ML20117J921

Responds to NRC Re Violations Noted in Insp Rept 50-382/96-03.Corrective Actions:Added Specific Guidelines for Turbine Driven EFW Pump Steam Supply to TS & Performed Root Cause Analysis Re TS Recognition & Implementation

ML20117J921
Person / Time
Site:	Waterford
Issue date:	05/16/1996
From:	James Fisicaro ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20117J915	List: ML20117J921
References
NUDOCS 9606030260
Download: ML20117J921 (6)

Text

I e

i

=Entergy Ent:rgy Oper; tion 2,Inc.

Ro. Box B

==

1 7

James J. Fisicaro

..~. _.

j9)r Dwoctor.

l1, # l EJ l 'l E96W ii d]f"NE!"I c1 r i

![

i~

W3F1-96-0072

- -. ~ _ _ _ _ _.

A4.05

.f!OH il PR l

\\

May 16,1990 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 96-03 Reply to Notice of Violation Gentlemen:

In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in the response to the violation identified in Enclosure 1 of the subject inspection Report.

The violation described in Inspection Report 96-03 involves a Limiting Condition for Operation (LCO) for the turbine driven emergency feedwater pump that was exceeded. This event was determined to be the result of a literal application of the Technical Specification associated with the turbine driven emergency feedwater pump.

By letter dated April 17,1996, the Staff indicated that Waterford 3's response to the violation may reference or include previous docketed correspondence if the correspondence adequately addresses the required response. Waterford 3 submitted Licensee Event Report (LER) 96-002-00 on this event on February 23, 1996. The root cause and corrective actions for this event are included in that LER. contains an abbreviated version of the LER. The Staff also requested l

9606030260 960530 PDR ADOCK 05000392 PDR a

G

r 3

NRC Inspection Report 96-03 l

Reply to Notice of Violation W3F1-96-0072 Page 2

)

l

' May 16,1996 1

that Waterford 3 specify the actions that will be taken to ensure that all l

interpretations of the Technical Specifications are appropriate. This information is also included in Attachment 1.

Should you have any questions concerning this response, please contact me at (504) 739-6242 or Don Vinci at (504) 739-6370.

Very truly yours, Qf i

1 I ur -

James J. Fisicaro Director Nuclear Safety JJF/RTK/tjs Attachment cc:

L.J. Callan (NRC Region IV), C.P. Patel (NRC-NRR),

R.B. McGehee, N.S. Reynolds, NRC Resident inspectors Office 4

l l

i

.---e

~

Att: chm:nt 1 to W3F1-96-0072 Page 1 of 4 ATTACHMENT 1 ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 96-03 j

VIOLATION NO. 9603-03 During an NRC inspection conducted on February 4 through March 16,1996, one violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"(60 FR 34381; June 30,1995), the violation is listed below:

Technical Specification 3.7.1.2 requires, in part, at least three independent steam generator emergency feedwater pumps be operable, with the turbine-driven feedwater pump capable of being powered from an operable steam supply system while the unit is in Modes 1-3. With one emergency feedwater pump inoperable, the action statement requires that the pump be restored to an operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or be in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Contrary to the above, from February 3-8,1994 (approximately 116 hours0.00134 days <br />0.0322 hours <br />1.917989e-4 weeks <br />4.4138e-5 months <br />),

the turbine-driven emergency feedwater pump was inoperable while the unit was in Mode 1 in that Steam Supply Valve MS-401B (i.e., the steam supply system) was inoperable and was not restored to an operable status within 72 i

hours, or the unit placed in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

This is a Severity Level IV violation (Supplement 1).

RESPONSE

(1)

Reason for the Violation l

As described in LER-96-002-00, the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> TS ACTION for the turbine driven emergency feedwater pump being out of service or inoperable was exceeded. This pump was inoperable from February 6,1994, at 1445 hours0.0167 days <br />0.401 hours <br />0.00239 weeks <br />5.498225e-4 months <br /> j

until February 8,1994, at 1117 hours0.0129 days <br />0.31 hours <br />0.00185 weeks <br />4.250185e-4 months <br />. The root cause of this event was determined to be the misleading wording currently in TS 3.7.1.2. The TS Limiting Condition for Operation (LCO) requires that the pump be " capable of being powered from an OPERABLE steam supply system." There are two separate steam supplies (one from each steam generator) to the turbine driven emergency feedwater pump. Operations personnel believed that l

when one MS-401 valve was out of service, the turbine driven emergency feedwater pump would remain operable as long as the second valve was operable. This application of the TS did not consider an event where a Main

Attachm::nt 1 to W3F1-96-0072 Page 2 of 4 Steam or Main Feedwater line break occurs on the steam generator feeding the remaining steam supply valve and the single active failure involves a motor driven emergency feedwater pump. The accident analysis in Chapter 15 of the FSAR assumes an available emergency feedwater flow of 700 gpm (i.e., one turbine driven emergency feedwater pump or two electrical driven emergency feedwater pumps). The literal application of TS 3.7.1.2 resulted

. in this event.

