ML20199J351
| ML20199J351 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 02/02/1998 |
| From: | Ewing E ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-382-97-27, W3F1-98-0015, W3F1-98-15, NUDOCS 9802050290 | |
| Download: ML20199J351 (4) | |
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PR February 2,1998 U.S. Nuclear Regulatory Commission
- ATTN: Document Control Desk Washington, D.C. 20555 l
Subject:
Waterford 3 SES Docket No. 50-382 License No NPF-38 NRC Inspection Report 97 27 Reply to Notice of Violation Gentlemen:
In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in the response to the violation identified in Enclosure 1 of the subject laspection Report.
If you have any questions concerning this response, pleare contact me at (504) 739-6242 or Tim Gaudet at (504) 739-6666.
Very truly yours, J
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E.C./ wing i
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- Director, Nuclear Safety & Regulatory Affairs l
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ECE/GCS/ssi V""^"7 t.-
Attachment
{T)l cc:
E.W. Merschoff (NRC Region IV), C.P. Patel (NRC-NRR),
J. Smith, N.S. Reynolds, NRC Resident inspectors Office 9902050290 990202 PDR ADOCK 05000382 G
PDR a
77 _. _ _ -
Attachment to W3F198-0015 Page 1 of 3 ATTACHMENT 1 I
ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 97 27 VIOLATION NO. 9727-01 Criterion XVI of Appendix B to 10 CFR Part 50 states, in part, measures shall be established to assure that conditions adverse to quality, such as nonconformances, are promptly identified and corrected, Procedure W2.501, " Corrective Action," Step 4.9, stated, in part, that a nonconforming condition is an adverse condition affecting a safety-related system caused by a deficiency in a characteristic that rendeis the quality of the item indeterminate. Step 4,9.2 stated that discovery of a condition of a system or component required to be operable by Technical Specifications, which calls into question the current or past operability, is an example of a nonconforming condition, Step 6,1.1 stated, in part, that an individual who identifies an adverse condition shall complete Sections 1,2, and 3 of Attachment I (the condition report form) in accordance with the instructions given in the attachment.
Contrary to the above, on February 24,1997, an individual, who identified an adverse condition affecting a safety-related system, failed to promptly identify a nonconformance that called into question the operability of a system required to be operable by Technical Specifications Specifically, the individual identified an adverse condition related to the refueling water storage pool level instrumentation and did not promptly complete a condition report form.
This is a Severity Level IV violation (50 382/9727-01) (Supplement 1).
RESPONSE
(1)
Reason for the Violation The apparent cause of this violation is inappropriate action due to a lack of information.
On February 23,1997, an Instrumentation & Controls (l&C) Technician observed an indicated change in RWSP level when the CVAS fan started.
The indicated level increased approximately two percent. The l&C Technician notified control room personnel of the observation. At that time, personnel had a reasonable expectation that the RWSP level instruments were operable. In addition, there was no reason to believe the observed change represented a condition involving a loss of quality or functional capability or the failure to meet requirements or commitments.
Attachment to W3F1-98-0015 Poge 2 of 3 i
Due to a questioning attitude, however, personnel initially aware of the
' observetion informed other personnel and attempted to obtain additional e
information. For example, Operations personnel promptly informed a Design Engineer of the observation and expected to obtain information substantiating their initial expectation. However, ths Design Engineer responded that he would be surprised if the effect had been accounted for in the RAS setpoint.
At that time, a potential adverse condition existed and personnel should have generated a condition report or an engineering request to facilitate a prompt 4
Subsequent to the above information request, the l&C Technician informed his superintentent who, in turn, involved others. As more people became involved and more information became available, a decision was made to initiate a condition report. On March 8,1997, condition report CR 97-0562 was generated.
in hindsight, personnel acted inappropriately in that a nonconforming condition existed prior to March 8,1997, and a condition report was not j
generated. As a practical matter, decision making requires good information and takes time. However, the process used to gather that information should call for prompt and continuous attention to deficiencies and potential system inoperabilities. Given the lack of information available on February 23,1997, personnel did not believe an adverse condition or potential nonconformance existed. As additionallnformation became available, however, it became clear an adverse condition existed and a condition report should have been previously generated.
(2)
Corrective Steps That Have Been Taken and the Results Achieved 1.
Condition Report 97-0562 was generated.
2.
On December 10,1997, Revision 7 to Site Procedure W2.501 was implemented. This revision includes condition report threshold examples.
3.
Management's expectations regarding the thresholds for generating condition reports and identification of problems have been communicated and reinforced to operations personnel. This activity was performed at department and SS/CRS meetings and was included in written communications. Operations personnel continue to aggessively identify and document plant problems in condition reports.
4.
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 cendition. In consequence, on December 17,1997, the Director, Design Engineering, issued a memorandum to all Design Engineering
Attachment to W3F198-0015 Pcge 3 of 3 l
personnel providing expectations on when to write a condition report i
and when to involve others in the decision making process.
(3)
Corrective Stoos Which Will Be Taken to Avoid Further Violations t
The next cycle of Engineering Support Personnel (ESP) Continuing Training will include examples of when to write a condition report and when to involve others in the decision making process.
i (4)
Date When Full Comollance Will Be Achieved
[
a Full compliance has been achieved. The next cycle of ESP Continuing l
Training is Scheduled for March,1998.
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