ML20116M767
| ML20116M767 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/19/1996 |
| From: | James Fisicaro ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-96-0130, W3F1-96-130, NUDOCS 9608210070 | |
| Download: ML20116M767 (20) | |
Text
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.m Ent gy Operatlins, Inc.
Killona. LA 70006 Tel 504 739 6242 James J. Fisicaro 5s*'
e W3F1-96-0130 A4.05 PR August 19,1996 s
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
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Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC inspection Report 96-05 Reply to Notice of Violations j
Gentlemen:
Entergy, Waterforo 3, hereby submits in Attachment 1 the responses to the violations
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identified in Enclosure 1 of the subject inspection Report in accordance with 10CFR2.201.
The Staff expressed performance concerns with Operations and Engineering activities in the cover letter of the Inspection Report. Regarding Engineering, the matter of engineering inputs is an issue of importance to Waterford 3. Waterford 3 is continuing to implement broad and specific actions as part of the Waterford 3 Focus Plan which are aimed at improving our performance in the area of engineering inputs. The Waterford 3 Focus Plan addresses the importance of a self critical engineering approach to station operations and the performance standards that will be implemented in a new management model for the engineering function at Waterford 3. The objectives for engineering in the Focus Plan central to engineering inputs are the need to improve the self critical attitude in engineering and the need to improve the interface between engineering and the plant organization. Some of the actions that are being implemented are: the use of self assessments as a tool to identify weaknesses, raise standards and expectations, and implement a self critical attitude; and the improvement of engineering organizational effectiveness by actions, such as refining the roles and responsibility for engineering, implementing a site-wide Engineering Request Process, evaluating the root cause capability, and T,L DI.ib
~ nnnn 9608210070 960819 PDR ADOCK 05000382 G
I NRC Inspection Report 96-05 Reply to Notice of Violation W3F1-96-0130 Page 2 August 19,1996 i
implementing communications improvements. Recent changes to the Corrective Action Program have also provided a basis for improving performance in the area of engineering inputs. For example, the new corrective action classification process has lessened the need for engineering to evaluate issues which are not substantive and to concentrate on issues which are significant from a safety, operational, and licensing basis standpoint. Also, the corrective action process has been changed to provide improved information for when to consider the need for and the use of engineering inputs.
From a broader perspective, on June 11,1996 we met with the NRC to discuss the Waterford 3 Focus Plan which was developed to improve the performance of Waterford 3. We conveyed the importance for engineering evaluations to be technically sound, address the root cause, and maintain the plant design basis; the importance of a self critical attitude and approach; and the need to set performance standards at an appropriate level. We have found that strengths exists which provide the foundation for improvement actions. There is now a shift in the safety culture and questioning attitude with personnel initiatives being taken which demonstrate a strengthening of performance. We are seeing high performance standards being set; a more thorough and comprehensive evaluation of potential problems and issues; an improvement in the integration of engineering into the plant organization; better clarity of accountability and priority for key issues; and the l
reevaluation of key programs and processes. We are continuing to endeavor to j
resolve long standing issues, implement efficiency improvements in the engineering process, and to use self assessments as a tool for continuous improvement. Overall, we have completed about 35% of the action items identified in the Waterford 3 Focus Plan. We are carefully monitoring engineering performance by virtue of managing engineering performance improvements, performing customer surveys, reducing the discovery of performance issues by the NRC, and assuring complete and l
unquestionable resolution of engineering problem issues which may arise.
Waterford 3, as part of the Focus Plan, is also continuing to implement broad and i
specific actions which address initiatives aimed at improving our performance in implementing the requirements of Technical Specifications. Objectives have been i
developed as part of the initiatives for procedure improvement, work process
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improvement, and work process quality. These objectives, in part, include the need to upgrade the technical quality and usability of procedures to reduce human errors, the need to increase operations awareness of plant status, and the need to achieve human performance improvements. Some of the actions wnich are being a
NRC Inspection Report 96-05 Reply to Notice of Violation W3F1-96-0130 Page 3 j
August 19,1996 i
implemented are the following: streamlining and enhancing the procedure process, j
utilizing assessments as a tool to identify additional improvement opportunities, j
implementing equipment status control improvements to ensure operator awareness j
of plant systems prior to approving maintenance activities, and establishing specific l
guidance concerning the control of work and pre-job briefings to ensure proper j
operations oversight is exercised.
