ML20199L262

Discusses Predecisional EC Conducted 980123 Re Insp Rept 50-382/97-26 on 971215 & Forwards NOV Re Failure to Return Controller for Valve ACC-126A to Automatic Operation Following Use on 971109

ML20199L262
Person / Time
Site:	Waterford
Issue date:	02/05/1998
From:	Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dugger C ENTERGY OPERATIONS, INC.
Shared Package
ML20199L269	List: ML20199L262 ML20199L285
References
50-382-97-26, EA-97-589, NUDOCS 9802090163
Download: ML20199L262 (5)

See also: IR 05000382/1997026

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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611 RYAN PLAZA DRIVE. SUITE 400

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ARUNGToN TEXAS 76011 8064

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February 5, 1998

EA 97-589

. Charles M. Dugger, Vice President

Operations - Waterford 3

Entergy Operations, Inc.'

P.O. Box B

~ Killona, Louisiana 70066

SUBJECT:

NOTICE OF V80LATION (NRC INSPECTION REPORT 50 382/97-26)

Dear Mr Dugger:

This refers to the predecisional enforcement comvence conducted January 23,1998, in the

NRC's Arlington, Texas office.' The conference was conducted to discuss several apparent

violations related to a November 1997 incident involving a mispositioned valve controller in the

auxiliary component cooling water system at the Waterford Steam Electric Station,

Unit 3 (Waterford 3). The apparent violations were identified during an NRC inspection that

concluded on December 15,1997, when the inspection findings were conveyed to Entergy

. Operations, Inc. (Entergy) by telephone, ard were documented in the subject inspection report ;

on January 5,1998.

Based on the information developed during the inspection, and our consideration of the -

information that you provided during the conference, the NRC has determined that violations of

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NRC requirements occurred. These violations are cited in the enclosed Notice of

Violation (Notice) and the circumstances surrounding them were described in detail in the

subject inspection report in brief, the violations are related to a failure to retum the controller for

Valve ACC-126A to automatic operation following its use on November 9,1997,- an error which

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went unrecognized for 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> despite several control board walkdowns by operators and a

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shift tumover. The failure to retum this valve to automatic rendered Train A of the auxiliary

component cooling water system inoperable. Operators compounded this error by removing

Train B of the auxiliary component cooling water system from service for routine maintenance on

November 10,1997, without first physically verifying the operability of Train A. Both trains of this

system remained inoperable for approximately 7.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. The problem was ultimately corrected

on November 10,1997, when a relief opt rator walked down the control boards and discovered

the mispositioned valve. Train A was imn ediately restored to service.

The violations include the procedural error that resulted in the mispositioned valve controller, the

failure to verify the operability of Train A before taking Train B out of service, and the failure to .

discover the mispositioned controller during control board walkdowns and shift turnover. We

recognize that the Waterford-3 auxiliary component cooling water system, which supports the

component cooling water system, may not have been necessary to support the safety function

of the ultimate heat sink, given the meteorological conditions that existed at the time of this

incident, and the likelihood that operators could have restored Train A operability after receiving

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9902090163 990205

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PDR

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Entergy Operations, Inc.

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a h!gh temperature alarm on the component cooling water system. The NRC also recognizes

- that no audible or visible alarms were triggered as a result of the controller being in the wrong

position. Nonetheless, these violations are safety significant because a safety system which is

designed to remove heat under certain accident conditions, and which was required to be

operable at the time, was rendered incapable of operating automatically as designed, in =

addition, as discussed at some !sngth during the conference, corrective actions for prevbus, .

similar events involving mispositioned switches and valves (NRC inspection report 50-382/96 ;

13) were not effectively implemented in this case, as evidenced by the many missed

opportunities to have discovered this error eariier,

Accordingly, these violations are classified in the aggregate as a Severity Level lil problem in

accordance with the "Genorcl Statement of Policy and Procedure for NRC Enforcement Actions"

(Enforcement Policy) NUREG-1600.' In accordance with the Enforcement Policy, a civil penaIty

with a base value of $55,000 is considered for a Seventy Level lli problem. Because your . _

facility has been the subject of escalated enforcement actions within the last two years l the

NRC considered whether credit was warranted for identification and Corrective Action in

accordance with the civil penalty assessment process in Section VI B.2 of the Enforcement

Policy. Given that the mispositioned valve controller was discovered by a Waterford-3 operator

and not revealed by an event, and that the failures to identify the error earlier also were

discovered by Entergy, the NRC concludes that credit for identification is warranted; We also

conclude that credit for corrective actions is warranted, Your corrective actions included:

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- immediate action to restore system operability and walk down all control boards; debrief of all

operators on duty when ACC-126A was mispositioned; meetings with all shift personnel to .

reinforce expectations for walkdowns and shift tumover; procedural revision to eliminate two

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actions in one step in OP-002-001; implementation of control board assessments by shift

technical advisor during shift tumover; enhancement of shift tumover control board walkdown

_ procedure; and plans for a corrective action effectiveness review within six months.

Therefore, to encourage identification and comprehensive correction of violations before events

- occur, I have been authorized, after consultation with the Director, Office of Enforcement, not to

assess a civil penalty in this case. However, significant violations of this nature in the future

could result in a civil penalty.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response The NRC will use your response, in part, to

determine whether further enforcement action is necessary to ensure compliance with regulatory

-requirements.

'For example, a $50.000 cml peratty was ,ssued March 28,1996 (EA 96-025), a $50,000 civil penalty was issued

December 26.1996 (EA 96-255); and a $55.000 cwil penalty was issued May 9,1997 (EA 97-099).

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Entergy Operations, Inc.

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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its

enclosure, and your response will be placed in the NRC Public Document Room (PDR).

Sincerely,

'

Ellis W.

Regional Admi

trator

Docket No.: 50-382

License No.: NPF 38

Enclosure: Notice of Violation

cc w/ Enclosure:

Executive Vice President and

Chief Operating Officer

Entergy Operations, Inc.

P.O. Box 31995

Jackson, Mississippi 39286-1995

Vice President, Operations Support

Entergy Operations, Inc.

P.O. Box 31995

Jackson, Mississippi 39286-1995

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.

P.O. Bo.y B

Killona, Louisiana 70066

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Entergy Operations, Inc.

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Chairman

Louisiana Public Service Commission

One American Place, Suite 1830

Baton Rouge, Louisiana 70825-1697

Director, Nuclear Safety &

Regulatory Affairs

Waterford 3 SES

Entergy Operations, Inc.

P.O. Box B

Killona, Louisiana 70066

William H. Spell, Administrator

Louisiana Radiation Protection Division

P,0. Box 82135

Baton Rouge, Louisiana 70884-2135

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Parish President

St. Charles Parish

P.O. Box 302

Hahnville, Louisiana 70057

1

Mr. William A. Cross

Bethesda Licensing Office

3 Metro Center

Suite 610

Bethesda, Maryland 20814

Winston & Strawn

1400 L Street, N.W.

Washington, D.C. 20005-3502

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Entergy Operations, Inc.

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