ML20216E724
| ML20216E724 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/12/1998 |
| From: | Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Dugger C ENTERGY OPERATIONS, INC. |
| Shared Package | |
| ML20216E728 | List: |
| References | |
| 50-382-97-25, EA-98-022, EA-98-22, NUDOCS 9803180135 | |
| Download: ML20216E724 (6) | |
See also: IR 05000382/1997025
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NUCLEAR REGULATORY COMMISSION
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REGION IV
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611 RYAN PLAZA DHIVE. SUITE 400
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AR LINGTON. TEXAS 760 t t 8064
March 12,1998
EA 98-022
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Charles M. Dugger, Vice President
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Operations - Waterford 3
Entergy Operations, Inc.
P.O. Box B
Kiliona, Louisiana 70066
SUBJECT: NRC INSPECTION REPORY 50-382/97-25 AND NOTICE OF VIOLATION
Dear Mr. Dugger:
From December 1,1997, through February 5,1998, an engineering team inspection was
conducted at your Waterford Steam Electric Station, Unit 3, reactor facility. The NRC performed
a safety system engineering inspection of the high pressure safety injection system, evaluated
implementation of 10 CFR 50.59, " Changes, Tests and Experiments," and evaluated the status
of various upgrade programs, which were planned or in progress. An exit meeting was
conducted on February 5,1998. The enclosed report presents the scope and results of that
inspection.
The team identified problerm involving: 1) the control of the design and licensing bates for the
facility: 2) the ability to fully scope. prioritize and correct identified problems; and 3) the
implementation of 10 CFR 50.59. The team noted that several significant upgrade programs
were in progress, and, in general, these programs appeared to be appropriately focused.
Based on the resu'ts of this inspection, the NRC has determined that one violation of NRC
requirements occurred. Your staff fai'ed to initiate a condition report to reassess the capability of
the main feedwater isolation valves in light of new valve factor information available from site-
specific motor-operated valve testing and promulgated in an NRC information notice. The viola-
tion is of concern because this new valve factor information potentially impacted the operability
of the valve. This violation is cited in the enclosed Notice of Violation (Notice) and the
circumstances surrounding this violation are described in detail in the subject inspection report.
Please note that 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.
In addition, six apparent violations were identified and ere being considered for escalated
'forcement action in accordance with the " General Statement of Policy and Procedure for NRC
uforcement Actions"(Enforcement Policy), NUREG-1600. The team identified one apparent
violation of 10 CFR Part 50, Appendix B. Criterion XVI, " Corrective Action," two apparent
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violations of 10 CFR 50.46, " Acceptance Criteria for Emergency Core Cooling Systems for Light
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Water Nuclear Power Reactors," one apparent violation of 10 CFR Part 50, Appendix B,
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Criterion XI, " Test Control," and two apparent violations of 10 CFR 50.59, " Changes, Tests and
Experiments." Accordingly, no Notice of Violation is presently being issued for these inspection
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findings. In addition, please be advised that the number and characterization of apparent '
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violations described in the enclosed inspection report may change as a result of further NRC
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review,
An open predecisional enforcement conference to discuss these apparent violations has been
scheduled for March 26,1998, at 1 p.m. In the Region IV office. The decision to hold a
predecisional enforcement conference does not mean that the NRC has determir,ed that
violations have occurred or that enforcement action will be taken. This conference is being held
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to obtain information to enable the NRC to make an enforcement decision, such as a common
understanding of the facts, root c&uses, missed opportunities to identify the apparent violations
corrective action.
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sooner, corrective actions, significance of the issues, and the need for lasting and effective
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During the predecisional enforcement conference, we would like you to address the missed
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opportunities to ' identify the apparent violations related to the high pressure safety injection
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system, which are described in Sections E2.2 and E2.3 of the enclosed report. Specifically, we
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are intercated in your perspectives on: 1) the adequacy of the review efforts each time the
issues involving emergency core cooling system instrument uncertainty surfaced; and 2) the
adequacy of the prioritization of the planned corrective actions. Additionally, with respect to the
ap' parent violation of 10 CFR 50.59 involving the emergency feedwater system, we would like
you to address any generic implications associated with this apparent violation. Specifically, we
would like you to address your definition of margin of safety in the context of 10 CFR 50.59, and '
whether you have implemented changes to the bases sections of other technical specifications
Du the basis of your definition. We would also like you to address any other approved changes
to t"e facility that were justified on the basis of alternative calculations, which differed from the
methods and assumptions used in the safety analysis.
. In addition, this is an opportunity for you to point out any errors in our inspection report and for
you to provide any information conceming your perspectives on 1) the severity of the violations,
2) the application of the factors that the NRC considers when it determines the amount of a civil
penalty that may be assessed in accordance with Section VI.B.2 of the Enforcement Policy, and
3) any other application of the Enforcement Policy to this case, including the exercise of
discretion in accordance with Section Vll.
You will be advised by separate correspondence of the results of our deliberations on this
matter. No response regaro,,19 these apparent vic!ations i required at this time.
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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 (s), and your response will be placed in the NRC Public Document Room (PDR),
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Should you have any questions concerning this inspection, we will be pleased to discuss thern
'with you.
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Sincerely,
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Anhur T. Howell 111, Director.
Division of Reactor Safety
Docket No.:
50-382
License No.:. NPF-38
Enclosurbs:
2. . NRC Inspection Report -
50 382/97-25
cc w/ enclosures:
Executive Vice President and
Chief Operating Officer
Entergy Operations, Inc.
.
P.O. Box 31995
Jackson, Mississippi 39266-1995
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
General Manager, Plant Operations
Waterford 3 SES
Entergy Operations, Inc.
P.O. Box B
Killona, Louisiana 70066
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EnterCy Operations, Inc.
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Manager- Licensing Manager
. Waterford 3 SES
Entergy Operations, Inc.
P.O. Box B
Killona, Louisiana 70066
Chairman
. Louisiana Public Service Commission
One American Place, Suite 1630
- Baton Rouge, Louisiana 70825-1697
Director, Nuclear Safety &
Regulatory Affairs
Waterford 3 SES
Entergy Operations, Inc.
P.O. Box B
Kil!ona, Louisiana 70066
William H. Spell, Administrator
Louisiana Radiation Protection Division
P.O. Box 82135
Baton Rouge, Louisiana 70884-2135
Parisn President
St. Charles Parish
P.O. Box 302 '
Hahnville, Louisiana 70057
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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E-Mail report to T. Frye (TJF)
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E-Mail report to T. Frye (TJF)
E-Mail report to T. Hiltz (TGH)
E-Mail report to NRR Event Tracking System (IPAS)
E-Mail report tc Document Control Desk (DOCDESK)
bec to DCD (IE01)
bec distrib. by RIV:
Regional Administrator
Resident inspector
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DRS-PSB
Branch Chief (DRP/D)
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Lieberman, OE (0-7H5)
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