I The management of Waterford 3 has placed significant focus and emphasis in assuring that the culture and policy for implementing Technical Specifications are conservative from a safety standpoint and are in strict compliance with regulatory requirements. In this regard, we have seen that operations is continuing to exhibit a questioning and self critical attitude about issues, an attitude which reflects a conservative safety standpoint. The specific changes and broad programs discussed in the violation report will further provide the tools for continuing to enhance our performance regarding the implementation of Technical Specifications.
We are beginning to see a significant improvement in the practice of entering Technical Specification Limiting Conditions For Operation (LCO). For example, a cursory review of entries into Technical Specifications revealed that we are entering conservatively about four time as many LCOs. Some examples of entries into Technical Specification LCOs that were not being entered in the recent past, and are now being entered are the Essential Chiller A/B replacement for the A Essential Chiller and the High Pressure Safety injection (HPSI) A/B pump replacement for the HPSI A pump during valve alignments. Waterford 3 management will continue to closely monitor our performance for the implementation of Technical Specifications to ensure our performance continues to reflect a conservative safety culture.
The responses to the violations 9605-04,9605-05, and 9605-06 address broad and detailed corrective actions relevant to the specific causes of the violations and the issues of engineering inputs and entry into Technical Specification LCOs. These corrective actions in conjunction with the initiatives of the FOCUS Plan are intended to ensure that engineering inputs are accurate and of a superior quality and that there is strict adherence and compliance with the requirements of Technical Specifications.
9 NRC Inspection Report 96-05 Reply to Notice of Violation W3F1-96-0130 Page 4 August 19,1996 Please contact me at (504) 739-6242 or Tim Gaudet at (504) 739-6666 if you have any questions concerning this response.
Very truly yours, p,'
J.J. Fisicaro Director Nuclear Safety JJF/GCS/tjs Attachment cc:
L.J. Callan (NRC-Region IV)
C.P. Patel (NRC-NRR)
R.B. McGehee N.S. Reynolds NRC Resident inspectors Office (W-MSB4-266)
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__.___._.___._______-_.____m Attachm::nt to VV3F1-96-0130 Page 1 of 16 ATTACHMENT 1 i
ENTERGY, WATERFORD 3, RESPONSES TO THE VIOLATIONS IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 96-05 VIOLATION NO. 9605-02 l
Technical Specification 6.8.1.a requires, in part, that written procadures shall be implemented and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A, Sections 1 and 9, require that the licensee have administrative and maintenance procedures / written instructions.
Administrative Procedure OP-100-001, " Duties and Responsibilities of Operators on Duty," Revision 10, Section 5.8.1.3 specified that operational activities performed locally in the plant must take place under the direction of, or with the concurrence of, the shift supervisor or control room supervisor.
1 Contrary to the above, on May 13,1996, Procedure OP-100-001 was not properly implemented in that operational activities were performed locally in the plant without J
the concurrence of the shift supervisor or control room supervisor in that maintenance personnel, under the direction of a licensed operations training instructor, repeatedly -
cycled the emergency diesel generator fuel oil override lever without the direction or concurrence of the shift supervisor or control room supervisor.
This is a Severity Level IV violation (Supplement 1)(382/9505-02).
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RESPONSE
(1)
Reason for the Violation This violation was due to personnel error in that the licensed operations training instructor and an experienced maintenance individual in training, both inadvertently failed to notify and obtain permission from the shift supervisor or
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control room supervisor prior to cycling the emergency diesel generator fuel oil override lever, in subsequent discussions with the individuals involved, they indicated awareness of the requirement to notify the Control Room before performing actions as described in the violation and acknowledged that the error in judgment caused the event.
1 (2)
Corrective Steps That Have Been Taken and the Results Achieved
1 i
Attachm::nt to W3F1-96-0130 Page 2 of 16 1
A condition report (CR-96-0721) was generated in accordance with plant procedures to implement the corrective action program.
i The Control Room Supervisor and Reactor Auxiliary Building (RAB) Watch were dispatched to verify that the fuel rack override lever on both Emergency Diesel Generators were in the correct position and that their linkages would not interfere with Diesel operation.
On May 14,1996, all of the Training Supervisors discussed this event with their instructors. During those discussions, it was stressed that, while in the plant, no equipment will be operated without specific permission from the Control Room. These expectations were also discussed with the maintenance safety cystem class, with the initial Reactor Operator class, and Operator Requal trainnig class. The instructor and the maintenance trainee involved with this event were counseled by supervision.
