ML20140J304

Notice of Violation from Insp on 970428-0502.Violation Noted:Licensee Failed to Translate Design Requirements for Cold Weather Operation of Wet Cooling Tower Into Sys Operating Procedure OP-002-001, Accws, Rev 10

ML20140J304
Person / Time
Site:	Waterford
Issue date:	06/16/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20140J301	List: ML20140J299 ML20140J304 ML20140J316
References
50-382-97-10, NUDOCS 9706190360
Download: ML20140J304 (5)

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ENCLOSURE 1 NOTICE OF VIOLATION Entergy Operations, Inc. Docket No.: 50-382 Waterford Steam Electric Station; Unit 3 License No.: NPF-38 During an NRC inspection conducted on April 28 through May 2,1997, four violations of NRC requirements were identified. In accordance with the " General Statement of Policy l and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

1 A. 10 CFR Part 50, Appendix B, Criterion lit, " Design Control," states, measures shall l be established to assure that applicable regulatory requirements and the design l basis are correctly translated into specifications, drawings, procedures, and I instructions. In addition, measures are required to be established for the l identification and control of design interfaces and for coordination among I participating design organizations.

10 CFR Part 50, Appendix A .erion 34, " Residual Heat Removal," requires that suitable redundancy in comt - ents and features shall be provided to assure that for l onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished assuming a single failure.

Contrary to the above, on May 2,1997, the NRC determined that:

1. The licensee had failed to translate the design requirements for cold weather operation of the wet cooling tower into System Operating Procedure OP-002- j 001, " Auxiliary Component Cooling Water," Revision 10.  ;

2. The licensee had failed to translate the design requirements for seismic j qualification into Maintenance Procedure MM-008-01, "(Inside) Maintenance Access Hatch and (Outside) Maintenance Access Hatch Shield Door Opening, inspection and Closing," Revision 5, the installation instruction for the reactor shield building door. l 1

3. The licensee had failed to establish adequate measures for the identification and control of design interf aces and for coordination among participating I

design organizations. Specifically, the licensee had failed to provide l

adequate coordination between the mechanical and the electrical design l organizations on three occasions:

a. The emergency diesel generator load calculation and the associated Final Safety Analysis Report Table were not updated when Licensing Document Change Request 96-0161 added the manual start of a fuel pool cooling pump 12 heurs after a loss-of-offsite power with a safety injection actuation signal.

9706190360 970616 PDR ADOCK 05000382 G PDR

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l C. Technical Specification 4.8.1.1.2.e, " Electrical Power Systems Surveillance Requirements," requires that each diesel generator shall be demonstrated OPERABLE at least once per 18 months during shutdown by.

"3. Simulating a loss-of-offsite power by itself, and:

1 "a) Verifying deenergization of the emergency busses and load shedding from the ,

emergency busses.  !

l "b) Verifying the diesel energizes the auto-connected shutdown loads through the load sequencer . . . ,

l "b. Simulating a loss-of-offsite power in conjunction with an $1AS actuation test signal, and:

"a) Verifying deenergization of the emergency busses and load shedding from the emergency busses.

"b) Verifying the diesel energizes the auto-connected shutdown loads through the load sequencer."

Contrary to the above, on May 2,1997, the NRC inspector identified that, within the last 18 months, the licensee had not adequately implemented these surveillance requirements. Specifically,

1. The licensee did not verify that the pressurizer heater group circuit l

l breakers opened as required and load shed during the simulated loss-

! of-offsite power test or the loss-of-offsite power in conjunction with the safety injection actuation signal test.

l l 2. The licensee did not verify the following loads correctly shed and started on their corresponding load sequencer block: Shutdown Heat Exchanger A and B room coolers, the Component Cooling Water Heat Exchanger A and B room coolers, and Control Room Heater EHC-34 and Switchgear Room Heater EHC-36.

This is a Severity Level IV violation (Supplement I) i50-382/9710-04).

