IR 05000382/1998014: Difference between revisions

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{{Adams
{{Adams
| number = ML20154L128
| number = ML20196F842
| issue date = 10/09/1998
| issue date = 11/30/1998
| title = Insp Rept 50-382/98-14 on 980726-0905.Violations Noted.Major Areas Inspected:Operations,Maint,Engineering & Plant Support
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/98-14
| author name =  
| author name = Harrell P
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| addressee name =  
| addressee name = Dugger C
| addressee affiliation =  
| addressee affiliation = ENTERGY OPERATIONS, INC.
| docket = 05000382
| docket = 05000382
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-382-98-14, NUDOCS 9810190155
| document report number = 50-382-98-14, NUDOCS 9812070140
| package number = ML20154L068
| title reference date = 11-19-1998
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| page count = 18
| page count = 4
}}
}}


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ENCLOSURE 2 U.S. NIICLEAR REGULATORY COMMISSION
ptk' "49  UNITED STATES
#- $+. NUCLEAR REGULATORY COMMISSION
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g  $  REGICN IV g  611 RYAN PLAZA DRIVE, SUITE 400
'g+9 * * * e +0  AR LING TON, TEXAS 76011-8064 NOV 3 0 i998 l
Charles M. Dugger, Vice President    I Operations - Waterford 3    !
Entergy Operations, Inc.
 
P.O. Box B Killona, Louisiana 70066    )
i SUBJECT: NRC INSPECTION REPORT 50-382/98-14 AND NOTICE OF VIOLATION  l i


==REGION IV==
==Dear Mr. Dugger:==
i L Docket No.: 50-382 L License No.: NPF-38 Report No.: 50-382/98-14 Licensee: Entergy Operations, In Facility: Waterford Steam Electric Station, Unit 3 Location: Hwy.18 Killona, Louisiana  :
Thank you for your letter of November 19,1998, in response to our October 9,1998, letter and Notice of Violation concerning the failure to perform a start of the emergency diesel generators as required byplant procedures. We have reviewed your reply and find it responsive to the concerns 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.
Dates: July 26 through September 5,1998 Inspectors: Thomas. R. Farnholtz, Senior Resident inspector Jack M. Keeton, Resident inspector
- Approved By: P. H. Harrell, Chief, Project Branch D Attachment: Supplement Information


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9810190155 981009 F  l PDR ADOCK 05000382 [  A G PDR g
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     . H. Harrell, e lef Project Branc.; D
    < Division of Rea' Proje
! Docket No.: 50-382 License No.: NPF-38
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Executive Vice President and Chief Operating Officer
  ' Entergy Operations, Inc.


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P.O. Box 31995 Jackson, Mississippi 39286-1995
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EXECUTIVE SUMMARY Waterford Steam Electric Station, Unit 3 NRC Inspection Report 50-382/98-14 Operations
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Operators took appropriate actions to resolve an issue related to required entry into the Technical Specifications for containment integrity when a containment spray pump was inoperable (Section 01.2).
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9812070140 981130 PDR ADOCK 05000382 i G  PDR ,


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When presented with a condition requiring entry to a Technical Specification shutdown action statement, operators recognized the need for and took prompt corrective actions to restore the minimum number of essential chiller trains to satisfy the required conditions for exiting the Technical Specification (Section 01.3).
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Entergy Operations, Inc. -2-Vice President, Operations Support Entergy Operations, Inc.
A violation of Technical Specification 6.8.1 was identified for the failure to start and load the emergency diesel generators when a hurricane warning was issued. This was because of ambiguity in the guidance procedure regarding when a step was not required to be performed. Operator f amiliarity with the off-normal procedure for severe weather was poor and training on the use of the procedure appeared to be lackin Also, operator understanding of the purpose of the steps in the procedure was not evident (Section 01.4).


Maintenance
- P.O. Box 31995 -
* A noncited violation of Technical Specification 6.8.1 was identified for the failure to establish adequate maintenance procedures to ensure that parts removed from safety-related components were controlled. The lack of such requirements resulted in a locking ring, removed from a control room ventilation system valve, being unaccounted for and not reinstalled during maintenance activities (Section M1.1).
Jackson, Mississippi 39286-1995 Wise, Carter, Child & Caraway
- P.O. Box 651.


Enaineerina
- Jackson, Mississippi 39205 General Manager, Plant Operations Waterford 3 SES Entergy Operations, Inc.
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A violation of Technical Specification 6.8.1 was identified for the failure to develop maintenance procedures for maintaining the floor and equipment drain systems functional. After inspector identification of this issue, licensee engineers did not demonstrate a questioning attitude during development of the procedures and addressing the potential problems with the drain systems (Section E8.1).


Plant Support
P.O. Box B Killona,-Louisiana 70066 Manager - Licensing Manager Waterford 3 SES -
* A prejob briefing for the repair of a charging system valve was conducted in an effective manner. All aspects of radiological protection and personnel safety were addressed (Section R4.1).
Entergy Operations, Inc. j P.O. Box B      l Killona, Louisiana 70066    !
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Chairman l Louisiana Public Service Commission    i One American Place, Suite 1630    i i Baton Rouge, Louisiana 70825-1697    .
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Director, iduclear Safety &
The licensee's hurricane preparedness efforts were well thought out and implemente The procedures in place and the supplies on hand were adequate to provide for the immediate needs of the personnel remaining on site. Site preparation following the
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Regulatory Affairs
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Waterford 3 SES      l
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Entergy Operations, Inc.


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P.O. Box B Killona, Louisiana 70066    l i William H. Spell, Administrator
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Louisiana Radiation Protection Division P.O. Box 82135
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Baton Rouge, Louisiana 70884-2135    ;
i Parish President l St. Charlec Parish
< P.O. Box 302 HahnviHe, Louisiana 70057
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Winston & Strawn
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1400 L Street, N.W. l
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Washington, D.C. 20005-3502
 
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issuance of a hurricane waming for an impending tropical storm / hurricane was timel .i
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and effective (Section P4.1).


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An unlocked vital area access and fire door was discovered by the inspectors. This is a . ;
violation of the Physical Security Plan. Corrective actions were promptly taken by the  'i licensee (Section S1.1).'      ;
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Entergy Operations, Inc.  -3-E-Mail report to T. Frye (TJF)
E-Mail report to D. Lange (DJL)
E-Mail report to NRR Event Tracking System (IPAS)
E-Mail report to Document Control Desk (DOCDESK)
E-Mail report to Richard Correia (RPC)
E-Mail report to Frank Talbot (FXT)
bec to DCD (IE01)
i bec distrib. by RIV-        l Regional Administrator  Resident inspector    l DRP Director  DRS-PSB    !
MIS System
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Branch Chief (DRP/D)
Project Engineer (DRP/D) RIV File
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Report Details Summarv of Plant Status During this inspection period, the plant operated at essentially 100 p went powe l. Operations 01 Conduct of Operations (71707)
01.1 General Comments (71707)
The inspectors performed frequent reviews of ongoing plant operations, control room ,
panel walkdowns, and plant tours. Observed activities were performed in a manner I consistent with safe operation of the facility. The inspectors also observed several shift I turnovers and daily routine shift activities. The shift turnovers were conducted in an 1 effective and thorough manner. The inspectors observed operators using self-checking i and peer-checking techniques when manipulating equipment. Three-way communication was consistently used by operators in the control room and in external communications with equipment operators and maintenance personnel.
 