On May 15,1996, an internal memorandum was issued by the Plant Manager to plant supervisory personnel, reinforcing expectations regarding operation of plant equipment. The memorandum stressed that all site personnel must be made aware (through their supervisors) that operation of plant equipment is to be coordinated through the Control Room and that inadvertent operation of plant equipment must be reported to the Control Room immediately.
(3)
Corrective Steps Which Will Be Taken to Avoid Further Violations l
Corrective actions taken adequately address this violation.
(4)
Date When Full Compliance Will Be Achieved Waterford 3 is currently in full compliance.
Attachm:nt to W3F1-96-0130 Page 3 of 16 VIOLATION NO. 9605-04 Technical Specification 6.8.1.a requires, in part, that written procedures shall be implemented and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A, Sections 1 and 9, require that the licensee have administrative and maintenance procedures / written instructions.
Contrary to the above, on May 14,1996, Work Authorization (WA) 01126155, which 1
provided written instructions for Dry Cooling Tower A logic card replacements, was not maintained in that the written instructions did not require isolating the Dry Cooling Tower A process analog controls cabinet prior to removing printed circuit logic cards internal to the cabinet and, as a result, dry cooling tower fans were rendered inoperable.
This is a Severity Level IV violation (Supplement 1)(382/9605-04).
RESPONSE
(1)
Reason for the Violation The reason for this violation was personnel error in that personnel failed to prepare adequate work instructions, prepare an adequate engineering input, and enter the Technical Specification Limiting Condition For Operation (LCO).
j Waterford 3 personnel on May 14,1996, were performing work on the Dry Cooling Tower (DCT) fan controls in accordance with Work Authorization (WA) 01126155. The work scope in the WA required the removal of six prom J
logic cards from the Process Analog Controls (PAC). The opto-isolator chips I
on the prom logic cards had experienced numerous failures, and the logic cards were to be replaced with like cards with new opto isolators. The function of the logic cards is to provide the logic circuitry for controlling the starting and the speed of the DCT fans, either in slow or fast speed, as required to maintain the component cooling water temperature between 88 F and 92 F.
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This work was planned and was performed without entering the appi. cable Technical Specification LCO for the DCT fans.
I There is no maintenance procedure which is specifically written for the replacement of logic cards for the DCT fan controls. The work instructions for j
the performance of the work were documented in WA 0"26155. Procedure l
Ml-005-565 provides instructions for testing the logic of the DCT fans. The l
WA made reference to certain sections of Procedure Ml-005-565 as part of i
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Attachmsnt to I
i W3F1-96-0130 Page 4 of 16 the work instructions. Specifically, the WA made reference to Procedure Mi-i
' 005-565, section 5.0, which required that the switches on the DCT fan controls be set to the manual fast position or that the DCT fans be declared 4
inoperable. However, the WA did not make reference to Procedure Mi-005-565, section 8.1, which requires that the field cables J11 through J15 be disconnected. Thus, because of the lack of specificity in the WA to remove or e
when to remove the field cables, the field cables were not disconnected prior s
to removing the logic cards. Waterford 3 personnel determined that the removal of the logic cards resulted in the loss of indication for certain DCT fans and could have made the DCT fans inoperable in the event that a Loss Of Offsite Power had occurred while the logic cards were removed.
The replacement of logic cards for the DCT fans similer to the foregoing activity had been performed in the past without any malfunctions occurring.
However, the field cables J11 through J15 had been disconnected prior to removing the logic cards. Thus, the primary reason for the malfunctions which occurred was personnel error in that maintenance personnel failed to develop adequate work instructions, with less dependence on worker knowledge, and which ensured the appropriate field cables were disconnected prior to removing the logic cards.
Operations and maintenance personnel in an effort to ensure a high standard of performance displayed a questioning attitude and requested that' engineering' provide an engineering input for the work that was going to be performed. An evaluation of the DCT circuitry was performed by the Component Cooling Water (CCW) and PAC systems engineers as well as a design engineer and a systems engineering supervisor. The review concluded that placing the DCT fans in manual fast speed would ensure that the DCT fans would perform their safety function. The review also concluded that the electrical distribution system was capable of withstanding all DCT fans starting at once and that the effect of running the DCT fans in fast speed would result in acceptable CCW temperatures. The engineering input was documented in accordance with Procedure UNT-007-053.
