ML20148H866
| ML20148H866 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 06/09/1997 |
| From: | Dugger C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-382-97-03, 50-382-97-3, EA-97-099, EA-97-99, W3F1-97-0149, W3F1-97-149, NUDOCS 9706130006 | |
| Download: ML20148H866 (17) | |
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I Enti gy Operttions,Inc.
Killena, LA 70006-0761 Tel 504 739 6000 Charles M. Dugger c Presdent, Operatmans W3F1-97-0149 A4.05 PR June 9,1997 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 50-382/97-03 Reply to Notice of Violation and Proposed imposition of Civil Penalty Gentlemen:
Entergy, Waterford 3, hereby. submits in accordance with 10 CFR2.201 the ret ponse to the notice of violation and proposed imposition of civil penalty documented in the NRC letter dated May 9,1997.
Waterford 3 admits the violations. We recognize the significance of the issues. We have taken comprehensive corrective actions which address the specific issues as well as the broader issues. We are committed ti continuous improvement in ensuring that conditions adverse to quality are promptly identified and effectively corrected to reduce the likelihood of recurrence.
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Reply to Notice of Violation and Proposed Imposition of Civil Penalty W3F1-97-0149 Page 2 June 9,1997 Please contact Early Ewing at (504) 739-6242 or Tim Gaudet at (504) 739-6666 should you have any questions regarding this response.
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Very truly yours, 1
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Vice President, Operations Waterford 3 CMD/RJM/ssf Attachments
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ADVICE VENDOR NUMBER: 305276 CHECK DATE:
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TREASURER OF THE US CHECK NUMBER: 987771 825 NORTH CAPITOL ST NE WASH.T.NGTON, DC 20426 d
j FOR INQUIRIES CONTACT: ACCOUNTS PAYABLE (601) 368-5595 INVOICE VOUCHER PURCHASE DATE NUMBER INVOICE NUMBER / DESCRIPTION ORDER.
DISCOUNT NET AMOUNT I
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CHECK NUMBER Entergy Servicoe,Inc. Agent For.
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Wilmington,DE 19801 P.0, Box 319135, Jackson, MS 39286 -1995 06-05-97
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Entergy Operations, Incorporated
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Docket No. 50-382 Waterford 3 Steam Electric Station
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AFFIDAVIT Charles Marshall Dugger, being duly sworn, hereby deposes and says that he is Vice President, Operations - Waterford 3 of Entergy Operations, incorporated; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached NRC Inspection Report 50-382/97 Reply to Notice of Violation and Proposed imposition of Civil Penalty; that hc is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.
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Charles Marshall Dugger
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Vice President, Operations Waterford 3 STATE OF LOUISlANA
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Subscribed and sworn to before me, a yotary Public in and for the Parish and State above named this SD day of M-~ t
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VV3F1-97-0149 Page 1 of 13 l
WATERFORD 3 RESPONSE TO THE VIOLATIONS IDENTIFIED IN THE l
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY OF LETTER DATED MAY 9,1997 (NRC INSPECTION REPORT 97-03) l l
VIOLATION NO. EA 97-099 A The limiting condition for operation for Technical Specification 3.6.2.2, l
" Containment Cooling System," requires, in part, that two indepen:ient groups of containment cooling fans shall be operable, with one fan system to each group in Modes 1,2,3, and 4.
l Technical Specification 4.6.2.2.b.2 requires that each group of containment cooling fans shall be dernonstrated operable at least once per 18 months by verifying a cooling water flow of greater than or equal to 1325 gpm to each cooler.
l 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 l
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 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.
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RESPONSE
Reasons for the Violation The fundamental reason for the violation is the failure to establish an adequate design basis for the containment cooling faris. This failure occurred during the l
original development of the design basis for the containment cooling fans prior to l
the initial operation of Waterford 3. The failure to establish an adequate design l
basis for the containment fan coolers and to clearly document the appropriate l
details of the design basis led to other errors and inadequacies. Specifically, l
these errors and inadequacies included the following: (1) failure to establish adequate surveillance test procedures, (2) failure to establish an adequate safety i
's Attechm:nt to W3F1-97-0149 Page 2 of 13 analysis, and (3) failure to develop and document a clear and unambiguous design and licensing basis in the Technical Specifications and UFSAR. These three errors are discussed in more detail.