01.2 Technical Specification Acolication with Containment Sorav (CS) Pumo Out of Service
      ! Insoection Scone (71707)
The inspectors reviewed the licensee's activities and followup actions involving CS system isolation for routine maintenanc , Observations and Findinas    l On August 18,1998, at 1:10 a.m., CS Pump B was removed from service for routine maintenance. T9 3.6.2 was appropriately entered for removal of CS Pump B from service. During shift change, a dircussion arose questioning whether entry into TS 3.6.3," Primary Containment," was also required and whether closure of an additional valve in the CS system was required to meet Technical Specification 3. The operators determined that entry into TS 3.6.3 and closure of Valves CS-117B and-118B were the appropriate actions pending further review. TS 16.3 requires that containment integrity be established within 4 hours or be in Hot Standby within the next 6 hours, a total 10-hour window to complete these actions. This action was completed
'It 8:35 a.m.,7 hours and 25 minutes after the CS pump was removed from servic Condition Report (CR) 98-1098 was written to address the issue and an engineering evaluation requested. As an interim measure, Standing Instruction 98-03 was written to require entry into TS 3.6.3 and closure of the additional valves in the appropriate train anytime a CS pump became inoperable. A past operability review found that the 10-hour allowed outage time had not been exceeded in prior CS pump outages; however, TS 3.6.3 entry had been inconsistently applied. A revision to Operations
 
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    -2-l Procedure OP-100-014, " Technical Specification Compliance," was in progress to ensure the appropriate Technical Specification entry was made when a CS pump was inoperable. Estimated completion date for this revision was September 15,199 Conclusions Operators took appropriate actions to resolve an issue related to required entry into the Technical Specifications for containment integrity when a containment spray pump was inoperabl .3 Failure of Essential Chiller B Causina Entry into a 6-Hour Technical Soecification Shutdown Action Statement Insoection Scope (71707)
The inspectors reviewed the sequence of events, interviewed operators, and reviewed followup corrective actions for the failure of Essential Chiller B, concurrent with planned maintenance on turbine-driven Emergency Feedwater (EFW) Pump A/ Observations and Findinas On August 20,1998, turbine-driven EFW Pump A/B was taken out of service to repair a failed steam piping heating component. The heating circuit is required to maintain the steam line to the turbine at elevated temperatures to preclude water hammer if the turbine started. While EFW Pump A/B was inoperable, Essential Chiller B faile Failure of the chiller resulted in all systems cooled by that train to be declared inoperable, including EFW Pump B. With two EFW pumps inoperable, TS 3.7.1.2, which required the plant to be placed in Hot Standby within 6 hours, was entere The operators responded by aligning Essential Cniller A/B to supply cooling to the
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Train B equipment. The realignment was completed in approximately 33 minutes. With Train B equipment, including EFW Pump B, operable, the shutdown action statement was exite Conclusion i When presented with a condition requiring entry to a Technical Specification shutdown i action statement, operators recognized the need for and took prompt corrective actions to restore the minimum number of essential chiller trains to satisfy the required ;
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conditions for exiting the Technical Specification.
 
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DOCUMENT NAME: R:\_WABWT814AK.JMK To receive copy of document, indicate in box: "ot = Copy Wthout enclosures *E" = Copy with enclosures *N" = No copy RIV:ASPE:DRFa  C:DRP/D ff    l .
M 'RVAzua;df % f/ PHHarrell y [    ' l f $ 11/ Zi/98 f  11/)$/98 (    l
. OFFICIAL RECORD COPY b
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3-01.4 Operations Staff Preparations for Trooical Storm Earl
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      , Inspection Scope (71707)
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i The inspectors observed preparations by the operations staff for severe weather associated with Tropical Storm Earl and performed a post-event review and interviews with Operations managemen Observations and Findinas On August 31,1998, at 5:55 p.m., the St. Charles Parish Emergency Operations Center notified the licensee that the National Weather Service predicted heavy rains because of Tropical Storm Earl and that the projected storm path included St. Charles Parish, where the plant is located. The licensee implemented Site Procedure W6.103,
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  " Emergency Preparedness-Hurricane Preparation / Response Guidelines," Revision ;
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Operations personnel assisted in identifying equipment that required sheltering or securing in preparation for a potential hurricane.
i L  Entergy Operations, Inc.   -3-    NOV 3 0 i993 i
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E-Mail report to T. Frye (TJF)
E-Mail report to D. Lange (DJL)      j E-Mail report to NRR Event Tracking System (IPAS)
l  E-Mail report to Document Control Desk (DOCDESK)      '
l  E-Mail report to Richard Correia (RPC)      :
E-Mail report to Frank Talbot (FXT)
l  bec to DCD (IE01)        ,
I  bec distnb. by RIV:
Regional Administrator Resident inspector DRP Director  DRS-PSB      i Branch Chief (DRP/D)  MIS System Project Engineer (DRP/D)  RIV File      ,
Branch Chief (DRP/TSS)        !
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l On September 1 at 4 p.m., the licensee was informed that St. Charles Parish was under d hurricane warning and the Emergency Operations Center had declared a general i emergency. The operators declared an Unusual Event in accordance with Site !
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Procedure W6.103 and entered Off-Normal Operating Procedure OP-901-521, " Severe Weather and Flooding," Section E4, " Hurricane Watch / Warning." The path of the ;
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tropical storm / hurricane was projected to be west of Waterford 3, which would '
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concentrate the highest winds and rainfallin the vicinity of the sit i l Operations personnel, began working through the off-normal procedure to prepare the i l plant for high wind conditions. Progress in completing the procedure appeared to be
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, slow in that all steps of the procedure had not been completed during the 12 hours l before the hurricane warning was lifted. The inspectors found that it was not clear that the steps that should have been taken prior to initiating a plant shutdown could have -
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been completed if the storrn had not changed course. The inspectors also noted that operator familiarity with this off-normal procedure was poor and training on the use of l this procedure appeared to be lacking. Operator understanding of the purpose of the l steps in the procedure was not evident. The hurricane warning was canceled on ,
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Although most of the steps in Off-Normal Operating Procedure OP-901-521 had been I completed, the inspectors noted that the emergency diesel generators (EDG) had not l r
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been started during the 12-hour period that the storm had been projected to affect Waterford 3. The inspectors noted that starting the EDG early in the warning would i allow time to rrake repairs if an EDG failed to start. During discussions with the Operations Superintendent, the inspectors identified that the operators decided not to start and load the EDG, as required by the procedure, because they did not want to use the fuel oil and they thought the storm would turn and miss them. In both of the9 instances, the inspectors found the logic to be flawed in that the amount of fur required to perform a start would be insignificant and the decision regarding the storm
;  DOCUMENT NAME: R:\_WABWT814AK.JMK
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;  To receive copy of document, Indicato in box: "Of = Copy without enclosures *E" = Copy with enclosures 'N" = No copy RIV:ASPE:DRS/) C:DRP/D M h 'RVAzua:df W f/  PHHarrell y I
    -4-path was based on speculation and not on factual weather data from the National Weather Service. Guidance for the use of off-normal operating procedures was contained in Procedure OP-100-001, " Duties and Responsibilities of Operators on Duty,"
  $ 11/l1/98 /  11/)i/98 y OFFICIAL RECORD COPY
Revision 15. Section 5, Step 5.16.5 of the procedure specified, in part, that steps may be performed out of sequence:lE the step is not applicable to plant conditions. Since all steps in Proceoure OP-901-521 had not been completed at the time the procedure was exited, the potential existed that the step requiring starting of the EDGs could be performed. However, since there was no plant conditions during the 12 hours that the hurricane warning was in effect that would prevent starting of the EDGs, the step should have been performed in sequence. The failure to start the EDGs in accordance with the procedure is a violation of Technical Specification 6.8.1 (50-382/9814-01).
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The inspectors reviewed Procedure OP-901-521 and noted that some ambiguity existed regarding the directions of when a procedure step did not have to be performed. The Operations Superintendent agreed that Procedure OP-901-521 should be ravised to more clearly define the steps that were required and also provide additional direction, keeping within the procedur Conclusions A violation of Technical Specification 6.8.1 was identified for the failure to start and load the emergency diesel generators when a hurricane warning was issued. This was because of ambiguity in the guidance procedure regarding wnen a step was not required to be performed. Operator familiarity with the off-normal procedure for severe weather was poor and training on the use of the procedure appeared to be lackin Also, operator understanding of the purpose of the steps in the procedure was not evident.
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08 Miscellaneous Operations issues (92901)
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O8.1 (Closed) Violation 50-382/9624-01: Failure to take prompt corrective action This violation cited two examples of a failure to take prompt corrective action. The first example involved a failure to determine all potential sources for water usage from the condensate storage pool following a tornado. The second example was a failure to implement immediate corrective actions specified in a CR. Imrrediate corrective actions were taken in response to this violation and compliance was acnieve Long-term corrective actions to prevent recurrence of this violation were complete The actions taken by the licensee included: (1) researched documentation addressing tornado events, (2) developed design basis for component cooling water makeup following a design basis accident, (3) revised calculations related to component cooling water makeup, and (4) performed testing of the component cooling water makeup system. The inspectors considered these actions to be adequat . . . _ _ _ _ ._ _ _ _ _ . _ ___ __ . _ . _ _ _ _
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I 08.2 (Closed) Licensee Event Reoort (LER) 50-382/96-015-01 and -02: Failure to isolate Containment Penetration 20 l
The licensee revised this licensee event report to document that the modification to ensure positive isolation of the temporary chiller units was an enhancement rather than a long-term corrective action to prevent recurrence. The inspectors identified that increased sensitivity by licensed operators to the requirements of the Technical Specifications provided sufficient corrective action to address the identified root cause Further, Operations management emphasized the types of boundaries allowed to positively isolate containment and emphasized that check valves are not appropriate isolation boundaries. .The inspectors found these corrective actions appropriat .3 (Closed) LER 95-002-01: Reactor Trip and Nonsafety-Related Switchgear Fir This LER updated the original LER to provide additional information regarding the modifications installed to ensure proper breaker functioning in the nonsafety-related electrical distribution syste Since the additional information provided was basically adminisrtrative in nature, no further review of this issue will be conducte II. Maintenance M1 Conduct of Maintenance (61726,62707)
The inspectors observed all or portions of the following maintenance and surveillance activities, as specified by the referenced work authorization (WA) or surveillance l procedure number:
* WA 01168464 EFW Pump A/B Governor Valve Manual Stroke Test
= WA 01171657 Change Lube Oilin Chilled Water Pump AB l
* WA 01165831 Overhaul Chiller AB Compressor and Inspect Internal I    Components
* WA 01172230 Rework Damaged Section of #2 Ground Wire and l
Reconnect to Box B5MS-V716 l
  * OP-903-068 EDG and Subgroup Relay Operability Verification l
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in general, the inspectors considered the conduct of the observed maintenance and l surveillance activities to be acceptable. All activities observed were performed with the I
work packages and/or test procedures present and in use. The inspectors observed supervisors and managers monitoring the progress of jobs as appropriate. Quality control personnel were present whenever required by procedure.


