IR 05000382/1997021

Ack Receipt of 980122 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/97-21 Issued on 971202.Corrective Actions Will Be Examined During Future Inspections

ML20199H806
Person / Time
Site:	Waterford
Issue date:	01/30/1998
From:	Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dugger C ENTERGY OPERATIONS, INC.
References
50-382-97-21, NUDOCS 9802050127
Download: ML20199H806 (5)

Text

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$11 RYAN PLAZA DRIVE, SUlt E 400 ARuNotow. te xAs n,oit soes January 30, 1998 Charles M. Dugger, Vice President Operations . Waterford 3 Entergy Operations, Inc.

P.O. Box B Killona, Louisiana 70066 SUBJECT: RESPONSE TO NRC INSPECTION REPORT 50-382!97-21

Dear Mr. Dugger:

Thank you for your letter of January 22,1998, in response to our December 2,1997, letter and Notice of Violation concerning two examples of a failure to follow procedures. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation.

We will review the implementation of your corrective actions during a future inspection to determine that full cor,pliance has been achieved and will be maintained.

Sincerely, A a

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Thomas F. Stetka, Acting Chief'

Engineering Branch Division of Reactor Safety Docket No.: 50-382 License No.: NPF 38 cc:

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

P.O. Box 31995 Jackson, Mississippi 39286-1995 Vice President, Operations Support Entergy Operations, Inc.

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

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Wise, Carter, Child & Caraway i

P.O. Box 651 Jackson, Mississippi 39205 f

General Manager, Plant Operations Waterford 3 SES Entergy Operations,Inc.

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Entergy Operations, Inc.

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

Director, Nuclear Safety &

Regulatory Affairs

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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 St. Charles Parish P.O. Box 302

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Hahnville, Louisiana 70057 Mr. William A. Cross >

Bethesda Licensing Office 3 Metro Center Suite 610 Bethesda, Maryland 20814

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v/ h@ma L A ?ODC4 Tel 504 ?39 0242 Earl C. Ewing. ill u.s, og,.3.,s s n,. san ,

W3F 197-0276 (A05 PR January 22,1998

U.S. Nuclear Regulatory Commission y o

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ATTN: Document Control Desk Washington, D.C. 20555 ih y1 Subject: Waterford 3 SES O

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Docket No. 50 382 -

License No. NPF-38 2 eh ~'FI'..d , _ ' .

L NRC Inspection Report 97 21 Reply to Notice of Violation Gentlemen:

In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in  ;

Attachment 1 the response to the violation identified in Enclosure _1 of the subject ',

Inspection Report.

On December 31,1997, Waterford 3 receivea permission to extend the due date for this reply from January 2,1998, to January 15,1998. On January 15,1998, permission was granted to extend the due date from January 15,1998, to January 22,1998. NRC personnel contacted for those extensions include the Region IV Director, Division of Reactor Safety, and the Region IV Deputy Director, Division of Reactor Safety.

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NRC Inspection Report 97 21 Reply to Notice of Violation W3F197 0276 Page 2 January 22,1998 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,

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n E.C. Ewing -

Director, Nuclear Safety & Regulatory Affairs ECE/WDM/ssi Attachment oc: E.W. Merschoff (NRC Region IV)'

J. 8.leberman (NRC-NRR)

C.P. Patel(NRC NRR)

J. Smith N.S. Reynolds NRC Resident inspectors Office

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Att:chment to

'. V/3F197-0276 Page 1 of 6 ATTACHMENT 1 ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 50-382/97-2_1, VIOLATION NO,9721-02 10 CFR Part 50, Appendix B, Criterion V, * Instructions, Procedures, and Drawings,"

states that activities affecting quality shall be prescribed by documented instructions, procedures, or drawingt,, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, and drawings.

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Site Procedure W4.503, " Changes to the Technical Specifications, Technical Requirements Manual, or Core Operating Limits Report," Revision 4.1, required that desired changes to the technical requirements manual be evaluated under the 10CFR50.59 process in accordance with Procedure W2.302, *10CFR50.59 Safety and Environmental Screenings," and reviewed by the plant operating review committee.

Procedure W2.501, " Corrective Action," Revision 6, states that an individual who identifies a condition adverse to quality shall initiate a condition report.