1 (2)

Corrective Steos That Have Been Taken and the Results Achieved As stated in LER-96-002-00, Change 1 to OP-100-014, " Technical Specification Compliance," added specific guidelines for the turbine driven emergency feedwater pump steam supply. These guidelines state that both steam supplies for the turbine driven emergency feedwater pump are required to be operable. If one steam supply is inoperable, the turbine driven emergency feedwater pump is to be declared inoperable.

In the cover letter to inspection Report 96-03, Waterford 3 was requested to specify the actions that will be taken to ensure that all interpretations of the TS are appropriate. Waterford 3 has performed a Root Cause Analysis (RCA) concerning TS recognition and implementation. The following corrective steps have been taken as a result of performing the RCA.

1. The Operations Manager discussed the degraded trend associated with recognition and implementation of TS and Technical Requirements Manual specifications at a meeting of Shift Supervisors and Control Room Supervisors.

2. The Operations Manager added a brief discussion of the trend in the Daily Instructions. This included a short list of questions for Operators to ask themselves when evaluating LCOs.

(3)

Corrective Steos Which Will Be Taken to Avoid Further Violations in the future, Waterford 3 plans to adopt an emergency feedwater TS similar to that in NUREG 1432, " Standard Technical Specifications for Combustion Engineering Plants." Until this TS change is made, training on Change 1 to OP-100-014, " Technical Specification Compliance," will be provided to Operations personnel during Operator Requalification Training. This corrective step is also specified in LER-96-002-00.

Waterford 3 plans to convert to NUREG 1432, " Standard Technical Specifications for Combustion Engineering Plants" following completion of the Waterford 3 power uprate project.

' Attachmsnt 1 to W3F1-96-0072

~..

Page 3 of 4 l

The following additional corrective steps were identified as a result of performing the RCA referenced above and will be implemented.

1. Administrative Procedure OP-100-010 " Equipment Out of Service" will be revised as follows: (Completion Date 07/30/96)

a. A shift Reactor Operator, Senior Reactor Operator (other than the Shift Supervisor), or the Shift Technical Advisor will be required to perform and document an initial screening of LCO applicability.-

b. The documentation for components taken out of service which have associated TS Actions will be separated from the documentation for components taken out of service which do not have TS Actions.

c. Improvements will be made to facilitate tracking of plant conditions, which if changed, could affect LCO requirements.

d. Improvements will be made to allow for tracking of all TS Actions entered, not just TS Actions entered due to declaring equipment out of service.

]

2. A reference document will be developed to assist Operators in identifying which LCOs to consider when removing equipment from service. After 1

development, the reference document will be incorporated into the job planning and scheduling process to ensure that LCO actions are considered early in the process. (Completion Date 10/30/97)

3. Site Procedure W4.503 " Changes to the Technical Specifications, Technical Requirements Manual, or Core Operating Limits Reports" will be revised to provide a mechanism for requesting TS interpretation guidance.

This will include a means for capturing the guidance provided. (Completion Date 08/30/96)

4..The Operations Manager will reinforce his expectations for dispositioning i

questions or potential problems with LCO implementations. '(Completion Date 06/28/96) l 5.' The Operations Department willlead a team composed of the appropriate Licensing and Engineering personnelin performing a thorough review of the i

existing guidance in Administrative Procedure OP-100-014 " Technical

[

Specification Compliance" to determine if the existing guidance accurately j

reflects management expectations. Upon completion of the review, the team will ensure that the information is presented in an easily understood, user friendly format that facilitates the easy location of guidance for particular

{

LCOs. (Completion Date 07/31/96)

L

6. Shift Supervisors will review the RCA Report with their shift personnel. In addition, Systems Engineering personnel and the Plant Operations Review Committee will also review the RCA Report. (Completion Date 06/28/96) m r

- to i

W3F1-96-0072 Page 4 of 4 (4)

Date When Full Comoliance Will Be Achieved Waterford 3 is currently in full compliance. Corrective steps to address the generic concern for ensuring that TS interpretations are appropriate are scheduled to be completed as identified above.

4 i