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O      Ente perations, Inc.


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Killona. LA 70066 Tel 504 739 6242 Early C. Ewing. til Daector ar Safety & Regulatory Affavs
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W3F1-98-0182 A4.05 PR November 19,1998 V20 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Subject: Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC inspection Report 50-382/98-14 Reply to Notice of Violation Gentlemen:
6-M1.1 Control Room Ventilation System Outside Air Isolation Valve Maintenance Insoection Scope (61726)    I
In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in Attachment 1 the response to Violation 50-382/9814-01 identified in the subject inspection report. On November 9,1998, Mr. P. Harrell, NRC Region IV, granted an l extension until November 19,1998, for this response.


1 The inspectors reviewed the work performed on the control room ventilation system j outside air isolation upstream valve (HVC-102). The purpose of the maintenance was to j remove and replace the T-ring of the valve, which forms the sealing surface when l
, Based upon our evaluation of the information contained in the inspection report,
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      ; Observations and Findinas On July 21,1998, the licensee performed maintenance on Valve HVC-102 to adjust the T-ring to correct a leakage condition past the valve disk and seat. During this maintenance activity, the licensee identified that the T-ring was installed incorrectly. The i decision was made to remove the valve from the system, take it to the shop, and !
Waterford does not contest the violation. However, we are taking exception to some l of the details provided in the discussion of the violation. Additionalinformation to support our position is provided in the attached response.
replace the T-ring with a newly designed ring. The new ring included a chamfer that !
more clearly indicated the correct orientation during installation. As part of this I maintenance, an outer locking ring was removed on the valve shaft. The locking ring was placed in a bucket along with assorted tools being used for this work. Upon reassembly of the valve, the locking ring was not reinstalled on the valve shaft as require The valve was reinstalled in the control room ventilation system without the locking ring in place. Upon completion, work commenced on the downstream control room ventilation system outside air isolation downstream valve (HVC-101). This valve was of a similar design and configuration and was located adjacent to Valve HVC-102. During work on Valve HVC-101, the technicians noted that the outer locking ring was not installed on Valve HVC-102. The locking ring was located in the bucket where it had been left and was reinstalled in its proper location on Valve HVC-102. The valve was subsequently tested and returned to operable statu The inspectors considered the cause of this event to be a lack of control of parts removed from safety-related components. The locking ring, once removed from the shaft of Valve HVC-102, was not labeled or tracked in any way, which allowed the ring to become unaccounted for. During reassembly of the valve, the ring was left off because there was no process in place to ensure that it was reinstalled. The inspectors considered placing removed parts from a safety-related component in a bucket, along with tools, to be an unacceptable work practic The inspectors questioned the licensee as to where and how the requirements for control of removed parts was proceduralized. Administrative Procedure MD-001-014,
" Conduct of Maintenance," Revision 4 was reviewed to determine if any guidance was provided to the technicians concerning control of parts during maintenance. No such guidance was provided in this or any other station procedure. The inspectors


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7-l considered Administrative Procedure MD-001-014 to be inadequate in that it did not provide sufficient requirements to ensure that parts removed from safety-related components were controlled and labeled such that they could be retrieved and reinstalled in their correct locatio The failure to establish an adequate maintenance procedure to ensure that parts removed from safety-related components are controlled is a violation of TS 6.8.1. This violation is considered to be noncited, consistent with the requirements of Section Vll.B.1 of the NRC Enforcement Policy. Specifically, the violation was nonrepetitive, identified by the licensee, it was not willful, actions taken as a result of a !
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previous violation should not have corrected this problem, and appropriate corrective actions were completed by the licensee (50-382/9814-02).