. i 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 at . Arlington, Texas this 16th day of June 1997 l

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, T Entergy Operations, Inc. E-Mail report to T. Boyce (THB)

E-Mail report to NRR Event Tracking System (IPAS)

E-Mail report to Document Control Desk (DOCDESK)

bec to DCD (IE01) bec distrib. by RIV:

Regional Administrator Resident inspector DRP Director DRS-PSB Branch Chief (DRP/D) MIS System Project Engineer (DRP/D) RIV File Branch Chief (DRP/TSS) l i(

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190013 DOCUMENT NAME: R:\_WAT\WT9710RP.LJS

, To receive copy of document, indicate in box: "C" = Copy without enclosuy "E" = Copy with enclosures "N" = No copy RIV:RI:EB C:EB D:DRf ), ,JJ/ D:DRSA)U LJSmith/Imb PM _ . CAVanDenbyr, qty TPGdy)( @ 7, / _ ATHoWgL W 06 8/97 V fD 06/(/97 NW 06/G4f94 fd #

06fb/9T OFFICIAL RECORD COPY

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Should you have any questions concerning this inspection, we will be pleased to discuss l them with you.  !

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Sincerely,  ;

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h Arthur T. Howell 111, Director Division of Reactor Safety  ;

Docket No.: 50-382 ,

License No.: NPF-38  ;

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Enclosures:

1.: Notice of Violation .

2. NRC Inspection Report 50-382/97 10 cc w/ enclosures:  !

Executive Vice President and Chief Operating Officer Entergy Operations, Inc. .

P.O. Box 31995 Jackson, Mississippi 39286-1995 Vice President, Operations Support Entergy Operotions, Inc.

P.O. Box 31995 Jackson, Mississippi 39286-1995 Wise, Carter, Child & Caraway P.O. Box 651 1 Jackson, Mississippi 39205 General Manager, Plant Operations Waterford 3 SES Entergy Operations, Inc.

P.O. Box B Killona, Louisiana 70066 9

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4 Entergy Operations, Inc. Manager - Licensing Manager

- Waterford 3 SES Entergy Operations, Inc.

P.O. Box B Killona, Louisiana 70066 Chairman Louisiana Public Service Commission One American Place, Suite 1630 Baton Rouge. Louisiana 70825 1697 Director, Nuclear Safety &

Regulatory Affairs Waterford 3 SES Entergy Operations, Inc.

P.O. Box B Killona, Louisiana 70066 William H. Spell, Administrator Louisiana Radiation Protection Division P.O. Box 82135 Baton Rouge, Louisiana 70884-2135 Parish President St. Charles Parish -

P.O. Box 302 f Hahnville, Louisiana 70057 )

Mr. William A. Cross Bethesda Licensing Office 3 Metro Center Suite 610 Bethesda, Maryland 20814 Winston & Strawn 1400 L Street, N.W.

Washington, D.C. 20005-3502 l

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i ENCLOSURE 1 1 NOTICE OF VIOLATION Entergy Operations, Inc. Docket No.: 50-382 Waterford Steam Electric Station, Unit 3 License No.: NPF-38 During an NRC inspection conducted on April 28 through May 2,1997, four violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

A. 10 CFR Part 50, Appendix B, Criterion Ill, " Design Control," states, measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and  ;

instructions. In addition, measures are required to be established for the '

identification and control of design interfaces and for coordination among i participating design organizations. )

10 CFR Part 50, Appendix A, Criterion 34, " Residual Heat Removal," requires that suitable redundancy in components and features shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished assuming a single failure.

Contrary to the above, on May 2,1997, the NRC determined that:

1. The licensee had failed to translate the design requirements for cold weather operation of the wet cooling tower into System Operating Procedure OP-002-001, " Auxiliary Component Cooling Water," Revision 10.

2. The licensee had failed to translate the design requirements for seismic l qualification into Maintenance Procedure MM-008-01, "(Inside) Maintenance Access Hatch and (Outside) Maintenance Access Hatch Shield Door l Opening, inspection and Closing," Revision 5, the installation instruction for the reactor shield building door.

3. The licensee had failed to establish adequate measures for the identification l

and control of design interfaces and for coordination among participating design organizations. Specifically, the licensee had f ailed to provide adequate coordination between the mechanical and the electrical design organizations on three occasions:

a. The emergency diesel generator load calculation and the associated Final Safety Analysis Report Table were not updated when Licensing Document Change Request 96-0161 added the manual start of a fuel pool cooling pump 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after a loss-of-offsite power with a safety injection actuation signal.

9706190360 970616 PDR ADOCK 05000382 G PDR

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b. The emergency diesel generator load calcelation and the associated Final Safety Analysis Report Table were not updated when Mechanical Calculation MN(Q)-9-9, " Wet Cooling Tower During a LOCA," Revision 3, Change 1, paragraph 5.2, changed the operating time of the wet cooling tower fans,

c. The emergency diesel generator load calculation and the associated Final Safety Analysis Report Table were not updated when Licensing Document Change Request 96-0161 changed the length of time that the auxiliary component cooling water system was required to be in service following a large break loss-of-coolant accident.

