Taken to Avoid Further Violations Entergy Operations, Inc. is developing corrective actions to address the unique aspects of this particular violation as well as the generic work control issues involved.
First, a notification form that will document upcoming painting activity is belag developed. This form will be presented to the Shift Supervisor / Control Room Supervisor each day to inform him of the painting activities scheduled for that day.
The form will also include a checklist that will aid the painting supervisor in determining whether a particular painting project will impact other systems or components. If the checklist indicates that temporary covers or screens will be used, engineering input will be obtained and included as an
-t addendum to the work authorization for the painting in question.
To address the broader scope issue of inadequacies in the work control process, steps are being taken to increase the sensitivity of personnel to the effect that their activities might have on overall plant conditions.
Seminars that present actual plant experiences and postulated scenarios showing the effects of work activities on plant configuration will bc developed and conducted with first line supervisors in the maintenance department and th_e field supervisors in the construction department. The information presented in the seminars will then be covered with _other -
maintenance and construction personnel in subsequent shop meetings _or L
training sessions. Finally, training of this nature will be added to the basic courses taught to newly hired maintenance personnel.
l (4)
Date When Full Compliance Will Be Achieved I-The daily painting checklist and all training initiatives will be in place by March 31,1992.
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