The failure to establish adequate procedures was the result of a lack of recognition the Technical Specification required testing in a configuration which simulated accident conditions.
The Component Cooling Water (CCW) System and the Auxiliary Component Cooling Water (ACCW) System remove heat from the containment in the event of an accident, LOCA or MSi_B, via the containment fan coolers. During a Safety injection Actuation Signal (SIAS) or low surge tank level, the CCW trains split to form two independent 100% capacity redundant trains. The non-essential loads are isolated from CCW in the event of an accident. Procedure OP-903-029,
" Surveillance Procedure Safety injection Actuation Signal Test," did not measure flow through the containment fan coolers based on an accident configuration.
The procedure has existed in its basic form since initial pre-operational testing and operation.
The failure to establish an adequate safety analysis was due to the failure to include conservatism and margin as necessary to account for uncertainties and degradation of the containment cooling system.
One function of the containment fan coolers is to remove heat from the containment in the event of an accident, i.e. LOCA or MSLB. An enalysis is performed to demonstrate that in the event of an accident two important criteria are met: (1) the peak containment pressure is less than 44 psig, and (2) the calculated containment pressure at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is less than one half the calculated containment peak pressure. This analysis is documented in UFSAR section 6.2.
The peak pressure for Waterford 3 is calculated for a LOCA and MSLB accident using the computer code CONTEMPT. One parameter that affects the determination of the containment peak pressure is the flow assumed through the containment fan coolers. The original containment peak pressure analysis of record used a flow of 1350 gpm. However,1350 gpm was the flow rate specified by the manufacturer for the containment fan coolers in a clean condition. The LOCA and MSLB containment peak pressure analyses did not account for system degradation, and therefore, the analyses were not conservative.
Subsequent analyses were performed in October 1995 using the CONTEMPT and GOTHIC computer codes to address the results of tests performed in October 1995. These analyses used substantially lower flow rates through the containment fan coolers. The analyses established that the impact of a 1350 l
gpm assumption in the determination of the containment peak pressure was
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small and not safety significant. Nonetheless, the analysis of record was not conservative, and this condition is important from a design control and regulatory standpoint.
The failure to develop and document a clear and unambiguous design and licensing basis in the Technical Specifications and UFSAR was the result, as part of the original design basis work, of a lack of understanding of the design basis for the containment fan coolers and the failure tc document the important elements of the design, testing, and safety analysis of the system.
Specifically, the containment peak pressure analysis in UFSAR section 6.2 was j
not conservative. The flow through the containment fan coolers was documented in UFSAR section 6.2 as 1350 gpm while the flow was documented in Technical Specification surveillance 4.6.2.2.b.2 as 1325 gpm. There was no i
documentation which provided clear and definitive reasons for a flow of 1350 l
gpm in the UFSAR and a flow of 1325 gpm in the Technical Specifications.
Further, the Technical Specification did not provide clear and definitive documentation to convey the flow through the containment fan coolers should be measured based on a CCW configuration which simulated accident conditions.
The lack of clear and definitive documentation in the Technical Specification was an important and vital factor in the failure of Waterford 3 personnel to take l
corrective action earlier than was taken. The following information provides a brief explanation of how the understanding of the Technical Specification was a factor in the timing of the corrective action taken.
j Wa"rford 3 personnel believed the purpose of the Technical Specification surveillance was to verify the containment fan cooler flow control valves moved to full open positions on a SIAS, not to demonstrate accident flow rates of 1325 gpm. The Waterford 3 CCW and containment fan cooler design is unique among CE plants. Most plants have a design wherein on a SIAS the water source is changed from a non-safety to a safety grade water source or the flow rate through the fan and fan speed is changed by a handswitch in the control room.
