ML20199L285

Notice of Violation from Insp on 971215.Violation Noted:On 971110,two Independent Trains of Auxiliary Component Cooling Water Were Not Maintained Operable in Mode 1

ML20199L285
Person / Time
Site:	Waterford
Issue date:	02/05/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20199L269	List: ML20199L262 ML20199L285
References
50-382-97-26, NUDOCS 9802090168
Download: ML20199L285 (4)

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i NOTICE OF VIOLATION Entergy Operations, Inc. Docket No. 50-382 Waterford Steam Electric Station, Unit 3 License No. NPF-36 EA 97-589 During an NRC inspection completed December 15,1997, violations of NRC requirements were identified in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below; A. Technical Specification 3.7.3 states that at least two independent trains of auxiliary component cooling water shall be operable while in Modes 1,2, 3, and 4.

Contrary to the above, on November 10,1997, two independent trains of auxiliary component cooling water were not maintained operable in Mode 1. Specifically, both trains of the auxiliary component cooling water were inoperable for approximately 7.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> with the riant in Mode 1. (01013)

B. Technical Specification 6.8.1.a states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33," Quality Assurance Program Requirements (Operations)," Revision 2, February 1978. Regulatory Guide 1.33, Item 1.b requires that administrative procedures be established for safe operation and shutdown of the facility.

Procedure OP-100-001, " Duties and Responsibilities of Operators on Duty," Revision 12, described the responsibilities for the control room supervisor and the nuclear plant operators related to personnel conduct and control of operating activities. These responsibilities are described, in part, by the following steps in this procedure:

Step 4.4.5: Nuclear plant opersars will" Continuously monitor performance of plant control systems and Contro, Room instrumentation to verify operability."

Step 5.4.1.1: "On-duty operators shall be attentive to all status indicators and plant parameters and investigate abnormal conditions or trends."

Step 5.4.1.2: "On-duty Operators must make every effort to keep themselves aware of the status of safety systems and major power generating components."

Contrary to the above, on November 9-10,1997, the control room supervisor, primary nuclear plant operator, and secondary nuclear plant operator failed to continuously monitor performance of Control Room instrumentation to verify operability, to remain attentive to all status indicators, and to keep themselves aware of the status of safety systems as stated in Steps 4.4.5, 5.4.1.1 and 5.4.1.2, respectively. Specifically, the operators failed to recognize that the manual / auto controller for Valve ACC-126A was not in the required automatic position, rendering Train A o'ine ACCW system inoperable.

(01023) 9002090168 990205 PDR 0 ADOCK 05000392 PDR

Entergy Operations, Inc.

CJ Technical Specification 6.8.1.a states, in part, that writteri procedures shall be

established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Regulatory Guide 1.33, item 1.b requires that administrative procedures be established for safe operation and shutdown of the facility, Procedure OP 100-001, Revision 12, Step 4.3.2,4 stated, in part, that the control room supervisor will " Monitor the Nuclear Plant Operators in the performance of their duties "

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- Contrary to the above,' on November 9-10,1997, the control room supervisor failed to monitor the activites of the secondary nuclear plant operator who secured Auxiliary - I Component Cooling Water Pump A without placing the manual / auto controller for Valve ACC-126A in automatic. (01033)

D. Technical Speedication 6.8.1.a states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Regulatory Guide 1.33, item 1.b requires that administrative procedures be established for safe operation and shutdown of the facility.

Procedure OP-100-001, Revision 12, described the responsibilities of the control room -

supervisor and the nuclear plant operators related to personnel conduct and control of -

operating activities.- Specifically, these responsibilities are described by the following steps in this procedure:

Step 4.3.2.9: The control room supervisor will, in part, " Direct the preparation and installation of Danger tags,' verifying that Technical Specification requirements are

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observed."

Step 5.8.2.1.B: " Redundant subsystems or components shall be ' verified to be -

operable, Upon discovery of inoperable components, or prior to initiating maintenance on components required by Technical Specification Limiting Condition for Operation, their redundant counterparts shall be verifed to be operable."