1. Contrary to the above, on April 8,1996, desired changes were identified for entries in Table 3.8-1 of the technical requirements manual and as of October 10, 1997, had not been evaluated under the 10CFR50.59 process, 2. Contrary to the above, the licensee failed to initiate a condition report following the discovery in 1997 of a condition adverse to quality involving Calculation EC-191-027, Revision 0, dated December 30,1991, which analyzed the error associated with the conta;nment spray riser level gauges. The calculation, which did not account for density changes in the water column being measured, affected the calculation of peak containment pressure for a loss of-coolant accident.

This is a Severity Level IV violation (Supplement 1). (50-382/9721-02)

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W3F197-0276 '{

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For the sake of clarity, each example of Violation 9721-02 is addressed separately below,

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(1) Reason for the VinjaEQD (Example 1)

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i Waterford 3 acknowledges that desired changes to Table 3.8-1 of the  !'

i Technical Requirements Manual (TRM) were not evaluated under the

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i . 10CFR50.59 process from April 8,1996 to October 10,1997. The apparent

cause of that cor.dition is inappropriate action. -l

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p Licensee Event Report (LER)95-006 dated January 8,1996, reporied a condition wherein two electrical alternating current circuits which use ,

containment electrical penetrations did not have backup overcurrent .  !

protection as required by the Technical Specifications Corrective actions for . i

, that condition included, among other things, a revision to the TRM (evaluated i

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under the provis!ons of 10CFR50,59) to reflect installation of backup

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overcurrent protection and a review of the TRM against the computerized  :

electrical penetrations list and associated electrical design drawings to ensure >

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L all electrical penetrations were adequately protected Both actions were_ -

tracked under LER 95-006 and Condition Report (CR) 95-1282 to ensure

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' As a result of the latter corrective action (i. .e, TRM review), minor.

, inconsistencies were identified in the TRM, Those inconsistencies did not  ;

impact the primary and backup electrical protection for the containment 1 L

penetrations, On April 8,' 1996, an inter-office memo from Design Engineering to Licensing personnel identified the discrepancies and committed to submit'

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the changes impacting the TRM to Electrical Maintenance for incorporation i F into the manual, in addition, the inter-office memo was submitted to Electrical ,

L Maintenance (to process the TRM change) and in-House Events Analysis (to- ?i close the action identified in CR 95-1282),

l Site procedures W2,302, "10CFR50,59 Safety and Environmental impact

Evaluations," and W4,503, " Changes to the Technical Specification, ,

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Technical Requirements Manual or Core Operating Limits Report," require all

- proposed TRM changes to be evaluated under the 50,59 process prior to

implementation Although TRM discrepancies were identified, personnel did .

not promptly process a TRM change per site procedures nor did they utilize a

tracking tool to ensure a TRM change was implemented.

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W3F1974276 Page 3 of 6 (2)- Corrective Stoos That Have Been Taken and the Result 1 Achieved TRM Change Request 98-001 has been initiated. That request has been assigned to Electrical Maintenance and will provide a tracking mechanism to ensure proposed changes to correct the TRM discrepancies are evaluated under the 10CFR50.59 process.

Design Engineering / Electrical reviewed this condition during a staff meeting to ensure department personnel understena expectatiens of the corrective action process in relaying information to other departinents and the

importance of appropriately following up on the completion of corrective actions.

The Licensing and lHEA departments have discussed this condition in departmental staff meetings to accentuate the importance of action item l tracking and completion. .

(3) Corrective Stoos Which Will Be Taken to Avoid Further Violations The desired changes to the TRM are being evaluated under the 10CFR50.59 process. Once that process is complete, the appropriate changes will be incorporated.

(4) Date When Full Comoliance Will Be Achieved The appropriate TRM changes will be completed by March 2,1998.

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Att: chm:nt to

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VV3F197-0276 Page 4 of 6 (1) Reason for the Violation (Example 2)

Waterford 3 acknowledges that a condition report was not initiated following the discovery of a condition adverse to quality associated with Calculation EC-101027. Revision 0. The apparent cause of that condition is inappropriate action in that site procedure W2.501, " Corrective Action," Revision 6 (R6), was not usod appropriately in deciding whether or not a condition repor1 should have been written.

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On March 21,1997, Design Engineering discovered a deficiency associated with calculation EC 191027, Revision 0. The calculation failed to include uncertainty allowances for the Containment Spray (CS) riser level instruments.

