IR 05000382/1997024

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/97-24

ML20203G918
Person / Time
Site:	Waterford
Issue date:	02/25/1998
From:	Harrell P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dugger C ENTERGY OPERATIONS, INC.
References
50-382-97-24, NUDOCS 9803030107
Download: ML20203G918 (4)

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. e p# "88% UNITEo STATES p- *t NUCLEAR REGULATORY COMMISSION

REGION IV

% # 611 RYAN PLAZA DRIVE,SulTE 400

$....+p 4 AR LINGTON, TE XAS 760114064 FEB 2 51998 Charles M. Dugger, Vice President Operations - Waterford 3 Entergy Operations, Inc.

P.O. Box B Killona, Louisiana 70066 SUBJECT: NRC INSPECTION REPORT 50-382/97-24

Dear Mr. Dugger,

Thank you for your lev.er of February 11,1998, in response to our letter and Notice of Violation dated January 12,1998. We have reviewed your reply and find it responsive to the concems raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.

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, arrell, Chief Pro et Branch D Divi on of Reactor Projects Docket No.: 50-382 License No.: NPF-38 cc:

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 .

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Entergy Operatiens, Inc. 2-Wise, Carter, Child & Caraway P.O. Box 651 Jackson Missiscippi 39205 General Manager, Plant Operations Waterford 3 SES t

- Entergy Operations, Inc.

P.O. Box B Killona Louisiana 70066 Manager - Licensing Manager Waterford 3 SES Entergy Operations, Inc.

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"!.!Iona, 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 Kisana, Louisiana 70066 William H. Spell, Administrator Louisiana Radiation Protection Division P.O. Box 82135 Baton Rouge, Louisiana 70884-2135 Parish President St. Charles Parish P.O. Box 302 Hahnville, Louisiana 70057 Mr. William A. Cross Bethesda Licensing C 3 Metro Center Suite 610 Bethesda, Maryland 20814

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l Entergy Operations, Inc. -3-Winston & Strawn 1400 L Street. N.W. .

Washington, D.C. 20005-3502

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kAcra LA F466 Tei D1739 C? 1; Early C. Ewing. ill 04e y eaae,+a m tg,234;n s n W3F1-98-0018 A4.05 PR February 11,1998 - ,- gj y ~ ; i'

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U.S. Nuclear Regulatory Commission u cp ATTN: Document Control Desk Hi Washing'on. D.C. 20555 I, _FB . -

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Subject: Waterford 3 SES L~

Docket No. 50-382 License No. NPF-38 NRC Inspection Report 97-24 Reply to Notice of Violation Gentlemen:

In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in Attachment 1 the response to the violation ider.tified in Enclosure 1 of the subject Inspection Report.

If you have any questions concerning this response, please contact me at (504) 739-6242 or Tim Gaudet at (504) 739-6666.

Very truly yours,

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E.C. Ewing Director,

. Nuclear Safety & Regulatory Affairs ECE/DMU/ssf Attachment 36- O'7 T'T '

cc: [E.Wi Msischoff (NRC. Region IV)',t.P. Patel (NRC-NRR),

J. Smith, N.S. Reynolds, NRC Resident inspectors Office 4 8 0 2lS-Q/6 9--- - _ _ - _

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Attachm*,nt to W3F1-98-0018 Pcg31 of 3 ATTACHMENT 1 '

ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 97-24 .

VIOLATION NO. 9724-05 10 CFR Part 50, Appendix B, Criterion Ill, " Design Control," states, in part, that measures shall be established to assure that the design basis, as defined in Section 50.2 and as identified in the license application, for those structures, systems, and components to which this appendix applies are correctly transinte-

, into specifications.

Contrary to the above, in December 1996, the licensee failed to properly translate design basis requirements into specifications, in that, the correct level for the onset of vortexing, which could affect net positive suction head for the safety injection and spray pumps, was not properly determined. Specifically, Calculation EC-M95-012, " Minimum Pipe Submergence to Prevent Vortexing," identified the minimum level in several safety-related tanks, including the refueling water storage pool, required to prevent vortexing; however, the calculation did not include consideration of pump recirculation flow back to the tank.

