ML20198T259
| ML20198T259 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 01/22/1998 |
| From: | Ewing E ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-382-97-21, W3F1-97-0276, W3F1-97-276, NUDOCS 9801270009 | |
| Download: ML20198T259 (8) | |
Text
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W3F197-0270 A4.05 PR January 22,1998 U.S. Nuclear Regulatory Commission ATTN: Document ControlDesk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50 382 License No. NPF-38 NRC Inspection Report 97 21 Reply to Notice of Violation Gentlemen:
In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits the response to the violation iden' 'ed in E.1 closure 1 o inspection Report.
this reply from January 2,1998, to January 15,1998.On De On January 15 1998 permission was granted to extend the due date from January 15,1998 22,1998.
NRC persor'nel contacted for those extensions includo the Region IV Director, Division of Reactor Safety, and the Region IV Deputy Director Reactor Safety,
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' NRC inspection Report 97 21..
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Reply to Notice of Violation W3F1-97-0276 Pa9e 2 January 22,1998 i
- if you have any questions concoming this response, please contact me rt (504) 739-t 6242 or Tim Gaudet at (504) 739-6666.
Very truly yours, j
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E.C. Ewing Director,-
Nuclear Safety & Regulatory Affairs ECE/WDM/ssf I
Attachment
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cc:
E.W. Merschoff (NRC Region IV)-
j J. Lieberman (NRC-NRR)
C.P. Patel(NRC NRR)
J. Smith.
N.S. Reynolds i
NRC Resident inspectors Office i
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Attachment to W3F197-0276 Page 1 of 6 ATTACHMENT 1 ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN ENCt.OSURE 1 OF INSPECTION REPORT 50-382/97-21 VIOLATION NO. 9721-02 10 CFR Part 50, Appendix 8 Criterion V, ' Instructions, Procedures, and Drawings
- states that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, and drawings.
Site Procedure W4.503, ' Changes to the Technical Specifications, Technical Requirements Manual, or Core Operating Limits Report," Revision 4.1, required that desired changes to the technical requirements manual be evaluated under the 10CFR50.59 process in accordance with Procedure W2.302, *10CFR50.59 Safety and Environmental Screenings," and reviewed by the plant operating review committee.
Procedure W2.501, ' Corrective Action, Revision 6, states that an individual who identifies a condition adverse to quality shall initiate a condition report.
- 1. Contrary to the above, on April 8,1996, desired changes were identified for entries in Table 3.8-1 of the technical requirements manual and as of October 10, 1997, had riot been evaluated under the 10CFR50.59 process.
- 2. Contrary to the above, the licensee failed to initiate a condition report following the discovery in 1997 of a condition adverse to quality involving Calculation EC-191-027, Revision 0, dated December 30,1991, which analyzed the error associated with the containment spray riser level gauges. The calculation, which did not account for density changes in the water column being measured, affected the calculation of peak containment pressure for a loss-of-coolant accident.
This is a Severity Level IV violation (Supplement 1). (50-382/9721-02) b A
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Attachment t)
W3F197-0276 Page 2 of 6
RESPONSE
For the sake of clarity, each example of Violation 9721-02 is addressed separately below:
(1)
Reason for the Violation (Example 1)
Waterford 3 acknowledges that desired changes to Table 3.8-1 of the Technical Requitements Manual (TRM) were not evaluated under the 10CFR50.59 process from April 8,1996 to October 10,1997. The apparent cause of that condition is inappropriate ection.
Licensee Event Report (LER)95-006 dated January 8,1996, reported a condition wherein two electrical alternating current circuits which use containment electrical penetrations did not have backup overcurrent protectiot, as required by the Technical Specifications. Corrective actions for that condition included, among other things, a revision to the TRM (evaluated under the provisions of 10CFR50.59) to reflect installation of backup overcurrent protection and a review of the TRM against the computerized electrical penetrations list and associated electrical design drawings to ensure all electrical penetrations were adequately protected. Both actions were tracked under LER 95 006 and Condition Reprt (CR) 95-1282 to ensure completion.
As a result of the latter corrective action (i.e., TRM review), minor inconsistencies were identified in the TRM. Those inconsistencies did not impact the primary and backup electrical protection for the containment penetrations. On April 8,1996, an inter-office memo from Design Engineering to Licensing personnel identified the discrepancies and committed to submit the changes impacting the TRM to Electrical Maintenance for incorporation into the manual. In addition, the inter-office memo was submitted to Electrical Maintenance (to process the TRM change) and in-House Events Analysis (to close the action identified in CR 95-1282).
Site procedures W2.302, "10CFR50.59 Safety and Environmental Impact c aluations," and W4.503, " Changes to the Technical Specification, Technical Requirements Manual or Core Operating Limits Report," require all proposed TRM changes to be evaluated under the 50.59 process prior to implementation. Although TRM discrepancies were identified, personnel did not promptly process a TRM change per site procedures nor did they utilize a tracking tool to ensure a TRM change was implemented.
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Attachment to W3F197-0276 Page 3 of 6 1
(2)
Corrective Steps That Have Been Taken and the Results Achieved TRM Change Request 98-001 has been initiated. That request has been assigned to Electrical Maintenance and will provide a tracking mechanism to ensure proposed changes to correct the TRM discrepancies are evaluated under the 10CFR50.59 process.
Design Engineering / Electrical reviewed this condition during a sta'f meeting to ensure department personnel understand expectations of the corrective action process in relaying information to other departments and the importance of appropriately following up on the completion of corrective actions.
