ML20198D989
| ML20198D989 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/21/1998 |
| From: | Ewing E ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-382-98-08, 50-382-98-8, W3F1-98-0203, W3F1-98-203, NUDOCS 9812230303 | |
| Download: ML20198D989 (5) | |
Text
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Enttrgy Operati:ns,Inc.
Killona, LA 70066 Tel 504 739 6242 Early C. Ewing. til a Safety & Regulatory Affairs u
W3F1-98-0203 A4.05 PR December 21,1998 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report 98-08 Reply to Notice of Violation Gentlemen:
In accordance with your letter of November 20,1998, Entergy Operations, Inc.
hereby submits in Attachment 1 a supplemental response to Violation 9808-03 identified in Inspection Report 50-382/98-08. We have carefully evaluated the information in the November 20,1998 letter and agree the failure to include the rifects of sensor delays in the acceptance criteria for testing re.sponse times for Engineered Safety Features Actuation Signal (ESFAS) functions is a violation of Criterion ill of 10 CFR 50, Appendix B. Included is a discussion of the reasons for the cited violation a.,d corrective actions taken and planned to be taken to ensure
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compliance with Critet!on lli of 10 CFR 50, Appendix B. In addition, with regard to the safety significance of this violation, we have provided additional perspectives in the attached response.
iI Also, with regard to the design basis discussion in our July 1,1998 letter, we recognize that differing positions exist both within the industry and NRC Staff regarding the relationship between equipment specific design values and conditions considered to be outside the design basis of the plant.
3 ADOCK05000302[*)
9812230303 981221 PDR G
PDR J;
1
' NRC Inspection Report 98-08 i
Reply to Notice of Violation
- W3F1-98-0203 Page 2
- December 21,.1998-If you have any questions concerning this response, please contact
- me at (504) 739-6242.
Very truly yours,
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A z. c. c.,..
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C E.C. Ewing
- Director,
- Nuclear Safety & Regulatory Affairs ECE/BVR/ssf Attachment cc:
E.W. Merschoff (NRC Region IV)
C.P.. Patel (NRC-NRR)
J. Smith N.S. Reynolds NRC Resident inspectors Office i
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i I.
Attachmant to W3F1-98-0203 Page 1 of 3 i
ATTACHMENT 1 ENTERGY OPERATIONS, INC. RESPONSE TO VIOLATION 9808-03 IDENTIFIED IN INSPECTION REPORT 50-382/98-08 L
VIOLATION 9808-03
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10 CFR Part 50, Appendix B, Criterion ill states, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into procedures and instructions.
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Contrary to the above, the licensee failed to correctly translate applicable regulatory -
I requirements and the design basis into procedures and instructions in that the L
response tima acceptance criteria contained in surveillance test procedures for the emergency feedwater system, containment fan coolers, and high pressure and low -
pressure safety injection systems did not ensure that the requirements of the licensing basis were met.
This is a Severity' Level IV violation (Supplement 1) (50-382/9808-03).
RESPONSE
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- Entergy, at Waterford 3, has carefully evaluated the information in the NRC Staff L
letter of November 20,1998. We agree the failure to include the effects of sensor delays in the acceptance criteria for testing response times for Engineered Safety Features Actuation Signal (ESFAS) functions is a violation of Criterion lli of 10 CFR 50, Appendix B.
We request you consider the guidance of EGM 98-006, dated July 27,1998, in that this violation is non-repetitive, within the context of the discussion in the EGM, non-L willful and will be corrected within a reasonable time. Further, this was a licensee identified issue. Although this violation is not repetitive, it is similar to other l
discrepancies identified as a part of the Waterford Design Basis Review Program.
H Entergy has identified these discrepancies as a result of prompt corrective actions taken in response to the discovery of potential surveillance procedure discrepancies.
