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| {{Adams | | {{Adams |
| | number = ML20217B698 | | | number = ML20236K200 |
| | issue date = 04/21/1998 | | | issue date = 07/01/1998 |
| | title = Insp Rept 50-382/98-06 on 980201-0321.Violations Noted.Major Areas Inspected:Operations,Maint & Engineering | | | title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/98-06 on 980421 |
| | author name = Harrell P | | | 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 = 50-382-98-06, 50-382-98-6, NUDOCS 9804230113 | | | document report number = 50-382-98-06, 50-382-98-6, NUDOCS 9807090213 |
| | package number = ML20217B670 | | | title reference date = 06-15-1998 |
| | document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | | | document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE |
| | page count = 21 | | | page count = 4 |
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| | l 0 4 "C%, UNITED STATES 1 of t- NUCLEAR REGULATORY COMMISSION y n |
| | {, ,c REClON IV |
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| | S cf 611 RYAN PLAZA DRIVE, SulTE 400 * |
| | i n...../ AR LINGTON, T EXAS 76011-8064 l JUL - l 1998 Charles M. Dugger, Vice President Operations - Waterford 3 Entergy Operations, Inc. |
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| | - P.O. Box B Killona, Louisiana 70066 SUBJECT: NRC INSPECTION REPORT 50-382/98-06 |
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| | ==Dear Mr. Dugger:== |
| ENCLOSURE 2 U.S. NUCLEAR REGU'ATORY COMMISSION
| | Thank you for your letter of June 15,1998, in response to our April 21,1998, !etter and Notice of Violation concerning the failure to test a containment isolation valve (CVC-103) after l performing maintenance to ensure that the valve could still perform its intended safety function, the failure to perform comprehensive corrective actions following overflow of the spent fuel pool, and an involvement by an engineer who performed an operational activity without the direction or concurrence of control room personnel. 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. , |
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| | Ph lip H. Harrell, Chief Pro ct Branch D |
| | . Divi ~on of Reactor Projects l |
| | Docket No.: 50-382 License No.: NPF-38 9007090213 990701 PDR ADOCK 05000382 G PDR |
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| ==REGION IV==
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| . Docket No.: 50-382 License No.: NPF-38 Report No.: 50-382/98-06 Licensee: Entergy Operations, In Facility: Waterford Steam Electric Station, Unit 3 Location: Hwy.18 Killona, Louisiana Dates: February 1 through March 21,1998 Inspectors: J. M. Keeton, Resident inspector D. R. Lanyi, Resident inspector, Region 11 Accompanied By: J. C. Edgerly, Resident inspector Trainee M. A. Kotzalas, NRC Headquarters intern Approved By: P. H. Harrell, Chief, Project Branch D ATTACHMENT: Supplemental Information l
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| l 9804230113 980421 PDR ADOCK 05000382 G PDR
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| | Executive Vice President and |
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| | . Chief Operating Officer |
| | : Entergy Operations, Inc. |
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| | P.O. Box 31995 ' |
| - | | ' Jackson, Mississippi 39286-1995 Vice President, Operations Support - |
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| EXECUTIVE SUMMARY Waterford Steam Electric Station, Unit 3 NRC Inspection Report 50-382/98-06 I
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| This routine, announced inspection included aspects of operations, maintenance, engineering i and plant support activities. The report covers a 7-week period of resident inspectio !
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| - The licensed operators performed in a professional manner and demonstrated excellent knowledge and understanding of the safety consequences of the loss of instrument power event (Section 01.1).
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| . In general, control room activities were conducted in a very good manner (Section 01.2). | | P.O. Box 31995 Jackson, Mississippi 39286-1995 Wise, Carter, Child & Caraway P.O. Box 651 |
| | : Jackson, Mississippi 39205 |
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| | General Manager, Plant Operations |
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| | Waterford 3 SES |
| | . Entergy Operations, Inc. |
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| - | | ~ P.O. Box B Killona, Louisiana 70066 I |
| Inattentiveness to licensed duties by a senior reactor operator resulted in a noncited violation of Technical Specification (TS) shift-manning requirements when both the shift superintendent (SS) and the control room supervisor (CRS) were absent from the control room for 1 minute 38 seconds (Section O4.1).
| | Manager- Licensing Manager |
| | . Waterford 3 SES Entergy Operations, Inc |
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| | P.O. Box B - |
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| | Killona, Louisiana '70066 Chairman Louisiana Public Service Commission One American Place, Suite 1630 ) |
| | . Baton Rouge, Louisiana .70825-1697 I Director, Nuclear Safety & |
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| | Waterford 3 SES '1 Entergy Operations, Inc. |
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| Maintenance
| | P.O. Box B l. Killona, Louisiana 70066 William H. Spell, Administrator |
| + The performance of the check valve leakage surveillance adequately tested the valve The inspectors noted good procedural compliance and good questioning attitudes by all of the operations personnelinvolved in the test (Section M1.1). | | . Louisiana Radiation Protection Division |
| | .P.O. Box 82135 Baton Rouge,' Louisiana 70884-2135 |
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| * The inspectors determined that the emergency feedwater turbine-driven pump surveillance was performed in accordance with approved procedures. The operators were knowledgeable about the test (Section M1.2).
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| | . Entergy Operations, Inc. -3- l |
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| | Parish President . |
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| | 'St. Charles Parish P.O. Box 302 Hahnville,. Louisiana '70057 - |
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| | Mr. William A. Cross |
| | ' Bethesda Licensing Office' |
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| | - Suite 610 Bethesda, Maryland 20814 i Winston & Strawn - |
| | . 1400 L Street, N.W. |
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| . Valve CVC-103 did not properly perform all its design functions during an event. A violation resulted because testing was not performed after completion of maintenance (Section M1.3). | | - Washington, D.C.'. 20005-3502 I |
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| - Personnel failed to implement broad, effective corrective actions following the spent fuel pool overflow event. Specifically, a violation was identified because the licensee failed to review the stop nut adjustment on similar valves since the stop nut adjustment was considered a contributing factor to the overflow of the spent fuel pool (Section M2.1). | | r |
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| - Engineers had been responsive to the need for developing a technical failure mechanism for a plant protective system relay (Section E1.1).
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| * An engineer inappropriately operated equipment in the plant without the SS or CRS knowledge or concurrence. This was a repeat of a similar occurrence within the last 2-years, and this issue is being treated as a violation (Section E5.1).
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| i | | l bec to DCD (IE01) , |
| | I bec distrib. by RIV. ! |
| | -Regional Administrator Resident inspector. f |
| | ; DRP Director DRS-PSB Branch Chief (DRP/D) MIS System Project Engineer (DRP/D) RIV File Branch Chief (DRP/TSS) |
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| The engineering review and the revised procedures for control of volatile organic compounds (VOC) was acceptable. This issue is being treated as a noncited violation (Section E8.1).
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| | DOCUMENT NAME: R:\_WAT\WAT806AK.JMK . |
| | j. To receive copy of document, Indicatejn box:"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy |
| | !. RIV:PE:DRP/D C:pA/3/D , h l l GAPi,ck (\\n / Pf'll-N f#7 07/ /@ hM" D7/lf V ; |
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| | \ OFFICIAL RECORD COPY L |
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| Reoort Details
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| Summary of Plant Status During this inspection period, the plant operated at essentially 100 percent power.
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| I 1. Operations 01 Conduct of Operations (71707)
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| 01.1 Loss of Static Uninterruotible Power Sucolv (SUPS) B
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| ' Insoection Scoce (71707) | | A.mona LA 70066 Te6 504 739 6242 Early C. Ewing, Ill eI Sa'ety & RegWtory A%s hWerford 3 W3F1-98-0104 A4.05 PR i |
| The inspectors observed the control room operators during the response to a loss of )
| | June 12,1998 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 |
| SUPS B, the activities involved in prioritizing recovery of power to the SUPS B distribution panel, and recovery of plant instruments required for continued plant operatio Observations and Findinas On February 4,1998, SUPS B failed and caused a loss of electrical power to instrumentation required for continued plant operation. The CRS entered Procedures OP-901-112, " Charging or Letdown Malfunction," and OP-901-312, " Loss of Vital Instrument Bus." The inspectors observed the CRS directing licensed operators in accordance with the applicable off-normal procedures. The SS directed the shift technical advisor to verify which TS were in effect and to track time clocks associated with the action statements in effect. Additionallicensed operators reported to the control room to assist the shift crew as necessar Investigation of the cause of the trip revealed that the SUPS B inverter had blown fuse The power to Distribution Panel PDP3918, which is supplied by SUPS B, was restored
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| ! by energizing the bypass power supply approximately 15 minutes after the SUPS l tripped. The order of restoration of loads had been priontized using the basic guidance l in Procedure OP-901-312, and field reports from nuclear plant operators verified that the loads being restored had not been affected. The inspectors reviewed the off-normal procedures used during recponse to the transient and noted that the guidelines were very general in that the procedure required the operators to develop the detailed restoration plan ad hoc. The operators demonstrated an excellent knowledge and understanding of the safety consequences of the event.
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| | Subject: Waterford 3 SES j;3 |
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| | Docket No. 50-382 l |
| | License No. NPF-38 NRC Inspection Report 98-06 Reply to Notice of Violation Gentlemen: |
| | In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in Attachment 1 the response to the violations identified in Enclosure 1 of the subject Inspection Report. On May 20,1998, an extension of the original 30-day response date until June 12,1998, was granted to Waterford 3 by Mr. G. Pick, NRC Region IV. |
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| l All components powered from Distribution Panel PDP3918 had been restored within approximately 3 hours. All TS action requirements were exited, except for TS 3.8.3.1, which required the SUPS bus to be energized from the inverter within 24 hours. All TS action statements had been satisfied within the required time limits. The SUPS B inverter was repaired and returned to service within 24 hour .