4. The licensee had not assured that the requirements of General Design Criterion 34 were correctly translated into specifications for the emergency feedwater system, which is credited as a residual heat removal system.

Specifically, Calculation EC-M96-004, " Design Basis Reconstitution for EFW Flow Rate," Revision A, had not been analyzed for offsite electric power system operation (assuming onsite power is not available).

This is a Severity Level IV violation (Supplement 1)(50-382/9710-01).

B. 10 CFR 50.59(a)(2) states, that a proposed change shall be deemed to involve an unreviewed safety question if the probability of malfunction of equipment important to safety previously evaluated in the safety analysis report may be increased.

10 CFR 50.59(b)(1) requires that the licensee maintain records of changes in the f acility and of changes in procedures made pursuant to this section, to the extent that these changes constitute changes in the facility as described in the safety analysis report or to the extent that they constitute changes in the procedures as described in the safety analysis report. Further, these records must includo a written safety cvaluation which provides the bases for the determination that the change does not involve an unreviewed safety question.

Contrary to the above, -on May 2,1997, the NRC determined that the licensee had not provided an adequate bases in their written safety evaluation that a change in diesel generator fuel oil margin did not involve an unreviewed safety questior.

Specifically, the safety evaluation for Licensing Document Change Request 93-0091 did not address the reduction in required fuel oil storage margin and the associated increase in probability that the emergency diesel generator would run out of iuel before 7 days because of uncertainties associated with the time-dependent load method for determining fuel oil storage requirements.

This is a Severity Level IV violation (Supplement l} (50-382/9710-02).

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C. Technical Specification 4.8.1.1.2.e, " Electrical Power Systems Surveillance Requirements," requires that each diesel generator shall be demonstrated  :

OPERABLE at hast once per 18 months during shutdown by-

"3. Simulating a loss-of-offsite power by itself, and:

"a) Verifying deenergization of the emergency  !

busses and load shedding from the emergency busses.

"b) Verifying the diesel energizes the auto-connected shutdown loads through the load sequencer . . .

"5. Simulating a loss-of-offsite power in conjunction with an SIAS actuation test signal, and: l "a) Verifying deenergization of the emergency busses and load shedding from the emergency busses.

"b) Verifying the diesel en'ergizes the auto-connected shutdown loads through the load sequencer."

Contrary to the above, on May 2,1997, the NRC inspector identified that, within the last 18 months, the licensee had not adequately implemented these surveillance requirements. Specifically,

1. Tne licensee did not verify that the pressurizer heater group circuit I breakers opened as required and load shed during the simulated loss- l of-offsite power test or the loss-of-offsite power in conjunction with the safety injection actuation signal test.

2. The licensee did not verify the following loads correctly shed and l started on their corresponding load sequencer block: Shutdown Heat Exchanger A and B room coolers, the Component Cooling Water Heat Exchanger A and B room coolers, and Control Room Heater EHC-34 and Switchgear Roon Heater EHC-36.

This is a Severity Level IV violation (Supplement 1)(50-382/9710-04).

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D. 10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action," states, measures shall be established to assure that conditions adverse to quality, such as failures, i malfunctions, deficiencies, deviations, defective material, and equipment are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and '

the corrective action taken to preclude repetition. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective actions taken shall be documented and reported to appropriate levels of 1 management.

Contrary to the above, on May 2,1997, the NRC determined that the licensee had failed to identify and correct two significant conditions adverse to quality.

Specifically:

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1. The licensee did not correct the deficient design basis for tornado protection )

of the ultimate heat sink and, as a result, they did not identify and correct ,

unprotected e' trical conduit and cables, l l

2. The licensee did unt promptly identify and correct nozzle ring setting deficiencies, similar to those described in information Notice 96-24, " Nozzle Ring Settings on Low Pressure Water-Relief Valves."

This is a Severity Level IV violation (Supplement 1)(50-382/9710-06). j J

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 f acility 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 corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the rcquired response, if an adequate reply is not received within the time specified in this Notice, an order or a 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.

Where good cause is shown, consideration will be given to extending the response time.  !

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l 5-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 j information so that it can be placed in the PDR without redaction. However, if you find it i necessary to include such information, you should clearly indicate the specific information l l 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. '

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j Dated at Arlington, Texas  !

l this 16th day of June 1997  ;

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