ML20134G100
| ML20134G100 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 02/03/1997 |
| From: | Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Mcgaha J ENTERGY OPERATIONS, INC. |
| References | |
| NUDOCS 9702100272 | |
| Download: ML20134G100 (5) | |
See also: IR 05000458/1996015
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NUCLEAR REGULATORY COMMISSION
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REGION IV
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611 RY AN PL AZA oRIVE, SUITE 400
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ARLINGTON, TEXAS 76011 8064
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FEB - 31997
John R. McGaha, Vice President Operations
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River Bend Station
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Entergy Operations, Inc.
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P.O. Box 220
St. Francisville, Louisiana 70775
SUBJECT: NRC INSPECTION REPORT 50-458/96-15
Thank you for your letter of January 24,1997,in response to our letter and Notice
of Violation dated December 2,1996. We have reviewed your reply and find it responsive
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to the concerns raised in our Notice of Violation. We will review the implementation of
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your corrective actions during a future inspection to determine that full compliance has
been achieved and will be maintained.
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Sin
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J. E. Dyer, D' ector
Division of R
tor Projects
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Docket No.: 50-458
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License No.: NPF-47
cc:
Executive Vice President and
Chief Operating Officer
Entergy Operations, Inc.
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P.O. Box 31995
Jackson, Mississippi 39286-1995
Vice President
Operations Support
Entergy Operations, Inc.
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P.O. Box 31995
Jackson, Mississippi 39286-1995
9702100272 970203
ADOCK 05000458
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Entergy Operations, Inc.
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General Manager
Plant Operations
River Bend Station
Entergy. Operations, Inc.
P O. Box 220
St. Francisville, Louisiana 70775
Director Nuclear Safety
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River Bend Station
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Entergy Operations, Inc.
P.O. Box 220
St. Francisville, Louisiana 70775
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Wise, Carter, Child & Caraway
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P.O. Box 651
Jackson, Mississippi 39205
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Mark J. Watterhahn, Esq.
Winston & Strawn
1401 L Street, N.W.
Washington, D.C. 20005-3502
Manager - Licensing
River Bend Station
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Entergy Operations, Inc.
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P.O. Box 220
St. Francisville, Louisiana 70775
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.The Honorable Richard P. leyoub
~ Attorney General
P.O. Box 94095
Baton Rouge, Louisiana 70804-9095
H. Anne Plettinger
3456 Villa Rose Drive
Baton Rouge, Louisiana 70806
President of West Feliciana
Police Jury-
P.O. Box 1921
St. Francisville, Louisiana 70775
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Entergy Operations, Inc.
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Larry G. Johnson, Director
Systems Engineering
Cajun Electric Power Coop. Inc.
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10719 Airline Highway
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P.O. Box 15540
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Baton Rouge, Louisiana 70895
William H. Spell, Administrator
Louisiana Radiation Protection Division
P.O. Box 82135
Baton Rouge, Louisiana 70884-2135
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FEB - 31997
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Entergy Operations, Inc.
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L. J. Callan
Senior Resident Inspector (Grand Gulf)
DRP Director .
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Branch Chief (DRP/D)
MIS System
Project Engineer (DRP/D)
RIV File
Branch Chief (DRP/TSS)
Leah Tremper (OC/LFDCB, MS: TWFN 9E10)
Resident inspector
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DOCUMENT NAME: R:\\_RB\\RB615AK.LAK
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Branch Chief (DRP/TSS)
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Resident inspector
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DOCUMENT NAME: R:\\_RB\\RB615 AK.LAK
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A4.05
PR
January 21,1997
JM P. 2
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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 50-382/96-13
Reply to Notice of Violation
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Gentlemen:
In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in
Attachment 1 the response to the violations identified in Enclosure 1 of the subject
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Inspection Report.
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Waterford 3 acknowledges the three concerns expressed in the cover letter to the
inspection report: (1) operators failed to follow procedures regarding configuration
control, (2) operators failed to recognize that the wet cooling tower fans were
rendered inoperable during a maintenance activity and failed to enter appropriate
Technical Specification (TS) Limiting Conditions for Operation, and (3) review of the
Inservice Test (IST) program did not identify the need to perform testing on the dry
cooling tower isolation valves which are required to be repositioned during the design
basis tornado event.
Regarding the first concern, Waterford 3 has previously identified an increasing trend
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in the number of human performance violations. Our comprehensive corrective
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actions to address that trend are detailed in Letter W3F1-96-0213 dated 12/13/96.