Contrary to the above, on November 10,1997, at 3 a.m. (CST) the control room supervisor failed to direct the preparation of Danger tags, verifying that Technical Specification requirements were observed; and the nuclear plant operators failed to verify redundant subsystems were operable and failed to verify a redundant counterpart -

to an auxiliary component cooling water train was operable prior to initiating maintenance on the opposite train Specifically, nuclear plant operators removed Auxiliary Comoonent Cooling Water Train B from service, which included placing Danger tags, for rouc maintenance without ensuring operability of Auxiliary Component Cooling Water Train A.

(01043) c

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Entergy Operations, Inc. 3-E. Technical Specification 6.8.1.a states, in part, that written procedures shall be established, implemented, anri maintained covering the applicable procedures recommenr.ed in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Regulatory Guide 1.33, item 1.d states requirements will be established for procedure adherence and temporary change methods and item 3.m states requirements for stariup, operation, and shutdown of the service water system.

Procedure OP-100-001, Revision 12, described the responsibilities of the nuclear plant operators related to use of procedures. Specifically, these responsibilities are described by the followiag steps in this procedure:

Step 4.4.11: Nuclear plant operators will" Operate plarit systems in accordance with plant procedures and as directed by the SS/CRS."

Step 5.13 S: " Operators shall comply with both the content and intent of approved procedures."

Procedure OP-002-001, " Auxiliary Component Cooling Water System," Revision 11 Section 7, Step 6 required operators to set tne manual / auto controller setpoint for Valve ACC-126A(B), auxiliary component cooling water system Cow contro!. to 5 95'F and to place the controller in automatic.

Contrary to the above, on November 9-10,1997, the secondary nuclear plant operator failed to comply with the intent of Procedure OP-002-001 for securing an auxilfary component cooling water train. Specifically, the operator failed to perform Procedure OP-002-001, Section 7, Step 6 that required placing the manual / auto controller for Valve ACC-126A to automatic. (01053)

F. Technical Specification 6.8.1.a states, in part, that written procedures shall be established, impicmented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Regulatory Guide 1.33, item 1.g states that requirements be established in administrative procedures for shift relief and turnover.

Procedure OP-100-007, " Shift Tumover " Revision 16, described the requirements for control room operators to perform control panel walkdowns during shift tumover and during the shift. Specifically, Step 5.1.7 stated, "Every shift the Shift Superintendent, Control Room Supervisor, Primary Nuclear Plant Operator, and the Secondary Nuclear Plant Operator shall perform two control board walkdowns. One control board walkdown-

. per watchstander shall be documented by signing the control board walkdown signature block of the appropriate tumover sheet." Step 5.1.8 stated, "A complete control b;ard walkdown is performed by thoughtfully observing every light, every indicator, every switch, and every button. Further, Step 5.5.3 stated,"The oncoming and off-going NPCs should walk down the control panels together. Discussioris should include, but are not limited to, the following items: Status of safety-related systems; operating equipment and system alignments;

Entergy Operations, Inc. Contrary to the above, on November 9-10,1997, numerous opportunities existed for the i night shift watchstanders to identify the mispositioned indicator when evaluating every '

indicator and every switch as specified in Procedure OP-100-007, Steps 5.1.7 and 5.1.8.

Also, several missed opportunities occurred during shift turnove, control panel walkdowns while the nuclear plant operators discussed the status of the safety-related auxiliary component cooling water system and the respective equipment sv.us/ alignment. Specifically, from 7:21 p.m. on November 9 until 10:25 a.m. (CST) on November 10,1997, several operators failed to comply with Procedure OP-100-007, in that, at least eight opportunities during the night 6hift and at least three opportunities during shift tumover occurred to identify that tha controller for Valve ACC-126A was misaligned. (01063)

These violations represent a Severity Level til problem (Supplement 1).

Pursuant to provisions of 10 CFR 2.201, Entergy Operations, Inc., is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region IV, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice), This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the .orrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response, if an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified,

( suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the rerponse time, if you contest this enforcement action, you should also provide a copy of your response to the

, Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555 0001.

Under the authority of Section 182 of the Act 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, ur cafequards information so that it can be placed in the PDR without redaction, if personal privac'; r proprietary information is necessary to provioe an acceptable response, then please p. ovide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you_must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by l

Entergy Ooerations, Inc. 10 CFR 2.790(b) to support a request for withholding confidential corrmercial or financial information), if safeguards information is necessaiy to provide an acceptable response, pleaso provide the level of protection described in 10 CFR 73.21.

Dated at Mington, Texas this 5th day of February 1998 L

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