Waterford 3 personnel concluded, in error, that placing the DCT fans in manual fast would ensure that the operation of the DCT fans would not be affected if the logic cards were pulled. Engineering personnel came to the erroneous conclusion that placing the DCT fans in manual fast electrically isolated the PAC from the DCT fan circuitry. Thus, although the PAC logic is extremely complicated and a review was performed, a second reason for this violation was personnel error in that engineering personnel failed to provide an accurate engineering input and to specifically identify the importance of disconnecting the field cables prior to removing the logic cards.
Attachm:nt to W3F1-96-0130 Page 5 of 16 4
Subsequent to the DCT fan malfunctions, Waterford 3 personnel conducted a comprehensive evaluation of the circuitry of both the DCT fan and PAC circuitry and performed a test on a mockup of the DCT and the PAC circuitry.
Waterford 3 would like to clarify some of the information in the NRC inspection i
report regarding the observation made that Card 5 was removed by itself and its associated fan lost indication and went into slow speed, reference page fourteen, third paragraph, of the inspection report. Waterford 3 personnel believe that the actual fan speed of the DCT fans was not affected by the i
removal of the logic cards. The pulling of the logic cards the first time only i
resulted in the loss of DCT fan speed indication in the control room. After the l
DCT fan speed indication in the control room was lost, an operator was I
dispatched to the DCT A, and the operator observed several of the fans I
running in slow speed. However, during the time that the operator was i
dispatched to DCT A, the control room operator had been trying to determine if the problem was associated with the control room switches, and the operator had positioned the DCT fan speed switch from the fast to the slow i
position. The DCT fans never changed speed until the operator positioned the DCT fan speed switch to the slow position. Waterford 3 personnel determined nonetheless as a result of the comprehensive evaluation of the DCT and PAC circuitry and the mockup test, that the capability of the affected l
j DCT fans to start automatically in the fast speed could be possibly lost only in the event that a Loss Of Offsite Power (LOOP) occurred while the logic cards were removed. In the event of a LOOP, the PAC logic circuit would have generated both a slow start signal from the automatic portion and a fast signal i
from the Manual switch. The fans would have started either in the slow or fast i
speed depending on which signal was the first to reach the fan controls.
Therefore, Waterford 3 personnel believe the removal of Card 5 by itself could not have caused the associated fan to go to the slow speed.
Waterford 3 performed the logic card removal without entering the applicable Technical Specification LCO for the DCT fans. Therefore, a third reason for this violation was personnel error in that operations personnel failed to take a conservative approach and enter the Technical Specification LCO prior to performing work which had the potential to render the DCT fans inoperable for a short period of time.
(2)
Corrective Steps That Have Been Taken and the Results Achieved The corrective steps that have been taken and the results achieved are discussed in terms of the specific conditions relevant to the violation and the broader issues of engineering inputs and entry into Technical Specification LCOs.
Attachm:nt to W3F1-96-0130 Page 6 of 16 4
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Specific Conditions Relevant To The Violation Engineering performed a detailed evaluation of the logic for the PAC and DCT fan circuitry and performed a test of the PAC and DCT circuit logic on a mockup test apparatus. Engineering personnel gained a thorough understanding of PAC and DCT circuit logic and determined that the DCT fans may not have been available in the event of a LOOP with the logic cards pulled.
4 WA 01126155 was revised on May 16,1996, prior to continuing any further work on the DCT fans to incorporate additional work instructions to ensure the field cables are removed prior to removing any logic cards.
l The I&C Maintenance Supervisor issued on May 23,1996, an electronic correspondence addressing the event for personnel who may have a need to i
work on the DCT tower fan sequencers. The electronic correspondence discussed the event and established that the step in Procedure Ml-05-565, sections 1 through 7, and the first step of section 8.1, disconnecting the field cables, must be accomplished prior to performing maintenance on the logic l
cards.
The Mi procedures were reviewed to determine whether there are any similar work tasks which may require additionalinstructions. There were no procedures identified that were determined to be inadequate because of a lack of work instructions. Twenty Five (25) MI procedures have been identified which may require enhancement of work instructions, and these j
procedures are undergoing further review.
Engineering Inputs d
Waterford 3 has taken comprehensive actions via specific corrective measures as well as broad programmatic changes to ensure that engineering inputs are accurate and of a superior quality. These measures are briefly j
described below.
A memorandum was issued on May 17,1996, by the General Manager-Plant Operations and engineering management and supervision which provioed instructions to Waterford 3 personnel for increasing the awareness of the Waterford 3 Defense-in-Depth culture. The memorandum clearly stated the importance of questioning the assumptions in procedures, WAs, or other guidance documents particularly when equipment could be degraded and the Technical Specification action statement is not entered.