The Waterford 3 system design uses the same safety grade water source (CCW) during both normal and accident conditions. The Waterford 3 fan speed and the CCW flow through the containment fan coolers are completely automatic, and there is no manual ccntrol of the CCW flow :ihrough the containment fan coolers or of the speeds of the fans. The flow through the containment fan coolers is automatically controlled by flow control valves. The flow control valves have four positions which are the following: closed, minimum open, normal open, and fully open. The position of the flow control valves determines the flow through the containment fan coolers, and the position of the flow control valves is a
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VV3F1-97-0149 l
Page 4 of 13 function of the number of containment fan coolers operating. Specifically, the l
CCW flow through the CFCs will be 0 gpm with both CFCs not operating,700 l
gpm with one CFC operating,1400 gpm with two CFCs operating, and 2700 gpm in the event of an SIAS. Therefore, there were reasonable and logical arguments to support the position advocated by Waterford 3 personnel.
l Nonetheless, the position was inferred and was not directly substantiated by i
objective evidence or documentation, and the position was not correct.
Corrective Steps That Have Been Taken and the Results Achieved 1
1 As part of the corrective actions for chilled water flow issues, CCW flow balance l
tests were performed in October 1995, during RF07, to determine the saw i
through the containment fan coolers under conditions simulating accident conditions. The results of the tests demonstrated the flows through all tour containment fan coolers was less than the acceptance criteria of 1350 gpm.
An operability evaluation was performed in October 1995 to evaluate the results l
of the CCW flow balance tests performed in October 1995. The evaluation was performed using the GOTHIC code and the following assumptions: flow of 1100 l
gpm through the containment fan coolers and 1 containment fan cooler operable in each CFC train. The analysis established the containment design pressure of 44 psig was not exceeded. The maximum containment pressure at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> was exceeded by a small amount which was judged to have a negligible impact on the radiological releases of record.
The Dry Cooling Tower (DCT) bundles were cleaned on both trains of CCW frora January to March 1996 to increase the flow through the containment fan coolers.
A decision was made to wait until Refuel 08 to perform another CCW flow balance test to confirm the effectiveness of the cleaning of the DCT bundles.
The decision was predicated on the intent to operate the plant in the safest possible manner and to avoid potential risks in performing the CCW flow balance tests. For example, one principal concern was the temperature element for controlled bleedoff for RCP 2B which had historically read about 20 degrees higher than the other RCP temperature elements. This condition resulted in an apparent loss of CCW system normal temperature margin.
An assessment was performed by Entergy personnel of the Ultimate Heat Sink (UHS)in August 1996. A number ofissues were raised as a result of this assessment and follow-up work. T hese issues dealt with the results of the October 1995 CCW flow balance tests, testing performed for the containment fan coolers, and the information documented in the UFSAR and Technical l
Specification for the containment fan coolers.
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CCW flow balance tests were performed on both trains of the containment fan coolers in August 1996 subsequent to the UHE assessment. The risk to RCP l
cooling was now minimal because the temperature element for RCP 2B was repaired in the July 1996 outage. The flow balance tests established the flow I
through at least one containment fan cooler in each train met the Technical Specification acceptance criteria of 1325 gpm.
Administrative requirements were established and implemented in February 1997, to require all containment fan coolers be operable as a result of the NRC interpretation of Technical Specification 4.6.2.2.b.2.
The Waterford 3 Technical Specification surveillance requirements and their bases were reviewed in March 1997 in order to determine if there were any other surveillance requirements for fluid system flow rates that could be subject to misinterpretation or misapplication of acceptance criteria. There were seven Technical Specifications identified that have flow rate requirements or require flow rate verification. These Technical Specifications, the corresponding UFSAR sections, and the implementing procedures were reviewed. There were no misinterpretations or misapplications identified.
A CONTEMPT containment peak pressure analysis was performed in February 1997 to calculate the containrnent peak pressure from a LOCA and MSLB accident. Two of the assumptions used in the analysis were two containment fan coolers operable per train and a flow rate of 1100 gpm through each containment fan cooler. The analysis demonstrated the two peak containment acceptance criteria were met: (1) a peak pressure less than 44 psig and (2) a maximum pressure at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> less than one half the maximum calculated peak pressure.
A Technical Specification Change Request, NPF-38-194, was submitted to the NRC on April 11,1997. The Technical Specification Change Request requires two containment fan coolers be operable for each train and that a flow rate of 1200 gpm be verified for each containment fan cooler.
