W3P90-1191, Responds to Violations Noted in Insp Rept 50-382/90-15. Corrective Actions:Tech Spec Surveillance Procedure PE-005-004 Will Be Revised to Ensure That Normally Closed Valves Opened & Verified to Close for Toxic Gas Signal
| ML20059E218 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/31/1990 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3P90-1191, NUDOCS 9009100092 | |
| Download: ML20059E218 (6) | |
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[W.A t.N;kw3gA"y3 W3P90-1191 A4.06 QA August 31, 1990 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES
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Docket No. 50-382 License No. NPF-38 NRC Inspection Report 90-15 Reply to Notices of Violations Gentlemen:
In accordance with 10 CFR 2.201, Entergy Operations, Inc. hereby submits in Attachment 1 the responses to the Notices of Violations identified in Appendix A of the subject Inspection Report.
If you have any questions concerning these responses, please contact L.W.
Laughlin at (504) 739-6726.
Very truly yours, nah
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RFB/DAR/ssf Attachment cc:
Messrs. R.D. Martin, NRC Region IV D.L. Wigginton, NRC-NRR E.L. Blake W.M. Stevenson R.B. McGehee NRC Resident Inspectors Office i
9009100092 900831 PDR ADOCK 05000382 O ;ow ggcl O
PDC Io
Attachment t3 W3P90-1191 Page 1 of 5 ATTACHMENT 1 l
ENTERGY OPERATIONS, INC. RESPONSE TO THE NOTICE OF VIOLATION IDENTIFIED IN APPENDIX A OF INSPECTION REPORT 90-15 VIOLATION NO. 9015-02 j
Failure to provide Adequate Retest Criterion XI of 10 CFR 50, Appendix B requires, in part, that all testing j
required to demonstrate that structures, systems, and componunts will perform satisfactorily in service is identified and performed in accordance with written test procedures, which incorporate the requirements and acceptanco limits contained in applicable design documents.
Contrary to the above, on June 20, 1990, ti.e inspector observed that the retest, Section 8.3 of PE-005-004, Revision 4, " Control Room Air Conditioning System Surveillance," which was designated to be performed as the result of a design change (DC 3300) to the A train of the control room air conditioning (CRAC) system, failed to demonstrate that all of the valves affected by the modification would perform satisfactorily in service.
CRAC Valves HVC-201A and -203A would not have been operated by this test procedure, representing two of the four valves affected.
This is a Severity Level IV violation.
Response
(1)
Reason for the Violation Entergy Operations, Inc. admits this violation and believes the root cause to be an inadequate test procedure used to verify operability following a modification.
As indicated in the inspection report, DC 3300 was initiated to correct an inappropriate appilcation of certain Potter - Brumfield rotary latching relays.
The work consisted of rewiring the relays to bypass internal contacts that were in series with the closing and reset coils.
These were lockout relays in the control circuits for valves in the safety-related CRAC system.
In preparation for DC 3300 acceptance testing, Waterford 3 personnel noted that a surveillance test-procedure for Technical Specification 4.7.6.e.5 already existed (PE-005-004, Control Room Air Conditioning System Surveillance).
Since the purpose of both PE-005-004 and the DC 3300 acceptance test was to verify that the CRAC system would switch to the isolation mode of operation in response to a toxic gas signal, engineering personnel concluded that PE-005-004 was cultable as the acceptance test.
Atta:hment ' to 6
W3P90-1191 Page 2 cf 5 PE-005-004 did verify the operability of the CRAC system in its normal l
configuration.
However, as written, it did not cycle all of the valves affected in the modification.
Two of the four valves in each train are closed in normal configuration.
The retest generates a toxic gas signal to induce the valves to close.
Since.wo of the valves were not opened before the retest, operability is not established for those valves.
Although the Design Change Package gave correct recommendations for retest, and the Work Authorization specified the correct test criteria, the chosen procedure did not' suitably demonstrate the operability of all safety-related equipment affected by the design change.
(2)
Corrective Steps That Have Been Taken and the Results Achieved Two corrective steps have been taken to date.
A Potentially Reportable Event, PRE 90-032, was initiated following discovery that PE-005-004 did not cycle the two normally closed valves._ In evaluating this suspected deficiency for violation of technical specifications, PRE 90-032 determined that Technical' Gpecificadon 4.7.6,0.5 was satisfied since the system was verified to automatically switch to the isolation mode of operation following a toxic gas signal.
t However, it is concluded that a procedure enhancement is desireable to address this issue.
Consequen?.ly, suggested corrective actions, as indicated below, are to improve the PE-005-004 methodology and to review the other HVAC surveillance procedures for similar deficiencies and revise them as necessary.
