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Undated Ltr Acknowledging Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/97-01.Response to Second Violation Lacking,In That, Described Corrective Actions Narrowly Focussed
	ML20141H127
Person / Time
Site:	Waterford
Issue date:	05/21/1997
From:	Howell A; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dugger C; ENTERGY OPERATIONS, INC.
References
	50-382-97-01, 50-382-97-1, NUDOCS 9705230200
	Download: ML20141H127 (6)
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UNITED STATES

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Charles M. Dugger, Vice President

Operations - Waterford 3

Entergy Operations, Inc.

P.O. Box B

Killona, Louisiana 70066

SUBJECT: NRC INSPECTION REPORT 50-382/97-01 AND NOTICE OF VIOLATION

Dear Mr. Dugger:

Thank you for your letter of April 21,1997, in response to our letter and Notice of

Violation dated March 21,1997. We have reviewed your reply and find it responsive only

to the concerns raised in our Notice of Violation for the first violation (50-382/9701-01).

Your re.sponse to 1Se second violation (50-382/9701-02) was lacking, in that, the

described correc ,vc actions were narrowly focussed. Specifically, the NRC inspectors

reviewed 14 plant systems and the site structures monitoring program during the

Maintenance Rule Baseline Team inspection at the Waterford-3 site. We identified five

examples of inadequate monitoring. Our review was a sampling of the total inventory of

Waterford-3 systems, trains, and components. Your April response letter did not address

the acceptability of nonsampled systems, trains, and components. Therefore, a potential

exists that the effectiveness of maintenance on other systems, trains, or components is

not being monitored as .*equired by the Maintenance Rule. Consequently, your response to

the violation should addreas the more broader aspects of your corrective actions. We

discussed this need for supplemental information with Mr. P. L. Caropino on May 5,1997. l

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in accordance with 10 CFR 2.201, you are required to provide an additional response !

within siO days of the dato of this letter addressing the corrective actions that have been

taken and the results achieved. The NRC will use this additional response to determine

whether further enforcement action is necessary to ensure compliance with regulatory

requirements, l

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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, l

its enclosure (s), and your response will be placed in the PDR without redaction.

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9705230200 970521

PDR ADOCK 05000382

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Entergy Operations, Inc. -2- l

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Should you have any questions concerning this matter, contact me at (817) 860-8180 or .;

Dr. Dale A, Powers at (817) 860-8195. j

Sincerely,

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Arthu T. Howell Ill, Director !

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Division of Reactor Safety !

Docket No.: 50-382

. License No.: NPF-38 ,

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Executive Vice President and {

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Entergy Operations, Inc. l

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P.O. Box 31995 i

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Jackson, Mississippi 39286-1995

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Vice President, Operations Support

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Entergy Operations, Inc. ;

P.O. Box 31995 l

Jackson, Mississippi 39286-1995 !

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Wise, Carter, Child & Caraway

' P.O. Box 651 l

Jackson, Mississippi 39205 i

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General Manager, Plant Operations :

Waterford 3 SES i

Entergy Operations, Inc. l

P.O. Box B

Killona, Louisiana 70066

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Manager - Licensing Manager -

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Waterford 3 SES

Entergy Operations, Inc.

P.O. Box B

Killona, Louisiana 70066 l

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Chairman

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Louisiana Public Service Commission

One American Place, Suite 1630

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Baton Rouge, Louisiana 70825 1697

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Entergy Operations, Inc. -3-

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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

SParish Prcaldent

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St. Charler, Parish

P.O. Box 302

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

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Entergy Operations, Inc. -4-

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E-Mail report to_T. Boyce (THB)

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

E-Mail report to Document Control Desk (DOCDESK)

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bec to DCD (IE01)

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Regional Administrator Resident inspector

DRP Director DRS-PSB

Branch Chief (DRP/D) MIS System

Project Engineer (DRP/D) - RIV File

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DRS Al 97-G-0040

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DOCUMENT NAME: R:\_WAT\WT701 ak. jew j

To receive copy of document, Indicate in box: "C" = Copy wyhput encigsures "E" = Copy with enclosures "N" = No copy

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DOCUMENT NAME: R:\_WAT\WT701 ak. jew

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Ksona LA 70066

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REGION N

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April 21,1997

U.S. Nuclear Regulatory Commission

ATTN: Director, Office of Enforcement

Washington, D.C. 20555

Subject: Waterford 3 SES

Docket No. 50-382

License No. NPF-38

NRC Inspection Report 97-01

Reply to Notice of Violation

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

inspection Report.

If you have any questions concerning this response, please contact Tim Gaudet at

(504) 739-6666.

Very truly yours,

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- E. C. Ewing

Director

Nuclear Safety & Regulatory Affairs

ECE/DMU/tjs

Attachments

cc: [E.W Merschoff (NRC Region IV), C.P. Patel (NRC-NRR),

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

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W3F1-97-0076 ,

Page 1 of 6 t

ATTACHMENT l l

, ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATIONS IDENTIFIED IN

ENCLOSURE 1 OF INSPECTION REPORT 97-01 .

