IR 05000382/1997011

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/97-11 on 970722

ML20216E700
Person / Time
Site:	Waterford
Issue date:	09/08/1997
From:	Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dugger C ENTERGY OPERATIONS, INC.
References
50-382-97-11, NUDOCS 9709110053
Download: ML20216E700 (5)

Text

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Charles M. Dugger, Vice President l Operations Waterford 3 J Entergy Operations, In P.O. Box B i Killona, Loulslana 70066 '

! SUBJECT: NRC INSPECTION REPORT 50 382/97 11

l Thank you for your letter of August 28,1997, in response to our letter and Notice of Violation dated July 22,1997, We have reviewed your reply and find it responsive to

i the concerns raised in our Notice of Violation. We will review the implementation of your i

i corrective actions during a future inspection to determine that full compliance has been

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achieved and will be maintaine Sincer ,

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l Thomas P. Gwynn Dir tor l

Divls!on of Reacto Pr jects l Docket No.: 50 382

License No.: NPF 38 i

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l Executive Vice President and i Chief Operating Officer j Entergy Operations, Inc.

i P.O. Box 31995 Jackson, Mississippi 39286 1995 g

j' Vice President, Operations Support (\

Entergy Operations, In P.O. Box 31995 Jackson, Mississippi 39286 1995 f {$fl l kkikk

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Entergy Operations, In Wise, Carter, Child & Caraway P.O. Box 651 Jackson, Mississippi 39205 General Maneger, Plant Operations Waterford 3 SES Entergy Operations, In P.O. Box B Killona, Loulslana 70000 Manager - Licensing Manager Waterford 3 SES Entergy Operations, In P.O. Box B l Killona, Louisiana 70000

Chairman Loulslana Public Service Commission One American Place, Suite 1630 Baton Rouge, Loulslana 70825 1697 Director, Nuclear Safety &

'legulatory Affairs Waterford 3 SES Entergy Operations, In P.O. Box B Killona, Louisiana 70066 William H. Spell, Administrator Loulslana 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 Bothesda Licensing Office 3 Metro Center Suite 610 Bethesda, Maryland 20814 J

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l Entergy Operations, In . 3 Winston & Strawn 1400 L Street, Washington, D.C. 20005 3502

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Regional Administrator Resident inspector DRP Director DRS PSB Branch Chief (DRP/D) MIS System Project Engineer (DRP/D) RIV File Branch Chief (DRP/TSS)

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Entergy Operations, In SEP - 81997 him to DCd (l'EO'1) 7 bec distrib. by RIV:

Regional Administrator Resident inspector DRP Director DRS PSB

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Branch Chief (DRP/D) MIS System I

Project Engineer (DRP/D) RIV Filo Branch Chief (DRP/TSS)

DOCUMENT NAME: r:\_WAT\WT711 AK.LAK To receive copy of document. Indicate in box: ,*{" o Copy without encbsures 'T" * Copy wnh enclosures *N" = No copy PE:DRP/D G APick;cmg/ J

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!ij AUG 2 91997 I y W3F197 0209 L--. -d A4.05 FIEGION IV PR ,

August 28,1997 U.S. Nuclear Regulatory Commission t ATTN: Document Control Desk l Washington, D.C. 20555 l Subject: Waterford 3 SES Docket No. 50 382 License No. NPF-38 NRC Inspection Report 97-11 Reply to Notice of Violation Gentlemen:

In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in Attachment 1 the response to the violation identified in Enclosure 1 of the subject inspection Report. A one week extension from the original 30-day response date for this submittal was granted by the Waterford 3 NRC Region IV Branch Chief per telecon on August 21,199 If you have any questions concerning this response, please contact me at (504) 739-624 Very truly yours,

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E.C. Ewing Director, Nuclear Safety & Regulatory Affairs

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ECE/DFUtjs Attachments

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NRC. Inspection Report 97-11 ,  !'

Reply to Notice of Violation W3F197-0209 Page 2

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August 28,1997 cc: m E.W. Merschoff(NRC RegioriIV) .