The !icensee provided the inspectors with a procedure revision to Administrative Procedure MD-001-014 to include appropriate requirements for the control of components, subassemblies, and parts. This revision included requirements to label removed parts, maintain removed parts separate from tools and equipment, and protect mechanicalinterfaces from damage. In addition, these expectations wi!: be reinforced during upcoming maintenance meetings. The inspectors considered these changes to be adequate, Conclusions A noncited violation of Technical Specification 6.8.1 was identified for the failure to establish adequate maintenance procedures to ensure that parts removed from safety related components were controlled. The lack of such requirements resulted in a locking ring, removed from a control room ventilation system valve, being unaccounted for and not reinstalled during maintenance activitie M8 Miscellaneous Maintenance issues (92902)
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i M8.1 (C_!osed) LER 50-382/97-010: Failure to Meet Shield Building Ventilation (SBV) Technical Specification Flow Criteri On March 5,1997, Technical Specification Surveillance PE-005-003, " Shield Building Ventilation System Surveillance," was performed on SBV Train B. The results of the test were outside the band for acceptance criteria; however, system engineer and vendor representative erroneously accepted the test results as satisfactory. Immediate corrective actions were taken by the licensee to return the system to an operable statu l The inspectors reviewed the long-term corrective actions, which included: (1) enhancing the human factors aspects of Surveillance Procedure PE-005-003, (2) review of other j Technical Specification surveillance procedures for human factors improvements,  l l
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    -8-(3) review other Technical Specification surveillance procedures to ensure adequate barriers existed to prevent recurrence, and (4) review all Technical Specification
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surveillance procedures that involved vendor participation to ensure proper vendor oversight was exercise M8.2 (Closed) Violation 50-382/9704-02: Failure to recognize SBV Train B failed its Technical Specification surveillanc This violation was addressed by LER 50-382/97-010 and Section M8.1 of this report. All corrective actions have been complete M8.3 (Closed) Violation 50-382/9522-04: Failure to perform an integrated leak test i As described in NRC Inspection Report 50-382/96-12, Section E8.3, this item was previously closed because the licensee took ,'ppropriate corrective actions to ensure ;
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that the 25 percent extension allowed by TS 4.0.2 would not be applied to administrative !
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tests required by Section 6 of the TS. Further, the corrective actions included requiring ,
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an integrated leak test at least once every 18 month j During this inspection period, the licensee questioned whether " refueling cycle interval or less," as used in Technical Specification 6.8.4.a. correlated to the definition provided in Table 1.1 for " refueling," which states at least once per 18 months. The inspectors i researched the requirements for performing the integrated leak rate determination for ;
systems outside containment, and determined that " refueling cycle interval" does not i
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imply at least once every 18 months, similar to the " refueling" surveillance interval provided in the Definitions section of the TS. The licensee performs the test in shutdown conditions during each refueling outage; therefore, as long as the test is completed during a refueling outage prior to startup, the licensee meets the intent of
" refueling cycle intervals." This provides the intended flexibility for extended shutdowns
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or for an extended operating cycl M8.4 (Closed) Unresolved item (URI) 50-382/9704-03: Testing of non-ASME code safety class component !
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This URI involved the classification of components as safety class versus code class for the determination if ASME Section XI testing was require This issue was discussed with the Office of Nuclear Reactor Regulation (NRR) and it !
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was determined that the dassification of components by a licensee does not affect the determination of whether ASME Section XI testing is required or not. Irregardless of the classification, the components must be tested if the requirements of the ASME Code ,
appl l This item is considered closed, as no violation was identified with the misclassification of components as safety class versus code class. With respect to the verification that all i
 
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NRC Inspection Report 50-382/98-14 Reply to Notice of Violation l
appropriate components had been included in the testing program, the NRC has performed extensive reviews of the Sating programs and allissues related to testing were dispositioned in the appropriate inspection report . Enoineerina E8 Miscellaneous Engineering issues (92903)
W3F1-98-0182      l Page 2 November 19,1998 i
E (Closed) URI '50-382/9724-02: Dirt and debris in reactor auxiliary building drain l As reported in NRC Inspection Report 50-382/97-24, no record could be found that the floor drain systems had been maintained since the plant became operationalin 198 Procedures for performing routine and periodic preventive maintenance had not been developed, nor had the system been tested to verify that the systems would function as assumed in the design basis document In response to the inspectors' findings, CR 97-2544 was written. The ensuing investigation resulted in an apparent cause and several specific corrective actions for closure of the CR on March 5,1998. The apparent cause was attributed to a lack of a formal program for periodic cleaning of the drain traps. Corrective actions  !
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included: (1) a walkdown of all floor drains by system engineers; (2) verifying drains were not plugged by pouring water down the drains; (3) cleaning of sediment traps, included in general housekeeping instructions; (4) initiation of tasks to periodically verify all drains were functional; (5) completion of engineering evaluations to determine if some sediment traps could be eliminated or replaced with disposable socks; (6) development of a test procedure and test plan for safeguards equipment rooms; and  i (7) review of flooding calculations and Updated Final Safety Analysis Report impac l
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After the initial cleanup of the visible debris in the drains, licensee engineers performed ;
walkdowns ano u ain flow verifications, several drains were found to be partially  l plugged. These drains were cleaned to clear the debris. Drains were found to contain boron crystals, trash, and the remains of a posting ribbon. Other drains were  ,
boroscoped and dirt, trash, nuts, and bolts were found and removed. The sediment  I traps on the floor drains were also cleaned, except for those in locked high radiation  )
area The Station Information Management System databnc was updated to provide repetitive tasks for periodically cleaning the floce crain systems throughout the plan ;
Additional tasks were identified to initiate engineering reviews for removal of  j unnecessary sediment traps to minimize the potential for blockag I
!' Special Test' Procedure STP-01168398, " Drain and Sump Pump Capacity Test," was i developed for testing of the drains and pumps in the safeguards equipment rooms. The
! procedure had been approved, but had not been implemented at the end of this (. inspection perio i
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If you have any questions concerning this response, please contact me at  l (504)739-6242.      l l
Very truly yours,    l l
L1
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E.C. Ewing      i Director, Nuclear Safety & Regulatory Affairs ECE/BVR/ssf Attachment cc: :
E.W."Merschoff (NRC Region'IV)    ;
C.P. Patel (NRC-NRR)    l J. Smith N.S. Reynolds l  NRC Resident inspectors Office l
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On August 31,1998, the inspectors performed a walkdown of the accessible floor drain systems in the reactor auxiliary building with the responsible engineering manager. All l  aspects of the floor drain and equipment drain problems appeared to have been addressed or were in progres !