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VIOLATION NO. 9701-01

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10 CFR 50.65(b)(1) states, in part, that the scope of the monitoring program shall

include safety-related structures, systems, and components. Paragraph (c) states,

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"the requirements of this section shall be implemented by each licensee no later than

July 10,1996." i

Contrary to the above, as of January 31,1997, the safety-related containment

atmospheric release system was not included in the licensee's 10 CFR Part 50.65

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monitoring program scope.

This is a Severity Level IV violation (Supplement 1) (50-382/9701-01).

RESPONSE

(1) Reason for the Violation

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Entergy admits this violation and believes the cause to be the result of

misinterpretation of 10CFR50.65 paragraph (b)(1), Regulatory Guide 1.160 !

and NUMARC 93-01 Section 8.2.1.1. The scoping decision to not include i

containment atmosphere release (CAR) system was originally made and

approved by the Maintenance Rule Expert Panel based on assessing the

system against criteria specified in 10CFR50.65 (b)(1), Regulatory Guide

1.160 and Section 8.2.1.1 of NUMARC 93-01. That Safety-Related scope

inclusion criteria consists of the system's ability to maintain the (1) integrity of

the reactor coolant pressure boundary, (2) capability to shutdown the reactor

and maintain it in a safe shutdown condition and (3) capability to prevent or

mitigate the consequences of accidents that could result in 10 CFR Part 100

limits. The basis for not including this system within scope was that, even

though it was designated at Waterford 3 as safety-related, CAR (1) does not

effect the integrity of the reactor coolant pressure boundary, (2) is not used to

shutdown or maintain the reactor shutdown and (3) does not provide an

accident safety function or prevent maintaining offsite exposure limits within

10 CFR Part 100 guidelines. The CAR system provides a long term post

accident cleanup function. The system's containment isolation function was !

adequately scoped in the rule under Containment Building. However, based

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Attechment to

W3F1-97-0076

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on the system's safety related designation, its function to transfer combustible

gases from the containment failed to be scoped into the rule.

(2) Corrective Steps That Have Been Taken and the Results Achieved

Condition Report 97-0256 was generated to place this event in the corrective

action program.

The containment atmosphere relief system has been included in the

Maintenance Rule Program.

The justification for the scoping of all remaining SSCs was verified to be in

accordance with this interruption of criteria of 10 CFR 50.65(b).

(3) Corrective Steps Which Will Be Taken to Avoid Further Violations

The containment atmosphere release system will be monitored against

reliability criteria. The reliability performance criteria will be established, a

historical review of the system will be performed and system categorization

made if determined that (a)(1) status is warranted, then (a)(1) goals will be.

established.

(4) Date When Full Compliance Will Be Achieved

The above actions will be completed by August 30,1997, when system

categorization will be made and, if needed, (a)(1) goals established. Upon

completion of the above, Waterford 3 will be in full compliance.

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ATTACHMENTl

ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATIONS IDENTIFIED IN

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ENCLOSURE 1 OF INSPECTION REPORT 97-01

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] VIOLATION NO. 9701-02

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10 CFR 50.65(a)(1) states, in part, that each holder of an operating license shall

i monitor the performance or condition of structures, systems, or components, against

licensee-established goals and that such goals shall be established commensurate

with safety.

I ' 10 CFR 50.65(a)(2) states, in part, that monitoring under paragraph (a)(1) is not

required where it has been demonstrated that the performance or condition of a

structure, system, or component is being effectively controlled through the

j performance of appropriate preventive maintenance such that the structure, system,

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or component remains capable of performing its intended safety function. Paragraph

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(c) states, "the requirements of this section shall be implemented by each licensee

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no later than July 10,1996."

I Regulatory Guide 1.160," Monitoring the Effectiveness of Maintenance at Nuclear

. Power Plants," Revision 1, endorses NUMARC 93-01, " Industry Guidelines for

I Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Revision 0,

as an acceptable method for implementing the requirements of 10 CFR 50.65.

Regulatory Guide 1.160 states that the methods described in the guide will be used

in the evaluation of the effectiveness of maintenance activities of licensees who are

L required to comply with 10 CFR 50.65 unless a licensee has proposed an acceptable

alternative method for compliance.

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NUMARC 93-01, Section 9.3.2 states, in part, that performance criteria for evaluating

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structures, systems, or components are necessary to identify the standard against

which performance is to be measured. Criteria are established to provide a basis for

! determining satisfactory performance (for structures, systems, or components

.- monitored under paragraph (a)(2)). Additionally, Section 9.3.2 states that

performance criteria for risk-significant structures, systems, and components be

established to assure that reliability and availability assumptions used in the plant-

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specific probabilistic risk assessment, individual plant examination, or other risk

determining analysis are maintained or adjusted when necessary. ~ Appendix B of

NUMARC 93-01 defines availability as the time that a structure, system, or

component is capable of performing its intended functio ~n as a fraction of the total

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1W3F1-97-0076

Page 4 of 6

time that the intended function may be demanded . . the numerical complement of

unavailability.

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.The licensee subscribed to the NUMARC 93-01 methodology in Procedure Tl 4.22,-

" Maintenance Rule Program," Revision 0. As a measure to demonstrate the ability of-

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certain risk-significant systems and components to perform the intended functions,

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the licensee chose to monitor unavailability of risk-significant systems.

