ML20197A910
| ML20197A910 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/18/1997 |
| From: | Ewing E ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-382-97-22, W3F1-97-0274, W3F1-97-274, NUDOCS 9712230243 | |
| Download: ML20197A910 (6) | |
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W3F1-97-0274 A4.05 PR December 18,1997' U.S. Nuclear Regulatory Commission AT'N: Document Control Desk Wasnington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report 97-22 Reply to Notice of Violation Gentlemen:
In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in the response to the violations identified in Enclosure 1 of the subject inspection Report.
If you have any questions concerning this response, please contact me at (5M) 739-6242 or Tim Gaudet at (504) 739-6666.
Very truly yours,
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E.C. Ewing
- Director, Nuclear Safety & Regulatory Affairs l I lill I HLI5 ECE/GCS/DMU/tjs 23b.. g-d!
Attachment cc:
E.W. Merschoff (NRC Region IV), C.P. Patel (NRC-NRR),
J. Smith, N.S. Reynolds, NRC Resident inspectors Office 9712230243 971218
.gDR ADOCK 050003821 PDR
Att:chment to VV3F1-97-0274 i
Page 1 of 5 ATTACHMENT 1 ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 97-22 VIOLATION NO. 9722-01 Technical Specification 6.8.1.a requires, in part, that written procedures shall be implemented covering applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A, Section 1.c, requires that the licensee have administrative procedures for equipment control.
Administrative Procedure UNT-007-006, " Housekeeping," Revision 7, Attachment 6.5, " Housekeeping Requirements to Prevent Seismic Interactions With Operable Safety Related Equipment," requires, in part, that loose items on wheels shall be restrained by wheellocking devices.
Contrary to the above, on October 23,1997, Administrative Procedure UNT-007-006 was not implemented in that numerous items on wheels were found in the reactor auxiliary building in areas of safety-related equipment, and the wheel locking devices were not engaged.
This is a Severity Level IV violation (Supplement 1) (50-382/9722-01).
RESPONSE
(1)
Reason for the Violation The root cause of this violation is inadequate management oversight of a portion of the Waterford 3 housekeeping program. Several occurrences of improperly stored wheeled carts in the Reactor Auxiliary Building (RAB) were identified which indicate a breakdown in the administration of this program. Management did not ensure expectations related to storing wheeled items were being met. Contributing to this event is personnel error in that the requirement of procedure UNT-007-006, Housekeeping, which states that loose items on wheel, such as portable carts, shall be restrained by wheellocking devices when the items remain in the designated areas was not followed. An investigation into the details of these events could not determine the individual (s) responsible for improperly storing the carts. Accordingly their reasons for improperly storing the carts could not be determined.
Attachment to L-W3F1-97-0274 L
Page 2 of 5 (2)-
Corrective Steps That Have Been Taken and the Results Achieved o'
Plant Services personnel secured all identified carts in the RAB.
Management discussed with appropriate personnel expectations with regard to storing wheel carts.
A walkdown of the RAB was performed to identify any additional unsecured carts in the area.
(3)
Corrective Steps Which Will Be Taken to Avoid Further Violations H
+ Locking devices will be installed on each portable cart issued from the Tool Room.
. Tra;ning will be provided to Maintenance and Construction Personnel emphasizing the requirements related to proper storage of wheel / portable carts.
. Procedure UNT-007-006, Housekeeping, will be revised to provide additional clarification of housekeeping requirements related to proper storage of wheel / portable carts.
. Quality Assurance will conduct a review of the effectiveness of maintaining the proper storage of wheet/ portable carts.
(4)
Date When Full Compliance Will Be Achieved Based on the completed corrective actions for Violation 9722-01, Waterford 3 has restored compliance to requirements. The corrective step to install the locking devices will be completed by February 28,1998. The corrective step to provide training to Maintenance and Construction personnel w;:: Le completed by February 28,1998. The corrective step to revise procedure UNT-007-006 will be completed by March 31,1998. The corrective step to conduct a review the effectiveness of maintaining the proper storage of wheel / portable carts will be completed by the March 31,1998.
s-
AttCchment to W3F1-97-0274 Page 3 of 5 VIOL.ATION NO. 9722-02 10_CFR 50.55a(f) requires, in part, that inservice testing to verify operational readiness of pumps and valves whose function is required for safety be accomplished in riccordance with Section XI of the ASME Boiler and Pressure VesselCode.
ASME Section XI, Article IWP-3000, Paragraph IWP-3112, specifies, "if it is necessary or desirable for some reason other than stated in IWP-3111 to establish an additional set of reference values, an inservice test shall first be run at the conditions of an existing set of reference values and the results analyzed. If operation is satisfactory, a second test run at the new reference conditiont., shall follow as soon as practical. The results of this (second] test shall establish the additional set of reference values. Whenever an additional set of reference values is established, the reasons for doing so shall be justified and documented in the record of tests (IWP-6000)."
Contrary to the above, in May 1997, prior to recalibrating the Low Pressure Safety injection Pump A discharge flow transmitter for a different normal operating temperature (120 versus 400 F):
(1) Pere 7nnel failed to establish an additional set of reference values following the calibration, as soon as practical, in that the first inservice test following the calibration change was not used to determine the new set of baseline values.