This is a Severity Level IV violation (Supplement 1) (50-382/9724-05).

RESPONSE (1) Reason for the Violation The root cause of this violation is human error in that all design inputs were not considered for a calculation. An inadequate review during preparation of calculation EC-M95-012 failed to identify and account for the affect of minimum recirculation flow to the refueling water storage pool (RWSP) and condensate storage pool (CSP) when determining the minimum pool height to prevent vortexing.

Revision 1 to Calculation EC-M95-012 was approved on December 4,1996.

The purpose of this calculation was to determine the minimum liquid levelin the CSD, boric acid makeup (BAM) tanks, emergency diesel generator (EDG)

storage & feed tanks, RWSP and volume control tank (VCT) to prevent air entrainment, as a result of vortexing during operation of the associated pumps.

As documented in CR-97-1596, it was determined that calculation EC-M95-012 did not account for the affect of minimum recirculation to the CSP and RWSP when calculabng the minimum pool height to prevent vortexing.

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Recirculation flow will cause additional perturbations in the storage poda, which will increase the level at which vortexing would occur. Therefore, because the effects of minimum recirculation flow were not considered, the calculated minimum water level to prevent vortexing in the RWSP and CSP was non-conservative.

(2) Corrective Steps That Have Been Taken and the Results Achieved

. Engineering calculation EC-M95-012 has been revised to remove all CSP and RWSP vortex calculations.

. Scaled models, which included the minimum recirculation flow, were built j for the CSP and RWSP. Based on scalo' testing, a vortex breaker design was established. Vortex breakers were subsequently installed in the CSP and RWSP.

. Engineering calculations EC-M97-025 and EC-M97-026 for the CSP and RWSP respectively, have been prepared and approved to address vortexing in these storage pools. The affects of minimum recirculation flow have been considered in the calculations.

(3) Corrective Steps Which Will Be Taken to Avoid Further Violations

. In addition to the CSP and RWSP, calculation EC-M95-012 also considered vortexing for the following tanks: the volume control tank (VCT), boric acid management (BAM) tanks, emergency diesel generator (EDG) feed tanks and EDG storace tanks. A detailed review is in progress to determine the vortex critical height for these tanks. This review will be completed by April 30,1998. An operability review for the above tanks was performed as part of CR-97-1844 on July 14,1997. This review concluded that the usable volume and/or function of the tanks was not adverseS, affected by vortexing.

. In accordance with NOECP-011, " Engineering Calculations", mdticle barriers are in place to identify the design inputs that are to be used in calculations. These include procedural guidance for the preparatic.) and review of calculations, design verification, review of supplier performed calculations, supervisor approval and, in some cases Design Review Committee (DRC) and Plant Operating Review Committee (PORC) review.

Waterford 3 believes this guidance is sufficient to ensure calculations are adequately prepared, reviewed and approved.

The onset of vortex formation in tanks is unpredictable. Several correlations have been established for determining vortex formation, but are based on empirical data rather than analytical methods. Due to the specific expertise required to perform the vortex analysis, W3 subcontracted the analysis to an independent consultant. The original

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• Attachmsnt to l W3F1-98-0018 j- Paga 3 of 3 correlation used by the contractor failed to account for the effects of recirculation flow. Scaled model testing of the RWSP and CSP was then performed during RF8 using various vortex breaker designs. The onset of vortexing in the CSP and RWP was then determined from the results of the scale model test. '

Given the unique method required to determine the vortex height in the CSP and RWSP, failure to initially consider the effects of recirculation flow on vortex height allowance is considered an isolated event. No additional corrective action to addiess this event is required.

(4) Date When Full Compliance Will Be Achieved The above corrective action that is in progress will be completed by April 30,1908. Upon completi)n of that item, Waterford 3 will be in full compliance.

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