| | If you have any questions concerning this response, please contact me at (504) 739-6242 or Tim Gaudet at (504) 739-6666. |
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| l 2-The inspectors discussed the off-normal procedure weaknesses with the Operations Manager and Operations Superintendent. They agreed to review the procedures and the actual activities required for event mitigation for potential procedure enhancemen Conclusions The licensed operators performed in a professional manner and demonstrated excellent
| | Very truly yours, |
| - knowledge and understanding of the safety consequences of the loss of instrument power even O1.2 . Control Room Observations Insoection Scooe (71707)
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| in addition to routine daily control room observations, on March 11 and 12,1998, the J Inspectors observed control room activities including accet.s control, operator conduct, general operator knowledge, and shift tumover, . Observations and Findinas The inspectors reviewed Administrative Procedures OP-100-001, Revision 14, " Duties and Responsibilities of Operators on Duty," and OP-100-007, Revision 13, " Shift Tumover," to determine the requirements for the conduct of control room activities. The inspectors determined that the observed operations crews were generally meeting these requirement The inspectors noted that control room access controls were good. The layout of the control room naturally funneled personnel into the SS office or to the entrance of the ,
| | E.C. Ewing Director, Nuclear Safety & Regulatory Affairs |
| control room proper. This arrangement minimized personnel congregating in the rear of 1 the control room. Also, extraneous conversations were maintained in the enclosed office space behind the control room, which minimized distractions to the operators. The i inspectors also noted that the CRS only allowed entrance to personnel requiring control I room access for a work- and business-related activit )
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| i The inspectors observed several hours of licensed operator activity and noted the l following:
| | ECE/ ELL /GCS/ssf Attachment cc: E.W. Merschoff (NRC Region IV), C.P. Patel (NRC-NRR), J. Smith, N.S. Reynolds, NRC Resident inspectors Office |
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| . The operation staff's conduct was professiona . The operators were generally attentive to plant status and indicator . Excellent communications were observed among the crew whenever one of the
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| -3-l partner and the CRS, but they also informed the SS. The inspectors did observe the SS and the CRS brief each other on plant changes whenever one of them retumed to the control room. | | Attachment to W3F1-98-0104 Page 1 of 8 ATTACHMENT 1 |
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| | l - ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN |
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| | ENCLOSURE 1 OF INSPECTION REPORT 98-06 VIOLATION NO. 9806-03 |
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| | Technical Specification 6.8.1.a requires, in part, that written procedures shall be i |
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| | established covering the applicable procedures recommended in Appendix A of |
| | . Regulatory Guide 1.33, Revision 2, February 1978. Appendix A, Section 9, requires that .! |
| | the licensee have maintenance procedures. |
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| | Contrary to the above, the licensee failed to establish a maintenance procedure that ! |
| | provided instructions for testing of a containment isolation valve following comp!etion of ! |
| | maintenance on Valve CVC-103. ! |
| | This is a Severity Level IV violation (Supplement I) (50-382/9806-03) |
| | RESPONSE (1) Reason for the Violation |
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| | The root cause for this violation is inadequate procedural guidance in regard to setup of valve CVC-103 following maintenance activities. CVC-103 is a fail closed, letdown and containment isolation valve with a Masoneilan Sigma F operator. During Refuel 8, maintenance was performed on the valve operator. |
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| | Maintenance procedure MM-006-002, Valve Operator Maintenance, provided instructions for post maintenance testing. However, the procedure states that either it can be used as guidance for maintenance and post maintenance testing or the valve vendor manual can be used. This choice is at the discretion of the maintenance planner and/or the field mechanic. Procedure MM-006-002 delineates steps for performing post maintenance testing, including instructions for valve stroke length testing. However the valve vendor manual, which was used to perform maintenance on valve CVC-103, did not include directions for checking the valve stroke length. As a result, adequate valve post maintenance testing was not performed. The lack of post maintenance verification led to the failure to detect the incorrect stroke length of the valve. |
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| | This adverse condition was revealed on September 7,1997, following refuel 8, when power was lost to CVC-103 due to a Static Uninteruptible Power Supply |
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| | failure. Upon loss of power, the valve went to its closed position. However, L approximately 23 gpm of letdown flow was observed through the valve with th'e valve indicating closed. The valve stroke length was found to be inadequately |
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| Control room command function was clearly delineated, including any changes in emergency response responsibilities.
| | Attachment to W3F1-98-0104 Page 2 of 8 Contributing to this condition were inconsistencies between the valve l manufacturer's data and existing plant data regarding the required stroke length for CVC-103. According to the manufacturer, the required stroke length for CVC-103 is 1.2" However, the plant's calibration sheet for CVC-103 stated that the valve's stroke length was 1.25" +/- 1/4" and the plant's Station Information Management System (SIMS) stated that the stroke length was 2.625" The valve j vendor manual gives three stroke lengths the valve is capable of, but does not |
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| | specify which stroke length is appropriate for CVC-103. The inconsistencies in these documents may have contributed to the stroke length being improperly set, j as revealed in the September 7,1997 event. |
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| | I Not all the safety functions of CVC _103 were identified and documented, further l contributing to the violation. The Letdown isolation function of CVC-103 was not l clearly identified and no impact on the IST program was documented. 1 (2) Corrective Steps That Have Been Taken and the Results Achieved |
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| | . An Engineering Evaluation was performed on September 8,1997, to confirm operability of CVC-103. The evaluation concluded that CVC-103 was capable of performing both its containment and letdown isolation functions. |
| Alarm and annunciator response by the operators was very good. Without fail, l the annunciators were acknowledged in an appropriate amount of time. The
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| ! alarm was announced to the CRS and/or SS, and shift supervision acknowledged the alarm and ensured appropriate actions were take . . During shift tumovers, operators followed the requirements in Procedure OP-100-007. The shift meeting was especially useful in providing the .
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| appropriate information to all key members of the shift. The CRS was able to
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| , coordinate conflicting maintenance and surveillance activities that had been l previously schedule I Conclusions 1
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| in general, control room activities were conducted in a very good manne Operations Procedures and Documentation O3.1 Station Loo Procedures Observations (71707)
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| The inspectors observed that with the computer logging process, the station log can be modified anytime within the 12-hour shift. The editing can be accomplished without appropriately identifying whether a modification was editorial or whether it should have been identified as a corrected entry or late entry. The logging procedure in Operating )
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| Instruction 01-004-000, Revision 25, " Operations Narrative and Shift Logs," implied that I the log was not final until printed at the end of the shift, and that only changes made after that time would be subject to identifying as a late or corrected entr The inspectors have implemented an ongoing review of this issue. An inspection followup item has been opened to continue review of this issue (50-382/9806-01).
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| | This was based on an engineering evaluation that concluded the following: ) |
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| | l 1. Based on the valve materials of construction, the valve plug / seat is not expected to degrade for the duration of a letdown line break event. |
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| . | | 2. Based on recent CVC-103 valve rework and LLRT, CVC-103 would perform its containment isolation safety function. |
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| 04 Operator Knowledge and Performance 04.1 Loss of Control Room Command Function Insoection Scoce (71707)
| | 3. An evaluation was performed by Safety and Engineering Analysis which determined the consequences of the leakage through CVC-103 is within 10CFR100 limits. |
| The inspectors reviewed the documentation of circumstances, reviewed the statements of the supervisors, and interviewed operations personnel regarding a loss of control room command functio Ohtervations and Findinos On February 15,1998, with the reactor stable at 100 percent power, the CRS had notified the SS that he was leaving the control room to get lunch. The SS had acknowledged the CRS. The SS had been engrossed in an electrical problem, which he was discussing with an electrician. He accompanied the electrician out of the control room to the relay room without notifying the remaining control room operators. One of the licensed operators noticed that neither the CRS nor the SS was in the control room and went to the lunch room to tell the CRS that the SS had also left the control roo The CRS reentered the control room and paged the SS to tell him that they had violated the TS control room manning requirements, as both the SS and the CRS had been absent from the control room for 1 minute 38 second Condition Report 98-0222 had been issued immediately following the incident. Also, personnel statements had been written by the CRS and SS. Review of these documents revealed no further pertinent informatio A root cause determination was performed by the licensee and it found that the incident was an isolated human error. The inspectors agreed with this evaluation based on a review of the documentation and interviews with the individuals who were involve Immediate corrective actions included counseling of the SS, issuance of a daily instruction reminding the control room staff of the procedural and TS requirements, and discussion of the incident at the next SS/CRS meeting. The long-term corrective actions identified involved enhanced training during scheduled requalification and additional management observations. Completion of the long-term actions will be verified during review of Licensee Event Report (LER) 50-382/98-00 TS 6.2.2.b states, in part, that at least one licensed operator shall be in the control room when fuelis in the reactor. In addition, while the reactor is in MODE 1,2,3, or 4, at least one licensed Senior Operator shall be in the control roo '
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| TS Table 6.2-1 contains a note that states, in part, that during any absence of the shift supervisor from the control room while the unit is in MODE 1,2, 3, or 4, an individual, J
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| | 4. The additional water released to the RAB due to CVC-103 leakage does not represent a flooding concern because of available drain |
| l i-S-l other than the shift technical advisor, with a valid senior operator license shall be j designated to assume the control room command functio )
| | ; paths, the large floor area, and the absence of safety-related equipment in communicating compartments. Also, the high energy flooding in the RAB is enveloped by existing moderate energy flooding analysis. |
| ! l Operating Procedure OP-100-001, " Duties and Responsibilities of Operators on Duty," l l Step 5.4.1.4, states, in part, that before leaving the control room for tours, troubleshooting, or other reasons; operators, shift superintendents, or control room l
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| activities and the approximate duration of these activities. Additionally, they shall verify {
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| that the control room command function remains appropnately delineate l i i
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| ; Failure to adhere to these TS and procedural requirements demonstrates inattentiveness to licensed duties by a senior licensed operator. However, this licensee-identified and corrected violation is being treated as a noncited violation consistent with Section Vll. of the NRC Enforcement Policy. Specifically, the violation was identified by the licensee, it was not willful, actions taken as a result of a previous violation should not have corrected this problem, and appropriate corrective actions were completed by the licensee (50-382/9806-02).
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| l l Conclusions Inattentiveness to licensed duties by a senior reactor operator resulted in a noncited violation of TS control room staffing requirements when both the SS and the CRS were l absent from the control room for 1 minute 38 seconds.
| | . Design Engineering performed a preliminary review of primary and secondary system air operated valves that may impact offsite dose if the operators were setup improperly for dual safety functions. No concerns l were identified. |
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| 08 Mhscellaneous Operations issues (92901)
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| l 08.1 (Closed) Violation S0-382/9704-01: Failure to comply with working-hour limitations for j operations personnel. | | l |
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| l Between February 1 and March 1,1997, the licensee failed to implement the j requirements of TS 6.2.2.e and Procedure UNT-005-005, " Working Hour Policy for l
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| Nuclear Safety-Related Work." Working-hour policy guidelines had been exceeded in several instances without proper approva The inspectors reviewed the corrective actions described in the LER and verified that: (1) the operations, maintenance, radiation protection, and site support department personnel had been briefed on the root cause of the event and resultant corrective actions; (2) Revision 5 to Procedure UNT-005-005 had been implemented to clarify the working-hour policy; (3) the quality assurance department incorporated evaluation of organizational compliance with the working-hour policy into its audit program; and (4) the quality assurance department audited the operations and health physics departments and found these departments to be in compliance with the working-hour policy guideline i
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| | Attachment to W3F1-98-0104 Page 3 of 8 |
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| | Containment was entered on September 11,1997, to adjust / lengthen the valve / actuator stem coupling. After the adjustment was made, CVC-103 was closed and no leakage was indicated. |
| i The inspectors concluded, based on verification of these actions, that the licensee j appropriately addressed this violation.
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| l 08.2 (Closed) LER 50-382/96-01* Control Room Ventilation Valve Leakag X l It was identified that the control room normal ventilation isolation valves were leaking during operation of the emergency filtration system. Assuming a single failure, this leakage could have resulted in a single individual exceeding the 30 Rem thyroid j exposure limit in 10 CFR Part 50, Appendix A, Criterion 19 and Standard Review 4 Plan 6.4, Section 11.6. The cause of the leakage was determined to be debris that had l
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| accumulated inside the valve disc region and prevented the valves from fully closing.
| | The Masoneilan technical manual for valve CVC-103 and similar valves was revised to require stroke length measurement upon reassembly. In addition, the appropriate stroke lengths for the safety related valves were added to the manual. |
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| a The inspectors reviewed the root cause analysis and corrective actions and determined i them to be appropriate. Long term corrective actions included: (1) establishing an i
| | (3) Corrective Steps Which Will Be Taken to Avoid Further Violations l |
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| 18-month frequency for leak rate checkirig the isolation dampers, (2) developing a j procedure with an administrative limit of 8 scfm to leak rate test the isolation valves, and (3) reviewing the testing configuration for the control room pressure test to ensure compliance with all licensing documents.
| | A review of active safety related air-operated valves (AOVs), including CVC-101 and CVC-103, will be performed; necessary Design Basis Documents will be revised if closed safety functions at Normal Operating Pressure exist ; |
| | but are not identified; and, if an unidentified safety function is discovered, an eveluation will be performed to determine its impact on the IST Program. |
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| i The implementation of these corrective actions are discussed in NRC Inspection l Report 50-382/96-21 and found to be fully satisfactor .3 (Closed) LER 50-382/97-012; Programmatic Breakdown of Overtime Program.
| | . The proper set-up parameters for the Masoneilan Sigma F safety related AOVs, including CVC-101 and CVC-103, will be established and transmitted to Maintenance for procedure incorporation. |
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| ! The corrective actions for this LER are the same as the corrective actions for NRC Violation 50-382/9704-01, discussed in Section 08.1 of this repor ,
| | . Maintenance procedures will be revised to include the set-up parameters. |
| I l 08.4 (Closed) LER 50-382/97-018: Dropped New Fuel Assembly.
