ML20217Q250
| ML20217Q250 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/28/1997 |
| From: | Ewing E ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-382-97-11, W3F1-97-0209, W3F1-97-209, NUDOCS 9709020141 | |
| Download: ML20217Q250 (8) | |
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W3F197-0209 A4.05 PR August 28,1997 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washin? ton, D.C. 20555 t
Subject:
Waterford 3 SES Docket No. 50 382 License No. NPF-38 NRC Inspection Report 97-11 Reply to Notice of Violation Gentlemen:
In accordarice with 10CFR2.201, Entergy Operations, Inc. hereby submits in the response to the violation identified in Enclosure 1 of the subject inspection Report. A one week extension from the original 30 day response date for this submittal was granted by the Waterford 3 NRC Region IV Branch Chlef per telecon on August 21,1997,-
if you have any questions concerning this response, please contact me at (504)739-6242.
Very truly yours, YY I
o E.C Ewing
- Director, Nuclear Safety & Regulatory Affairs ECE/DFUtjs
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- Attachments PDR= ADOCK 05000382
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NRC Inspection Report 9711 Reply to Notice of Violation W3F197-0209 Page_2 August 28,1997 cc:
E.W. Merschoff (NRC Region IV)
C.P. Patel (NRC-NRR)
J. Smith N.S. Reynolds NRC Resident inspectors Office 1
i 4
___m.m.
Att:chmert to W3F197 0200 Pcgo 1 of 5 ATTACHMENT 1 ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 9711 VIOLATION NO. 9711-01 Technical Specification 6.8.1 a requires, in part, that written procedures shall be implemented covering applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A, Section 1.c, requires that the licensee have administrative procedures for equipment control (e.g.,
locking and tagging).
Administrative Procedure UNT 005 003," Clearance Request, Approval, and Release," Revision 14, Section 5.3, " Preparation of the Clearance Form," requires, in part, that, if tags are added or deleted to a clearance, the individual making the changes shall ensure that the clearance affords the same level of protection or better than the original clearance, the clearance shall receive an independent review by a licensed operator to verify that the boundaries chosen are adequate, and the clearance is forwarded to the shift supervisor / control room supervisor for review.
Contr.ry to the above, on May 20,1997, Administrative Procedure UNT-005 003 was not implemented in that tags were added to Clearance 97-0864 without adequately ensuring the revised clearance afforded the same level of protection as the original clearance, without an independent review by a lleensed operator, and without forwarding the clearance to the shift supervisor / control room supervisor, This is a Sever!ty Level IV violation (Gupplement 1) (50-382/9711-01).
Attachment to VV3F1-97-0209 Page 2 of 5
' RESPONSE TO VIOLATION NO. 9711-01 (1)
Reason for the Violation l
l The issuance of an inadequate clearance modification to the field was due to personnel errcr invoiving inattention to detail, in that the Shift Support Center (SSC) plant operator (NPO) did not ensure the same level of protection as the original clearance. The Refueling Water Storage Pool (RWSP) purification system was in service and should have been secured prior to hanging the tags. When the fuel pool ion exchanger to RWSP isolation valve, FS-404, was shut, the RWSP purification pump was running essentially dead-headed against velve FS-404 and the fuel pool ion exchanger to fuel pool isolation valve, FS-345 (See Attachment 2). The failure of the NPO to obtain the appropriate reviews for the clearance modification was a combination of poor judgment and unclear procedural guidance in UNT-005-003, " Clearance Request, Approval, and Release." Obtaining an independent operator review and SS/CRS review is clearly required and performed when preparing the initial clearance. However, the procedure is unclear as to the review requirements for adding tags to an existing clearance, which resulted d inconsistent implementation of this procedure. This inconsistency was further evidenced by a follow up evaluation performed by the Waterford 3 Quality Assurance Department, which revealed other instances of failure to obtain the appropriate reviews for adding tags. Regardless, it is Operations Management's expectation these reviews were to be performed.
An Event Review Team was formed to investigate the Spent Fuel Pool (SFP) overflow event and determined several other factors which contributed to the event including the following:
The nuclear auxiliary operators (NAOs) hanging the clearance took inadequate actions to correct the abnormal condition of running the RWSP Purification Pump with its discharge flow path isolated. The fact that RWSP Purification needed to be secured was discussed; however poor communications between the NAOs and the SSC NPO led the SSC to believe FS-404 remained open. The status of the clearance and the system was not effectively communicated to the SSC. The SSC NPO assumed that the NAQs re-opened FS-404 once they realized there was still flow through the pipe.
The assumption by the SSC NPO that FS-404 was opened, and therefore a flow path existed for the RWSP Purification Pump, led him to believe that securing RWSP Purification was not a high priority. Communications from the SSC NPO were poor in that the SSC NPO did not inform the Control Room that a clearance was sent to the field. This is contrary to management expectations.