I l The initial cleanup of the floor drains had been conducted with no quantification nor identification of material removed from the drains. Also, those drains that were plugged .
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had not been docurnented, and as a result, potentially valuable data was los t
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; Throughout the period of time since this issue was identified, the licensee was slow to respond to questions and concerns raised by the inspectors. A questioning attitude had  !
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not been consistently demonstrated by the engineering staff. Flooding calculations and l verifications had not been completed at the end of this inspection period, but were in progress. Preliminary results of the calculations indicated that no unresolved safety issue existed. The failure to implement a procedure for periodic cleaning of floor drains is a violation of Technical Specification 6.8.1 (50-382/9814-03).
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Since the licensee had taken or planned to take appropriate actions to address this issue, as discussed above, no response to this violation is required. The inspectors  !
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verified that the actions were fully implemented by the licensee; therefore, this violation
Attachment to o;     W3F1-98-0182 i
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Page 1 of 4
is considered close E8.2 (Closed) Unresolved Item 50-382/9704-05: Inspection of ventilation system damper This issue involved the inspection of isolation dampers internal to the ventilation system, and was identified as a result of a concern that the damper was providing an isolation function between volatile organic compounds and the charcoal filter Based on a review of regulatory standards and discussions with NRR, it has been determined that physical inspection of the dampers is not required. This issue is considered closed as no violation of NRC requirements was identifie IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls During routine tours, the inspectors observed radiation survey measurements posted, as required by licensee procedures and NRC regulations. A samp,e of doors were found locked for the purpose of radiation protection. Licensee personnel in radiologically controlled areas were obse,rved following applicable procedures for radiation protectio .
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R4.1 - Preiob Briefina for Maintenance on Reactor Coolant System Looo 2A Isolation Valve CVC-218B i        i l        l
- Inspection Scoce (71750)
l  The inspectors attended a prejob briefing conducted on August 11,1998. The purpose j j'  ' of the briefing was to familiarize maintenance technicians with the expected working l
!  conditions during the repair of Valve CVC-218B (charging line to Reactor Coolant l  System Loop 2A isolation valve'. ;
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l Observations and Findinas The licensee conducted a prejob briefing prior to technicians entering the reactor !
building to perform maintenance on Valve CVC-2188. This valve failed to close on l l  August 10,1998, and is located in the regenerative heat exchanger room. The licensee '
i estimated the dose area in this room to be 50-80 mrem /hr gamma and 10 mrem /hr i  neutron. A low dose standby area was identified just outside the room with dose rates !
estimated to be 5 mrem /hr gamma and 10 mrem /hr neutron. The total estimated dose !
for this job was 200 mrem. The use of up to three different crews was planned to complete the tas!; due to stay times in the heat stress area of the heat exchanger room.


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ATTACHMENT 1 i
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ENTERGY OPERATIONS, INC. RESPONSE TO VIOLATION 50-382/9814-01
Health physics personnel were assigned to accompany the technicians during the entire time that work was in progress in the reactor building. Personnel safety issues were j stressed during the briefing and safety conditions were discussed in detail. Expected heat stress and atmospheric conditions were described. Actions to be taken in the
!  event of a medical emergency were covere The inspectors considered this prejob briefing to have been an effective and useful meeting for the participants of this task. All aspects of radiological protection and personnel safety were discussed and all questions and concerns of the participants were addressed. The actual total dose received during this job was 62 mre Conclusions
, A prejob briefing for the repair of a charging system valve was conducted in an effective l        !
manner. All aspects of radiological protection and personnel safety were addressed.


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IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 98-14
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j-12-P4 Staff Knowledge and Performance in EP P Hurricane Preoarations Insoection Scope (71750)
i VIOLATION NO. 50-382/9814-01 Technical Specification 6.8.l.a requires, in part, that written procedures shall be implemented and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A,  ,
The inspectors reviewed the licensee's preparations for hurricane events and inspected the materials designated for use in such an event, in addition, the inspectors observed preparations in progress for Tropical Storm Earl, which threatened the sit Observations and Findinas The inspectors reviewed Site Procedures W6.102," Emergency Preparedness Hurricane !
Section 6 requires that the licensee have procedures for combating emergencies and  ;
l  Policy," Revision 1, and W6.103, " Emergency Preparedness-Hurricane l Preparation / Response Guidelines," Revision 3, to determine the extent of preparations l made for severe weather. The procedures included required actions when a hurricane !
other significant events.      .
watch or warning is issued. Emergency response personnel assignments and  )
Off-Normal Operating Procedure OP-901-521, " Severe Weather and Flooding,"  i Revision 2, Section E4.12 specified, in part, that: lF a Hurricane Warning is issued,
arrangements for long-term (2-3 days) stays on site during and immediately following i the passage of a storm were detailed. In addition, extensive hurricane check lists were I
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included in Site Procedure W6.103 to ensure staffing, grounds and buildings, tools and l equipment, supplies and personnel safety, emergency response facilities, and recovery planning issues were appropriately addresse j The inspectors, accompanied by the manager of emergency planning, inspected supplies stockpiled by the licensee for use during severe weather events. These supplies included sufficient food, drinking water, and cots and bedding for those personnel who would be expected to remain at the site during and immediately following !
THEN perform the following. Step C stated, in part: Perform the following for BOTH  l Emergency Diesel Generators (EDGs), ONE EDG at a time. Start EDG in   I accordance with OP-009-002, EMERGENCY DIESEL GENERATOR.    '
the hurricane. The supplies were stored in climate controlled conditions in the
Contrary to the above, on September 1,1998, at 4 p.m. (CDT), the National Weather Service issued a hurricane waming for St. Charles Parish, where Waterford 3 is located. The licensee entered Off-Normal Operating Procedure OP-901-521, but  ,
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failed to perform a start of the emergency diesel generators, as required by the procedure.
warehouse area and would be moved into the power block area of the plant in the event i of severe weather. The power block of the plant was designed to withstand the effects j of the most severe hurricane and would not be damaged during such an event so personnel protection during a storm would be assured. The inspectors considered the procedures in place and the supplies on hand to be adequate to provide for the immediate needs of the personnel remaining on site during a hurricane, it was evident that emergency preparations for hurricanes and severe weather were well thought out and implemente During this inspection period, Tropical Storm Earl threatened the site and a hurricane ;
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warning was issued on September 1,1998, at 4 p.m. The storm developed and behaved in such a way that a hurricane watch was not issued prior to the warning. This triggered the licensee's emergency preparedness procedures described above and a Notice of Unusual Event was entered. The inspectors observed the preparations made at the site to minimize the impact of the expected severe weather. Allloose items were either removed to more sheltered areas or tied down such that high wind conditions would not impact them. The inspectors noted that the urgency of this action was effectively communicated to plant personnelinvolved in the effort. The plant site was i
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This is a Severity Level IV violation (Supplement 1) (50-382/9814-01).
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    -13-prepared for severe weather and plant personnel assignments were established. The inspectors considered the licensee's overall response to the hurricane warning to be very good with the site preparations to be timely and effective. The hurricane warning was canceled at 8:34 a.m. on September 2 and the Notification of Unusual Event was exited at 9:08 a.m. Tropical storm / hurricane conditions were not experienced on site during the warning perio Conclusions The licensee's hurricane preparedness efforts were well thought out and implemente The procedures in place and the supplies on hand were adequate to provide for the immediate needs of the personnel remaining on site. Site preparation following the issuance of a hurricane warning for an impending tropical storm / hurricane was timely and effectiv S1 Conduct of Security and Safeguards Activities S1.1 Security Locked and Alarmed Door Found Unsecured a. Insoection Scope (71750)
The inspectors identified an unsecured security / fire door, notified appropriate licensee staff, and reviewed followup activities and corrective action b. Observations and Findinas On July 21,1998, the inspectors had been conducting a plant tour when they noted that Door 206 on the minus 35-foot level of Dry Cooling Tower A was not locked, but resting against the door latch plate. Door 206 was identified as an alarmed security door providing vital area access between the dry cooling tower and fuel handling buildin The door was also posted as a fire door. The inspectors immediately notified the central alarm station and a security officer was dispatched to the door. Further inspection revealed that although the door was not completely closed, the alarm was not actuate However, when the security officer further opened the door the alarm actuated. The door was closed to perform its fire protection function and a compensatory security offber was posted at the door until the alarm could be repaire .
CR 98-0976 was written to ensure that appropriate corrective actions would be take The alarm history for Door 206 was reviewed, which revealed that a fire watch had performed a fire door surveillance on that door approximately 1 hour before the door was discovered in the unsecured position. The failure to maintain a vital area door locked and alarmed is a violation of the Physical Security Plan (50-382/9814-04).