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Reason for the Violation L
As part of th'e Waterford Design Basis Review Program, a potential discrepancy was l
identified where the surveillance procedures associated with the testing of the response time of the pumps in the Low Pressure Safety injection (LPSI), High Pressure Safety injection (HPSI), Emergency Feedwater (EFW) and Containment L
Fan Coolers (CFC) systems would not adequately support the assumptions described in the Technical Requirements Manual (TRM). The Design Basis Review
l Attachm::nt to W3F1-98-0203 Page 2 of 3 Proiram determined the acceptance criteria of the surveillance procedures did not account for the amount of time required for sensors in these systems to process and initiate an ESFAS.
Entergy performed a root cause analysis for the above condition. The investigation identified a weakness in the testing procedures of response times at Waterford 3.
The cause of this was a poor understanding of the scope of the response time testing of subcomponents, which needed to be formally established and documented. The existing documentation did not adequately identify the interfaces between safety analyses, design and testing requirements.
Safety Significance of the Violation Entergv has reviewed the information provided in the NRC Staff's letter regarding the safety significance of this violation and believe that the following additional perspectives should be considered. The letter states that "the safety significance of this violation is not based on the quantitative results of system testing, rather it is based on the number of identified errors in the established acceptance criteria for three different safety-related systems."
We believe that the violation has minor safety significance. A complete review of the TRM values and surveillance testing acceptance criteria was performed to ensure the safety analysis assumptions were protected. Acceptance criteria and TRM values were reviewed for ESFAS functions associated with the HPSI, LPSI, EFW and CFC systems. Based on the review, it was determined that an increase in response time, as a result of the condition identified, would not affect any safety analysis with respect to design acceptance limits.
'he also believe the violation has minor regulatory significance. The condition which is the subject of this violation had minor safety significance as discussed above and was identified through Entergy's ongoing Design Basis Review efforts. In addition, operability was promptly established and effective corrective actions to identify other similar conditions and to prevent recurrence were initiated.
Corrective Steps That Have Baen Taken and the Results Achieved
- 1. Entergy evaluated the safety significance of increased response times (i.e.,
increased such that they would bound the condition described in this violation) for the EFW, CFC, HPSI and LPSI functions. Depending on the particular scenarios, there was either no effect or a minimal effect on the plant's response to the postulated event. These analyses determined the effects, if any, were not safety significant. The ability of these systems to protect the health and safety of the public was never compromised.
I Attachmsnt to W3F1-98-0203 Page 3 of 3 2.' Entergy revised Operations Procedure OP-903-047, " Emergency Feedwater-Actuation Signal Test," to ensure surveillances contain an allowance for differences in automatic actuation from a setpoint on the Plant Protection System (PPS) and manual actuation from the " Initiate" test button. In addition, the procedure was revised to change the acceptance criteria response time to a more conservative value of less than or equal to 41.3 seconds.
- 3. Emergency Feedwater Pump AB was retested and the response time was verified to be less than or equal to 41.3 seconds.
- 4. Entergy revised Operations Procedure OP-903-029, " Safety injection Actuation Signal," to change the acceptance criteria response time for the containment fan coolers to a more conservative value of less than or equal to 11.4 seconds.
Review of actual response time indicates that TRM limits were not exceeded.
- 5. The worst case response times for HPSI and LPSI from recent surveillances were evaluated to determine if they were within the maximum start times specified in the UFSAR. The review determined that the UFSAR requirements were met and therefore, the HPSI and LPSI systems remained operable.
Corrective Steps Which Will Be Taken to Avoid Further Violations
- 1. Entergy will establish design basis documentation to specifically document the basis of the response times for the Technical Requirements Manual and the Safety Analysis. The response time subcomponents for each ESFAS in the TRM will be defined.
- 2. Entergy will revise the notes in the Technical Requirements Manual regarding the response time limits for the Emergency Feedwater pump to clarify the applicability of the two different response times specified.
- 3. Operations procedure OP-903-029, " Safety injection Actuation Signal," will be revised to change the acceptance criteria response time for the HPSI and LPSI pumps to a more conservative value. This change will be completed before performing this surveillance for Cycle 10 operation.
Date When Full Compliance Will Be Achieved The above corrective actions ensure compliance with Criterion 111 of 10 CFR 50, Appendix B. The corrective measures to reduce the likelihood of recurrence will be completed by February 26,1999.
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