ML20148C320
| ML20148C320 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 05/09/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20148C314 | List: |
| References | |
| EA-97-099, EA-97-99, NUDOCS 9705150331 | |
| Download: ML20148C320 (4) | |
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AND PROPOSED IMPOSITION OF civil PENALTY Entergy Operations, Inc.
Docket No. 50-382 Waterford-3 Steam Electric Station License No. NPF-38 EA 97-099 l
During an NRC inspection completed February 28,1997, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the Nuclear Regulatory Commission proposes to j
impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act),42 U.S.C. 2282, and 10 CFR 2.205. The particular violations and associated civil penalty are set forth below 1
A.
The limiting condition for operation for Technical Specification 3.6.2.2,
" Containment Cooling System," requires, in part, that two independent groups of containment cooling fans shall be operable, with one fan system to each group in Modes 1, 2, 3, and 4.
Technical Specification 4.6.2.2.b.2 requires that each group of containment cooling fans shall be demonstrated operable at least once per 18 months by verifying a cooling water flow rate of greater than or equal to 1325 gpm to each cooler.
Contrary to the above, from October 31,1995, to August 23,1996, the licensee operated the facility without assuring that two independent groups of containment cooling fans were operable. Specifically, in October 1995, the licensee performed a flow balance test which showed that the flow achieved through each containment cooling fan was less than required by Technical Specification 4.6.2.2.b.2 (i.e., less than 1325 gpm for each cooler). On August 23,1996, special flow balance testing demonstrated that at least one fan cooler in each train was capable of achieving the TS acceptance criteria flow. (01013)
B.
Criterion 111 of Appendix B to 10 CFR Part 50 states, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis as defined in 10 CFR 50.2 are correctly translated into specifications, drawings, procedures, and instructions.
Table 6.2-21 of the Waterford-3 Updated Final Safety Analysis Report (UFSAR) specified that the component cooling water accident flow rate through each containment cooling fan was 1350 gpm." The UFSAR, on page 6.2-11, specified that tha main steamline break analysis assumed three containment cooling fans operated.
- On February 11,1997, the licensee changed the design basis regarding CCW flow through the CFCs from 1350 to 1100 gpm via the 10 CFR 50.59 process.
9705150331 970509 PDR ADOCK 05000382 G
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i Notice of Violation Contrary to the above, for the dates specified below, the licensee's measures to assure that the design basis for the containment cooling system was correctly translated into specifications, drawings, procedures, and instructions, were inadequate. Specifically:
1.
From initiallicensing on March 16,1985, until February 11,1997, the equipment manufacturer's spechied maximum expected clean-tube cookng water flow (1350 gpm) was used as the minimum accident flow assumed in the loss-of-coolant and main steamline break accident analyses, an
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unrealistic and unachievable design assumption because it left no margin for fouling or other degradation.
2.
From January 2,1991, until February 11,1997, the main steamline break analysis of record assumed three containment cooling fans would be in operation following a main steamline break, an assemption that was in conflict with, and nonconservative with respect to, Technical Specification 3.6.2.2, which required only two containment cooling fans to be operable.
3.
From initiallicensing on March 16,1985, until February 11,1997, Technical Specification 4.6.2.2.b.2, which requires that each group of containment cooling fans shall be demonstrated operable at least once per 18 months by verifying a cooling water flow rate of greater than or equal to 1325 gpm to each cooler, conflicted with the design basis value assumed in the UFSAR of 1350 gpm to each cooler. (01023)
C.
Criterion XI of Appendix B to 10 CFR Part 50 requires, in part, that all testing required to demonstrate that systems will perform satisfactorily in service is performed in accordance with written test procedures which incorporate the requirements contained in applicable design documents.
Technical Specification 4.6.2.2.b.2 requires that each group of containment cooling fans shall be demonstrated operable at least once per 18 months by verifying a cooling water flow rate of greater than or equal to 1325 gpm to each cooler.
Procedure OP-903-029, " Safety injection Actuation Signal Test," Revision 6, implemented Technical Specification 4.6.2.2.b.2 by requiring that the cooling water flow rates be verified to be greater than or equal to 1325 gpm to each containment cooling fan following a safety injection actuation signal.
Contrary to the above, as of February 28,1997 (the end of the inspection),
Procedure OP-903-029 was not adequate to demonstrate that the containment cooling system will perform satisfactorily in service because Procedure OP-903-029 failed to establish test conditions that were representative of accident conditions to ensure that accident flow rates could be achieved. (01033)
D.
Criterion XVI of Appendix B to 10 CFR Part 50 requires, in part, that measures be established to assure that conditions adverse to quality be promptly identified and corrected.
i Notice of Violation Contrary to the above, from August 23,1996, until February 11,1997, a condition adverse to quality in the containment cooling system v *s identified and was not promptly corrected. Specifically, testing co'nducted on August 23,1996, demonstrated the inability to attain design basis component cooling water flow (1350 gpm) through three of the four containment fan coolers under accident conditions, however, the licensee did not restore the required flows to design basis values or change the design basis until February 11,1997.(01043)
These violations represent a Severity Level ill problem (Supplement 1).
Civil Penalty - $55,000 Pursuant to the provisions of 10 CFR 2.201, Entergy Operations, Inc. (Licensw) is hereby required to submit a written statement or explanation to the Director, OfJce of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this j
Notice of Violation and Proposed impo::ition of Civil Penalty (Notice).. This reply should be j
clearly marked as a " Reply to a Notice of Violation" and should include for each alleged violation: (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective steps that have been taken d
and the results achieved, (4) the ccrrective steps that will be taken to avoid further violations, and (5) the date when full compliance will be achieved. 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 why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act,42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
i Within the same time as provided for the response required above under 10 CFR 2.201, the Licensee may pay the civil penalty by letter addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, money order, or electronic transfer payable to the Treasurer of the United States in the amount of the civil
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penalty proposed above, or the cumulative amount of the civil penalties if more than one civil penalty is proposed, or may protest imposition of the civil penalty in whole or in part, by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission. Should the Licensee fail to answer within the time specified, an order imposing the civil penalty will be issued. Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, in whole or in part, such answer should be clearly marked as an " Answer to a Notice of Violation" and may: (1) deny the violation (s) listed in this Notice, in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalty
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should not be imposed. In addition to protesting the civil penalty in whole or in part, such answer may request remission or mitigation of the penalty.
I in requesting mitigation of the proposed penalty, the factors addressed in Section VI.B.2 of the Enforcement Policy should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. The
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-4 attention of the Licensee is directed to the other provisions of 10 CFR 2.205, regarding the l
procedure for imposing a civil penalty.
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l Upon failure to pay any civil penalty due which subsequently has been determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be i
j collected by civil action pursuant to Section 234c of the Act,42 U.S.C. 2282c.
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The response noted above (Reply to Notice of Violation, letter with payment of civil l
penalty, and Answer to a Notice of Violation) should be addressed to: James Lieberman, Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Orts White Flint j
North,11555 Rockville Pike, Rockville, MD 20852-2738, with a copy :: the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV,611 Ryan Plaza Drive, l
Suite 400, Arlington, Texas 76011, and a copy to the NRC Resident inspector at the f acility that is the subject of this Notice.
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. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide j
a bracketed copy of your response that identifies the information that should be protected l
and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the pnrtions of your response that you seek to have withheld and provide in detail the bases for your claim of withhold-ing (e.g., explain why the disclosure of information will create an unwarranted invasion of
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personal privacy or provide the information required by 10 CFR 2.790(b) to support a j
request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
Dated at Arlington, Texas, this 9th day of May 1997
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