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| | The actions taken, as described above, will bring Waterford 3 into full compliance and will resolve the issue with those valves found to be sensitive to valve adjustments. |
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| During Refueling Outage 8, a new fuel assembly became disengaged from the spent fuel handling tool and dropped approximately 5 inches. The assembly came to rest at a 40 ;
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| i angle against the side of the spent fuel pool. No other fuel assemblies were damaged ;
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| and no spent fuel pool liner leakage was detected. The root cause of the event was j determined by the licensee to be human erro j
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| I l The inspectors reviewed the root cause analysis and considered it to be thorough and
| | (4) Date When Full Compliance Will Be Achieved |
| , | | . The review of safety related AOVs and subsequent actions are scheduled to be completed by March 31,1999. |
| j representative of a good self-assessment. Corrective actions included a revision to the '
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| l refueling procedure, training, and removal of several environmental distractions. These l are described in NRC Inspection Report 50-382/97-08.
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| I Based on the review completed by the inspectors, it was determined that the licensee had taken the appropriate actions to address this issu i
| | * Revising Maintenance procedures to include the set-up parameters for Masoneilan Sigma F safety related AOVs, including CVC-101 and CVC-103, is scheduled to be completed by December 18,1998. |
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| | Upon completion of the above actions, Waterford 3 will be in full compliance. |
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| 11. Maintenance i
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| ! M1 Conduct of Maintenance (61726,62707)
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| l The inspectors observed all or portions of the following surveillances:
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| OP-903-119 Secondary Auxiliaries Quarterly Valve Tests
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| OP-903-046 Emergency Feed Pump Operability Check
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| OP-903-068 Emergency Diesel Generator and Subgroup Relay Train B Operability Test Additionally, the inspectors observed portions of Work Authorization 01167398, which was issued to troubleshoot Control Element Assembly 14 to determine why it slipped l approximately 5 inches while moving it.
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| l l The inspectors found the conduct of these maintenance and surveillance activities to be l good. All activities observed were performed with an appropriate authorization package j or test procedure. The inspectors observed supervisors monitoring job progres M1.1 Quarterly Surveillance of Comoonent Coolino Water (CCW) Makeuo System Check l j Valves
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| ! 4 Insoection Scoce (61726) l l The inspectors observed portions of Surveillance Procedure OP-903-119, Revision 4,
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| " Secondary Auxiliaries Quarterly IST Valve Tests." The operators performed the applicable sections to leak test various CCW makeup water check valves.
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| | Attachment to r W3F1-98-0104 : |
| | Page 4 of 8 VIOLATION NO. 3806-04 Criter5n XVI of Appendix B to 10 CFR Part 50 requires, in part, that measures shall be l established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. |
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| j Observations and Findinas l
| | i Contrary to the above, from May 21,1997, to February 2,1998, the licensee failed to establish adequate measures to promptly identify and correct conditions adverse to quality in that the spent fuel pool overflow event had been attributed to a misadjusted j stop nut on a manually-operated diaphragm valve and all other similar type valves ' |
| On March 12,1998, the operators performed a quarterly leak check on two CCW makeup system check valves. The procedure required securing CCW Makeup Pump B for a portion of the test. Not only did the operators declare CCW Makeup System B out of service, but also those loads sen/ed by the system. Therefore, the cascading TS action statements for securing CCW System B, Emergency Diesel Generator B, and Essential Chiller B were entere The briefing for the evolution was thorough, covered the details of the test, expected responses, and personnel responsibilities. All appropriate personnel were present and actively involved in the briefing. The CRS made it clear to the crew that this was not an evolution to be rushed. When the operators arrived on station to perform the surveillance, they found the spent resin transfer cask being moved from the minus 35-foot level. The operators and the CRS made the conservative decision to wait for the I
| | installed in the facility were not inspected for the same deficiency. |
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| | This is a Severity Levol IV viniation (Supplement 1) (50-382/9806-04). j RESPONSE i (1) Reason for the Violation ! |
| -8-cask to be lifted from the area prior to beginning work. Their concern was leaving the i CCW makeup system in a degraded state if there were problems with lifting the cas l The inspectors observed the operators perform the surveillance. The operators properly followed the procedure, recorded all required information, and appeared knowledgeable j in their tasks. They exhibited good three-part communications between each other and )
| | The cause for this violation is misjudgment due to inadequate assumptions made regarding the cause of the diaphragm valves' deficiencies. The valves were first identified as being misadjusted following a Root Cause Analysis (RCA) |
| the control room. Peer checking was also properly used to ensure that the right i component was being operated and they used appropriate cleanliness control The inspectors noted that while the CRS was reviewing the procedure and drawings in preparation for the brief, he noted that a simple addition of a drain line installed on the nonsafety-related portion of the piping would, in the future, prevent the necessity of securing Makeup Pump B and cause entrance into cascading TS. The CRS contacted the system engineer who would look into the matter furthe Conclusions l l
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| The performance of the check valve leakage surveillance adequately tested the valve I Very good procedural compliance and questioning attitudes by all of the operations l personnel involved in the test was note M 1.2 Emeraency Feedwater (EFW) Pumo AB Surveillance Observation ' Insoection Scoce (61726)
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| On March 12,1998, the inspectors observed the EFW Pump AB surveillance. The surveillance was performed using Surveillance Procedure OP-903-046, Revision 14,
| | Investigation of an overflow of the Spent Fuel Pool. It was determined that the travel stop nuts on Fuel Pool lon Exchanger to Fuel Pool isolation Valve, FS-345, l were incorrectly positioned 1/8 inch lower than specified by the valve technical i manual. This resulted in the valve not fully blocking flow to the Spent Fuel Pool i when closed. This, in part, led to the overflow of the Spent fuel Pool. |
| " Emergency Feed Pump Operability Check." Observations and Findinos The operators performed a routine run and overspeed trip check of EFW Pump AB. The inspectors were present for the pretest briefing and for the majority of the test. The briefing was performed by a licensed operator and contained the appropriate precautions and limitations. However, the operator stated that the crew was familiar with the procedure and he would not review it step by step. One of the nonficensed operators asked several pertinent questions about the procedure. These questions, in combination with the rest of the information presented, made the briefing information complete.
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| I The inspectors observed a licensed operator starting the EFW pump from the control
| | A review of the maintenance history on the valve revealed that it was modified in I May,1992, by installation of an extension stem per Design Change DC-3211. |
| ! room. The operator exhibited good control of the evolution. The inspectors noted that the procedure was in constant use in the control room. The operators used good three-part communication among each other and with the operators in the field.
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| | This activity required the travel stops nuts to be removed. An inspection was also |
| | . performed on all of the valves that were affected by DC-3211. Within this scope, four additional valves, FS-304, CMU-513, CMU-5132 and CMU-5133, were |
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| | identif:ed with misadjustments. It was determined that the same work instructions |
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| | . used to install the extension stem on FS-345 were used for these four valves. |
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| | l Based on these findings, it was concluded that this condition was due to the activities associated with DC-3211. In hindsight, it is clear that this conclusion l was incorrect. |
| The inspectors observed the pump operate from the minus 35-foot level of the reactor auxiliary building. Besides the operators and system engineer, there were several mechanics in the area with measuring equipment. One of the operators was surprised by the number of mechanics assigned to the job since they had not been present for the briefing in the control room. The inspectors spoke to the system engineer about the mechanics. The system engineer stated that he had been working on gathering pump data for some time. The inspectors noted that the mechanics worked well together in gathering the required dat The inspectors observed the overspeed trip test of the pump. The operators then restored the pump to service. No problems were noted with this portion of the tes ;
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| Procedure adherence by the operators was good. The inspectors asked several l questions about the pump operation. The inspectors found the nonlicensed operators l knowledge level goo Conclusions The surveillance test of the EFW turbine-driven pump was very good. The operators were knowledgeable about the tes M1.3 Postmaintenance Testina of Valve CVC-103 Observations and Findinas i
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| In September 1997, SUPS SB failed as a result of an internal fault. Failure of SUPS SB resulted in a loss of power to a number of components, one of which was Valve CVC-103. All other components responded as designed without any problem Valve CVC-103 is installed in the letdown line and serves as a containment isolation valve for the line. As such, it is required to close to prevent flow from the reactor coolant system to the auxiliary building in the event of a line break outside containmen When power from SUPS SB was lost, Valve CVC-103 closed, but the valve did not fully shut, which allowed flow through the valve of approximately 25 gpm. Another valve in the letdown line was shut to stop the flo Licensee personnel made a containment entry to inspect the valve to verify there was no physical damage to the valve. After verifying no damage occurred, the licensee inspected the valve stem travel stop nut and noted that it appeared to be misadjuste The stop nut was adjusted and a subsequent leak test performed. The test results indicated no further leakage through the valv During review of this issue by the inspectors, it was noted that maintenance had been performed on Valve CVC-103, and no postmaintenance test had been performed to verify that the valve could perform its intended function of isolating letdown flow. | |
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| | l I .Since the discovery of additional similar misadjusted diaphragm valves, there is l no conclusive evidence to support whether the problems associated with the five valves, affected by DC-3211, existed prior to or after the design change. In , |
| | addition to the potential for the valves being set-up incorrectly, undetected degradation in the material condition of the valves by normal wear appears to have contributed to the degraded condition of these valves. |
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| - 10-l The failure to provide instructions to specify postmaintenance testing of Valve CVC-103 is a violation of TS 6.8.1 (50-382/9806-03). Conclusions Valve CVC-103 did not properly perform all of its design functions because testing was not performed after completion of maintenanc M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Soent Fuel Pool (SFP) Overflow Corrective Action Followuo Insoection Scooe (62702)
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| The inspectors assessed the adequacy of the licensee's corrective actions pursuant to a SFP overflow event that occurred in May 199 ' Observations and Findinas On May 21,1997, approximately 5000 gallons of radioactive water had overflowed from the SFP into the fuel handling building (FHB). The licensee had estimated that approximately 2500 gallons was contained in the FHB railroad bay and that between 230 and 1850 gallons had escaped outside the FHB through the railroad bay doors, where it had contaminated a large area of asphalt and gravel within the protected area and the storm drain system. The remainder of the spilled fluid was captured in the reactor auxiliary building sump and waste systems. Condition Report (CR) 97-1284 had been initiated and an event review team was convened on May 21 to investigate the even The event review team had concluded that the spill had been the result of a combination of tagging and communication errors, which had resulted in dead-heading of a purification pump, combined with a leaking SFP purification isolation valve. The investigation revealed that the travel stop nuts on SFP isolation Valve FS-345 (a manually-operated diaphragm valve) had been incorrectly positioned %-inch lower than required by the valve technical manual. The mispositioning occurred during a maintenance activity in May 1992, when reach rods were installed per Design Change (DC) 3211. DC 3211 had required the travel stop nuts to be removed; however, neither DC 3211 nor the associated work authorization had contained specific instructions as to the required position for the travel stop nuts upon replacement. This resulted in the valve not fully blocking flow when it indicated shut. The licensee had taken soil and liquid samples to determine if any reportable releases to the environment had occurred and concluded that 10 CFR Part 20 limits had not been exceede I l- -11-
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| | Attachment to W3F1-96-0104 Page 5 of 8 Contributing to the failure to identify the full scope of this adverse condition is a |
| ! The event review team had determined that isolation Valve FS-345 and four other diaphragm valves had extension stems installed per DC 3211, as required. These valves were checked and the travel stop nuts were adjusted. The licensee had not inspected any other diaphragm valve On February 2,1998, the inspectors performed an inspection of travel stop nuts on other diaphragm valves in the FHB and noted the following deficiencies: )
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| i l Valve Condition FS-1058 - Fuel Pool Pump B Discharge Drain No travel stop lock nut
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| l FS-210 - Refueling Canal Drain Pump Discharge Loose travel stop lock nut FS-212 - Refueling Canal Drain Pump Discharge Drain No travel stop lock nut i s FS-214 - Refueling Canal Drain Pump Discharge No travel stop lock nut l | | lack of trainings Plant personnel, including personnel from maintenance, operations and engineering, routinely walkdown plant systems.* Deficiencies with the valves were not identified during the walkdowns. The problems were l |
| isolation to Fuel Pool The inspectors notified the licensee of the above conditions. The licensee initiated i l CR 98-0146 to address the identified deficiencies. At the end of this inspection period, {
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| the licensee was in the process of inspecting approximately 800 other diaphragm valves l installed in the plant. | | apparently not detected due to a lack of understanding of the construction, operation, and maintenance of the manual diaphragm valves. |
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| | (2) Corrective Cteps That Have Been Taken and the Results Achieved - |
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| | . A walkdown of approximately fifty diaphragm valves was performed to determine the scope of the valve deficiencies. A wide range of discrepancies were noted with the manual diaphragm valves. |
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| | l e An inspection of all manual diaphragm valves immediately accessible |
| | - (approximately 400 valves) has been performed by Plant Engineering. There were no valve operability concerns identified following this inspection and the above walkdown. |
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| | . A Training Request has been issued to develop and administer a lesson plan |
| | ' for the proper construction, operation, and maintenance of manual diaphragm valves. |
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| | (3)_ Corrective Steps Which Will Be Taken to Avoid Further Violations e Based on the inspections discussed above, the population of valves to be inspected (and repaired, as necessary) has been increased to include the entire population (approximately 262 additional valves). |
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| | . Training will be provided to nuclear auxiliary operators, mechanical maintenance personnel, and system engineers with manual valves installed in |
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| l When the event team identified that the stop nut on Valve FS-345 was incorrectly installed, the team incorrectly limited the population of other potentially affected valves to l those modified per DC 3211. No effort was made by the licensee to inspect other similar ]
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| valves to determine the full scope of the stop nut misadjustment problem. As a result, full l and effective evaluation did not occur for the hardware deficiencies on the relatively large population of valve The failure to promptly identify and correct the travel stop nut deficiencies, after having i | | , |
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| | .(4) Date When Full Compliance Will Be Achieved |
| attributed the misadjustment as a contributing factor to a SFP overflow event, is a violation of Criterion XVI (50-382/9806-04).
