ML20199H429
| ML20199H429 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/24/1997 |
| From: | Ewing E ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-382-97-16, GL-91-18, W3F1-97-0253, W3F1-97-253, NUDOCS 9711260111 | |
| Download: ML20199H429 (6) | |
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W3F1-07-0253 A4.05 PR November 24,1997 U.S. Nuclear Regulatory Commission
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ATTN: Document Control Desk Washirigton, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50 382 License No. NPF-38 NRC Inspection Report 50 382/9716 Reply to Notice of Violation i
Gentlemen:
In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in the response to the violation identified in Enclosure 1 of the subject inspection Report.
Waterford 3 believes that, for Example 1 of the cited violation, the operability assessment was processed in accordance with the administrative guidance provided in Site Directive W2.501, " Corrective Action," and as such ;; not representative of the cited 10CFR50, Appendix B, Criteria V violation.- The basis for this position is provided below.
Guidance has been provided to Waterford 3 engineering personnel that, when equipment is in a degraded or nonconforming condition, a determination must be
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made as to whether or not a condition adverse to quality exists. Although these determinations call for prompt and continuous attention to deficiencies and potential equipment or system inoperabilities, it is a continuous and ongoing process. This
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process requires good information and as such, requires some amount of time. This guidance is consistent with Generic Letter (GL) 91-18/NRC Inspection Manual 9900.
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NRC Inspection Report 50-382/97-16 j
Reply to Notice of Violation W3F197-0253 Page 2 November 24,1997 On or about the same day the engineer discovered the incorrect relays, engineering judgment was used to determine the incorrect relays did not present an operability concern. This judgment was proven correct when a review of the applicable calculation determined the relays met the calculation requirements.
However, at the same time, Waterford 3 recognizes the need to emphasize to personnel the importance of communicating any information discovered which involves a degraded or non-conforming e ondition. In that light, management expectations related to the guidelines of GL 91-18 will be communicated to all engineering personnel. This action will be completed by January 1,1998.
In reference to Examples 2 and 3 of the cited violation, Waterford 3 had previously identified a need for improvement in the area of corrective action. As a result, from August 4,1997, to August 15,1997, an Entergy self assessment of the Waterford 3 corrective action program was performed. The inspection team consisted of members from the other Entergy nuclear plants along with personnel from Duke Power (Catawba), Union Electric (Calloway) and a management consultant from Synetics Corporation.
While the team looked at all aspects of tha corrective action program, the following results/ conclusions concerning operability determinations were documented:
Relative to operability reviews, no instances were identified in which the appropriate (TS) was not entered or appropriate action was not taken as a result of a degraded condition.
Operability assessments were adequate.
Documentation of some operability determinations was weak.
Waterford 3 recognizes that, although the conclusions have been supported, some operability assessments have lacked the proper documentation. As such, Waterford 3 is tsking actions to strengthen our corrective action program. Those actions are described in Attachment 1 of this response.
In a conversation with Phil Harrell on November 14,1997, Waterford 3 was granted a one week extension to respond to this violation.
i' NRC Inspection Report 50 382/97-16 Reply to Notice of Violath si W3F197-0253 Page 3 Novernber 24,1997 If you have any questions concerning this response, please contact me at (504) 739-8242 or T.J. Gaudet at (504) 739-6666.
Very truly yours, i
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E.C. Ewlag
- Director, Nuclear Safety & Regulatory Affairs ECE/WDM/tjs Attachment cc:
E.W. Merschoff (NRC Region IV)
C.P. Patel(NRC NRR)
J. Smith N.S. Reynolds NRC Resident inspectors Office 1
Attachment to W3F1-97-0253 Page 1 of 3 ATTACHMENT 1 ENTERGY OPERATIONS. INC, RESPONSE TO THE VIOL ATION IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 97-16 VIOLATION NO. 9716-01 10CFR50, Appendix B, Criterion V, states, in part, that activities affecting quality shall be accomp!!shed in accordance with documented instructions appropriate to the circumstances.