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j Contrary to the above, as of January 31,1997, for the reactor protection system, the

engineered safety features actuation system, the core protection calculators, the

broad range toxic gas monitors, and the containment polar crane function of lifting

heavy loads over safety-related equipment, the licensee: (1) failed to establish goals

commensurate with safety as described in 10 CFR 50.65(a)(1); or (2) as an

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alternative, failed to demonstrate that the performance of the above specified

' systems components, and functions were effectively controlled through the

performance of appropriate preventive maintenance and that the systems and

components remained capable of performing their intended function, in that, neither

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the unavailability of the functions performed by the systems and components were

monitored, nor an acceptable alternative method for compliance proposed.

This is a Severity Level IV violation (Supplement 1) (50-382/9701-02).

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l RESPONSE

i. (1) Reason for the Violation

io Entergy admits to this violation which addresses 5 systems. The reason for

the violation pertaining to the containment polar crane was personnel error.

g Although cranes were scoped in the Maintenance Rule, the lift function of the

cranes over safety related equipment was inadvertently overlooked and is

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further discussed in item 1 below.

I The reason for the violation on the plant protection system (PPS), core

, protection calculators (CPCs), engineered safety features (ESF) actuation

system and broad range gas monitors was an inadequate determination of the

i monitoring requirements of those components and systems. This is

addressed further in items 2 and 3 below.

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1; Waterford 3 initially scoped all cranes with the building in which they are

located and only monitored the structural function of the cranes. The

crane function associated with the safe lifting of heavy loads was not

monitored at the plant, system, or component level. Failure to monitor

the functions related to lifting loads does not provide assurance of the

success of these functions.

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2. The decision to exclude PPS availability performance monitoring was

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based on: (1) system design conservatism, (2) no change in risk from

individual channel unavailability and (3) availability monitoring would be

redundant to reliability monitoring already being performed. However,

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i the decision failed to recognize the importance of individual channel

, availability monitoring as a precursor to overall PPS reliability. The PPS

is designated as risk significant; but, Waterford 3 determined that

monitoring unavailability of this system was not required based on: (1)

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the conservative 2 out of 4 logic inherent in the system's design, (2) on

occasion with a channel out-of-service (by-pass or trip) the Probabilistic

Safety Assessments (PSA) risk associated with the system did not

change and (3) unavailability of the system would be reflected in

maintenance preventable functional failures and therefore redundant.

For these reasons, monitoring maintenance preventable functional

failures was felt sufficient without availability monitoring to assess the

overall performance of the systems. The above reason also applies to

the CPCs and ESF actuation systems not being monitored for

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unavailability.

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g 3. The focus for the broad range gas monitors' availability performance

criteria was on maintaining the overall control room isolation function. It

did not consider individual monitor unavailability as a precursor to overall

broad range gas monitor reliability. The broad range gas monitors

provided train isolation signals for the control room envelope on detection

of toxic chemicals. The broad range gas monitors were not considered

, unavailable when the monitors were taken out-of-service because the

control room was placed in an isolated condition and the isolation

actuation function was not needed. Additionally, when a single train was

taken out-of-service, the function of the system was considered to be

available with the remaining monitor and did not count the out-of-service

monitor as unavailable.

Performance monitoring under (a)(2) for redundant or installed spares of

multi-train risk significant systems provides an indication of the overall

reliability of the system. This is reflective in that all of the risk significant

system redundant or installed spares are and have been monitored

against reliability performance criteria under (a)(2). In addition, except

for those systems identified in this violation, availability performance

monitoring under (a)(2) has and is being performed on risk significant

system redundant or installed spare components and trains.

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(2) Corrective Steps That Have Been Taken and the Results Achieved . ;

Condition Report 97-0257 was generated to place this event in the corrective -

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action program.

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(3) Corrective Steps Which Will Be Taken to Avoid Further Violations !

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Provisions will be made to monitor under 10 CFR50.65 paragraph (a)(2) the' j

availability performance of the broad range gas monitors, PPS, CPCs and the j

ESF actuation system. The PSA will be reviewed and unavailability criteria' .

. established accordingly. These criteria will be reviewed and approved by the !

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Expert Panel. The availability maintenance history of these systems will then

be reviewed against their respective (a)(2) unavailability performance criteria ;

and system categorization made if determined that (a)(1) status is warranted, ;

,' then (a)(1) goals will be established. ;

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Provisions will be made to monitor under 10 CFR50.F5 paragraph (a)(2) the l

reliability performance of the lift function of the containment polar crane. in

addition, the (a)(2) reliability performance criteria will be established and i

approved by the Expert Panel. A reliability historical review will be performed

against criteria established and system categorization made. If determined

that (a)(1) status is warranted, then (a)(1) goals will be established. !

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(4) Date When Full Compliance Will Be Achieved

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The above actions will be completed by August 50,1997. At that time, system

categorization will be made and, if needed, (a)(1) goals established. Upon

i completion of the above, Waterford 3 will be in full compliance.

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ML20141H127

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