These reviews and possible revisions will be completed in accordance with the schedule specified in Section 4, below.
Its closure will coincide with the completion of these items.
Additionally, retest work instructions were written to test the normally closed valves in the A train.
These work instructions were completed on June 21, 1990 and the valves operated satisfactorily.
(3)
Corrective Steps Which Will Be Taken to Avoid Further Violations To address root cause and contributing factors, Entergy Operations, Inc. is pursuing two actions.
First, the Technical. Specification i
surveillance procedure, PE-005-004, will be revised to ensure that the normally closed valves are opened and verified to close on the initiation of a toxic gas signal.
With this complete, all other Technical Specification surveillance procedures relating to HVAC systems will be reviewed to ensure that no similar condition exists in those procedures.
Specifically, these procedures will addrens the surveillances of the shield building vs tilation system, the controlled ventilation area system, and the fuel handling building ventilation system.
Should it he necessary, these surveillance procedures will also be revised.
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Attachment to W3P90-1191 Page 3 of 5 (4)
Date when Full Compliance Will Be Achieved i
The revision of the CRAC surveillance procedure, PE-005-004, will be l
complete by October 31, 1990 or prior to its next use, whichever occurs first.
The review of the remaining Technical Specification i
surveillance procedures will be cuplete by October 31, 1990.
If revision is necessary, the revisions will be completed by December 31, 1990 or prior to their next ute, whichever occurs first.
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Att chment to W3P90-1191 Page 4 of 5
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VIOLATION 9015-03 Failure to Properly Review and Approve a Test Procedure l
Technical Specification ' f.c requires, in part, that written procedures shall be established, fr.
W ited, and maintained covering test activities of I
safety-related equipment. '
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Technical Specification 6.5.1.6.a requires, in part, that all procedures tequired by Technical Specification 6.8 shall be reviewed by the plant l
operations review committee (PORC).
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Technical Specification 6.5.1.7 tequires, in part, the PORC to recommend in
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writing to the plant manger, approval of the above precedures prior to implementation.
Contrary to the above, on June 21, 1990, the inspector observed that the postmodification testing of the control room air conditioning system response to a toxic gas detection signal which was performed in accordance with Work Authorization 99000342 (Condition Identification Report 269976) was not i
reviewed by the PORC or recommended for approval in writing to the plant manager.
This is a Severity Level IV violation.
Response
(1)
Reason for the Violation Entergy Operations, Inc. admits this violation und believes the root cause to be a failure to comply with an existing procedure, UNT-001-004, which defines $ne circumstances requiring a formal I
proceduro and which of these procedures require review by PORC.
After acknowledging PE-005-004 did not cycle all the necessary valves, as described in the response to the previous violation, a work authorization, WA99000342 (Condition Identification Report 269976), was prepared to perform the necessary testing.
It confirmed that all valves that should be cycled in the retest to prove operability were opened before the toxic gas signal was initiated.
The Waterford 3 staff viewed this as an elementary post modification retest which did not afr t plant safety and overlooked the technical specification e
regul anent (and UNT-001-004 requirement) for PORC review and General Manager approval.
(2)
Corrective Steps That Have Been Taken and the Results Achieved WA99000342 was completed on June 21,1990, "erifying satisfactory operation on the valves.
The requhemW. for PORC review and General Manager approval were not discovered until after completing WA99000342.
Inspection Report 90-15 states that the test procedure was adequate and clearly written.
Since this work had already been performed, the completed work instructions were reviewed by PORC on August 23, 1990.
PORC concurred that the test was adequate and was satisfactorily performed.
Attachment to W3P90-1191 Page 5 of 5 Additionally, a letter, W3Y90-0082 has been sent to Waterford 3 System Engineering personnel alerting them to the circumstances of this violation as an effort to prevent similar errors.
(3)
Corrective Steps Which Will Be Taken to Avoid Further Violations To assure protection against similar occurrences, the plant administrative procedure that governs postmodification test requirements (UNT-007-028) will be changed to more clearly identify -
the conditions under which a postmodification test requires PORC review and approval by the General Manager.
Discussions held with the NRC senior resident addressed the potential for a similar occurrence in the area of postmaintenance testing.
This discussion is being taken into consideration as part of an ongoing review cf postmaintenance teenng administrative controls.
The results will be incorporated into a postmaintenance retest procedure which had been under development for some time.
(4)
Date when Full Compliance Will Be Achieved UNT-007-028 will be revised by October 31, 1990.
The development of a guidance procedure to formulate postmaintenance retest instructions will be complete by November 30, 1990.
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