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

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ATTACHMENT 1 ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN ENCLOSURE 1_OF INSPECTION REPORT 97-11

VIOLATION NO. 971101 -

Technical Specification 6.8.1 a requires, in part, that written procedures shall be implemented covering applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A, Section 1.c, requires that the licensee have administrative procedures for equipment control (e.g.,

locking and tagging).

Administrative Procedure UNT-005-003," Clearance Request, Approval, and Release," Revision 14, Section 5.3, " Preparation of the Clearance Form," requires, in part, that, if tags are added or deleted to a clearance, the individual making the changes shall ensure that the clearance affords the same level of protection or better than the original clearance, the clearance shall receive an independent review by a i

licensed operator to verify that the boundaries chosen are adequate, and the clearance is forwarded to the shift supervisor / control room supervisor for revie !

Contrary to the above, on May 20,1997, Administrative Procedure UNT-005-003 was not implemented in that tags were added to Clearance 97-0864 without adequately ensuring the revised clearance afforded the same level of protection as the original clearance, without an independent review by a licensed operator, and without forwarding the clearance to the shift supervisor / control room superviso This is a Severity Level IV violation (Supplement 1) (50-332/9711-01).

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RESPONSE TO VIOLATION NO 9711-01 (1) Reason for the Violation The issuance of an inadequate clearance modification to the field was due to

, personnel error involving inattention to detail, in that the Shift Support Center

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(SSC) plant operator (NPO) did not ensure the same level of protection as the -

original clearance. The Refueling Water Storage Pool (RWSP) purification system was in service and should have been secured prior to hanging the tags. When the fuel poolion exchanger to RWSP isolation valve, FS-404, was shut, the RWSP purification pump was running essentially dead headed

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against valve FS-404 and the fuel pool lon exchanger to fuel pool isolation

, valve, FS-345 (See Attachment 2). The failure of the NPO to obtain the appropriate reviews for the clearance modification was a combination of poor judgment and unclear procedural guidance in UNT-005-003, " Clearance Request, Approval, and Release." Obtaining an independent operator review

, and SS/CRS review is clearly required and performed when preparing the

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initial clearance. However, the procedure is unclear as to the review requirements for adding tags to an existing clearance, which resulted in inconsistent implementation of this procedure. This inconsistency was further evidenced by a follow up evaluation performed by the Waterford 3 Quality Assurance Department, which revealed other instances of failure to obtain the appropriate reviews for adding tags. Regardless, it is Operations j Management's expectation these reviews were to be performed.

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An Event Review Team was formed to investigate the Spent Fuel Pool (SFP)

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overflow event and determined several other factors which contributed to the event including the following:

The nuclear auxiliary operators (NAOs) hanging the clearance took inadequate actions to correct the abnormal condition of running the RWSP Purification Pump with its discharge flow path isolated. The fact that RWSP Purification needed to be secured was discussed; however poor communications between the NAOs and the SSC NPO led the SSC to believe FS-404 remained open. The status of the clearance and the system was not effectively communicated to the SSC. The SSC NPO assumed that the NAOs re-opened FS-404 once they realized there was still flow through the pip The assumption by the SSC NPO that FS-404 was opened, and therefore a flow path existed for the RWSP Purification Pump, led him to believe that securing RWSP Purification was not a high priority Communications from the SSC NPO were poor in that the SSC NPO did not inform the Control Room that a clearance was sent to the field, This is contrary to management expectation The travel stop nuts on FS 345 were incorrectly positioned 1/8 inch lower than required by the valve technical manual. This resulted in the valve not fully

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blocking flow to the Spent Fuel Pool when closed. A review of maintenance history on the valve revealed the valve was last worked in May,1992, to install an extension stem per Design Change (DC) 3211. This activity required the travel stop nuts to be removed. Neither DC 3211 nor the associated work authorization contained specific instructions as to the required position of tho travel stop nuts upon replacemen .