| | . Manual diaphragm valves, with safety functions, will be inspected and-repaired by Maintenance by May 31,1999. Several of the valves require outage conditions to perform the above activity. Waterford 3's next scheduled outage is February,1999. |
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| l Conclusiong l | | l . ' All other manual diaphragm valves will be inspected and deficiencies documented in the work control system for tracking of repairs by May 13,1999. |
| The scope of the corrective actions identified after the SFP overflow event was j l
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| i inadequate because other similiar diaphragm valves were not deficiencies. This is a l violation of Criterion XV .
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| -12-111. Engl.neerina E1 Conduct of Engineering (37551)
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| E Enaineerina Evaluation of Delaved Reactor Trio Breaker (RTB) Ooenina Insoection Scoce (37551)
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| The inspectors reviewed enginecring activities associated with evaluating the delayed opening of RTB Observations and Findinas On February 8,1998, while performing Procedure OP-903-107, " Plant Protection System Functional Test," RTB 2 opened 15 seconds after the trip signal was initiated. RTB 6, which is designed to open concurrently, did respond and open immediately. RTB 2 was declared inoperable and both breakers were left in the tripped position to comply with TS 3.3.1-13, Action 5. CR 98-0182 was written to address the issue. Electrical maintenance technicians determined that the K2 relay had failed. The relay was replaced, the breakers retested satisfactorily, and the RTBs were declared operabl The K2 relay was a Potter & Brumfield MDR Model 170-1 with Date Code 9416. A generic issue related to these relays was reported in NRC Inspection Report 50-382/98-02, Section M2.1. Inspection Followup Item 50-382/9802-01 was opened to track the status of the action plan to identify, evaluate, and replace MDRs prior to failure. The inspectors determined that this relay had failed before the program had been effectively implemente The K2 MDR relay was sent to Combustion Engineering in Windsor, Connecticut, for failure analysis. The failure was determined to most likely be caused by a slight misalignment of the shaft and top end bell. This condition caused excessive wear, a buildup of wear materials, and binding of the shaft, which prevented full rotation. Glass fiber contamination was also discove ed (in the grease) and may have been a contributo A review of the relay history for the plant protective system indicated that the K2 relay had been replaced in April 1997. On that occurrence, RTB 6 had been slow to ope Failure analysis had indicated that hardened grease, mechanical binding, and grease contamination had contributed to that failure. CR 97-0787 had been initiate The inspectors questioned the engineer to determine if they had checked the other three relays in the plant protection system to identify the date codes. The response wat, that they had not checked those relays. After checking the other relays, the date codes found were: K1 - 9404; K3 - 9345; and K4 - 9416. Relay K2 had been replaced with Date Code 9730. The inspectors asked if these relays were going to be replaced because
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| l their date codes were part of those of originalindustry concem. The reply was that they would not be replaced unless they failed. The justification was that each relay was tested quarterl .i The inspectors found that the engineers had been responsive to the need for providing root cause determination. Tne technical approach and understanding of the mechanical problems were goo Conclusions .
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| Engineers had been responsive to the need for developing a technical failure mechanism for plant protective system relay ]
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| l l E5 Engineering Staff Training and Qualification
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| E5.1 Ooeration of EFW Pumo AB without Control Room Concurrence Insoection Scooe (37551)
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| The inspectors reviewed the licensee's findings and corrective actions related to this l l issu I b. Observations and Findinas l On March 5,1998, an engineer determined that he had been operating equipment in the plant without the SS or CRS knowledge or concurrence. He had been partially stroking j EFW Turbine Governor Valve MS-417 by moving the stem approximately % inch for the !
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| purpose of detecting stem binding. The engineer wrote CR 98-0333 to address the i issue, which involved operation of equipment in the plant without the consent of the l control room staf l This activity constituted a violation of Procedure OP-100-001," Duties and Responsibilities of Operators on Duty," Section 5.8.1.3, which stated, in part, that l operational activities performed locally in the plant to support overall plant operating activities must take place under the direction of or with the concurrence of the SS/CR This was a repeat of Violation 50-382/9605-02. The !!censee had taken immediate steps to stress proper conduct of any operations with plant personnel. Long-term corrective actions had not been finalized (50-382/9806-05). Conclusions ;
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| An engineer inappropriate!y operrated equipment in the plant without the SS or CRS l knowledge or concurrenc I
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| | Upon completion of the above actions, Waterford 3 will be in full compliance. |
| - 14-l E8 Miscellaneous Engineering issues (92903)
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| E8.1 (Closed) Unresolved item 50-382/9704-04: Failure to have a procedure addressing VOCs in areas serviced by engineered safety features (ESF) filtration unit NRC Inspection Report 50-382/97-04 identified two issues that remained unresolved pending additionalinput from the licensee and a response from the Office of Nuclear Reactor Regulation (NRR). The first issue identified a failure to have a procedure that specifically limited the amount of VOCs in an area that could adversely affect safety-related ventilation charcoal adsorbers. The second issue involved use of a waiting period in lieu of performing testing following painting in an area served by charcoal filters. This issue was referred to NRR for resolutio The inspectors performed a detailed review of the procedure that had been revised in response to the first issue. Procedure PMC-002-007, " Installation Procedure Maintenance and Construction Painting," limits the amount of VOCs in the areas that would affect ventilation charcoal filters. A detailed engineering review was performed to evaluate the amount of VOCs it would require in a given area to inhibit adsorption in the charcoal filter to the extent that it could not perform its safety function. Engineering Request Response ER-W3-97-0040, "VOC Limits for Insulation Cement and Painting in ESF Areas," dated April 11,1997, provided conservative calculations showing the maximum VOC loadings in critical areas. The procedure further reduces the amount of VOC allowed in any critical area to less than that shown in the engineering evaluatio The response from NRR was in a letter to Mr. Jerrold D. Dewease from Jack N. Donohew, SUBJECT: "lNTERPRETATION OF FILTRATION UNIT FREQUENCY-OF-TESTING REQUIREMENTS SPECIFIED IN THE TECHNICAL SPECIFICATIONS AND REGULATORY GUIDE 1.52 FOR ARKANSAS NUCLEAR ONE, UNITS 1 AND 2, GRAND GULF NUCLEAR STATION, UNIT 1, RIVER BEND STATION, AND WATERFORD 3 STEAM ELECTRIC STATION (TAC NOS. M98367, M98368, M98369, M98370, AND M98371)," dated September 11,1997. The oveiall conclusion of the issued response was that the licensee had the responsibility to define the criteria based on a well-documented, sound, and conservative technical basis. The letter stated that the staff considered that a painting, fire, or chemical release was not communicating with a ventilation system only if the ventilation system is not in operation and the isolation dampers for the system are closed and leaktight thereby preventing air from passing through the filter The inspectors determined that the engineering review and the procedure appropriately addressed this unresolved issue and the licensee was in full compliance with NRC regulations. This licensee-identified and corrected violation is being treated as a i noncited violation consistent with Section Vll.B.1 of the NRC Enforcement Polic Specifically, the violation was identified by the licensee, it was not willful, actions taken as a result of a previous violation should not have corrected this problem, and appropriate corrective actions were completed by the licensee (50-382/9806-06).
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| | Attachment to W3F1-98-0104 Page 6 of 8 |
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| | ' VIOLATION NO. 9806-05 Technical Specification 6.8.1.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 1, requires that the licensee have administrative procedures / written instructions. |
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| i E8.2 (Closed) LERs 50-382/97-007-00 and 50-382/97-007-01: Refueling Water Storage I
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| Pool (RWSP) Level Indication inaccuracies and Discovery of Additional Refueling Water Storage Pool Instrument Uncertainty The licensee discovered that the analytical limit for tha RWSP level instrument was exceeded due to an inadequate design of the level transmitter reference leg. The low side of each RWSP level transmitter was vented to an area filtered by the controlled l ventilation area system, whereas the high side was connected to the RWSP. Operation of the controlled ventilation area system caused indicated RWSP level to differ from actuallevelin the nonconservative direction. This would have resulted in a recirculation actuation signal being generated below the TS allowed valu ,
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| l The inspectors determined that adequate corrective actions were implemented, dunng l Refueting Outage 8, in that a design change was initiated to reroute the reference legs for the RWSP level instruments back to the RWSP. This change eliminated any i ventilation system interactions. The corrective actions are discussed in NRC Inspection l Reports 50-382/97-12 and 50-382/97-27.
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| | l Administrative Procedure OP-100-001, " Duties and Responsibilities of Operators on Duty," Revision 14, Section 5.8.1.3 specified, in part, that operational activities performed locally in the plant must take place under the direction of, or with the concurrence of, the shift superintendent or control room supentisor. |
| ! Based on reviews performed by the inspectors, it was concluded that the licensee had
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| taken the appropriate actions to address this issue.