We believe those corrective actions, in concert with the actions detailed in
Attachment 1, will help prevent similar violations from recurring and will improve
operator attentiveness.
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-940/23o/68,
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Reply to Notice of Violation (IR 96-13)
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January 21,1997
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In addition to the corrective actions detailed in Attachment 1 for the second concern,
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we are continuing to implement corrective actions from the FOCUS plan (reference
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Letter W3F1-96-0130 dated 8/19/96) to improve our performance in the area of TS
implementation. These actions include enhancing the procedure process, utilizing
assessments as a tool to identify additional improvement opportunities, improving
operator awareness of plant conditions prior to approving maintenance activities, and
establishing specific guidance concerning the control of work and pre-job briefings to
ensure proper Operations oversight. Furthermore, Waterford 3 management has
placed significant focus on assuring that the culture and policy for implementing
Technical Specifications are conservative from a safety standpoint and comply with
regulatory requirements.
Regarding the third concern, the dry cooling tower isolation valves will be added to
the IST plan. Furthermore, we are developing a document that details the design
basis tornado event. This document should increase the probability that similar
conditions, if they exist, are identified and corrected.
Should you have any questions concerning this response, please contact
me at (504) 739-6666 or Jeff Thomas at (504) 739-6531.
Very truly yours,
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T.J. Gaudet
Acting Director,
Nuclear Safety & Regulatory Affairs
TJG/GCS/tjs
Attachment
cc:
E.W. Merschoff (NRC Region IV)
C.P. Patel (NRC-NRR)
R.B. McGehee
N.S. Reynolds
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NRC Resident inspectors Office
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Attachm:mt to
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Page 1 of 8
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ATTACHMENT 1
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ENTERGY OPERATIONS. INC RESPONSE TO THE VIOLATION IDENTIFIED IN
ENCLOSURE 1 OF INSPECTION REPORT 96-13
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VIOLATION NO. 9613-01
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Technical Specification 6.8.1.a requires, in part, that written
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procedures shall be implemented covering applicable procedures recommended in
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Appendix A of Regulatory guide 1.33, Revision 2, February 1978. Appendix A,
Section 3, requires that the licensee have procedures for operation of safety related
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systems.
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Procedure OP-002-010. " Reactor Auxiliary Building HVAC and Containment
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Purge," Revision 11, Section 6.6, required that the airbome radioactivity
removal system be secured when stopping containment purge.
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Contrary to the above, on October 1,1996, the licensee failed to secure the
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airborne radioactivity removal system after stopping containment purge. The
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airborne radioactivity removal system was not secured until observed in the
abnormal configuration on October 20,1996, a period of 19 days.
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2.
Procedure OP-002-003, " System Operating Procedure - Component Cooling
Water System," Revision 10, Section 6.0, " Normal Operations," required the
dry cooling tower fan control switches be in the AUTO position.
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Contrary to the above, on October 19,1996, at 3:37.a.m., operators
inadvertently placed the Dry Cooling Tower Fan 13-B control switch in the
OFF position. The switch remained in the OFF position until observed in the
abnormal configuration at 4:40 p.m. on October 20, a period of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
3.
Procedure OP-903-121, " Safety Systems Quarterly IST Valves Tests,"
Revision 1, Section 7.2, " Safety injection Train B," requires that Valve S11398
be closed following inservice testing.
Contrary to the above, on November 19,1996, at 1:42 a.m., operators failed
to close Valve SI-1398 following inservice testing. Valve SI-139B was not
closed until operators observed the abnormal configuration at 4 p.m. on
November 21,1996, a period of 62 hours7.175926e-4 days <br />0.0172 hours <br />1.025132e-4 weeks <br />2.3591e-5 months <br />.
This is a Seve@ Level IV violation (Supplement 1). (50-382/9613-01)
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RESPONSE
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(1)
Reason for the Violation
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This violation was due to personnel error and inattention to detail in that
operators involved with each of the occurrences failed to follow procedures
and failed to closely monitor activities that were taking place on the control
board. The operators are required to be cognizant of activities on all the -
control panels and the attention given to the control panels with the incorrect
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configurations was not adequate. The operations shift turnover on the plant
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configuration was inadequate in that configuration errors existed over several
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shifts and were never discussed or identified by the oncoming shifts until 19
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days for example 1,36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> for example 2 and 62 hours7.175926e-4 days <br />0.0172 hours <br />1.025132e-4 weeks <br />2.3591e-5 months <br /> for example 3 of the
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violation. In addition, Operations supervisory personnel (Control Room
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Supervisor (CRS) and Shift Superintendent [SS) ) did not provide adequate
oversight of the activities taking place on the control panels.
