ML20199H806
| ML20199H806 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 01/30/1998 |
| From: | Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Dugger C ENTERGY OPERATIONS, INC. |
| References | |
| 50-382-97-21, NUDOCS 9802050127 | |
| Download: ML20199H806 (5) | |
See also: IR 05000382/1997021
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January 30, 1998
Charles M. Dugger, Vice President
Operations . Waterford 3
Entergy Operations, Inc.
P.O. Box B
Killona, Louisiana 70066
SUBJECT: RESPONSE TO NRC INSPECTION REPORT 50-382!97-21
Dear Mr. Dugger:
Thank you for your letter of January 22,1998, in response to our December 2,1997,
letter and Notice of Violation concerning two examples of a failure to follow procedures. We
have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation.
We will review the implementation of your corrective actions during a future inspection to
determine that full cor,pliance has been achieved and will be maintained.
Sincerely,
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Thomas F. Stetka, Acting Chief'
Engineering Branch
Division of Reactor Safety
Docket No.: 50-382
License No.: NPF 38
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Executive Vice President and
Chief Operating Officer
Entergy Operations, Inc.
P.O. Box 31995
Jackson, Mississippi 39286-1995
Vice President, Operations Support
Entergy Operations, Inc.
P.O. Box 31995
Jackson, Mississippi 39286-1995
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Entergy Operations, Inc.
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Wise, Carter, Child & Caraway
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P.O. Box 651
Jackson, Mississippi 39205
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General Manager, Plant Operations
Waterford 3 SES
Entergy Operations,Inc.
P.O. Box B
Killona, Louisiana 70066
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Manager Lloonsing Manager
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Waterford 3 SES
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Entergy Operations, Inc.
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P.O. Box B
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Chairman-
Louisiana Public Service Commission
One American Place, Suite 1630
Baton Rouge, Louisiana 70825-1697
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Director, Nuclear Safety &
Regulatory Affairs
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- Waterford 3 SES
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Entergy Operations, Inc.
P.O. Box B
Killona, Louisiana 70066
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William H. Spell, Administrator
Louisiana Radiation Protection Division
P.O. Box 82135
Baton Rouge, Louisiana 70884 2135
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Parish President
St. Charles Parish
P.O. Box 302
Hahnville, Louisiana 70057
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Mr. William A. Cross
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3 Metro Center
Suite 610
Bethesda, Maryland 20814
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W3F 197-0276
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January 22,1998
U.S. Nuclear Regulatory Commission
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Subject:
Waterford 3 SES
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Docket No. 50 382
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License No. NPF-38
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NRC Inspection Report 97 21
Reply to Notice of Violation
Gentlemen:
In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in
Attachment 1 the response to the violation identified in Enclosure _1 of the subject
Inspection Report.
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On December 31,1997, Waterford 3 receivea permission to extend the due date for
this reply from January 2,1998, to January 15,1998. On January 15,1998,
permission was granted to extend the due date from January 15,1998, to January
22,1998. NRC personnel contacted for those extensions include the Region IV
Director, Division of Reactor Safety, and the Region IV Deputy Director, Division of
Reactor Safety.
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NRC Inspection Report 97 21
Reply to Notice of Violation
W3F197 0276
Page 2
January 22,1998
If you have any questions concerning this response, please contact me at (504) 739
6242 or Tim Gaudet at (504) 739 6666.
Very truly yours,
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E.C. Ewing
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Director,
Nuclear Safety & Regulatory Affairs
ECE/WDM/ssi
Attachment
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E.W. Merschoff (NRC Region IV)'
J. 8.leberman (NRC-NRR)
C.P. Patel(NRC NRR)
J. Smith
N.S. Reynolds
NRC Resident inspectors Office
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Att:chment to
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V/3F197-0276
Page 1 of 6
ATTACHMENT 1
ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN
ENCLOSURE 1 OF INSPECTION REPORT 50-382/97-2_1,
VIOLATION NO,9721-02
10 CFR Part 50, Appendix B, Criterion V, * Instructions, Procedures, and Drawings,"
states that activities affecting quality shall be prescribed by documented instructions,
procedures, or drawingt,, of a type appropriate to the circumstances and shall be
accomplished in accordance with these instructions, procedures, and drawings.