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| | Contrary to the above, on March 5,1998, it was discovered that equipment in the 1 plant was operated without direction from the shift superintendent or control room supervisor. Specifically, on past occasions, an engineer had operated the governor valve on the emergency feedwater turbine without the direction or concurrence of the , |
| l IV. Plant Suncort
| | shift superintendent or the control room supervisor and without written procedures or l instructions. |
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| F8 Miscellaneous Fire Protection issues (92904)
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| ; F (Closed) Insoection Followuo item 50-382/9708-08: Reactor coolant pump (RCP) oil fill i administrative control There was no separate oil collection system under the remote fill lines for the RCP lube oil system. This condition did not meet 10 CFR Part 50, Appendix R, requirements. The licensee recognized that their system did not meet Appendix R requirements and submitted an exemption request (Letter W3F1-97-0021, February 10,1997). The letter addressed administrative controls that would be implemented if the licensee had to use the RCP remote lube oil fill lines. The inspectors concluded that the controls were generally adequate, except for monitoring levelin the reservoirs. The licensee did not have a formal reservoir volume versus indicated level curve for either the upper or lower RCP oil reservoir. The licensee informed the inspectors that they would generate formal curves for both the upper and lower reservoir.
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| t The inspectors verified that volume versus level curves for both the upper and lower
| | This is a Severity Level IV violation (Supplement 1, (50-382/9806-05). |
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| RCP oil reservoirs were incorporated into Volume 1 of the RCP vendor technical manua The actions taken by the licensee to address this issue were acceptabl ,
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| | RESPONSE l: |
| ' | | (1) Reason for the Violation The root cause of this violation was unclear expectations regarding manipulations of plant equipment by engineering personnel. The Waterford 3 Plant Engineering Deck Guide states that " Operations is the sole authority for control and manipulation of plant equipment." While this expectation appears |
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| | to be well understood with regard to manipulations of plant equipment involving a change in state, rendering equipment temporarily out of service and/or altering the status of equipment (such as manipulating hand wheels, manipulating control switches, and starting or stopping equipment), |
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| | expectations were not as well communicated regarding more subtle manipulations. Checking equipment vibration and temperature through contact is an accepted and expected observation; however, the extension of 4 this action to checking freedom of movement and spring engagement did not meet expectations and unacceptably encroached on the concept of manipulation of plant equipment, particularly in the absence of prior i Operations knowledge and pemiission. |
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| . | | (2) Corrective Steps That Have Been Taken and the Results Achieved |
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| | . The event was discussed on March 5,1998, by the System Engineer-Nuclear Steam Supply System (NSSS) Superintendent with the Emergency Feedwater (EFW) System Engineer. The expectations |
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| V. Manaaement Meetinas l X1 Exh Meeting Summary The inspectors presented the inspection results to members of licensee management on March 20,1998. The licensee acknowledged the findings presented.
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| : The inspectors asked the licensee whether any materials examined during the inspection 1 l should be considered proprietary. No proprietary information was identifie l
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| | Attachment to W3F1-98-0104 Page 7 of 8 regarding manipulations of plant equipment were clarified (no movement of the governor valve stem without prior Operations permission and proper documentation), reinforcing that the event did not meet the intent of expectations as established in the Plant Engineering Desk Guide and the requirements of Operations Administrative Procedure OP-100-009, |
| | " Control of Valves and Breakers" The need for proper notificc. tion of Operations, documentation of activities, avoidance of preconditioning and consideration of Technical Specification LCOs were included in the discussion. |
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| ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee F. J. Drummond, 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 G. D. Pierce, Director of Quality D. W. Vinci, Superintendent, System Engineering A. J. Wrape, Director, Design Engineering INSPECTION PROCEDURES USED IP 37551 Engineering IP 61726 Surveillance Observation IP 62702 Maintenance Program IP 71707 Plant Operations IP 92901 Followup - Operations IP 92903 Followup - Engineering IP 92904 Followup - Plant Support ITEMS OPENED. CLOSED. AND DISCUSSED Ooened 50-382/9806-01 IFl Station logkeeping procedures (Section O3.1) ,
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| 50-382/9806-02 NCV Loss of control room command function (Section 04.1)
| | This event was reviewed on March 6,1998, by the System Engineer. |
| 50-382/9806-03 VIO Postmaintenance Testing of Valve CVC-103 (Section M1.3)
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| 50-382/9806-04 VIO Corrective Actions for Diaphragm Valves (Section M2.1)
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| | NSSS Superintendent with System Engineers at the System Engineering daily meeting with emphasis on the same expectations as outlined in the item above. |
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| -2-50-382/9806-05 VIO Operation of EFW Pump AB without control room concurrence (Section E5.1) J1 50-382/9806-06 NCV Failure to have procedure addressing VOCs in areas serviced by i ESF filtration units (Section E8.1)
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| 50-382/9806-02- NCV Loss of control room command function (Section 04.1)
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| 50-382/9704-01 VIO Failure to comply with working-hour limitations for operations personnel (Section 08.1).
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| 50-382/96-011 LER Control Room Ventilation Valve Leakage (Section 08.2)
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| 50-382/97-012 LER Programmatic Breakdown of Overtime Program (Section 08.3).
| | This event was reviewed on March 6,1998, by the Plant Engineering Manager with Plant Enginesrs at the P! ant Engineering bi-weekly meeting regarding the expectations as outlined in the item above. |
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| 50-382/97-018 LER Dropped New Fuel Assembly (Section 08.4)
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| 50-382/9704-04 URI Failure to have a procedure addressing VOCs in areas serviced by ESF filtration units (Section E8.1).
| | This event was reviewed by the System Engineer-NSSS Superintendent with new engineering personnel and staff augmentation contractors regarding the same expectations as outlined in the item above. |
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| l 50-382/9806-06 NCV Failure to have a procedure addressing VOCs in areas serviced by ESF filtration units (Section E8.1).
| | . . An "on demand" repetitive task was developed and approved to be used for obtaining Operations approval and documentation prior to fu Jre partial strokes of valve MS-417. |
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| 50-382/9708-08 IFl RCP oil fill administrative controls (Section F8.1).
| | . The General Manager Plant Operatinns issued a letter to Waterford 3 personnel on March 20,1998, regarding manipulation of plant equipment. |
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| l 50-382/97-007-00 LER RWSP Level Indication inaccuracy (Section E8.2)
| | This letter re-emphasized managernent expectations and emphasized that manipulation of plant equipment may not be performed by anyone other than qualified Operations personnel unless specifically allowed for in an approved procedure / work package or unless specific permission is granted by the on-shift operating crew. |
| 50-382/97-007-01 LER RWSP Level Indication inaccuracy (Section E8.2)
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| | As a result of the above actions, the individual initially involved in this violation has stopped the undesired action. In addition, Waterford 3 management has clearly conveyed its expectation to site personnel regarding manipulation of plant equipment. |
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| LIST OF ACRONYMS USED CCW component cooling water CR condition report CFR Code of Federal Regulations CRS control room supervisor DC design change EFW emergency feedwater ESF engineered safety features FHB fuel handling building gpm gallons per minute LER licensee event report NRC Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation MDR motor-driven relay RCP reactor coolant pump RTB reactor trip breaker RWSP refueling water storage pool l
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| SFP spent fuel pool SS shift superintendent SUPS station uninterruptible power supply TS Technical Specifications i
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| VOC volatile organic compound l
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| | Page 8 of 8 (3) Corrective Steps Which Will Be Taken to Avoid Further Violations |
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| | The above corrective steps are adequate to avoid further violations of this- |
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| | ! (4) Date When Full Compliance Will Be Achieved Waterford 3 is in full compliance. |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217L0421999-10-21021 October 1999 Forwards Insp Rept 50-382/99-20 on 990815-0925 & Notice of Violation.Two Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20217N2111999-10-19019 October 1999 Forwards Insp Rept 50-382/99-14 on 990913-17 & 1004-08.No Violations Noted.Licensed Operator Requalification Program, Effective,Utilized Systems Approach to Training & Showed Continued Improvements Over Previous Insp Findings ML20217L0101999-10-18018 October 1999 Provides Update of Waterford 3 Effort for Review of Ufsar. Info Listed Includes Background Mgt Expectations,Review Status & Results,Clarifications Re Review & Conclusions ML20217L0141999-10-18018 October 1999 Submits Update to NRC Staff Re Circumstances & Plans for Submitting Certification Rept on Waterford 3 Plant Specific Simulator ML20217G7051999-10-14014 October 1999 Forwards Comments on Four of NRC RO Examination Questions for Exam Administered During Week of 991004 05000382/LER-1999-014, Forwards LER 99-014-00,providing Details of Reactor Shutdown Due to Loss of RCP Controlled bleed-off Flow.Attached Commitment Identification/Voluntary Enhancement Form Identifies All Commitments Contained in Submittal1999-10-12012 October 1999 Forwards LER 99-014-00,providing Details of Reactor Shutdown Due to Loss of RCP Controlled bleed-off Flow.Attached Commitment Identification/Voluntary Enhancement Form Identifies All Commitments Contained in Submittal ML20217D5151999-10-0707 October 1999 Forwards Application for Renewal of SRO License for C Fugate License SOP-43039-3,IAW 10CFR55.57.Without Encls ML20217C6251999-10-0505 October 1999 Informs That NRC Reviewed Util Ltr & Encl Exercise Scenario Package for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Based on Review,Nrc Determined That Exercise Appropriate to Meet Objectives ML20212J6921999-09-29029 September 1999 Forwards Insp Rept 50-382/99-18 on 990830-0902.One Noncited Violation Identified Re Failure to Follow Procedural Instructions to Ensure That Members on Fire Brigade Shift Were Qualified ML20216G2441999-09-27027 September 1999 