(2) Personnel failed to first operate the pump at the conditions for the existing set of reference values and analyze the results.
This is a Severity Level IV violation (50-382/9722-02) (Supplement 1).
RESPONSE
(1)
R_eason for the Violation The root cause for this violation was an inadequate Condition Report (CR) corrective action in that a procedure change to address a previous IST baselining issue was not suffic:ent.
On August 25,1996, adjustments were made to the turbine speed control system of the Emergency Feedwater Pump (EFW). These adjustments were made without first performing an inservice test to confirm that pump operation was satisfactory.
".k event was documented on CR-96-1321.
AttachmGnt to W3F1-U J-0274 Page 4 of 5 4
The corrective action specified in this CR was to revise UNT-005-015, " Work Authorization Preparation and Implementation", to require all work authorizations (WAs) on IST related equipment receive a review by the IST Program Coordinator to ensure implementation of IST requirements. This procedure change was made on 2-12-97. The procedure includes a list of components whose inspection and/or testing is required in accordance with ASME Section XI. Any work to be performed on the listed components would require IST coordinator review of the WA package.
One function of certain permanently installed astruments is their use during inservice testing. These plant instruments are used to test certain ASME Section XI components in accordance with the IST Plan, but are not considered ASME code components. Although this instrumentation directly affects inservice testing baseline data, it was not considered when revising the procedural guidanca specified in UNT-005-015. Therefore, there was no procedural requirement for the IST Coordinator to review a WA involving permanent plant instrumentation, even though it is used during inservice testing.
On 3-19-97, CR-97-0649 was initiated which required Design Engineering to determine the temperature at which LPSI flow indication accuracy was most critical.
As a result, calculation EC-196-002 was revised to reflect a temperature change from 400 deg F to 120 deg F. The calibration data packages for flow transmitters SI-lFT-1307A and SI lFT-1306B were modified accordingly. In May 1997, the flow transmitters were recalibrated to reflect this temperature change.
SI IFT-1307A and SI-IFT-1306B n used to measure ~3w during the LPSI pump quarterly surveillance tests as required by the Inservice Test (IST) plan and performed in accordance with surveillance procedure OP-903-030, "Safaty injection Pump Operabil;ty Procedure". Prior to recalibrating these instruments, the IST coordinator was not contacted to evaluate the effect this action might have on the IST reference values for the LPSI pumps. There was at that time no procedural requirement to route an instrumentation WA to the IST Coordinator. As a result, an inservice test was not run at existing reference values to ensure satisfactory pump operation, nor was a second inservice test run as soon as practical after instrument calibration to establish a new baseline.
(2)
Corrective Steps That Have Been Taken and the Results Achieved The operability of LPSI pumps A & B was reviewed as a result of the recalibration of their respective flow instruments. The pumps were determined to remain operable.
A new IST baseline was established for both the A & B LPSI pumps.
Att: chm:nt to W3F1-97-0274 Pcg2 5 of 5 Programs Engineering reviewed the IST plan to identify all components that utilized permanent plant instrumentation for their respective surveillance tests.
- The baseline data for these components was compared to the results of their last 2 surveillance tests to identify any notable variations. This review identified no relevant variations other than those previousiy identified for the LPSI pumps.
A review of calibration packages for the permanent plant instruments used during inservice testing has been performed. With the exception of those calibration package changes already identified for the LPSI pumps, no other changes to calibration packages were identified that could adversely effect IST baseline data.
(3)
Corrective Steps Which Will Be Taken to Avoid Further Violations The instrument calibration package checklist in administrative procedure UNT-005-035, " Instrument Calibration Package" is being revised to require any calibration package changes be compared to the list of permanent plant instruments used for IST testing and listed in Attachment 6.5 of OP-100-014, " Technical Specification and Technical Requirements Compliance" If the calibration package change affects the scaling or accuracy of the instrument or instrument loop, the Programs Engineering IST Coordinator will be notified. If the calibration change is determined to affect the IST baseline data, provisions will then be made to perform an inservice test at the existing reference values before the instrument is recalibrated. This will ensure the IST component is operable before any work is performed on the instrument.
Following the instrument calibration, a new set of baseline values can be established in accordance with ASME/ ANSI OM Part 6, section 4, as required in the 1989 edition of ASME Section XI, Article IWP-1000.
The revision to procedure UNT-005-035 is expected to be complete and approved by February 1,1998. In the interim, Design Engineering personnel responsible for changes to instrument calibration packages have been given a list of permanently installed instruments used for inservice testing. Should any change to the calibration package for these instruments be required, the IST coordinator will be contacted prior to field implementation of the change. The effect of the calibration change will then be evaluated for the IST component.
The potential to impact IST baseline data by any other means has also been evaluated. The guidance presently provided in UNT-005-015 in conjunction with that proposed in UNT-005-035 will adequately ensure accurate baseline data will be maintained in accordance with ASME Section XI.
(4)
Date When Full Compliance Will Be Achieved The above corrective actions that are in progress will be completed by February 1, 1998. Upon completion of these items, Waterford 3 will be in full compliance.