I Attachment to W3F1-96-0130 1
Page 7 of 16 i
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h A memorandum was issued on June 5,1996, by the Director, Design L
Engineering and the Manager, Systems Engineering to provide interim
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guidance on Engineering inputs. The memorandum established that engineering inputs should not be used to change the way the plant is operated, develop design basis information, or change the configuration of the plant. The memorandum further establishes that engineering inputs will have two signatures including preferably the signature of a supervisor.
Standing Instruction 96-07 was issued and Procedure UNT-007-053 was revised on June 10,1996, to provide additional requirements regarding engineering inputs. Some c,f these requirements include the following: the engineering input will be reviewed against the applicable Technical Specifications, the Shift Technical Advisor (STA) will review the engineering input and provide a recommendation to the Shift Supervisor regarding the adequacy of the engineering input, a 10 CFR 50.59 will accompany the engineering input when the engineering input is establishing a basis for an operability determination, the Project Evaluation Information Request (PEIR) should be used for complex engineering questions or infonnation requests, and the engineering input will have two signatures including the signature of a technical reviewer. The Standing Instruction clearly emphasizes the need to ensure the engineering input is correct.
A case study on engineering inputs was developed and distributed on July 22, 1996, to the appropriate operations and engineering personnel for review stemming from the event having to do with the installation of temporary netting i
above the Wet Cooling Tower (WCT) basin. The case study provided lessons I
learned regarding the effect on plant configuration and the proper use of engineering inputs. The case study also provided a cause analysis and the corrective actions plans.
Entry into Technical Specification LCOs in December 1995, Operations identified the need to significantly improve performance in recognizing and implementing Technical Specification and Technical Requirements Manual LCOs. An effort was begun to fundamentally restructure the Equipment Out Of Service program, which tracks the LCOs at Waterford 3. This restructuring effort was placed in the Operations Excellence Plan.
in April 1996, Operations formed a team to perform a Root Cause Analysis on the degraded trend in Technical Specification and Technical Requirements Manual LCO performance. The Root Cause Analysis (RCA) was associated
t.
Attachmsnt to W3F1-96-0130 Page 8 of 16
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with Condition Report (CR) 96-0497. Some of the actions that have been i
completed as part of CR 96-0497 include the following: (1) guidance has been developed to address the dispositioning of partially completed surveillances; (2) the Operations Manager reinforced his expectations regarding entering i
Technical Specification LCOs via shift supervisor and control room personnel meet ngs; (3) a team consisting of licensing and engineering personnel j
reviewed Procedure OP-100-014 to verify that the procedure accurately reflected management expectations; (4) the shift supervisors reviewed the RCA associated with CR 96-0497 with operations personnel; and (5) t operations procedure writers, systems engineering personnel, and Plant
- Operations Review Committee (PORC) members reviewed the RCA associated with CR 96-0497 to ensure that the proper emphasis is given to i
the review'of revisions to procedures.
Standing Instruction 96-06 was issued to reinforce the policy regarding entry i
j into Technical Specification LCOs. The Standing Instruction clearly i
establishes that should any system, sub-system, or component become unable to perform its intended safety function at any time for any reason, the
- equipment should be declared inoperable and the appropriate action l
statement should be entered. The Standing Instruction further emphasizes that if there is any question as to the operability of a component at any time, it l
is most likely inoperable, and the appropriate Technical Specification LCO j
action should be entered.
(3)
Corrective Steps Which Will Be Taken to Avoid Further Violations Il The following are the corrective actions that will be taken to prevent reoccurrence of this violation.
Specific Conditions Relevant to the Violation This specific event will be reviewed as part of the Engineering Support Personnel (ESP) training provided to engineering personnel.
The Mi procedures which were identified as potentially requiring further enhancement of work instructions will undergo a further review, and any identified enhancements will be implemented.
Engineering Inputs The PElR procedure, " Site Directive W5.602," will be used in the interim to provide the higher tier of engineering evaluations that the engineering input is not allowed to provide.
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Attachmsnt to VV3F1-96-0130 Page 9 of 16 The Engineering Request (ER) process will replace the PElR process for the purpose of engineering evaluations.