Corrective actions taken by the licensee included: (1) performing corrective maintenance on the door latch and door closure device, (2) relocating the alarm magnetic switch to ensure the alarm was received when the door unlatched, (3) all other
RESPONSE Waterford has carefully evaluated the information in Violation 9814-01 and does not contest the violation. However, this response takes exception to some of the information in the inspection report.


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Because off-normal procedures are written to provide guidance under numerous circumstances, it is management's expectation that operators will prioritize the tasks in accordance with plant conditions. This expectation is represented by Section 5.16.5 of OP-100-001, which allows steps in off-normal procedures to be addressed out of sequence "lF the step is not applicable to the present plant condition."
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doors with the same type alarm devices were checked (three other alarm devices were found to require corrective maintenance), and (4) a special training session was given to fire watch personnel by security supervision. All identified corrective actions have been completed. The inspectors considered these actions to be adequate, and as a result, no response to this violation is required. The inspectors verified that these actions had
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! been implemented by the licensee; therefore, this violation is close Conclusions An unlocked vital area access and fire door was discovered by the inspectors. This is a violation of the Physical Security Plan. Corrective actions were promptly taken by the license V. Manacement Meetinas X1 Exit Meeting Summary      !
I Waterford believes the operators were following management's expectation to prioritize tasks when preparing for Tropical Storm Earl and acted in accordance with the required procedures. However, off-normal procedure OP-901-521, as written,
The inspectors presented the inspection results to members of licensee management on September 15,1998.' The licensee acknowledged the findings presente The inspectors asked the licensee whether any materials examined during the inspec;''n should be considered proprietary. No proprietary information was identifie l
, did not clearly represent management's additional expectation to start the EDGs as soon as possible to ensure their availability. Procedure requirements included


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Attachment to l
;      W3F1-98-0182 Page 2 of 4 starting, paralletirm and loading the EDGs. Based on the operators' judgement regarding specific weather conditions, availability of personnel on shift, plant conditions and their conclusion that procedure requirements were excessive, the operators decided not to perform the step for testing the EDGs in the sequence explicitly required by the procedure.


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Reason for the Violation
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    -ATTACHMENT SUPPLEMENTAL INFORMATION    j i
PARTIAL LIST OF PERSONS CONTACTED    j Licensee -
R. F. Burski, Director Site Support C. M. Dugger, Vice-President, Operations E. C. Ewing, Director, Nuclear Safety & Regulatory Affairs C. Fugate, Operations Superintendent T. J. Gaudet, Manager, Licensing J. G. Hoffpauir, Manager, Operations -
T. R. Leonard, General Manager, Plant Operations D. C. Matheny, Manager, Operations G. D. Pierce, Director of Quality D. W. Vinci, Superintendent, System Engineering A. J. Wrape, Director, Design Engineering i
NBQ        i
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- K. M. Kennedy, Senior' Resident inspector, ANO l
INSPECTION PROCEDURES USED    j IP 37551: 'Onsite Engineering IP 61726: Surveillance Observations IP 62707: Maintenance Observations IP 71707: Plant Operations
' lP 71750: Plant Support Activities IP 92700: Onsite LER Review IP 92901: Followup-Plant Operations IP 92903: Followup-Engineering
- IP 92904: Followup-Plant Support ITEMS OPENED. CLOSED. AND DISCUSSED Opened /9814-01 VIO Failure to start EDGs as required by procedure (Section 01.4)
50-382/9814-02 NCV Failure to establish an adequate maintenance procedure for '
control of removed parts (Section M1.1)
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50-382/9814-03 VIO Failure to provide a procedure for cleaning floor and equipment
At approximately 1600 on September 1,1998, a hurricane warning was issued for St.
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drain systems (Section E8.1)
Charles Parish due to a potential for winds associated with Tropical Storm Earl
L '50-382/9814-04- VIO Vital door partially open and not in alarm (Section S1.1)
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(located in the Gulf of Mexico) to strengthen to hurricane force. Waterford declared an Unusual Event and entered off-normal procedure OP-901-521. Consistent with management's expectation to prioritize the work associated with preparing for the storm, Control Room personnel reviewed the actions necessary and personnel required for the upcoming steps in the procedure. As part of this review, the operators evaluated Step 12.c that required staiting, paralleling and loading both EDGs in accordance with the normal operating procedure (OP-009-002, " Emergency Diesel Generators"). The operators also evaluateo step 12.c within the context of OP-100-001, which provides guidance for the use of c.ff-normal procedures (such as ,
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OP-901-521) and allows steps in a procedure to be addressed out of sequence "lF  l the step is not applicable to the present plant condition.'' In accordance with Section l 5.16.5 of OP-100-001, the operators decided to postpone step 12.c for the following )
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reasons.
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. OP-901-521 required using the normal operating procedure for the diesel (OP-009-002), which could take up to 4 hours per EDG to complete. Realizing that OP-009-002 was intended for use under normal operating conditions, the operators felt that the amount of time and manpower needed to start, parallel and load each EDG was excessive and could potentially prevent the shift personnel from completing other required actions to prepare for the storm.


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. Shift personnel were tending to numerous tasks to ensure the outside area of the plant was prepared if conditions should worsen.
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    -2-Closed 50-382/9624-01 VIO Failure to take prompt corrective actions (Section 08.1).


50-382/9615-01,-02 LER Failure to isolate a containment penetration (Section 08.2).
. The Shift Supervisor was involved in several discussions that included: returning Train "A" of the Shield Building Ventilation System to operable status; security concems from the Arkansas security department and a plant in Florida; and NRC notifications and updates.


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. Watchstanders that were needed to assist with testing the EDGs were performing thorough walkdowns to verify items that were moved or stowed for the hurricane near safety-related equipment would not potentially interfere with the operation of such equipment.
50-382/95-002-01 LER Reactor trip and nonsafety-related switchgear fire (Section 08.3).


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. Based on information periodically received from the National Weather Service (NWS), the shift determined that adequate time was available to test the diesels if the path of the tropical storm changed towards the direction of Waterford or
50-382/9814-02 NCV Failure to establish an adequate maintenance procedure for control of removed parts (Section M1.1).
,
conditions worsened. Throughout the shift, the amount of time available to test
,  the EDGs was evaluated upon receipt of new information from the NWS.


l 50-382/97-10 LER Failure to meet SBV Technical Specification flow criteria (Section M8.1).   ;
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50-382/9704-02 VIO Failure to recognize SBV Train B failed its Technical Specification sur/eillance (Section M8.2).
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l j  The above considerations indicate the Control Room staff was aware of the purpose j. of Step 12.c in OP-901-521. However, the excessive requirements in the procedure l  for paralleling and loading the EDGs required a significant amount of manpower and j  time that could potentially prevent the shift personnel from completing other required
;  actions to prepare for the storm. This resulted in the operators taking actions that i  contradicted management's expectation that the EDGs would be tested as soon as l  possible.
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!  At approximately 0500 on September 2,1998, the need to test the EDGs was discussed with the on-coming Shift Supervisor and Operations Superintendent. The i  oncoming shift was informed that the step requiring the starting, paralleling and j  loading of the EDGs had been addressed, but not performed. The oncoming shift i  was also informed other actions related to the hurricane preparations were complete.


