ML20091C830
| ML20091C830 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/05/1991 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-91-0452, W3F1-91-452, NUDOCS 9108070210 | |
| Download: ML20091C830 (4) | |
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August 5, 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 Inepection Report 91-10 Reply to Notice of Violation Gentlemen:
In accordance with-~10CFR2.201, Entergy Operathns, 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 T.W. Gates at (504) 739-G697.
'Very truly yours, e
RFB/TWG ssf Attachment ee:
R.D, Martin, NRC Region IV D.L. Wigginton, NRC-NR R R.B. McGehee N.S. Reynolds l_
NRC Resident Inspectors Office
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W3 F1-91-0-152 Page 1 of 3
_ATT A CilM ENT 'l --
- ENTERGY OPERATIONS, INC. RESPONSE TO Tile VIOLATION IDENTIFlED IN j
APPENDIX A OF INSPECTION-IIEPORT 91-19 1
- VIOLATION NO. 9119-01 Criterion XVI of Appendix B to 10 CFR Part 50 states, in part, " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of significant 1
conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition..."
Nonconformance report, "NCR Repair Work Authorization 01071639 on MSIV #1
'and #2 Stem Corrosion," identified a significant condition adverse to quality (i.e., main steam isolation valve (MSIV) stem corrosion resulting from hydrolysis of leaking hydraulle fluid) and required that, if evidonee of hydraulic fluid leakage was found, the fluid must be diverted away f rom the valve stem to prevent pooling in the packing gland area.
. Contrary to the above, the inspector determined on June 6,1991, that hydraulic fluid leakage was occurring in the MSIVs without measures having been established to provide for either prompt identH1 cation of leakage or to preclude MSIV_ stem corrosion. Specifically, a program had not been established to provide
. for routine hispection of the MSIVs to detect hydraulic fluid leaks, and no actions had been taken to divert leaking fluid away frcm the MSIV stem to prevent pooling in the packing gland area.
- R ESpONSE '
(1)-
Reason for the Violation
' Entergy Operations, Inc. admits this violation nnd believes that the root cause of the failure to implement corrective action was improper work control resulting from the selection of an inadequate method of initiating -
- and tracking the necessary valve inspections. In the absence of available procedural control, the mechanism selected we.s not sufficient to ensure that required inspections were conducted as necessary.
-In'this particular instance, personnel involved opted not to generate a Condition Identification / Work Authorization (Cl/WA) or a Repetitive Task v
but rather to initiate and control the required inspectiona by means of a
" department instruction" and entries in a shift log book maintained by the Mechanical Maintenance Department.
- in light of their importance, supervisory personnel should have written a
- CI/WA or a Repetitive Task to initiate the inspections. This would have put the process in " automatic" to a certain extent with a proceduralized system in place to prompt timely corrective action.
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Page 2 of 3
- Furthermore, the types of work ti at can be performed withent n Cl/WA are intentionally limited by Administrative Procedures UNT-005-00?,-
" Condition Identification," and UNT-005-015, _" Work Authorization -
Preparation and implementation," to thoso evolutions which hav_e no impact on plant operations or.are inhorontly straightforwarrl. In this instaneo, personnelintended to use an allowed exception to monitor tha MSIVs for hydraulic fluid leakage.
- Although th_o actuators were not leaking when thh decision was made, it is clear _in retrospect that more control over the inspections was necessary.
According to the origined engineering evaluation, undetected hydraulle i
fluid leakage had potential implications for the continund satisfactory operation of an important plant component. 11y extension then, th.o
'lunpections themselves were important enough so that formal means should have been established to track their progress.
j in summary then, the decision 'to use a comparatively less formal means of initiating and tracking the required valve inspections was improper in light of the importance of the inspections. Ultimately 3 the necessary inspections
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were not started as required, hydraulle Guld leakage was not notleed when j
lt began, and corrective uetion to keep the leaking fluid from collectin'g in I
the packing gland area was not initiated.
-(2)
. Corrective Steps That llave Been Taken and the Resuha Achieved Design Engineering issued a revised evaluation of the significance of Fyrquel (hydraulic fluid) leakage and the potential for additional MSIV stem corrosion on June 7,1991. The evaluation recommends that, while the integrity of the MSIV stems is assured through the current operating -
cycle, Pyrquel accumulation in the packing gland area of the valvo stems bo minitnized. In accordance with_that recommendation, the hydraulle fluid leakage rate is being qualitatively monitored on a daily basis by means of Condition Identification 27GS12 and Work Authorization 01081940. In conjunction with that daily check, any visiblo hydraulic fhtid leakage is
- being wiped down.
!In addition, Station Modification Request (SMR) MS-020,- " Main Steam 1
~ isolation Valve Operator Stem Leakage Correction," has been submitted, The SMR requests that Design Engineering evaluato the actuator duaign and identify a long term solution to preclude the recurrence of hydraulic -
fluid leakage.
(3)
Corrective Steps Which Will Be Taken to Avold Further Violations
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Three procedures-Engineering Procedure PE-002-005, " Engineering' Work -
Authorization Processing," as well as UNT-005-002 and UNT-005-015-will be changed to require the identification of any necessary " interim measu res. " - In the example described above, the root cause is known but interim action is required to minimize further problems. _No mechanism
- exists that requires the identification of actions necessary to bridge the gap between problem identification and its ultimate resolution, I
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Page 3 'of 3 y..
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Dat'oLWhen Full Compliance Will llo Achieved 1
-The revisions to the three procedure will be complete by i
Septernber 30, 1991..
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