ML20198M275

Notice of Violation from Insp on 971102-1213.Violation Noted:Licensee Failed to Require Adequate Postmaintenance Testing to Insure That Equipment or Sys Capable of Performing Intended Safety Function

ML20198M275
Person / Time
Site:	Waterford
Issue date:	01/12/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20198M274	List: ML20198M269 ML20198M275 ML20198M280
References
50-382-97-24, EA-97-587, EA-97-588, NUDOCS 9801200060
Download: ML20198M275 (2)

See also: IR 07100102/2012013

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ENCLOSURE 1

WOTICE OF VIOLATION

Entergy Operations, Inc. Docket No.: 50 382

Waterford Steam Electric Station, Unit 3 License No.: NPF 38

EA Nos.: 97 587,588

During an NRC inspection conducted on November 2 through December 13,1997,

violations of NRC requirements were identified. In occordance with the " General Statement

of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violations are

listed below:

A. Technical Specification 6.8.1.a requires, in part, that written procedures be

imolemented covering applicable procedures recommended in Appendix A of

Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33,

Appendix A, Section 9.e, requires that the licensee have general procedures for

control of maintenance.

Procedure UNT 005 015, " Work Authorization Preparation and implementation,"

Section 5.5.11, required, in part, that postmaintenance test instructions be int,luded

in accordance with Procedure UNT-005-020, " Post Maintenance Testing."

Procedure UNT-005 020 Section 5.1.1, required, in part, that the application of

postmaintenance testir:3 be based on extent of the maintenance to ensure that the

equipment or rystem is capable of performing its intended function.

Contrary to the above, on October 17,1997, the licensee f ailed to require adequate

postmaintenance testing to ensure that the equipment or system was capable of

performing its intended safety function in that, on September 9,1997, Work

Authorization 01163329 for Valve CC-8350 did not provide instructions to stroke

test the valve to verify that it would stroke to its full open position.

This is a Severity Level IV violation (Supplement l} (50-382/9724 01).

B. 10 CFR Part 50, Appendix B, Criterion 111, " Design Control," states, in part, that

measures shall be establithed to assure that the design basis, as defined in

Section 50.2 and as identified in the license application, for those structures,

systems, and components to which this appendix applies are correctly translated

into specifications.

Contrary to the above, in December 1996, the licensee f ailed to properly translate

dasign basis requirements into specifications, in that, the correct level for the onset

of vortoxing, which could affect net positive suction head for the safety injection

and spray pumps, was not properly determined. Specifically,

Calculation EC M95-012, " Minimum Pipe Submergence to Prevent Vortexing,"

identified the minimum level in several safety-related tanks, including the refueling

water storage pool, required to prevent vortexing; however, the calculation did not

include consideration of pump recirculation flow back to the tank.

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This is a Severity LevelIV violation (Supplement 1)(50 382/9724 05).

The NRC has concluded that information regarding the reason for Violation A, the corrective

actions taken and planned to correct the violation and prevent recurrence and the date when full

compliance was achieved is already adequately addressed on the docket in LER

50-382/97 027. However, you are, required to submit a written statement or explanation

pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective

actions or your position. In that case, or if you choose to respond, clearly mark your response

as a "Peply to a Notice of Violation," and send it to the U.S. Nuclear Regulatory Commission,

ATTN: Document Control Desk, Washington, D.C. 20555 aith a copy to the Regional

Administrefor, Region IV, and a cepy to the NRC Resident inspector at the facility that is the

subject of this Notice, within 30 dayn of the date of the letter transmitting thisNotice.

Pursuant to the provisions of 10 CFR 2.201, Entergy Operations, Inc. is hereby required to

submit a written stahment or explanation for Violation B to the U.S. Nuclear Regulatory

Commission. ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the

Regional Administrator, Region IV,611 Ryan Plaza D,ive Suite 400, Arlington, Texas 76011,

and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within

30 days of the date of the letter transraitting this Notice of Violation (Notice). This reply should

be clearly marked as a * Reply to a Notice of Violation" and should include for each violation: (1)

the reason for the violation, or, if conteeted, the basis for disputing the violation, (2) the

corttative steps that hav3 been takt 1 and the results achieved, (3) the corrective steps that will

be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your

response may reference or include previous docketed correspondence, if the correspondence

adequately addresses the required response, 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 to why the

license should not be nodified, suspended, or revoked, or why such other action as may be

proper should not be taken. Where gnod cause is shown, consideration will be given to

extending the response tima.

If you contest this enforcement 9ction, you should also provide a copy of your responte to the

Director, Office cf Enforcement, United States Nuclea F.egulatory Commission, Washington, DC

20555-0001, and a copy 'o the Enforcement Officer, NM Region IV,611 Ryan Plaza Drive,

Suite 400, Arlirgon, Texas 76011.

Becauso 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. However, if you find it necessary to include

such infr rmation, you should clearly indicate the specific information that you desire not to be

placed iq the PDR, and provide the legal basis to support your request for withholding the

infarmation from the public.

Dated at Arlington, Texas

this 12th day of January 1998

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