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Contributing to the failure to follow procedure OP-002-010, " Reactor Auxiliary
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Building HVAC and Containment Purge," to secure the airborne radioactivity
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removal system was an inadequate place keeping method in procedure OP-
002-010. This procedure does not have sign-offs for each action step
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delineated. Consequently, steps in the procedure, such as those sccuring the
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airborne radioactivity system, may be overlooked due to a sign-off not being
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required. In addition, Operations supentisory personnel (Control Roam
Supervisor (CRS] and Shift Superintendent [SS) ) did not provide adequate
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oversight of the activities taking place on the control panels.
Contributing to the failure to follow procedure OP-002-003, " System Operating
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Procedure- Component Cooling Water System," which requires the Dry
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Cooling Tower Fan 13-B control switch to be in Auto position was that there is
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no difference in light indication on the DCT fan control switch when the switch
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is in auto position compared with the off position. The operators rely on the
position of the control knob pointer to determine the position of the control
switch. In addition, Operations supervisory personnel did not provide
adequate oversight of the activities taking place on the control panels.
Contributing to the failure to follow Section 7.2, " Safety injection Train B," of -
procedure OP-903-121, " Safety Systems Quarterly IST Valves Tests," was
that the operators, who should have closed valve SI-139 from the control
board, were involved with another activity which distracted their attention and
caused them to overlook the position of valve SI-139. Even though
distractions are a cue to self checking, proper self checking was not done. In
addition, Operations supervisory personnel did not provide the proper work
environment to minimize these distractions.
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(2)
Corrective Steos That Have Been Taken and the Results Achieved
1.
Condition reports 96-1639,96-1640 and 96-1847 were generated for
each one of the self-identified occurrences.
2.
All the components were placed in their correct configuration.
3.
All the operators involved with the failure to restore the plant to its
correct configuration have been counseled.
4.
Operations Manager reinforced the operators requirement to perform
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thorough control board walkdowns.
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All control room operators are required to sign a new addendum sheet
to the shift log indicating completion of control board panel walkdowns.
(3)
Corrective Steos Which Will Be Taken to Avoid Further Violations
1.
The Operations Manager will issue a letter to all Shift Superintendent
and Contro! Room Supervisors which will emphasize the importance of
properly prioritizing tasks to avoid excessive operator work load.
2.
The Operations Manager will clarify to operations supervisory
personnel the expectation that licensed operators have responsibility
for monitoring plant controls. The supervisory personnel will convey
these expectations to the operations staff.
3.
The Operations department will form a team to review and improve, if
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appropriate, the current method used for shift turnover. A review of the
inadequacy of reviewing shift logs will also be performed.
4.
A review will be performed on normal operating procedures to
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determine if the method for place keeping in procedures can be
improved.
(4)
Date When Full Comoliance Will Be Achieved
Waterford 3 is in full compliance. Items 1,2, and 3 will be completed by
2/28/97 and item 4 will be completed by 7/1/97.
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ATTACHMENT 1
ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN
ENCLOSURE 1 OF INSPECTION REPORT 96-13
VIOLATION NO. 9613-03
Technical Specification 3.7.4.f requires, in part, that, with more than one wet cooling
tower fan inoperable and the outside air temperature greater than 70 degrees F, the
dry bulb temperature must be determined at least once every 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
Contrary to the above, between May 5 and 9,1996, with more than one wet cooling
tower fan inoperable and the outside air temperature greater than 70 degrees F, the
licensee did not determine the dry bulb temperature at least once every 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
This is a Severity Level IV violation (Supplement 1). (50-382/9613-03)
RESPONSE
(1)
Reason for the Violation
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Entergy Operations admits this violation and believes that the root cause is
inadequate work controls in that the method used in the engineering
evaluations was not standardized. There was no standard method or process
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to establish administrative controls for the format, required level of
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review / approval, and operations interface of the evaluation that was used to
document the inoperability of the _ wet cooling tower fans. Guidance on the use
of engineering input to evaluate work that may impact operabilty of safety
related or technical specification equipment was inadequate. As a result, an
adequate level of review of the engineering evaluation was not performed and
the fact that the wet cooling tower fans would be rendered inoperable while
netting was placed around the wet cooling tower basin was not clearly
communicated to operations. As a result of operations not being cognizant of
the wet cooling tower fans inoperability, the required actions per Technical Specification 3.7.4.f was not performed.
(2)
Corrective Steos That Have Been Taken and the Results Achieved
1.
Condition report 96-729 was generated to document and address this
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matter.