Entry into Technical Specification LCOs System Wide Policy MA-102 will replace UNT-005-015. System Wide Policy MA-102 will incorporate a modified definition of a " scope change".which will include taking Technical Specification equipment out of service. The maintenance work package will be treated as a scope change and be re-cubmitted again through the review process if the engineering evaluation identifies the need to remove Technical Specification equipment from service or recommends restricted operating conditions.
The actions that will be implemented as part of the RCA associated with CR 96-0497 are the following: (1) Procedure OP-100-010 will be revised to require a shift RO, SRO, or STA to perform and document an initial screening of LCO applicability; to separate LCO related items from non-LCO'related items in order to allow easier management of affected LCOs; to facilitate tracking of plant conditions, which if changed, could affect LCO requirements; and to allow for tracking of all LCOs entered, not just those LCOs entered due to declaring equipment out of service; (2) an approved reference document will be developed to assist operators in identifying which LCOs to consider when removing equipment from service, and the document will be made an integral part of job planning and scheduling; (3) a plan will be developed to upgrade the Technical Requirements Manual to comply with the improved Technical Specifications standards; and (4) Procedure W4.503 will be revised s
to provide a formal mechanism for requesting Technical Specification clarification guidance and for documenting the clarification guidance.
(4)
Date When Full Compliance Will Be Achieved Waterford 3 is currently in full compliance. The corrective actions taken address the deficiencies and provide improvement measures. The future corrective actions will provide additional improvement measures, and they will be completed by January 30,1997, with the exception of having the ER process replace the PElR process which will be completed by March 30, 1997, and item (2) regarding the development of a Technical Specification reference document which will be completed by October 30,1997.
i At+achmsnt to W3F1-96-0130 Page 10 0f 16 VIOLATION NO. 9605-05 Technical Specification 6.8.1.a requires, in part, that written procedures shall be implemented and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A, Sections 1 and 9, require that the licensee have administrative and maintenance procedures / written instructions.
Site. Directive W2.302, "10 CFR 50.59 Safety and Environmental Impact Evaluations,"
Section 5.2.1 specified that all proposed changes to the facility or procedures that have a potential to affect, either directly or indirectly, nuclear safety or which may change the Updated Final Safety Analysis Report shall receive a 10 CFR 50.59 and environmental impact evaluation screening, Contrary to the above, on March 23,1996, Site Directive W2.302 was not properly implemented in that the licensee made a change to the facility which had the potential L
to affect nuclear safety but did not perform a 10 CFR 50.59 safety and environmental impact evaluation screening. The change involved the installation of 50x40-ft. curtains adjacent to Wet Cooling Tower Basin Train'A and did not evaluate the impact the curtains would have on the operability of the ultimate heat sink following a design-basis tornado event.
l This is a Severity LevelIV violation (Supplement I)(382/9605-05).
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RESPONSE
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(1)
Reason for the Violation l
The root cause of this violation has been determined to be improper work
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practices. The correct process was not used to evaluate placing the net in front of the WCT basin. A process that addresses temporary changes to the plant configuration, (ie. Temporary Alteration Request (TAR)), was not used.
The TAR process would have resulted in a more in-depth evaluation which would have required that a designated engineer complete a Safety Screening / Evaluation per Site Directive W2.302,10CFR50.59 Safety &
EnvironmentalImpact Evaluation.
(2)
Corrective Steps That Have Been Taken and the Results Achieved A memorandum dated May 17,1996, from Waterford 3's General Manager Plant Operations to Plant / Engineering management and supervision was i
i issued which provides instructions to increase awareness to our Defense-in-Depth culture, included in the memorandum is a requirement that whenever
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Attachmsnt to W3F1-96-0130 Page 11 of 16 an engineering input is provided to establish a basis for an operability determination with a degraded component or non-standard line-up, a 10 CFR -
50.59 screening shall accompany the engineering input.
4 A case study on engineering inputs was developed and distributed on July 22, j
1996, to the appropriate operations and engineering personnel for review stemming from the event having to do with the installation of temporary netting above the WCT basin. The case study provided lessons learned regarding the effect on plant configuration and the proper use of engineering inputs.
The case etudy also provided a cause analysis and tne corrective actions l
plans.
i' A Licensee Event Report (LER 96-005) was issued to the NRC documenting i
i this occurrence.
In addition to the above, the corrective actions taken for violation 9605-04 regarding inadequate engineering i.1 puts apply here.