Procedur^ W2.501, " Corrective Action," Step 6.1.2.3, states that the shift technical advisor or a senior reactor operator will perform an operability assessment for a condition report in accordance with the instructions given in Attachment II,
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" Operability Assessment and immediate Reportability Determination.' Atttchment ll provides an example of the OPERABILITY ASSESSMENT portion of the condition report form including instructions. Attachment II, Instruction 1.A requires personnel to identify whether the component affects Technical Specification or Technical Requirements Manual applicable equipment or systems. Attachment Instruction 1.D.2 directs that if the equipment or system remains operable, document an evaluation in the BASIS section of the form.
Contrary to the above, operability assessments, an activity affecting quality, were not processed in accordance with the administrative requirements discussed above, in that:
(1)
As of July 31,1997, Condition Report 97-0989 identified three additional valves that had nonqualified thermal overload relays installed in Technical Specification required equipment without personnel assessing the impact on operability of the nonqualified relays in the basis section of the form.
(2)
On April 23,1997, Condition Report 97-0989, mlated to the overload relays for Valve EFW 2208, Emergency Feedwater Header A isolation valve, did not correctly identify this as Technical Specification / Technical Requirements Manual related equipment and, as a result, no operability evaluation was documented in the basis section of the form.
(3)
On February 3,1997, Condition Report 97-0258, related to a missing spent fuel handling machine seismic restraint, did not have documented an appropriate evaluation of operability in the basis section of the form.
This is a Severity Level IV violation. (Supplement I) (50-382/9716-01)
' 3 W3F1-97-0253 Page 2 of 3
' RESPONSE (1)
~ Reason for the Violation Waterford 3 believes the root cause of Examples 2 and 3 of this violation is that, becauce instructions provided to Control Room personnel in Site Directive W2.501, " Corrective Action,' are somewhat vague, management expectations are not clearly communicated, in Example 2, the STA stated that because the valve in question was normally deenergized, an incorrect thermal overload relay did not affect the operation of the valve. Therefore, Technical Specification (TS) equipment was not affected and an operability determination was not required.
In Example 3, the Shift Technical Advisor (STA) believed that he was only required by procedure to state the basis for the operability determination, not to provide documentation for that determination.
(2)
Corrective Steps That Have Been Taken and the Results Achieved Operations' department management discussed the need for improved operability determinations during a weekly Shift Superintendent / Control Room Supervisor (SS/CRS) meeting. Plant management had noted the bases for some operability determinations were weak. At that SS/CRS meeting, the need for a well-grounded, logical and documented basis for each operability determination was discussed. Also stressed was each basis must be detalied enough for non-operations personnel to understand the oporability rationale.
(3)
Corrective Steps Which Will Be Taken to Avold Further Violations As a result of self-assessments and Entergy peer group input, Waterford 3 is in the process of revising Site Directive W2.501, ' Corrective Action," which will contain detailed operability assessment guidance. Examples of that guidance include:
Operability and time of entry in TS Action Statements items clearly inoperable e
Missed or deficient surveillance Pipe hangers, supports, and cestraints Hydraulic and mechanical snubbers Manual valve position Power operated valve position ASME Section XI qualification Equipment exposed to operating condition in excess of design ratings
Attachment ts W3F197-0253 Page 3 of 3 Normal and emergency power source availability Setpoint and calibration tolerance e
. Equipment with automatic and manual start /stop capability Environmental qualification l
e Electrical breakers l
Safety parameter display system e
e Fire barriors Use of engineering judgment for operability assessments l
e Training will be conducted on Site Directive W2.501 for all Reactor Operators, Senior Reactor Operators, and Shift Technical Advisors. The scope of the training will be developed by Waterford 3 personnel with assistance from personnel from Arkansas Nuclear One Operations department personnel.
The operability determinations for CRs 97-0258 and 97-0989 will be revised, (4)
Date When Full Comollance Will Be Achieved Management expectations to report all information that could affect equipment operability will be communicated to all engineering personnel by January 1, 1998.
Revision 7 to Site Directive W2.501 la scheduled to be Imnlemented on December 15,1997.
Operations department training will be completed by December 15,1997.
The revisions to the operability determinations for CRs 97-0258 and 97-0989 will be completed by January 1,1998.
' Waterford 3 will be in full compliance upon completion of the above procedure revision, training and revisions to the above CRs.
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