ML20199L262
| ML20199L262 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 02/05/1998 |
| From: | Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Dugger C ENTERGY OPERATIONS, INC. |
| Shared Package | |
| ML20199L269 | List: |
| References | |
| 50-382-97-26, EA-97-589, NUDOCS 9802090163 | |
| Download: ML20199L262 (5) | |
See also: IR 05000382/1997026
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGloN IV
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611 RYAN PLAZA DRIVE. SUITE 400
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ARUNGToN TEXAS 76011 8064
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February 5, 1998
EA 97-589
. Charles M. Dugger, Vice President
Operations - Waterford 3
Entergy Operations, Inc.'
P.O. Box B
~ Killona, Louisiana 70066
SUBJECT:
NOTICE OF V80LATION (NRC INSPECTION REPORT 50 382/97-26)
Dear Mr Dugger:
This refers to the predecisional enforcement comvence conducted January 23,1998, in the
NRC's Arlington, Texas office.' The conference was conducted to discuss several apparent
violations related to a November 1997 incident involving a mispositioned valve controller in the
auxiliary component cooling water system at the Waterford Steam Electric Station,
Unit 3 (Waterford 3). The apparent violations were identified during an NRC inspection that
concluded on December 15,1997, when the inspection findings were conveyed to Entergy
. Operations, Inc. (Entergy) by telephone, ard were documented in the subject inspection report ;
on January 5,1998.
Based on the information developed during the inspection, and our consideration of the -
information that you provided during the conference, the NRC has determined that violations of
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NRC requirements occurred. These violations are cited in the enclosed Notice of
Violation (Notice) and the circumstances surrounding them were described in detail in the
subject inspection report in brief, the violations are related to a failure to retum the controller for
Valve ACC-126A to automatic operation following its use on November 9,1997,- an error which
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went unrecognized for 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> despite several control board walkdowns by operators and a
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shift tumover. The failure to retum this valve to automatic rendered Train A of the auxiliary
component cooling water system inoperable. Operators compounded this error by removing
Train B of the auxiliary component cooling water system from service for routine maintenance on
November 10,1997, without first physically verifying the operability of Train A. Both trains of this
system remained inoperable for approximately 7.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. The problem was ultimately corrected
on November 10,1997, when a relief opt rator walked down the control boards and discovered
the mispositioned valve. Train A was imn ediately restored to service.
The violations include the procedural error that resulted in the mispositioned valve controller, the
failure to verify the operability of Train A before taking Train B out of service, and the failure to .
discover the mispositioned controller during control board walkdowns and shift turnover. We
recognize that the Waterford-3 auxiliary component cooling water system, which supports the
component cooling water system, may not have been necessary to support the safety function
of the ultimate heat sink, given the meteorological conditions that existed at the time of this
incident, and the likelihood that operators could have restored Train A operability after receiving
h.
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9902090163 990205
5
ADOCK 05000382
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Entergy Operations, Inc.
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a h!gh temperature alarm on the component cooling water system. The NRC also recognizes
- that no audible or visible alarms were triggered as a result of the controller being in the wrong
position. Nonetheless, these violations are safety significant because a safety system which is
designed to remove heat under certain accident conditions, and which was required to be
operable at the time, was rendered incapable of operating automatically as designed, in =
addition, as discussed at some !sngth during the conference, corrective actions for prevbus, .
similar events involving mispositioned switches and valves (NRC inspection report 50-382/96 ;
13) were not effectively implemented in this case, as evidenced by the many missed
opportunities to have discovered this error eariier,
Accordingly, these violations are classified in the aggregate as a Severity Level lil problem in
accordance with the "Genorcl Statement of Policy and Procedure for NRC Enforcement Actions"
(Enforcement Policy) NUREG-1600.' In accordance with the Enforcement Policy, a civil penaIty
with a base value of $55,000 is considered for a Seventy Level lli problem. Because your . _
facility has been the subject of escalated enforcement actions within the last two years l the
NRC considered whether credit was warranted for identification and Corrective Action in
accordance with the civil penalty assessment process in Section VI B.2 of the Enforcement
Policy. Given that the mispositioned valve controller was discovered by a Waterford-3 operator
and not revealed by an event, and that the failures to identify the error earlier also were
discovered by Entergy, the NRC concludes that credit for identification is warranted; We also
conclude that credit for corrective actions is warranted, Your corrective actions included:
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- immediate action to restore system operability and walk down all control boards; debrief of all
operators on duty when ACC-126A was mispositioned; meetings with all shift personnel to .
reinforce expectations for walkdowns and shift tumover; procedural revision to eliminate two
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actions in one step in OP-002-001; implementation of control board assessments by shift
technical advisor during shift tumover; enhancement of shift tumover control board walkdown
_ procedure; and plans for a corrective action effectiveness review within six months.
Therefore, to encourage identification and comprehensive correction of violations before events
- occur, I have been authorized, after consultation with the Director, Office of Enforcement, not to
assess a civil penalty in this case. However, significant violations of this nature in the future
could result in a civil penalty.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response The NRC will use your response, in part, to
determine whether further enforcement action is necessary to ensure compliance with regulatory
-requirements.
'For example, a $50.000 cml peratty was ,ssued March 28,1996 (EA 96-025), a $50,000 civil penalty was issued
December 26.1996 (EA 96-255); and a $55.000 cwil penalty was issued May 9,1997 (EA 97-099).
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Entergy Operations, Inc.
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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its
enclosure, and your response will be placed in the NRC Public Document Room (PDR).
Sincerely,
'
Ellis W.
Regional Admi
trator
Docket No.: 50-382
License No.: NPF 38
Enclosure: Notice of Violation
cc w/ Enclosure:
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
Wise, Carter, Child & Caraway
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
Manager - Licensing Manager
Waterford 3 SES
Entergy Operations, Inc.
P.O. Bo.y B
Killona, Louisiana 70066
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Entergy Operations, Inc.
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Chairman
Louisiana Public Service Commission
One American Place, Suite 1830
Baton Rouge, Louisiana 70825-1697
Director, Nuclear Safety &
Regulatory Affairs
Waterford 3 SES
Entergy Operations, Inc.
P.O. Box B
Killona, Louisiana 70066
William H. Spell, Administrator
Louisiana Radiation Protection Division
P,0. 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
Bethesda Licensing Office
3 Metro Center
Suite 610
Bethesda, Maryland 20814
Winston & Strawn
1400 L Street, N.W.
Washington, D.C. 20005-3502
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Entergy Operations, Inc.
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bec w/ Enclosure:
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