(3)-
Corrective Steps Which Will Be Taken to Avoid Further Violations This event will be reviewed with engineering personnel as part of ESP Continuing Training. The focus of this review will be that engineering evaluations that may affect configuration control shall be performed using an approved configuration change process (i.e. TAR). Also, it will be stressed that engineering evaluations included in engineering inputs must clearly define assumptions and required restrictions such that the engineering input can exist as a stand alone document.
i (4)
Date When Full Compliance Will Be Achieved i
Waterford 3 is currently in full compliance. The corrective actions taken address the deficiencies and provide improvement measures. The future corrective actions will provide additional improvement measures, and they will be completed by January 30,1997.
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Attachmsnt to i
W3F1-96-0130 Page 12 of 16 l'
VIOLATION NO. 9605-06 10 CFR Part 50, Appendix B, Criterion 111 states, in part, that measures shall be established to assure that applicable regulatory requiremere are correctly translated into instructions.
Procedure OP-100-014, " Technical Specification Compliance," Section 6.4, Table A, l
" Addendum to Technical Specification 3/4.7.4," requires that with four wet cooling tower fans inoperable, the maximum dry bulb and wet bulb temperatures shall be less l
than 78.1 degrees F and 71.3 degrees F, respectively.
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Contrary to the above, during March 22 through May 13,1996, the licensee l'
implemented the guidance specified in an Engineering Input for Work Authorization j
01144587 that would have allowed continued plant operation with four wet cooling tower fans inoperable at a dry bulb and wet bulb temperature of less than 85 degrees l
F and 72 degrees F, respectively.
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This is a Severity Level IV repeat violation (Supplement I) (382/9605-06).
RESPONSE
i-(1)
Reason for the Violation
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The root cause for this violation is that inadequate controls were in place.
l Engineering evaluations, that recommend or result in plant operational j
restrictions, had no standard method or process to establish administrative controls for the format, required level of review / approval, and operations i
interface. Although UNT-007-053, Engineering Work Authorization Processing, stated many limitations, guidance on the use of the engineering input form to evaluate work that may impact operability of safety related or technical specification equipment was not included.
Contributing to the violation was that procedure UNT-007-053 did not establish clear standards and expectations for the use of engineering input i
forms. Review of previous engineering inputs demonstrated that the engineering input form is used for a variety of purposes. These include, recommendations for rework not expected in the original work package, clarification of work instruction steps, recommendations for component operability, instructions for changing setpoints and valve positions, and operationa! restrictions under which work can be performed.
Also contributing to the violation was that the work instructions did not include limitations assumed to be imposed by the engineering input. The engineering input only provided a basis for Auxiliary Component Cooling Water (ACCW)
Attachment to W3F1-96-0130 Page 13 of 16 being isolated under the ambient conditions specified. Currently the work packages for tasks such as painting are written with generalinstructions. The planner assumes that any specific work instructions not included in the WA will be added via the engineering input form.
2 In addition, another contributor to the violation was that site administrative procedure UNT-005-015," Work Authorization Preparation And Implementation" was incorrect. Step 5.6.7 of UNT-005-015, defined a change in scope or intent as follows: "If a change to a work authorization affects any other groups involved in the opening review cycle or creates the necessity for review by additional groups, then this shall constitute a change in scope or intent." The engineering evaluation that was obtained to support the request by construction, constituted a change in work scope, and the package she.ld have gone back to planning. However, there appears to be a disconnect between step 5.6.7 of the UNT and the painting notification / checklist. The painting notification / checklist only required that an engineering evaluation be obtained, and the work controls prescribed by UNT-005-015 are not imposed on the painting notification / checklist.
1 Poor Communications is another contributor to the violation in that proper communications did not exist between operations, construction, and engineering to ensure operations was cognizant of assumptions in the engineering input. There was ineffective communication between engineering and operations. Based on conversations with construction, engineering assumed construction would request that operations isolate ACCW flow to one cell of the WCT. Therefore engineering prepared the engineering input with new ambient restrictions based on isolating ACCW flow to one WCT cell.
Engineering assumed that when construction requested ACCW flow to be isolated, the engineering input would provide a basis for operations to perform i
that task. Since construction never needed to isolate ACCW flow, operations was never requested to perform any action. Therefore, the engineering input was not applicable to the actual plant configuration of hanging the net without ACCW flow isolated. The actual plant configuration placed the four.WCT fans out of service, and the restrictions in OP-100-014 were applicable. The new ambient wet bulb restriction was 72 F and the wet bulb restriction in OP-100-014 for removing 4 WCT fans from service is 71.3 F.
l The NRC noted in the cover letter of the inspection report that violation 9605-l 06 was similar to a recent violation, violation 9510-01. There are similarities in j
these two violations in ths.t they both deal with the DCT fans, personnel error, i
communication issues, and in a broad sense input from engineering.