An evaluation of that enor determined CS riser indicated level could be a much as 10 feet higher than actuallevel. Because the error could prohibit or detract from the safe operation of Waterford 3, a condition report (CR 97-0682) was, generated. -

On April 21,1997, Licensee Event Report 97-011-00 reported that, due to the uncertainty error, CS Riser level may have been less than required by Technical Specifications (TS). However, the condition would not have prevented the CS or Containment Cooling System or any other auxiliary system required to ensure operability of those systems from performing their specified safety functions.

During Refuel Outage 8 (RF08), the CS riser level instruments were replaced with more accurate devices to reduce the calculated uncertainty The B Train instrument was replaced on May 5,1997, under work Authorization (WA)

01159013 and the A Train instrument was replaced on May 12,1997, under WA 01159014. The plant was in Mcde 6 (Refueling) at the time.

On May 20,1997, EC-191-027, Revision 1, was implemented in consequence of the aforementioned instrument leplacements. Revision 1 included an uncertainty factor to account for density changes in the water column being measured in accordance with standard fluid calculation practices. On July 17, 1997, EC-191-027, Revision 2 was implemented to account for a change in the TS allowed boron concentration in the Refueling Water Storage Pool.

While conducting IR 97-21, NRC inspectors noted the additional term for density effects applied a biased effect that, absent any other considerations, could cause the indicated CS riser level to be as mtah as 11.6 feet higher than actuallevel. The inspectors questioned if the additional bias invalidated previous conclusion : regarding safety significance.

In response to NRC questions, Waterford 3 personnel stated that, in their judgment, changes to other assumptions in the oiiginal calculation would

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Att: chm:nt to

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W3F197 0276 Page 5 of 6 offset the increase in uncertainty added by the density affects, but had not confirmed that judgment. Furthermore, the application of density effects is a standard practice and it is unlikely that effect would be missed on a broad scale. IR 97-21 states the Inspectors considered the lack of consideration of density effects in the original calculation to constitute a condition adverse to quality, in that it was a source of error that should have been considered, and for which its exclusion in this one instance, could imply its possible exclusion from other level Instrument calculations.

W2.501 R6 defines a condition adverse to quality as a condition (or deficiency) that could result in a degradation or challenge to nuclear safety.

At the time of discovery, personnel knew EC 191-027, Revision 0, affected level instruments no longer installed in the plant. In addition, they believed that changes to other assumptions in the original calculation would offset the increase in uncertainty added by the density effect. That offset was later confirmed and was all that was necessary to disposition the error in EC 191-027, Revision 0. W2.501 does not require personnel to initiate a condition report following the discovery of non significant issues that question past operability.

Although personnel considered it unlikely for the density effect to be missed on a broad scale and that belief was later confirmed, neither a confirmatory review or a condition report was promptly initiated. In addition, an appropriate level of supervisory review was not included in the decision making process.

The failure to promptly initiate a confirmatory review or a condition report for a potential recurring deficiency constitutes a failure to comply with W2.501.

Pursuant to W2.501 and our commitment to ANSI N45.2.11, corrective actions for significant or recurring calculation deficiencies require the initiation of a condition report.

(2) Corrective Steps That Have Been Taken and the Results Achieved A condition report was generated.

On May 20,1997, EC-191-027, Revision 1, was implemented. Revision 1 included an uncertainty factor to account for density changes in the water column being measured.

Design Engineering performed a review that confirmed the lack of consideration of density effects in EC-191-0:!7, Revision 0, was offset by other assumptions in the calculation.

A review of level calculations and selected pressure calculations was performed. No other calculations were identified that failed to include the water density factor.

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'e Attachm:nt to W3F197-0276 Page 6 of 6 in response to IR 97-16 dated November 24,1997, Waterford 3 identified the need to emphasize the importance of communicating new information that involves a potentially degraded or nonconforming condition, in consequence,

. on December 17,1997, the Director, Design Engineering, issued a ,

memorandum to all Design Engineering personnel providing expectations on '

when to write a condition report and when to involve others in the decision making process.

(3) Corrective Steps Which Will Be Taken to Avoid Further Violations This condition will be discussed during the next cycle of Engineering Support Personnel (ESP) Continuing Training. Also, that training will include additional examples of when to write a condition report and when to involve others in the decision making process.

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(4) Date When Full Compliance Will Be Achieved Full compliance has been achieved. The next cycle of ESP Continuing L

Training is scheduled for Mwch,1998.

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