Forwards Insp Rept 50-382/99-19 on 990830-0903.No Violations Noted 05000382/LER-1999-013, Forwards LER 99-013-00,providing Details of Exceeding TS Limits for RCS Cooldown Rates.All Commitments Contained in Submittal Are Identified on Encl Commitment Identification/ Voluntary Enhancement Form1999-09-23023 September 1999 Forwards LER 99-013-00,providing Details of Exceeding TS Limits for RCS Cooldown Rates.All Commitments Contained in Submittal Are Identified on Encl Commitment Identification/ Voluntary Enhancement Form IR 05000382/19993011999-09-21021 September 1999 Informs That NRC License Exam Previously Associated with NRC Insp Rept 50-382/99-301 Will Be Incorporated Into NRC Insp Rept 50-382/99-14 ML20212D8761999-09-16016 September 1999 Informs That on 990818,NRC Staff Completed Midcycle PPR of Waterford 3.During Assessment Period,Number of Personnel Errors Occurred,Which Demonstrated Lack of Attention to Detail by Plant Personnel.Historical Listing of Issues,Encl ML20212C2471999-09-16016 September 1999 Forwards Five Final Applications for RO Licenses for G Esquival,Jm Hearn,Md Lawson,Re Simpson & PI Wood.Written Exam & Operating Test to Be Administered,Is Requested. Encls Withheld ML20212C2391999-09-16016 September 1999 Requests Cancellation of SRO Licenses for Bn Coble,License SOP-43835,due to Job Assignment Location & CA Rodgers, License SOP-43537-1,due to Resignation from Company, Effective 990901 ML20212C5881999-09-14014 September 1999 Forwards Insp Rept 50-382/99-15 on 990719-23 with Continuing in Ofc Insp Until 0819.No Violations Noted ML20211Q4421999-09-0909 September 1999 Forwards Insp Rept 50-382/99-07 on 990601-11.Three Violations Being Treated as Noncited Violations ML20211P4121999-09-0707 September 1999 Requests NRC Staff Review & Approval of Integrated Nuclear Security Plan (Insp) & Integrated Security Training & Qualification Plan (Ist&Q), for Use by All Entergy Operations,Inc.Encl Withheld,Per 10CFR2.790(d) ML20211M8391999-09-0303 September 1999 Forwards Revised Epips,Including Rev 25 to EP-001-020,rev 24 to EP-001-030,rev 25 to EP-001-040,rev 30 to EP-002-100,rev 22 to EP-001-010,rev 27 to EP-002-010,rev 26 to EP-002-102 & Rev 16 to EP-002-190.Listed Proprietary Revs to Epips,Encl ML20211L3681999-09-0202 September 1999 Forwards Five Preliminary Applications for Reactor Operator Licenses for Individuals Listed,Iaw 10CFR55.31.Encls Withheld ML20211K9741999-09-0101 September 1999 Forwards Insp Rept 50-382/99-16 on 990704-0814.Two Severity Level IV Violations Identified & Being Treated as Noncited Violations,Consistent with App C of Enforcement Policy 05000382/LER-1999-011, Forwards LER 99-011-00,providing Details of Reactor Shutdown Due to Loss of Controlled bleed-off Flow.All Commitments Contained in Submittal Identified on Attached Commitment Identification/Voluntary Enhancement Form1999-08-31031 August 1999 Forwards LER 99-011-00,providing Details of Reactor Shutdown Due to Loss of Controlled bleed-off Flow.All Commitments Contained in Submittal Identified on Attached Commitment Identification/Voluntary Enhancement Form ML20211M3641999-08-30030 August 1999 Forwards Written Examination,Operating Tests & Supporting Ref Matl Identified in Attachment 2 of ES-210,in Response to NRC .Encl Withheld ML20211G5751999-08-27027 August 1999 Forwards RAI Re IPEEE Submittal.Please Provide RAI within 60 Days of Receipt of Ltr,Per Util Response to GL 88-20,suppl 4 ML20211E3281999-08-26026 August 1999 Forwards fitness-for-duty Performance Data for Period of 990101-0630,IAW 10CFR26.71(d).Ltr Does Not Contain Commitments 05000382/LER-1999-009, Forwards LER 99-009-00 Re Discovery of Condition of Noncompliance with App R Involving Inadequate Separation of Essential Cables Routed in Fire Area RAB-30 in Rab. Compensatory Measures Were Established Immediately1999-08-26026 August 1999 Forwards LER 99-009-00 Re Discovery of Condition of Noncompliance with App R Involving Inadequate Separation of Essential Cables Routed in Fire Area RAB-30 in Rab. Compensatory Measures Were Established Immediately 05000382/LER-1999-010, Forwards LER 99-010-00,providing Details of Inadequate Pumping Capacity in Dry Cooling Tower Area.All Commitments Contained in Submittal Are Identified on Attached Commitment Identification Voluntary Enhancement Form1999-08-26026 August 1999 Forwards LER 99-010-00,providing Details of Inadequate Pumping Capacity in Dry Cooling Tower Area.All Commitments Contained in Submittal Are Identified on Attached Commitment Identification Voluntary Enhancement Form ML20211F5421999-08-24024 August 1999 Forwards Proposed marked-up TS Page Xviii, Index Administrative Controls, Correcting Page Number Re TS Change Request NPF-38-220.Editorial Changes for TS Change NPF-38-221 Discussed ML20211F3561999-08-24024 August 1999 Forwards CTS Pages & TS Proposed marked-up Pages for Insertion Into TS Change Request NPF-38-207 Re Efas, Originally Submitted on 980702.Original NSHC Determination Continues to Be Applicable ML20211F4611999-08-24024 August 1999 Informs That NRC Reviewed Ltr & Encl Objectives for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Exercise Objectives Appropriate to Meet Emergency Plan Requirements ML20211G1731999-08-23023 August 1999 Informs That Info Submitted in ,B&W Rept 51-1234900-00,will Be Withheld from Public Disclosure,Per 10CFR2.790 ML20211C5101999-08-19019 August 1999 Forwards Certified Copies of Liability Insurance Policy Endorsements Issued in First Half of 1999 for Each Entergy Operations,Inc Nuclear Unit,Per 10CFR140.15 ML20210T9791999-08-18018 August 1999 Discusses Which Responded to Reconsideration of Violation Denial (EA 98-022) Enforcement Action Detailed in .Concludes That Violation Occurred as Stated ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210S0561999-08-12012 August 1999 Submits Voluntary Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for NRC Fys 2000 & 2001 for Waterford 3 ML20210Q6161999-08-12012 August 1999 Forwards Corrected Copy of Monthly Operating Rept for July 1999 for Waterford 3.Original Rept,Submitted with ,Contained Typos ML20217F2661999-08-12012 August 1999 Forwards Copy of 1999 Waterford 3 Biennial Exercise Package to Be Performed Using Waterford 3 CR Simulator ML20210R9231999-08-11011 August 1999 Forwards Insp Rept 50-382/99-10 on 990719-23.Violations Noted.Nrc Has Determined That One Severity Level IV Violation of NRC Requirements Occurred ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams 05000382/LER-1999-008, Forwards LER 99-008-00,re Failure to Perform Testing of ESF Filtration Units Per TS Srs.Commitments Made by Util Also Encl1999-07-29029 July 1999 Forwards LER 99-008-00,re Failure to Perform Testing of ESF Filtration Units Per TS Srs.Commitments Made by Util Also Encl ML20210H4291999-07-29029 July 1999 Forwards Response to NRC Rai,Associated with TS Change Request NPF-38-208,proposing to Replace Ref to Supplement 1 with Ref to Supplement 2 of Calculative Methods for CE Small Break LOCA Evaluation Model, in ACs Section of TSs ML20210F9451999-07-27027 July 1999 Forwards Proprietary & non-proprietary Version of Rev 29 to EPIP EP-002-100, Technical Support Ctr Activation,Operation & Deactivation. Proprietary Info Withheld,Per 10CFR2.790 ML20210D3171999-07-23023 July 1999 Submits Proposal for Final Resolution of Reracking Spent Fuel Pool at Plant,Per License Amend 144,issued by NRC in .No New Commitments Are Contained in Ltr 05000382/LER-1999-007, Forwards LER 99-007-00,providing Details of Operation Outside Tornado Missile Protection Licensing Basis for turbine-driven Emergency Feedwater Pump Exhaust Stack & Steam Supply Piping.All Commitments Identified on Attached1999-07-23023 July 1999 Forwards LER 99-007-00,providing Details of Operation Outside Tornado Missile Protection Licensing Basis for turbine-driven Emergency Feedwater Pump Exhaust Stack & Steam Supply Piping.All Commitments Identified on Attached ML20210D8701999-07-23023 July 1999 Forwards Safety Evaluation Re First 10-yr Interval Inservice Insp Plan Requests for Relief ISI-018 Through ISI-020 for Entergy Operations,Inc,Unit 3 ML20210B1521999-07-15015 July 1999 Forwards Insp Rept 50-382/99-13 on 990523-0703.Three Violations Being Treated as Noncited Violations ML20209G9771999-07-13013 July 1999 Forwards Objectives & Guidelines for Waterford 3 Emergency Preparedness Exercise Scheduled for 991013.List of Objectives cross-referenced Where Applicable to Relevant Sections of NUREG-0654 IR 05000382/19990081999-07-12012 July 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/99-08 Issued on 990503 ML20209E5231999-07-0909 July 1999 Informs That as Result of NRC Review of Util Responses to GL-92-01,rev 1 & Suppl 1,staff Revised Info in Reactor Vessel Integrity Database & Releasing Database as Rvid Version 2.This Closes Staff Efforts Re TAC MA0583 ML20209D4051999-07-0707 July 1999 Forwards Revised TS Pages to Replace Attachment C,Entirely in Original TS Change Request NPF-38-207,per 990519 Discussion with C Patel of Nrc.Changes to Action 20 Delete Word Requirement & Revise Word Modes to Mode 1999-09-09
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20217L0421999-10-21021 October 1999 Forwards Insp Rept 50-382/99-20 on 990815-0925 & Notice of Violation.Two Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20217N2111999-10-19019 October 1999 Forwards Insp Rept 50-382/99-14 on 990913-17 & 1004-08.No Violations Noted.Licensed Operator Requalification Program, Effective,Utilized Systems Approach to Training & Showed Continued Improvements Over Previous Insp Findings ML20217C6251999-10-0505 October 1999 Informs That NRC Reviewed Util Ltr & Encl Exercise Scenario Package for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Based on Review,Nrc Determined That Exercise Appropriate to Meet Objectives ML20212J6921999-09-29029 September 1999 Forwards Insp Rept 50-382/99-18 on 990830-0902.One Noncited Violation Identified Re Failure to Follow Procedural Instructions to Ensure That Members on Fire Brigade Shift Were Qualified ML20216G2441999-09-27027 September 1999 Forwards Insp Rept 50-382/99-19 on 990830-0903.No Violations Noted IR 05000382/19993011999-09-21021 September 1999 Informs That NRC License Exam Previously Associated with NRC Insp Rept 50-382/99-301 Will Be Incorporated Into NRC Insp Rept 50-382/99-14 ML20212D8761999-09-16016 September 1999 Informs That on 990818,NRC Staff Completed Midcycle PPR of Waterford 3.During Assessment Period,Number of Personnel Errors Occurred,Which Demonstrated Lack of Attention to Detail by Plant Personnel.Historical Listing of Issues,Encl ML20212C5881999-09-14014 September 1999 Forwards Insp Rept 50-382/99-15 on 990719-23 with Continuing in Ofc Insp Until 0819.No Violations Noted ML20211Q4421999-09-0909 September 1999 Forwards Insp Rept 50-382/99-07 on 990601-11.Three Violations Being Treated as Noncited Violations ML20211K9741999-09-0101 September 1999 Forwards Insp Rept 50-382/99-16 on 990704-0814.Two Severity Level IV Violations Identified & Being Treated as Noncited Violations,Consistent with App C of Enforcement Policy ML20211G5751999-08-27027 August 1999 Forwards RAI Re IPEEE Submittal.Please Provide RAI within 60 Days of Receipt of Ltr,Per Util Response to GL 88-20,suppl 4 ML20211F4611999-08-24024 August 1999 Informs That NRC Reviewed Ltr & Encl Objectives for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Exercise Objectives Appropriate to Meet Emergency Plan Requirements ML20211G1731999-08-23023 August 1999 Informs That Info Submitted in ,B&W Rept 51-1234900-00,will Be Withheld from Public Disclosure,Per 10CFR2.790 ML20210T9791999-08-18018 August 1999 Discusses Which Responded to Reconsideration of Violation Denial (EA 98-022) Enforcement Action Detailed in .Concludes That Violation Occurred as Stated ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210R9231999-08-11011 August 1999 Forwards Insp Rept 50-382/99-10 on 990719-23.Violations Noted.Nrc Has Determined That One Severity Level IV Violation of NRC Requirements Occurred ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20210D8701999-07-23023 July 1999 Forwards Safety Evaluation Re First 10-yr Interval Inservice Insp Plan Requests for Relief ISI-018 Through ISI-020 for Entergy Operations,Inc,Unit 3 ML20210B1521999-07-15015 July 1999 Forwards Insp Rept 50-382/99-13 on 990523-0703.Three Violations Being Treated as Noncited