2.
LER 96-005 Revision 0 was issued to report this occurrence.
3.
The temporary netting that rendered the fans inoperable was removed.
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Page 5 of 8
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4.
Operations Administrative Procedure OP-100-014, " Technical
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Specification Compliance," has been revised to require the following:
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a.
If any system, sub-system, or component becomes unable to
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perform its intended safety function due to surveillance,
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calibration, or maintenance, then declare that equipment
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inoperable and enter the appropriate Tech / Spec TRM (Technical
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Requirements Manual) action.
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b.
If a component is thought to be Inoperable enter the appropriate
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Tech Spec /TRM action and initiate LCO tracking in accordance
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with OP-100-010, " Equipment Out of Service."
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c.
The engineering guidance should have at least two signatures
on it indicating that a technical review has been performed.
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d.
The engineering guidance must be specifically bounded against
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any applicable Tech Specs. All engineering guidance
parameters must be bounded by Tech Spec parameters, and in
all cases, operators will adhere to the Tech Specs.
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e.
The STA should perform a review of the engineering guidance
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and provide a recommendation to the SS concerning the
adequacy of the guidance.
5.
Plant Administrative Procedure UNT 007-053 " Engineering Work
Authorization," has been revised to specify the following:
a.
An engineering input will not be used to make operability
determinations for technical specifications or safety related
equipment, nor will it be used to implement configuration '
changes.
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b.
. All nonconformance conditions are addressed by Corrective
Action Site Directive, W2.501,
c.
Engineering inputs are only used to facilitate work such as
bolting, torquing, gasketing, material condition improvements,
troubleshooting and venting requirements.
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d.
All engineering inputs require a technical reviewer signature.
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Page 6 of 8
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(3)
Corrective Steos Which Will Be Taken to Avoid Further Violations
The Engineering Request process will replace the Problem
Evaluation /Information Request (PElR) for the purpose of engineering
evaluations.
(4)
Date When Full Comoliance Will Be Achieved
Waterford 3 is currently in full compliance. The above corrective action will be
completed by 9/30/97.
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ATTACHMENT 1
ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN
ENCLOSURE 1 OF INSPECTION REPORT 96-13
VIOLATION NO. 9613-04
10 CFR 50.55a(g) requires, in part, that inservice testing to verify operational
readiness of pumps and valves whose function is required for safety be
accomplished in accordance with Section XI of the ASME Boiler and Pressure Vessel
Code.
Contrary to the above, as of October 29,1996, the licensee failed to verify the
operational readiness of certain valves whose function is required for safety in
accordance with Section XI of the ASME Boiler and Pressure Vessel Code.
Specifically, the licensee failed to perform testing which ensured the operational
readiness of manually operated dry cooling tower isolation valves used to maintain
the safety function of the ultimate heat sink during the design basis tornado event.
This is a Severity Level IV violation (Supplement 1). (50-382/9613-04)
RESPONSE
(1)
Reason for the Violation
The root cause of this violation is believed to be insufficiently explicit design-
basis tornado event documentation. The documentation was not specific
enough to readily allow the IST plan reviewers to conclude that the Dry
Cooling Tower inlet and outlet valves had a safety function and should be
included in the IST program for testing. These valves were not included in the
IST plan during initial IST plan development, during the IST design basis
document (DBD 24) review, or during the current (although not completed)
review of all ASME Class 1,2, and 3 valves.
A contributing cause for this violation was that the reviewer did not examine all
of the available design basis tornado event documentation during the current
IST plan review process. It is believed that had the reviewer examined the
calculation related to the design basis tornado event, he would have
concluded that the Dry Cooling Tower inlet and outlet valves should have
been in the IST plan.
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Page 8 of 8
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(2)
Corrective Steos That Have Been Taken and the Results Achieved
The Dry Cooling Tower manual inlet and outlet valves were successfully
tested per IST requirements on 12/7/96.
(3)
Corrective Steos Which Will Be Taken to Avoid Further Violations
1.
The Dry Cooling Tower Manual inlet and outlet valves will be included
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in the IST program.
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2.
A review of the design basis tornado event will be performed and the
design basis documents will be revised, as necessary, based on the
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results of the review.
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3.
The IST basis document will be reviewed by the appropriate design
engineering disciplines in support of the development of the IST plan
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for the second ten interval.
(4)
Date When Full Comoliance Will Be Achieved
Waterford 3 is in full compliance. Item 1 will be completed by 1/31/97, item 2
will be completed by 8/31/97 and item 3 will be completed by 12/1/97.
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