50-382/9522-04 VIO Failure to perform integrated leak test (Section M8.3).
l  The NWS cancelled the Hurricane Warning for St. Charles Parish at approximately i  0800 and Operations Procedure OP-901-521 was exited prior to the new shift having
}  an opportunity to perform the step for starting, paralleling and loading the EDGs.


50-382/9704-03 URI Testing of non-AMSE Code safety class components (Section M8.4).
,
i j  Corrective Steps That Have Been Taken and the Results Achieved


50-382/9724-02 URI Dirt and debris in reactor auxiliary building drains (Section E8.1).
j  inspection Report 98-14 states that the guidance in OP-100-001 contained ambiguity
;  regarding when a step was not required to be performed. Waterford does not
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believe this was a contributor to this event. Instead, Waterford believes off-normal procedure OP-901-521 contained excessive requirements that created an unnecessary burden on the operators and resulted in the operators postponing step    l 12.c. Thus, off-normal procedure OP-901-521 was revised in order to remove the    ;
excessive requirements. Since the requirement to start, parallel and load the EDGs    i
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was based upon normal operation of the EDGs, the amount of time and manpower involved in the process did not support the intent of step 12.c in OP-901-521. The intent of step 12.c is to ensure the availability of the EDGs during off-normal conditions. Therefore, the step was changed to start the EDGs and return them to standby mode. A note was also added to the procedure that allows the operators to not start the EDGs if they were tested within the previous 48 hours.


50-382/9814-03 VIO Failure to provide a procedure for cleaning floor and equipment drain systems (Section E8.1).
The report also states that operator familiarity with OP-901-521 was poor and training on the use of the procedure appeared to be lacking. Waterford believes the operators' considerations provided in the previous section indicate that the operators were familiar with the purpose of step 12.c in OP-901-521 and additional training is not necessary. Management's expectation that the EDGs will be tested as early as possible when prioritizing the steps in off-normal procedure OP-901-521 was clarified to Operations personnel.


50-382/9704-05 URI Inspection of ventilation system dampers (Section E8.2).
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50-382/9814-04 VIO Vital door partially open and not in alarm (Section S1.1).
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c'~      Attachment to i      W3F1-98-0182 l Page 4 of 4 i Corrective Steps Which Will Be Tanen to Avoid Further Violations  ,
t Waterford 3 is in full compliance. No further corrective steps are needed to avoid  ,
future violations.   .
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Date When Full Compliance Will Be Achieved    J
  . Waterford 3 is in full compliance.
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I LIST OF ACRONYMS USED
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.ASM American Society of Mechanical Engineers CR condition report CS containment spray EDG emergency diesel generator EFW emergency feedwater LER . licensee event report mrem /hr millirem / hour NCV noncited violation NRC Nuclear Regulatory Commissio NRR Nuclear Reactor Regulation NUREG NRC technical report designation (!iyclear Eggulatory Commission)
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PDR Public Document Room SBV shield building ventilation 0 Technical Specification URI unresolved item
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Latest revision as of 05:21, 9 December 2021

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/98-14
ML20196F842
Person / Time
Site: Waterford Entergy icon.png
Issue date: 11/30/1998
From: Harrell P
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Dugger C
ENTERGY OPERATIONS, INC.
References
50-382-98-14, NUDOCS 9812070140
Download: ML20196F842 (4)
v • d • e


Text

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ptk' "49 UNITED STATES

  1. - $+. NUCLEAR REGULATORY COMMISSION
. l

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g $ REGICN IV g 611 RYAN PLAZA DRIVE, SUITE 400

'g+9 * * * e +0 AR LING TON, TEXAS 76011-8064 NOV 3 0 i998 l

Charles M. Dugger, Vice President I Operations - Waterford 3  !

Entergy Operations, Inc.

P.O. Box B Killona, Louisiana 70066 )

i SUBJECT: NRC INSPECTION REPORT 50-382/98-14 AND NOTICE OF VIOLATION l i

Dear Mr. Dugger:

Thank you for your letter of November 19,1998, in response to our October 9,1998, letter and Notice of Violation concerning the failure to perform a start of the emergency diesel generators as required byplant procedures. We have reviewed your reply and find it responsive to the concerns 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.

l

. Since ,

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. H. Harrell, e lef Project Branc.; D

< Division of Rea' Proje

! Docket No.: 50-382 License No.: NPF-38

cc

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Executive Vice President and Chief Operating Officer

' Entergy Operations, Inc.

P.O. Box 31995 Jackson, Mississippi 39286-1995

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9812070140 981130 PDR ADOCK 05000382 i G PDR ,

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Entergy Operations, Inc. -2-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 Manager - Licensing Manager Waterford 3 SES -

Entergy Operations, Inc. j P.O. Box B l Killona, Louisiana 70066  !

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Chairman l Louisiana Public Service Commission i One American Place, Suite 1630 i i Baton Rouge, Louisiana 70825-1697 .

)

Director, iduclear Safety &

~

Regulatory Affairs

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Waterford 3 SES l

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Entergy Operations, Inc.

P.O. Box B Killona, Louisiana 70066 l i William H. Spell, Administrator

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Louisiana Radiation Protection Division P.O. Box 82135

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Baton Rouge, Louisiana 70884-2135  ;

i Parish President l St. Charlec Parish

< P.O. Box 302 HahnviHe, Louisiana 70057

{

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Winston & Strawn

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1400 L Street, N.W. l

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Entergy Operations, Inc. -3-E-Mail report to T. Frye (TJF)

E-Mail report to D. Lange (DJL)

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DOCUMENT NAME: R:\_WABWT814AK.JMK To receive copy of document, indicate in box: "ot = Copy Wthout enclosures *E" = Copy with enclosures *N" = No copy RIV:ASPE:DRFa C:DRP/D ff l .

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i L Entergy Operations, Inc. -3- NOV 3 0 i993 i

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E-Mail report to T. Frye (TJF)

E-Mail report to D. Lange (DJL) j E-Mail report to NRR Event Tracking System (IPAS)

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DOCUMENT NAME
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O Ente perations, Inc.

Killona. LA 70066 Tel 504 739 6242 Early C. Ewing. til Daector ar Safety & Regulatory Affavs

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W3F1-98-0182 A4.05 PR November 19,1998 V20 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Subject: Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC inspection Report 50-382/98-14 Reply to Notice of Violation Gentlemen:

In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in Attachment 1 the response to Violation 50-382/9814-01 identified in the subject inspection report. On November 9,1998, Mr. P. Harrell, NRC Region IV, granted an l extension until November 19,1998, for this response.

, Based upon our evaluation of the information contained in the inspection report,

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Waterford does not contest the violation. However, we are taking exception to some l of the details provided in the discussion of the violation. Additionalinformation to support our position is provided in the attached response.