Corrective Steps Which Will Be Taken to Avoid Further Violations A CCW flow balance test will be performed in accordance with Procedure PE-004-024, and in conjunction with procedures OP-903-115 and OP-903-116, prior to entering Mode 4 fcr Cycle 9 operation. The test will verify a flow rate of 1200 gpm to each containment fan cooler.
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n Attachment to W3F1-97-0149 Page 6 of 13 The UFSAR will be updated to reflect the changes documented in Technical j
Specification Change Request, NPF-38-194.
Procedures OP-903-115 and OP-903-116 will be finalized to require verification of the required flow rate through each containment fan cooler with CCW in a lineup which simulates the accident configuration.
F Waterford 3 has undertaken a number of initiatives which address broader i
issues related to this violation. These broader issues are the need to better i
define the design and licensing basis and to perform training for personnel. The implementation of these initiatives are not required to ensure full compliance with the violations herein documented, but rather are initiatives which will provide improvement in the definition of the design and licensing basis and personnel awareness of the design and licensing basis.
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As part of the 10 CFR50.54(f) response, Waterford 3 has committed to better define original design and licensing basis and to upgrade or rework original l
design and licensing basis. The review and upgrade of bases for design and l
testing includes the following: Containment isolation Design Basis, Ultimate Heat j
Sink Design Basis, Tornado Missile Design Criteria, inservice Testing Basis Reconstitution, Emergency Feedwater Flow Design Basis, and Technical Specification LCO Instrument Uncertainty Evaluation Project. The design and licensing upgrade or rework includes: upgrade of selected DBSs for safety significant systems, upgrade of selected mechanical calculat;ons for safety
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significant systems, development of a process and a relational data base to i
establish links between design basis, licensing basis, and plant procedures, review of selected sections of the UFSAR for accuracy, and full conversion to new CE-STS.
Waterford 3 will implement additional corrective actions to improve design basis awareness and verification. Design basis training will be given to operations, maintenance, licensing, and engineering personnel. Certain operations and maintenance procedures will be reviewed to ensure they incorporate the necessary design basis information and configuration controls. Waterford 3 will continue to perform self assessments which evaluate the design basis of the plant.
Date When Full Compliance Will Be Achieved j
Waterford 3 will be in full compliance by July 15,1997, the date by which Technical Specification Change Request NPF-38-194 is expected to be approved and implemented and the corresponding UFSAR sections changed.
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Page 7 of 13 WATERFORD 3 RESPONSE TO THE VIOLATIONS IDENTIFIED IN THE NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALT(
l OF LETTER DATED MAY 9,1997 l
(NRC INSPECTION REPORT 97-03)
VIOLATION NO. EA 97-099 B l
Criterion 111 of Appendix B to 10 CFR Part 50 states, in part, that measures shall I
l 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 cooler fan was 1350 gpm. The UFSAR, on page 6.2-11, specified i
that the main steamline break analysis assumed three containment cooling fans operated.
Contrary to the above, for the dates specified below, the licensee's measures to l
assure that the design basis for the containment cooling system was correctly translated into specifications, drawings, procedures, and instructions, were inadequate. Specifically:
1.
From initial licensing on March 16,1985, until February 11,1997, the equipment manufacturer's specified maximum expected clean-tube cooling water flow (1350 gpm) was used as the minimum accident flow assumed in the loss-of-coolant and main steamline break analyses, an 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 assumption 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.
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From initial licensing 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 l
l 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.
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RESPONSE
Reasons for the Violation The root causes for examples 1 and 3 cf this violation are identical to the root causes documented in violation EA 97-099 A. In summary, the causes were the failure to establish an adequate design basis for the containment coolir>g fans and the corresponding failures: (1) failure to establish adequate survdlance test procedures, (2) failure to establish an adequate safety analysis, and (3) failure to develop and document a clear and unambiguous design and licensing basis in the Technical SpM'ications and UFSAR.
The root cause for example 2 of this violation was miscommunication between Waterford 3 staff and Ebasco staff and the lack of a thorough review of the Ebasco containment calculations by Waterford 3 personnel. The failed barrier was worker performance. The error occurred in January 1991, and the error was not related to the original work that was performed as part of the development of the original design and licensing basis of Waterford 3.