The travel stop nuts on FS-345 were incorrectly positioned 1/8 inch lower than required by the valve technical manual. This resulted in the valve not fully
Att: chm:nt to VV3F1-97-0209 Pcga 3 of 5 blocking flow to the Spent Fuel Pool when closed. A review of maintenance history on the valve revealed the valve was last worked in May,1992, to install an extension stem per Design Change (DC) 3211. This activity required the travel stop nuts to be removed. Neither DC-3211 nor the associated work authorization contained specific instructions as to the required position of the travel stop nuts upon replacement.
With several critical outage evolutions taking place at the time (EDG A run, venting of HPSI system, fill and vent of LPSI system), the Operating Crew placed a lower priority on lowering SFP level following the High Level Alarm which led to the SFP overflow. When the crew received the SFP High Level Alarm, a NAO was promptly sent to investigate. The NAO reported that the level in the GFP had risen approximately one inch in the last twenty-four hours. The crew appropriately had the NAO check all influent valves into the SFP closed in accordance with the Annunciator Response Procedure. The crew discussed the possible cause of the rise in SFP level. However they did not contact the SSC to determine if they had done any evolutions that would have resulted in the level rise. They believed that the rise may have been attributable to the Emergency Diesel Generator (EDG) A run that had just been completed. During the dDG run the CCW makeup pump was running.
The crew believed that the Condensate Makeup (CMU) valves to the SFP l
may have been leaking and appropriately requested a boron sample of the SFP from Chemistry. Because the cause of +e level rise was still not positively identified, they instructed the RAB Watch to periodically monitor the SFP level on his normal rounds.
The shift was unaware of the continued in-leakage to the SFP because there is no Hi/Hilevel alarm to provide additional warning and there is no remote levelindication for the Soent Fuel Pool. The only methods available to the crew to detect continued in-leakage was through periodic local monitoring of level or lowering the SFP level below the high alarm.
(2)
Corrective Steps That Have Been Taken and the Results Achieved The following corrective actions which address the violation are complete:
On May 25,1997, the Operations Manager sent a message to all Shift s
Superintendents and Control Room Supervisors stating: 1) On-shift SS/CRS will initial each clearance to release the system for work and 2) Additional tags shall not change the scope and intent of the original clearance. if the additional tags will challenge either the scope or intent, then a new clearance shall be prepared, complete with all necessary reviews.
The Opeiations Manager has counseled the Operations Department concerning this incident and reinforced standards and expectations.
Attachm:nt to W3F1-97-0209 P gs 4 of 5 n
The Planning and Scheduling Manager has reviewed expectations for preparing tagout requests with departmental personnel and maintenance planners.
The following corrective actions to correct the additional contributing factors associated with the overflow event are complete:
When the SFP overflow was identified and communicated to the Control Room, the RWSP Purification Pump was secured, stopping in-leakage.
The spill area was confined to stop further leakage and isolated to prevent spreading of contamination.
Valve FS-345 was opened and inspected to determine the failure mechanism.
The travel stop nuts on FS-345 were adjusted to the position required by the Technical Manual.
It was determined that four other valves had extension stems installed under DC-3211. The travel stop bolts on these four valves were checked for proper travel stop nut position and were adjusted as necessary.
Systems Engineering has initiated a Station Modification Request to add / change annunciators for the SFP and to provide remote SFP level i
indication to the Control Room.
Other tanks and pools at Waterford 3 were evaluated for generic implications for level indication and were determined to have the necessary level indication and instrumentation.
Annunciator response procedure OP-500-008 has been revised to include directions to restore SFP level to normal band upon receipt of any Fuel Pool level alarm.
(3)
Corrective Steps Which Will Be Taken to Avoid Further Violations Procedure UNT-005-003," Clearance, Request, Approval, and Release," will be reviewed for enhancements and will be revised to clarify review requirements for modified clearances.
Generic actions for improving human performance and addressing procedure noncompliance at Waterford 3 are outlined in the Performance Improvement Plan, which was issued to the NRC on May 8,1997
Attachm2nt to W3F197-0209
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Pcgs 5 of 5 -
Operations will review all Hi/ Low Level annunciator response procedures to ensure that either adequate monitoring still exists, or the shift is directed to clear the annunciator immediately.
(4)
Date When Full Compliance Will Be Achieved The corrective step to revise UNT-005-003 will be completed by September 30,1997, at which time Waterford 3 will be in full compliance.
The corrective step to review annunciator response orocedures will also be completed by September 30,1997.
As mentioned above, generic actions to address human performance and procedure noncompliance site-wide have been previously committed with_
targeted due dates via the Waterford 3 Performance improvement Plan, and will be tracked per this previous docketed correspondence, u
ATTACHMENT 2: SKETCH OF FUEL POOL PURIFICATION SYSTEM 329 326 321 420 4-b<
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\\uRmCruoN FILTER g 429 f
AL FLT.L POOL ION l
EXCIIANGER 4g 1 CONTAINMENT kd ri L -.J 405 1
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RWSP 343 Y401 423 W
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345 RWSP PURIFICATION PUMP 1r SPENT FUEL POOL
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