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NRC Inspection Report 50-382/98-14 Reply to Notice of Violation l

W3F1-98-0182 l Page 2 November 19,1998 i

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

Very truly yours, l l

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E.C. Ewing i Director, Nuclear Safety & Regulatory Affairs ECE/BVR/ssf Attachment cc: :

E.W."Merschoff (NRC Region'IV)  ;

C.P. Patel (NRC-NRR) l J. Smith N.S. Reynolds l NRC Resident inspectors Office l

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Attachment to o; W3F1-98-0182 i

Page 1 of 4

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ATTACHMENT 1 i

ENTERGY OPERATIONS, INC. RESPONSE TO VIOLATION 50-382/9814-01

IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 98-14

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i VIOLATION NO. 50-382/9814-01 Technical Specification 6.8.l.a requires, in part, that written procedures shall be implemented and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A, ,

Section 6 requires that the licensee have procedures for combating emergencies and  ;

other significant events. .

Off-Normal Operating Procedure OP-901-521, " Severe Weather and Flooding," i Revision 2, Section E4.12 specified, in part, that: lF a Hurricane Warning is issued,

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THEN perform the following. Step C stated, in part: Perform the following for BOTH l Emergency Diesel Generators (EDGs), ONE EDG at a time. Start EDG in I accordance with OP-009-002, EMERGENCY DIESEL GENERATOR. '

Contrary to the above, on September 1,1998, at 4 p.m. (CDT), the National Weather Service issued a hurricane waming for St. Charles Parish, where Waterford 3 is located. The licensee entered Off-Normal Operating Procedure OP-901-521, but ,

failed to perform a start of the emergency diesel generators, as required by the procedure.

This is a Severity Level IV violation (Supplement 1) (50-382/9814-01).

RESPONSE Waterford has carefully evaluated the information in Violation 9814-01 and does not contest the violation. However, this response takes exception to some of the information in the inspection report.

Because off-normal procedures are written to provide guidance under numerous circumstances, it is management's expectation that operators will prioritize the tasks in accordance with plant conditions. This expectation is represented by Section 5.16.5 of OP-100-001, which allows steps in off-normal procedures to be addressed out of sequence "lF the step is not applicable to the present plant condition."

I Waterford believes the operators were following management's expectation to prioritize tasks when preparing for Tropical Storm Earl and acted in accordance with the required procedures. However, off-normal procedure OP-901-521, as written,

, did not clearly represent management's additional expectation to start the EDGs as soon as possible to ensure their availability. Procedure requirements included

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W3F1-98-0182 Page 2 of 4 starting, paralletirm and loading the EDGs. Based on the operators' judgement regarding specific weather conditions, availability of personnel on shift, plant conditions and their conclusion that procedure requirements were excessive, the operators decided not to perform the step for testing the EDGs in the sequence explicitly required by the procedure.

Reason for the Violation

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At approximately 1600 on September 1,1998, a hurricane warning was issued for St.

Charles Parish due to a potential for winds associated with Tropical Storm Earl

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(located in the Gulf of Mexico) to strengthen to hurricane force. Waterford declared an Unusual Event and entered off-normal procedure OP-901-521. Consistent with management's expectation to prioritize the work associated with preparing for the storm, Control Room personnel reviewed the actions necessary and personnel required for the upcoming steps in the procedure. As part of this review, the operators evaluated Step 12.c that required staiting, paralleling and loading both EDGs in accordance with the normal operating procedure (OP-009-002, " Emergency Diesel Generators"). The operators also evaluateo step 12.c within the context of OP-100-001, which provides guidance for the use of c.ff-normal procedures (such as ,

OP-901-521) and allows steps in a procedure to be addressed out of sequence "lF l the step is not applicable to the present plant condition. In accordance with Section l 5.16.5 of OP-100-001, the operators decided to postpone step 12.c for the following )

reasons.

. OP-901-521 required using the normal operating procedure for the diesel (OP-009-002), which could take up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per EDG to complete. Realizing that OP-009-002 was intended for use under normal operating conditions, the operators felt that the amount of time and manpower needed to start, parallel and load each EDG was excessive and could potentially prevent the shift personnel from completing other required actions to prepare for the storm.

. Shift personnel were tending to numerous tasks to ensure the outside area of the plant was prepared if conditions should worsen.

. The Shift Supervisor was involved in several discussions that included: returning Train "A" of the Shield Building Ventilation System to operable status; security concems from the Arkansas security department and a plant in Florida; and NRC notifications and updates.

. Watchstanders that were needed to assist with testing the EDGs were performing thorough walkdowns to verify items that were moved or stowed for the hurricane near safety-related equipment would not potentially interfere with the operation of such equipment.

. Based on information periodically received from the National Weather Service (NWS), the shift determined that adequate time was available to test the diesels if the path of the tropical storm changed towards the direction of Waterford or

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conditions worsened. Throughout the shift, the amount of time available to test

, the EDGs was evaluated upon receipt of new information from the NWS.

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$[ Attachment to

: VV3F1-98-0182 Page 3 of 4 f

l j The above considerations indicate the Control Room staff was aware of the purpose j. of Step 12.c in OP-901-521. However, the excessive requirements in the procedure l for paralleling and loading the EDGs required a significant amount of manpower and j time that could potentially prevent the shift personnel from completing other required

actions to prepare for the storm. This resulted in the operators taking actions that i contradicted management's expectation that the EDGs would be tested as soon as l possible.

! At approximately 0500 on September 2,1998, the need to test the EDGs was discussed with the on-coming Shift Supervisor and Operations Superintendent. The i oncoming shift was informed that the step requiring the starting, paralleling and j loading of the EDGs had been addressed, but not performed. The oncoming shift i was also informed other actions related to the hurricane preparations were complete.

l The NWS cancelled the Hurricane Warning for St. Charles Parish at approximately i 0800 and Operations Procedure OP-901-521 was exited prior to the new shift having

} an opportunity to perform the step for starting, paralleling and loading the EDGs.

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i j Corrective Steps That Have Been Taken and the Results Achieved

j inspection Report 98-14 states that the guidance in OP-100-001 contained ambiguity

regarding when a step was not required to be performed. Waterford does not

believe this was a contributor to this event. Instead, Waterford believes off-normal procedure OP-901-521 contained excessive requirements that created an unnecessary burden on the operators and resulted in the operators postponing step l 12.c. Thus, off-normal procedure OP-901-521 was revised in order to remove the  ;

excessive requirements. Since the requirement to start, parallel and load the EDGs i

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was based upon normal operation of the EDGs, the amount of time and manpower involved in the process did not support the intent of step 12.c in OP-901-521. The intent of step 12.c is to ensure the availability of the EDGs during off-normal conditions. Therefore, the step was changed to start the EDGs and return them to standby mode. A note was also added to the procedure that allows the operators to not start the EDGs if they were tested within the previous 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

The report also states that operator familiarity with OP-901-521 was poor and training on the use of the procedure appeared to be lacking. Waterford believes the operators' considerations provided in the previous section indicate that the operators were familiar with the purpose of step 12.c in OP-901-521 and additional training is not necessary. Management's expectation that the EDGs will be tested as early as possible when prioritizing the steps in off-normal procedure OP-901-521 was clarified to Operations personnel.

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c'~ Attachment to i W3F1-98-0182 l Page 4 of 4 i Corrective Steps Which Will Be Tanen to Avoid Further Violations ,

t Waterford 3 is in full compliance. No further corrective steps are needed to avoid ,

future violations. .

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Date When Full Compliance Will Be Achieved J

. Waterford 3 is in full compliance.

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