Violations IR 05000382/19990081999-07-12012 July 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/99-08 Issued on 990503 ML20209E5231999-07-0909 July 1999 Informs That as Result of NRC Review of Util Responses to GL-92-01,rev 1 & Suppl 1,staff Revised Info in Reactor Vessel Integrity Database & Releasing Database as Rvid Version 2.This Closes Staff Efforts Re TAC MA0583 ML20196E6931999-06-22022 June 1999 Forwards Corrected Ltr Re Changes to Rev 19 to Emergency Plan.Original Ltr Had Error in Subject Line ML20196E0831999-06-21021 June 1999 Forwards Insp Rept 50-382/99-12 on 990524-27.No Violations Noted.Purpose of Insp Was to Conduct Assessment of Emergency Preparedness Program ML20196D9941999-06-18018 June 1999 Forwards Insp Rept 50-382/99-11 on 990524-28.No Violations Noted ML20195J8091999-06-17017 June 1999 Forwards Safety Evaulation Re First 10-yr Interval Inservice Insp Relief Request for Plant,Unit 3 ML20196C8711999-06-15015 June 1999 Discusses Insp Rept 50-382/99-08 & Forwards Notice of Violation Re Unescorted Access Which Was Mistakenly Granted to Individual Whose Background Investigation Indicated That He Had Failed Prior Drug Screening with Another Employer ML20196F3721999-06-0909 June 1999 Corrected Ltr Forwarding Rev 19 to Emergency Plan ML20195G3711999-06-0909 June 1999 Ack Receipt of Ltr Dtd 981223,which Transmitted Waterford 3 Steam Electric Station Emergency Plan,Rev 24,under Provisions of 10CFR50,App E,Section V.No Violations of 10CFR50.54(q) Identified During Review ML20207E8541999-06-0303 June 1999 Forwards SE Accepting Licensee 990114 Submittal of one-time Request for Relief from ASME B&PV Code IST Requirements for Pressurizer Safety Valves at Plant,Unit 3 ML20207G3441999-06-0303 June 1999 Forwards Insp Rept 50-382/99-09 on 990411-0522 & Notice of Violation.One Violation Identified & Being Treated as Noncited Violation C ML20207D3771999-05-27027 May 1999 Ack Receipt of 990401 & 0504 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/99-01 on 990303 ML20207A5121999-05-24024 May 1999 Refers to Which Responded to NOV & Proposed Imposition of Civil Penalty Sent by .Violations A,B & E Withdrawn & Violations C & D Changed to Severity Level IV ML20206U7851999-05-18018 May 1999 Forwards Insp Rept 50-382/99-06 on 990405-09.Three Violations of NRC Requirements Occurred & Being Treated as non-cited Violations ML20206N6961999-05-11011 May 1999 Informs That NRC Office of Nuclear Reactor Regulation Reorganized Effective 990328.As Part of Reorganization, Division of Licensing Project Management Created ML20206S4411999-05-10010 May 1999 Forwards Insp Rept 50-382/99-05 on 990228-0410.Three Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20206H3841999-05-0707 May 1999 Informs That on 990407,NRC Administered Generic Fundamental Exam Section of Written Operator Licensing Exam.Licensee Facility Did Not Participate in Exam,However Copy of Master Exam,With Answer Key,Encl for Info.Without Encl ML20206K0951999-05-0606 May 1999 Discusses Insp Rept 50-382/99-08 Issued 990503 Without Cover Ltr Documenting EA Number & Subject Line Indicated NOV Which Was Incorrect.Corrected Cover Ltr Encl ML20206F4701999-05-0303 May 1999 Forwards Insp Rept 50-382/99-08 on 990405-07.One Apparent Violation Re Failure to Review & Consider Derogatory Access Authorization Background Info as Required by PSP Identified & Being Considered for Escalated Enforcement Action ML20206K1211999-05-0303 May 1999 Corrected Cover Ltr Forwarding Insp Rept 50-382/99-08 on 990405-07.One Violations Noted & Being Considered for Escalated EA ML20205N7251999-04-13013 April 1999 Forwards Summary of 990408 Meeting with EOI in Jackson, Mississippi Re EOI Annual Performance Assessment of Facilities & Other Issues of Mutual Interest.List of Meeting Attendees & Licensee Presentation Slides Encl ML20205M0561999-04-0909 April 1999 Forwards Insp Rept 50-382/99-04 on 990301-19.One Violation of NRC Requirements Occurred & Being Treated as Noncited Violation,Consistent with App C of Enforcement Policy ML20205J8781999-04-0505 April 1999 Forwards Insp Rept 50-382/99-02 on 990117-0227.No Violations Noted.Inspectors Determined That Six Violations Occurred & Being Treated as Noncited Violations Consistent with App C of Enforcement Policy ML20205J0901999-04-0202 April 1999 Informs That Info Submitted by & 970313 Affidavit Will Be Withheld from Public Disclosure,Per 10CFR2.790(b) (5) ML20205A4681999-03-26026 March 1999 Forwards Insp Rept 50-382/99-03 on 990308-12.Two Violations of Radiation Protection Requirements Occurred & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20205A6141999-03-25025 March 1999 Forwards SE Accepting Request to Use Mechanical Nozzle Seal Assemblies (Mnsas) as an Alternative Repair Method,Per 10CFR50.55a(a)(3)(i) for Reactor Coolant Sys Application at Plant,Unit 3 ML20205F3311999-03-19019 March 1999 Advises of Planned Insp Effort Resulting from Plant,Unit 3 PPR Review,Which Was Completed on 990211.Performance at Plant,Unit 3 Was Acceptable ML20204E4941999-03-17017 March 1999 Discusses TSs Bases Change Re 3/4.4.1,3/4.6.1.7,3/4.6.3, 3/4.7.12 & 3/4.8.4.Forwards Affected Bases Pp B 3/4 4-1, B 3/4 6-3,B 3/4 6-4,B 3/4 7-7 & B 3/4 8-3 ML20207F1251999-03-0303 March 1999 Forwards Insp Rept 50-382/99-01 on 990125-29 & 0208-12 & Notice of Violations ML20203H8501999-02-17017 February 1999 Forwards SE Accepting Licensee 970701 Submittal of Second Ten Year ISI Program & Associated Relief Request for Plant, Unit 3.Nine Relief Requests Had Been Authorized Previously & Proposed Alternatives Remain Authorized ML20203D7211999-02-11011 February 1999 Forwards Request for Addl Info Re Licensee 970317 & 990111 Responses to GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves. Response Should Be Provided within 60 Days 1999-09-09
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l 0 4 "C%, UNITED STATES 1 of t- NUCLEAR REGULATORY COMMISSION y n
{, ,c REClON IV
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S cf 611 RYAN PLAZA DRIVE, SulTE 400 *
i n...../ AR LINGTON, T EXAS 76011-8064 l JUL - l 1998 Charles M. Dugger, Vice President Operations - Waterford 3 Entergy Operations, Inc.
- P.O. Box B Killona, Louisiana 70066 SUBJECT: NRC INSPECTION REPORT 50-382/98-06
Dear Mr. Dugger:
Thank you for your letter of June 15,1998, in response to our April 21,1998, !etter and Notice of Violation concerning the failure to test a containment isolation valve (CVC-103) after l performing maintenance to ensure that the valve could still perform its intended safety function, the failure to perform comprehensive corrective actions following overflow of the spent fuel pool, and an involvement by an engineer who performed an operational activity without the direction or concurrence of control room personnel. 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. ,
Sinc re ,
Ph lip H. Harrell, Chief Pro ct Branch D
. Divi ~on of Reactor Projects l
Docket No.: 50-382 License No.: NPF-38 9007090213 990701 PDR ADOCK 05000382 G PDR
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Entergy Operations, Inc. -2-
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Executive Vice President and
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. 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
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General Manager, Plant Operations
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Waterford 3 SES
. Entergy Operations, Inc.
~ P.O. Box B Killona, Louisiana 70066 I
Manager- Licensing Manager
. Waterford 3 SES Entergy Operations, Inc
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P.O. Box B -
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Killona, Louisiana '70066 Chairman Louisiana Public Service Commission One American Place, Suite 1630 )
. Baton Rouge, Louisiana .70825-1697 I Director, Nuclear Safety &
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' Regulatory Affairs L
Waterford 3 SES '1 Entergy Operations, Inc.
P.O. Box B l. Killona, Louisiana 70066 William H. Spell, Administrator
. Louisiana Radiation Protection Division
.P.O. Box 82135 Baton Rouge,' Louisiana 70884-2135
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Parish President .
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'St. Charles Parish P.O. Box 302 Hahnville,. Louisiana '70057 -
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Mr. William A. Cross
' Bethesda Licensing Office'
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' 3 Metro Center ,
- Suite 610 Bethesda, Maryland 20814 i Winston & Strawn -
. 1400 L Street, N.W.
- Washington, D.C.'. 20005-3502 I
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-Regional Administrator Resident inspector. f
- DRP Director DRS-PSB Branch Chief (DRP/D) MIS System Project Engineer (DRP/D) RIV File Branch Chief (DRP/TSS)
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DOCUMENT NAME: R:\_WAT\WAT806AK.JMK .
j. To receive copy of document, Indicatejn box:"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy
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Entergy Operations, Inc.
A.mona LA 70066 Te6 504 739 6242 Early C. Ewing, Ill eI Sa'ety & RegWtory A%s hWerford 3 W3F1-98-0104 A4.05 PR i
June 12,1998 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
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Subject: Waterford 3 SES j;3
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Docket No. 50-382 l
License No. NPF-38 NRC Inspection Report 98-06 Reply to Notice of Violation Gentlemen:
In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in Attachment 1 the response to the violations identified in Enclosure 1 of the subject Inspection Report. On May 20,1998, an extension of the original 30-day response date until June 12,1998, was granted to Waterford 3 by Mr. G. Pick, NRC Region IV.
If you have any questions concerning this response, please contact me at (504) 739-6242 or Tim Gaudet at (504) 739-6666.
Very truly yours,
'G w
E.C. Ewing Director, Nuclear Safety & Regulatory Affairs
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ECE/ ELL /GCS/ssf Attachment cc: E.W. Merschoff (NRC Region IV), C.P. Patel (NRC-NRR), J. Smith, N.S. Reynolds, NRC Resident inspectors Office
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Attachment to W3F1-98-0104 Page 1 of 8 ATTACHMENT 1
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l - ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN
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ENCLOSURE 1 OF INSPECTION REPORT 98-06 VIOLATION NO. 9806-03
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Technical Specification 6.8.1.a requires, in part, that written procedures shall be i
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established covering the applicable procedures recommended in Appendix A of
. Regulatory Guide 1.33, Revision 2, February 1978. Appendix A, Section 9, requires that .!
the licensee have maintenance procedures.
Contrary to the above, the licensee failed to establish a maintenance procedure that !
provided instructions for testing of a containment isolation valve following comp!etion of !
maintenance on Valve CVC-103. !
This is a Severity Level IV violation (Supplement I) (50-382/9806-03)
RESPONSE (1) Reason for the Violation
The root cause for this violation is inadequate procedural guidance in regard to setup of valve CVC-103 following maintenance activities. CVC-103 is a fail closed, letdown and containment isolation valve with a Masoneilan Sigma F operator. During Refuel 8, maintenance was performed on the valve operator.
Maintenance procedure MM-006-002, Valve Operator Maintenance, provided instructions for post maintenance testing. However, the procedure states that either it can be used as guidance for maintenance and post maintenance testing or the valve vendor manual can be used. This choice is at the discretion of the maintenance planner and/or the field mechanic. Procedure MM-006-002 delineates steps for performing post maintenance testing, including instructions for valve stroke length testing. However the valve vendor manual, which was used to perform maintenance on valve CVC-103, did not include directions for checking the valve stroke length. As a result, adequate valve post maintenance testing was not performed. The lack of post maintenance verification led to the failure to detect the incorrect stroke length of the valve.
