ML20138K224
| ML20138K224 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 05/05/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20138K222 | List: |
| References | |
| 50-382-97-04, 50-382-97-4, EA-97-101, EA-97-156, NUDOCS 9705120278 | |
| Download: ML20138K224 (3) | |
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ENCLOSURE 1_
i NOTICE OF VIOLATION Entergy Operations, Inc.
Docket No.:
50-382 Waterford Steam Electric Station, Unit 3 License No.:
During an NRC inspection conducted on February 23 through April 5,1997, violations of 1
NRC requirements were identified. In accordance with the " General Statement of Policy 1
and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
A.
Technical Specification 6.2.2.e requires, in part, that administrative procedures be l-developed and implemented to limit the working hours of individuals of the nuclear plant operating staff. In the event that unforeseen problems require substantial amounts of overtime to be used, the following guidelines shall be followed:
... (2) An individual shall not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period, excluding shift turnover time. Deviations shall be approved by the General Manager, Plant Operations: Manager, Technical Services; j
Manager, Operations and Maintenance; Operations Superintendent; or higher levels j
of management.
1 The requirements of Technical Specification 6.2.2.e are partially implemented by Procedure UNT-005-005, " Working Hour Policy for Nuclear Safety-Related Work."
Section 5.2.1 of Procedure UNT-005-005 specified, in part, that approval shall be received prior to exceeding the policy guidelines.
l Contrary to the above, between February 1 and March 1,1997, the licensee failed to implement the requirements of Technical Specification 6.2.2.e and Procedure UNT 005-005 in that there were:
Three individuals exceeded 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in a 24-hour period, excluding shift turnover time, without approval.
Thirty individuals exceeded 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48-hour period, excluding shift turnover time, without approval.
Six individuals exceeded 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7-day period, excluding shift turnover time, without approval.
Twelve instances where the Operations Administrative Assistant, a l
management position below the General Manager, Plant Operations; l
Manager, Technical Services; Manager, Operations and Maintenance; and Operations Superintendent approved working hour deviations.
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i 9705120278 970505 PDR ADOCK 05000382 O
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. Fifteen overtime deviations were approved after exceeding the maximum working-hour limitations.
This is a Severity Level IV violation (Supplement 1)(50-382/9704-01).
B.
5 Technical Specification Limiting Condition of Operation 3.6.6.1 requires two independent Shield Building Ventilation systems to be OPERABLE during Modes 1 through 4. The limiting condition for operation action statement requires that, with one Shield Building Ventilation system inoperable, the inoperable system be restored to operable status within 7 days 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 COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Technical Specification Surveillance Requirement 4.6.6.1.b.3 requires that each Shield Building Ventilation system be demonstrated operable at least once per 18 months by verifying a system flow rate of 10,000 acfm
- 10 percent.
Contrary to the above, on March 5,1997, Shield Building Ventilation Train B was inappropriately declared operable despite test results which indicated that the system flow rate was 11,911 acfm, which exceeded the Technical Specification 4.6.6.1.b.3 required flow rate of 10,000 acfm i 10 percent. Shield Building Ventilation Train B was inoperable from March 5-20,1997, a period greater than 7 days without placing the unit 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 COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
This is a Severity Level IV violation (Supplement 1)(50-382/9704-02).
C.
10 CFR 50.59(a)(1) states, in part, that the holder of a license authorizing operation of a production or utilization facility may make changes in the facility as described in the safety analysis report without prior Commission approval, unless the proposed change test or experiment involves a change in the Technical Specifications incorporated into the license or an unreviewed safety question.
Technical Specification 3.3.3.6, Table 3.310, " Accident Monitoring Instrumentation," and its bases section indicate that position indication for Category 1 containment isolation valves will be consistent with the recommendations of Regulatory Guide 1.97, " Instrumentation for Light-Water-Cooled Nuclear Plants to Assess Plant Conditions During and Following an Accident," Revision 3.
Regulatory Guide 1.97 requires that Type B, Category 1, primary containment isolation valve position indicators provide direct closed /not closed indication.
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Contrary to the above, on May 12,1995, and again on November 1,1995, the L
licensee modified the Updated Final Safety Analysis Report to permit Flow Control Valves EFW-223A(B) and EFW-224A(B) to perform as containment isolation valves, contrary to the requirement of Technical Specification 3.3.3.6, without obtaining prior Commission approval. Specifically, the flow control valves did not have direct closed /not closed position indication as required by the Technical Specification.
This is a Severity Level IV violation (Supplement I) (50-382/9704-06).
Pursuant to the provisions of 10 CFR 2.201, Entergy Operations, Inc. is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission.
ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region IV,611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the l
corrective steps that will be taken to avoid further violations, and (4) the date when full i
compliance will be achieved. Your response may reference or include previous docketed l
correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a i
l Demand for information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken.
i Where good Isause is shown, consideration will be given to extending the response time.
Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction, However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.
Dated this 5th day of May 1997
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