Nonetheless, the two violations are fundamentally different in the following i
manner. The correct process, the corrective action process, was used for i
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i Attachmsnt to 4
VV3F1-96-0130 Page 14 of 16
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I work that led to violation 9510-01. However, the engineering information developed by engineering was incorrect and was not consistent with the licensing basis. Also, the conveyance of the information to operations was not an issue. For violation 9605-06, the proper process for developing engineering information was not used The engineering input form in accordance with Procedure UNT-007-053 was used. The Temporary Alteration Request (TAR) process which addresses changes to plant
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configuration should have been used. The use of the TAR process would i
have resulted in a more in-depth review and ensured that configuration control j
barriers were applied. In this instance, the engineer input was correct and consistent with the licensing basis. Further, there were communication problems which impeded the conveyance of the information to operations.
Therefore, from a standpoint of root causes, corrective actions, and assessing j
the correlation of repeat occurrences, we believe these violations are fundamentally different. This position was discussed with the on-site NRC staff during the 9510 NRC inspection.
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(2)
Corrective Steps That Have Been Taken and the Results Achieved The temporary netting that was placed over the Wet Cooling Toiner was removed on May 14,1996, at approximately 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br />.
In addition to the above, the corrective actions for 9605-04 apply here.
(3)
Corrective Steps Which Will Be Taken to Avoid Further Violations The corrective actions for violation 9605-04 apply here.
(4)
Date When Full Compliance Will Be Achieved Waterford 3 is currently in full compliance. The completion dates for the corrective actions for violation 9605-04 apply here.
Attachment to W3F1-96-0130 l
Page 15 of 16 VIOLATION NO. 9605-09 License Condition 2.E. of the Waterford 3 facility operating license, requires, in part, that the licensee fully implement and maintain in effect all provisions of the Commission-approved physical security plan, including amendments made pursuant to the provisions of the Miscellaneous Amendments and Search Requirements, revision to 10 CFR 73.55, and revisions to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).
Section 6.3 of the Waterford 3 Physical Security Plan requires, in part, that illumination in the protected area be at least 0.2 footcandles.
Contrary to the above, May 18,1996, the licensee failed to ensure that the illumination in the protected area was at least 0.2 footcandles in that the underside of the construction trailers and the space between storage trailers in the gas yard, areas within the protected area, were not illuminated to at least 0.2 footcandles.
This is a Severity Level IV repeat violation (Supplement 111)(382/9605-09).
RESPONSE
(1)
Reason for the Violation The root cause of this violation is inadequate administrative controls in that procedures were not in place that address replacement of or notification of burned out security lighting. A contributing'cause is that measures were not in place that required security personnel to conduct low light area surveys. As a consequence of these deficiencies the area near the underside of the.
construction trailers was not surveyed for illumination and the lights near the storage trailers in the gas yard were not identified as burned out.
The corrective actions for a similar violation identified as 9522-05 were inadequate in that no programmatic changes (procedure changes) were taken to produce a long term solution to the inadequate lighting issue.
(2)
Corrective Steps That Have Been Taken and the Results Achieved A review of the lighting deficiencies was discussed with personnel at the Plan j
of the Day meeting.
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A retraining program has been started to emphasize the proper patro!
i methods and observations, including the responsibility to inspect skirting and l
building areas for proper lighting.
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i Attachment to VV3F1-96-0130 Page 16 of 16 A lighting survey was conducted by Security Management and the Director, Site Support of the Plant's protected area. Lighting survey sheets identifying light deficiencies were given to the electrical department to correct.
(3)
Corrective Steps Which Will Be Taken to Avoid Further Violations Security procedure PS-012-102 will be revised to include steps requiring security officers to notify security supervision immediately upon completion of their first evening patrol of temporary lighting deficiencies. Security will be required to contact the responsible ' department for repairs and request the temporary lighting problems be corrected.
Security personnel will be retrained to further emphasize proper patrol methods and observations, to include their responsibility to inspect skirting and building areas for proper lighting.
A light meter will be provided to security personnel for use in surveying areas for proper lighting.
(4)
Date When Full Compliance Will Be Achieved i
The actions described above will be completed by October 30,1996.
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