With several critical outage evolutions taking place at the time (EDG A run, venting of HPSI system, fill and vent of LPSI system), the Operating Crew placed a lower priority on lowering SFP level following the High Level Alarm which led to the SFP overflow. When the crew received the SFP High Level Alarm, a NAO was promptly sent to investigate. The NAO reported that the levelin the SFP had risen epproximately one inch in the last twenty four hours. The crew appropriately had the NAO check allinfluent valves into the SFP closed in accordance with the Annunciator Response Procedure. The crew discussed the possible cause of the rise in SFP level. However they did not contact the SSC to determine if they had done any evolutions that would have resulted in the level rise. They believed that the rise may have been attributable to the Emergency Diesel Generator (EDG) A run that had just been completed. During the EDG run the CCW makeup pump was runnin The crew believed that the Condensate Makeup (CMU) valves to the SFP may have been leaking and appropriately requested a boron sample of the SFP from Chemistry. Because the cause of the level rise was still not positively identified, they instructed the RAB Watch to periodically monitor the SFP level on his normal round The shift was unaware of the continued in-leakage to the SFP because there is no Hl/H1 level alarm to provide additional warning and there is no remoto levelindication for the Spent Fuel Pool. The only methods available to the crew to detect continued in leakage was through periodic local monitoring of level or lowering the SFP level below the high alar (2) Corrective Steps That Have Been Taken and the Results Achieved The following corrective actions which address the violation are complete:

On May 25,1997, the Operations Manager sent a message to all Shift Superintendents and Control Room Supervisors stating: 1) On-shift SS/CRS will initial each clearance to release the system for work and 2) Additional tags shall not change the scope and intent of the original clearance. If the additional tags will challenge either the scope or intent, then a new clearance shall be prepared, complete with all necessary review The Operations Manager has counseled the Operations Department concerning this incident and reinforced standards and expectation _

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The Planning and Scheduling Manager has revie'wed expectations for preparing tagout requests with departmental personnel and maintenance planner The following corrective actions to correct the additional contributing factors associated with the overflow event are complete:  !

When the SFP overflow was identified and communicated to the Control Room, the RWSP Purification Pump was secured, stopping in-leakag The spill area was confined to stop further leakage and isolated to prevent

! spreading of contaminatio Valve FS-345 was opened and inspected to determine the failure mechanis The travel stop nuts on FS 345 were adjusted to the position required by the

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Technical Manua It was determined that four other valves had extension stems installed under DC-3211. The travel stop bolts on these four valves were checked for proper travel stop nut position and were adjusted as necessar Systems Engineering has initiated a Station Modification Request to add / change annunciators for the SFP and to provide remote SFP level indication to the Control Roo Other tanks and pools at Waterford 3 were evaluated for generic implications for level indication and were determined to have the necessary level indication and instrumentatio Annunciator response procedure OP 500-008 has been revised to include directions to restore SFP level to normal band upon receipt of any Fuel Pool level alar (3) Corrective Steps Which Will Be Taken to Avoid Further Violations Procedure UNT-005-003," Clearance, Request, Approval, and Release," will be reviewed for enhancements and will be revised to clarify review requirements for modified clearance Generic actions for improving human performance and addressing procedure noncompliance at Waterford 3 are outlined in the Performance improvement Plan, which was issued to the NRC on May 8,199 .  ;

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Pcgs 5 of 5 Operations will review all Hl/ Low Level annunci$for response procedures to l'

ensure that either adequate monitoring still exist,s, or the shift is directed to clear the annunciator immediatel (4) Date When Full Compliance Will Be Achieved

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The corrective step to revise UNT-005 003 will be completed by September 1 30,1997, at which time Waterford 3 will be in full complianc l The corrective step to review annunciator response procedures will also be completed by September 30,199 As mentioned above- generic actions to address human performance and procedure noncompliance site-wide have been previously committed with targeted due dates via the Waterford 3 Performance Improvement Plan, and will be tracked per this previous docketed correspondenc ,

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ATTACHMENT 2: SKETCH OF FUEL POOL PURIFICATION SYSTEM

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