Corrective Steps That Have Been Taken and the Results Achieved The corrective steps for examples 1 and 3 of this violation are identical the corrective steps for violation EA 97-099 A.
The following corrective steps were taken to address example 2 of this violation.
An evaluation was performed in February 1997. The evaluation concluded crediting 2 CFCs rather than 3 CFCs would not increase the containment peak pressure by more than 0.1 psi. Therefore, the containment peak for the limiting MSLB accident would remain within the acceptance criteria of 44 psig.
The current procedure for the review of calculations, NOECP-011, was reviewed, and the procedure was found to contain the necessary procedural requirements for the review of calculations.
The corrective steps discussed in violation EA 97-099 A regarding the CONTEMPT analysis performed in February 1997 and the Technical Specification Change Request NPF-38-194 are also corrective steps for example 2 of this violation.
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3 Attachm::nt to W3F1-97-0149 Page 9 of 13 Corrective Steps Which Will Be Taken to Avoid Further Violations I
The corrective actions that will be taken to avoid further violations are the same carrective actions as specified for violation EA 97-099 A.
i Date When Full Compliance Will Be Achieved Waterford 3 will be in full compliance by July 15,1997, the date by which Technical Specification Change Request NPF-38-194 is expected to be j
approved and implemented and the corresponding UFSAR sections changed.
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,3 Att: chm:nt to W3F1-97-0149 Page 10 of 13 WATERFORD 3 RESPONSE TO THE VIOLATIONS IDENTIFIED IN THE NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY OF LETTER DATED MAY 9,1997 (NRC INSPECTION REPORT 97-03)
VIOLATION NO. EA 97-099 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.
Tiocedure 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.
RESPONSE
Reasons for the Violation The root causes for this violation are identical to the root causes documented in violation EA 97-099 A. In summary, the causes were the failure to establish an adequate design basis for the containment cooling fans and the corresponding failures: (1) failure to establish adequate surveillance test procedures, (2) failure to establish an adequate safety analysis, and (3) failure to develop and document a clear and unambiguous design and licensing basis in the Technical Specifications and UFSAR.
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Corrective Steps That Have Been Taken and the Results Achieved The corrective steps that have been taken and the results a::hieved are the same as for violation EA 97-099 A.
't Corrective Steps Which Will Be Taken to Avoid Further Violations The corrective actions that will be taken to avoid further violations are the same e
as for violation EA 97-099 A.
Date When Full Compliance Will Be Achieved Waterford 3 will be in full compliance by July 15,1997, the date by which Technical Specification Change Request NPF-38-194 is expected to be approved and implemented and the corresponding UFSAR sections changed.
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W3F1-97-0149 Page 12 of 13 WATERFORD 3 RESPONSE TO THE VIOLATIONS IDENTIFIED IN THE NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY
_OF LETTER DATED MAY 9,1997 (NRC NSPECTION REPORT 97 03)
VIOLATION NO. EA 97-099 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. Contrary to the above, from August 23,1996, until February 11, 1997, a condition adverse to quality in the containment cooling system was identified and was not promptly corrected. Specifically, testing conducted 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.
RESPONSE
Reasons for the Violation The root causes for this violation are identical to the root causes documented in violation EA 97-099 A. In summary, the causes were the failure to establish an adequate design basis for the containment cooling fans and the corresponding failures: (1) failure to establish adequate surveillance test procedures, (2) failure to establish an adequate safety analysis, and (3) failure to develop and 4
document a clear and unambiguous design and licensing basis in the Technical Specifications and UFSAR.
Corrective Steps That Have Been Taken and the Results Achieved The corrective steps that have been taken and the results achieved are the same as for violation EA 97-099 A.
Corrective Steps Which Will Be Taken to Avoid Further Violations The corrective action that will be taken to avoid further violations are the same as for violation EA 97-099 A.
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Waterford 3 will be in full compliance by July 15,1997, the date by which Technical Specification Change Request NPF-38-194 is expected to be approved and implemented and the corresponding UFSAR sections changed.
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