The Licensing and IHEA departments have discussed this condition in f
departmental staff meetings to accentuate the importance of action item tracking and completion.
(3)
Corrective Steps Which Will Be Taken to Avoid Further Violations The desired changes to the TRM are being evaluated under the 10CFR50.59 preass. Once that process is complete, the appropriate changes will be incorporated.
(4)
Date When Full Compllance Will Be Achieved The appropriate TRM changes will be completed by March 2,1998.
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Att: chm:nt to W3F197-0276 Page 4 of 6 (1)
Reason for the Violation (Example 2)
Waterford 3 acknowledges that a condition report was not initiated following the discovery of a condition adverse to quality associated with Calculation EC-101027, Revision O. The apparent cause of that condition is inappropriate i
action in that site procedure W2.501, " Corrective Action," Revision 6 (R6), was not used appropriately in deciding whether or not a condition report should have been written.
On March 21,1997, Design Engineering discovered a deficiency associated with calc'ilation EC 191027, Revision 0. The calculation failed to include uncertainty allowances for the Containment Spray (CS) riser level instruments.
An evaluation of that error determined CS riser indicated level could be a much as 10 feet higher than actuallevel. Because the error could prohibit or detract from the safe operation of Waterford 3, a condition repor1 (CR 97-0682) was generated.
On April 21,1997, Licensee Event Report 97-011-00 reported that, due to the uncertainty error, CS Riser level may have been less than required by Technical Specifications (TS). However, the condition would not have prevented the CS or Containment Cooling System or any other auxiliary system required to ensure operability of those systems from performing their specified safety functions.
During Refuel Outage 8 (RF08), the CS riser level instruments were replaced with more accurate devices to reduce the calculated uncertainty. The B Train instrument was replaced on May 5,1997, unuer work Authorization (WA) 01159013 and the A Train lnstrument was replaced on May 12,1907, under WA 01159014. The plant was in Mode 6 (Refueling) at the time.
On May 20,1997, EC 191027, Revision 1, was implemented in consequence of the aforementioned instrument replacements. Revision 1 included an uncertainty factor to account for density changes in the water column being measured in accordance with standard fluid calculation practices. On July 17, 1997 EC 191027, Revision 2 was implemented to account for a change in the TS allowed boron concentration in the Refueling Water Storage Pool.
While conducting IR 97-21, NRC inspectors noted the additional term for density effects applied a biased effect that, absent any other considerations, could cause the indicated CS riser level to be as much as 11.6 feet higher than actuallevel. The inspectors questioned if the additional bias invalidated previous conclusions regarding safety significance.
In response to NRC questions, Waterford 3 personnel stated that, in their judgment, changes to other assumptions in the original ca!culation would
Att:chment to W3F197-0276 Page 5 of 6 offset the increase in uncertainty added by the density affects, but had not confirmed that judgment. Furthermore, the application of density effects is a standard practice and it is unlikely that effect would be missed on a broad scale. IR 97 21 states the inspectors considered the lack of consideration of density effects in the original calculation to constitute a condition adverse to quality, in that it was a source of error that should have been considered, and for which its exclusion in this one instance, could imply its possible exclusion from other level instrument calculations.
W2.501 R6 defines a condition adverse to quality as a coridition (or i
deficiency) that could result in a degradation or challenge to nuclear safety.
At the time of discovery, personnel knew EC 191027, Revision 0, affected levelinstruments no longer installed in the plant. In addition, they believed that changes to other assumptions in the original calculation v!ould offset the increase in uncertainty added by the density effect. That offset was later confirmed and was all that was necessary to disposition the error in EC-191-027, Revision 0. W2.501 does not require personnel to initiate a condition report following the discovery of non significant issues that question past operability.
Although personnel considered it unlikely for the density effect to be missed on a broad scale and that belief was later confirmed, neither a confirmatory review or a condition report was promptly initiated. In addition, an appropriate level of supervisory review was not included in the decision making process.
The failure to promptly initiate a confirmatory review or a condition report for a potential recurring deficiency constitutes a failure to comply with W2.501.
Pursuant to W2.501 and our commitment to ANSI N45.2.11, corrective actions for significant or recurring calculation deficiencies require the initiation of a i
condition report.
l (2)
Corrective Steps That Have Been Taken and the Results Achieved l
A condition report was generated.
On May 20,1997, EC-191-027, Revision 1, was implemented. Revision 1 included an uncertainty factor to account for density changes in the water column being measured.
Design Engineering performed a review that confirmed the lack of consideration of density effects in EC-191-027, Revision 0, was offset by other assumptions in_the calculation.
l A review of level calculations and selected pressure calculations was performed No other calculations were identified that failed to include the water density factor.
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Atts:hroent to W3F19b0276 Page 6 of 6 j
a in response to IR 97-16 dated November 24,1997, Waterford 3 identified the need to emphasize the importance of communicating new information that
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involves a potentially degraded or nonconforming condition in consequence, on December 17,1997, the Director, Design Engineering, issued a memorandum to all Design Engineering personnel providing expectations on when to write a condition report and when to involve others in the decision making process.
(3)
Corrective Steps Which Will Be Taken to Avoid Further Violations This condition will be discussed during the next cycle of Engineering Support Personnel (ESP) Continuing Training. Also, that training will include additional' examples of when to write a condition report and when to involve others in the decision making process.
(4)
Date When Full Compliance Will Be Achieved Full compliance has been achieved. The next cycle of ESP Continuing
. Training is scheduled for March,1998.
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