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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 not 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 conta;nment 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)
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RESPONSE
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For the sake of clarity, each example of Violation 9721-02 is addressed separately
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(1)
Reason for the VinjaEQD (Example 1)
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Waterford 3 acknowledges that desired changes to Table 3.8-1 of the
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Technical Requirements Manual (TRM) were not evaluated under the
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. 10CFR50.59 process from April 8,1996 to October 10,1997. The apparent
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cause of that cor.dition is inappropriate action.
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Licensee Event Report (LER)95-006 dated January 8,1996, reporied a
condition wherein two electrical alternating current circuits which use
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containment electrical penetrations did not have backup overcurrent .
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protection as required by the Technical Specifications Corrective actions for .
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that condition included, among other things, a revision to the TRM (evaluated
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under the provis!ons of 10CFR50,59) to reflect installation of backup
overcurrent protection and a review of the TRM against the computerized
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electrical penetrations list and associated electrical design drawings to ensure
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all electrical penetrations were adequately protected Both actions were_
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tracked under LER 95-006 and Condition Report (CR) 95-1282 to ensure
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completion.
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inconsistencies were identified in the TRM, Those inconsistencies did not
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impact the primary and backup electrical protection for the containment
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penetrations, On April 8,' 1996, an inter-office memo from Design Engineering
to Licensing personnel identified the discrepancies and committed to submit'
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the changes impacting the TRM to Electrical Maintenance for incorporation
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into the manual, in addition, the inter-office memo was submitted to Electrical
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Maintenance (to process the TRM change) and in-House Events Analysis (to-
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close the action identified in CR 95-1282),
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Site procedures W2,302, "10CFR50,59 Safety and Environmental impact
Evaluations," and W4,503, " Changes to the Technical Specification,
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Technical Requirements Manual or Core Operating Limits Report," require all
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- proposed TRM changes to be evaluated under the 50,59 process prior to
implementation Although TRM discrepancies were identified, personnel did
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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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W3F1974276
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Page 3 of 6
(2)-
Corrective Stoos That Have Been Taken and the Result 1 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 staff meeting to
ensure department personnel understena expectatiens of the corrective
action process in relaying information to other departinents and the
importance of appropriately following up on the completion of corrective
actions.
The Licensing and lHEA departments have discussed this condition in
departmental staff meetings to accentuate the importance of action item
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tracking and completion.
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(3)
Corrective Stoos Which Will Be Taken to Avoid Further Violations
The desired changes to the TRM are being evaluated under the 10CFR50.59
process. Once that process is complete, the appropriate changes will be
incorporated.
(4)
Date When Full Comoliance Will Be Achieved
The appropriate TRM changes will be completed by March 2,1998.
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Att: chm:nt to
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VV3F197-0276
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(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 0. The apparent cause of that condition is inappropriate
action in that site procedure W2.501, " Corrective Action," Revision 6 (R6), was
not usod appropriately in deciding whether or not a condition repor1 should
have been written.
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On March 21,1997, Design Engineering discovered a deficiency associated
with calculation EC 191027, Revision 0. The calculation failed to include
uncertainty allowances for the Containment Spray (CS) riser level instruments.
An evaluation of that enor 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 report (CR 97-
0682) was, generated.
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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, under work Authorization (WA)
01159013 and the A Train instrument was replaced on May 12,1997, under
WA 01159014. The plant was in Mcde 6 (Refueling) at the time.
On May 20,1997, EC-191-027, Revision 1, was implemented in consequence
of the aforementioned instrument leplacements. 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-191-027, 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 mtah as 11.6 feet higher
than actuallevel. The inspectors questioned if the additional bias invalidated
previous conclusion : regarding safety significance.
In response to NRC questions, Waterford 3 personnel stated that, in their
judgment, changes to other assumptions in the oiiginal calculation would
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Att: chm:nt to
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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 condition (or
deficiency) that could result in a degradation or challenge to nuclear safety.
At the time of discovery, personnel knew EC 191-027, Revision 0, affected
level instruments no longer installed in the plant. In addition, they believed
that changes to other assumptions in the original calculation would 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
condition report.
(2)
Corrective Steps That Have Been Taken and the Results Achieved
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-191-0:!7, Revision 0, was offset by other
assumptions in the calculation.
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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Page 6 of 6
in response to IR 97-16 dated November 24,1997, Waterford 3 identified the
need to emphasize the importance of communicating new information that
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
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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.
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(4)
Date When Full Compliance Will Be Achieved
Full compliance has been achieved. The next cycle of ESP Continuing
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Training is scheduled for Mwch,1998.
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