This adverse condition was revealed on September 7,1997, following refuel 8, when power was lost to CVC-103 due to a Static Uninteruptible Power Supply
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failure. Upon loss of power, the valve went to its closed position. However, L approximately 23 gpm of letdown flow was observed through the valve with th'e valve indicating closed. The valve stroke length was found to be inadequately
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adjusted which led to the excessive leakage.
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Attachment to W3F1-98-0104 Page 2 of 8 Contributing to this condition were inconsistencies between the valve l manufacturer's data and existing plant data regarding the required stroke length for CVC-103. According to the manufacturer, the required stroke length for CVC-103 is 1.2" However, the plant's calibration sheet for CVC-103 stated that the valve's stroke length was 1.25" +/- 1/4" and the plant's Station Information Management System (SIMS) stated that the stroke length was 2.625" The valve j vendor manual gives three stroke lengths the valve is capable of, but does not
specify which stroke length is appropriate for CVC-103. The inconsistencies in these documents may have contributed to the stroke length being improperly set, j as revealed in the September 7,1997 event.
I Not all the safety functions of CVC _103 were identified and documented, further l contributing to the violation. The Letdown isolation function of CVC-103 was not l clearly identified and no impact on the IST program was documented. 1 (2) Corrective Steps That Have Been Taken and the Results Achieved
. An Engineering Evaluation was performed on September 8,1997, to confirm operability of CVC-103. The evaluation concluded that CVC-103 was capable of performing both its containment and letdown isolation functions.
This was based on an engineering evaluation that concluded the following: )
l 1. Based on the valve materials of construction, the valve plug / seat is not expected to degrade for the duration of a letdown line break event.
2. Based on recent CVC-103 valve rework and LLRT, CVC-103 would perform its containment isolation safety function.
3. An evaluation was performed by Safety and Engineering Analysis which determined the consequences of the leakage through CVC-103 is within 10CFR100 limits.
4. The additional water released to the RAB due to CVC-103 leakage does not represent a flooding concern because of available drain
- paths, the large floor area, and the absence of safety-related equipment in communicating compartments. Also, the high energy flooding in the RAB is enveloped by existing moderate energy flooding analysis.
. Design Engineering performed a preliminary review of primary and secondary system air operated valves that may impact offsite dose if the operators were setup improperly for dual safety functions. No concerns l were identified.
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Attachment to W3F1-98-0104 Page 3 of 8
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Containment was entered on September 11,1997, to adjust / lengthen the valve / actuator stem coupling. After the adjustment was made, CVC-103 was closed and no leakage was indicated.
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The Masoneilan technical manual for valve CVC-103 and similar valves was revised to require stroke length measurement upon reassembly. In addition, the appropriate stroke lengths for the safety related valves were added to the manual.
(3) Corrective Steps Which Will Be Taken to Avoid Further Violations l
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A review of active safety related air-operated valves (AOVs), including CVC-101 and CVC-103, will be performed; necessary Design Basis Documents will be revised if closed safety functions at Normal Operating Pressure exist ;
but are not identified; and, if an unidentified safety function is discovered, an eveluation will be performed to determine its impact on the IST Program.
. The proper set-up parameters for the Masoneilan Sigma F safety related AOVs, including CVC-101 and CVC-103, will be established and transmitted to Maintenance for procedure incorporation.
. Maintenance procedures will be revised to include the set-up parameters.
The actions taken, as described above, will bring Waterford 3 into full compliance and will resolve the issue with those valves found to be sensitive to valve adjustments.
(4) Date When Full Compliance Will Be Achieved
. The review of safety related AOVs and subsequent actions are scheduled to be completed by March 31,1999.
- Revising Maintenance procedures to include the set-up parameters for Masoneilan Sigma F safety related AOVs, including CVC-101 and CVC-103, is scheduled to be completed by December 18,1998.
Upon completion of the above actions, Waterford 3 will be in full compliance.
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Attachment to r W3F1-98-0104 :
Page 4 of 8 VIOLATION NO. 3806-04 Criter5n XVI of Appendix B to 10 CFR Part 50 requires, in part, that measures shall be l established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
i Contrary to the above, from May 21,1997, to February 2,1998, the licensee failed to establish adequate measures to promptly identify and correct conditions adverse to quality in that the spent fuel pool overflow event had been attributed to a misadjusted j stop nut on a manually-operated diaphragm valve and all other similar type valves '
installed in the facility were not inspected for the same deficiency.
This is a Severity Levol IV viniation (Supplement 1) (50-382/9806-04). j RESPONSE i (1) Reason for the Violation !
The cause for this violation is misjudgment due to inadequate assumptions made regarding the cause of the diaphragm valves' deficiencies. The valves were first identified as being misadjusted following a Root Cause Analysis (RCA)
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Investigation of an overflow of the Spent Fuel Pool. It was determined that the travel stop nuts on Fuel Pool lon Exchanger to Fuel Pool isolation Valve, FS-345, l were incorrectly positioned 1/8 inch lower than specified by the valve technical i manual. This resulted in the valve not fully blocking flow to the Spent Fuel Pool i when closed. This, in part, led to the overflow of the Spent fuel Pool.
A review of the maintenance history on the valve revealed that it was modified in I May,1992, by installation of an extension stem per Design Change DC-3211.
This activity required the travel stops nuts to be removed. An inspection was also
. performed on all of the valves that were affected by DC-3211. Within this scope, four additional valves, FS-304, CMU-513, CMU-5132 and CMU-5133, were
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identif:ed with misadjustments. It was determined that the same work instructions
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. used to install the extension stem on FS-345 were used for these four valves.
l Based on these findings, it was concluded that this condition was due to the activities associated with DC-3211. In hindsight, it is clear that this conclusion l was incorrect.
l I .Since the discovery of additional similar misadjusted diaphragm valves, there is l no conclusive evidence to support whether the problems associated with the five valves, affected by DC-3211, existed prior to or after the design change. In ,
addition to the potential for the valves being set-up incorrectly, undetected degradation in the material condition of the valves by normal wear appears to have contributed to the degraded condition of these valves.
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Attachment to W3F1-96-0104 Page 5 of 8 Contributing to the failure to identify the full scope of this adverse condition is a
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lack of trainings Plant personnel, including personnel from maintenance, operations and engineering, routinely walkdown plant systems.* Deficiencies with the valves were not identified during the walkdowns. The problems were l
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apparently not detected due to a lack of understanding of the construction, operation, and maintenance of the manual diaphragm valves.
(2) Corrective Cteps That Have Been Taken and the Results Achieved -
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. A walkdown of approximately fifty diaphragm valves was performed to determine the scope of the valve deficiencies. A wide range of discrepancies were noted with the manual diaphragm valves.
l e An inspection of all manual diaphragm valves immediately accessible
- (approximately 400 valves) has been performed by Plant Engineering. There were no valve operability concerns identified following this inspection and the above walkdown.
. A Training Request has been issued to develop and administer a lesson plan
' for the proper construction, operation, and maintenance of manual diaphragm valves.
(3)_ Corrective Steps Which Will Be Taken to Avoid Further Violations e Based on the inspections discussed above, the population of valves to be inspected (and repaired, as necessary) has been increased to include the entire population (approximately 262 additional valves).
. Training will be provided to nuclear auxiliary operators, mechanical maintenance personnel, and system engineers with manual valves installed in
~t heir system.
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.(4) Date When Full Compliance Will Be Achieved
. Manual diaphragm valves, with safety functions, will be inspected and-repaired by Maintenance by May 31,1999. Several of the valves require outage conditions to perform the above activity. Waterford 3's next scheduled outage is February,1999.
l . ' All other manual diaphragm valves will be inspected and deficiencies documented in the work control system for tracking of repairs by May 13,1999.
. Training will be provided to nuclear auxiliary operators, mechanical maintenance personnel, and system engineers with manual valves installed in
- their system by December 18.1998.
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Upon completion of the above actions, Waterford 3 will be in full compliance.
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Attachment to W3F1-98-0104 Page 6 of 8
' VIOLATION NO. 9806-05 Technical Specification 6.8.1.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 1, requires that the licensee have administrative procedures / written instructions.
l Administrative Procedure OP-100-001, " Duties and Responsibilities of Operators on Duty," Revision 14, Section 5.8.1.3 specified, in part, that operational activities performed locally in the plant must take place under the direction of, or with the concurrence of, the shift superintendent or control room supentisor.
Contrary to the above, on March 5,1998, it was discovered that equipment in the 1 plant was operated without direction from the shift superintendent or control room supervisor. Specifically, on past occasions, an engineer had operated the governor valve on the emergency feedwater turbine without the direction or concurrence of the ,
shift superintendent or the control room supervisor and without written procedures or l instructions.
This is a Severity Level IV violation (Supplement 1, (50-382/9806-05).
RESPONSE l:
(1) Reason for the Violation The root cause of this violation was unclear expectations regarding manipulations of plant equipment by engineering personnel. The Waterford 3 Plant Engineering Deck Guide states that " Operations is the sole authority for control and manipulation of plant equipment." While this expectation appears
to be well understood with regard to manipulations of plant equipment involving a change in state, rendering equipment temporarily out of service and/or altering the status of equipment (such as manipulating hand wheels, manipulating control switches, and starting or stopping equipment),
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expectations were not as well communicated regarding more subtle manipulations. Checking equipment vibration and temperature through contact is an accepted and expected observation; however, the extension of 4 this action to checking freedom of movement and spring engagement did not meet expectations and unacceptably encroached on the concept of manipulation of plant equipment, particularly in the absence of prior i Operations knowledge and pemiission.
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(2) Corrective Steps That Have Been Taken and the Results Achieved
. The event was discussed on March 5,1998, by the System Engineer-Nuclear Steam Supply System (NSSS) Superintendent with the Emergency Feedwater (EFW) System Engineer. The expectations
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Attachment to W3F1-98-0104 Page 7 of 8 regarding manipulations of plant equipment were clarified (no movement of the governor valve stem without prior Operations permission and proper documentation), reinforcing that the event did not meet the intent of expectations as established in the Plant Engineering Desk Guide and the requirements of Operations Administrative Procedure OP-100-009,
" Control of Valves and Breakers" The need for proper notificc. tion of Operations, documentation of activities, avoidance of preconditioning and consideration of Technical Specification LCOs were included in the discussion.
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This event was reviewed on March 6,1998, by the System Engineer.
NSSS Superintendent with System Engineers at the System Engineering daily meeting with emphasis on the same expectations as outlined in the item above.
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This event was reviewed on March 6,1998, by the Plant Engineering Manager with Plant Enginesrs at the P! ant Engineering bi-weekly meeting regarding the expectations as outlined in the item above.
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This event was reviewed by the System Engineer-NSSS Superintendent with new engineering personnel and staff augmentation contractors regarding the same expectations as outlined in the item above.
. . An "on demand" repetitive task was developed and approved to be used for obtaining Operations approval and documentation prior to fu Jre partial strokes of valve MS-417.
. The General Manager Plant Operatinns issued a letter to Waterford 3 personnel on March 20,1998, regarding manipulation of plant equipment.
This letter re-emphasized managernent expectations and emphasized that manipulation of plant equipment may not be performed by anyone other than qualified Operations personnel unless specifically allowed for in an approved procedure / work package or unless specific permission is granted by the on-shift operating crew.
As a result of the above actions, the individual initially involved in this violation has stopped the undesired action. In addition, Waterford 3 management has clearly conveyed its expectation to site personnel regarding manipulation of plant equipment.
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Page 8 of 8 (3) Corrective Steps Which Will Be Taken to Avoid Further Violations
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The above corrective steps are adequate to avoid further violations of this-
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! (4) Date When Full Compliance Will Be Achieved Waterford 3 is in full compliance.
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