IR 05000382/1990015

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/90-15.NRC Unable to Clearly Determine Actions Intended to Address Overall Retest & Program Weaknesses

ML20062B125
Person / Time
Site:	Waterford
Issue date:	10/11/1990
From:	Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Barkhurst R ENTERGY OPERATIONS, INC.
References
NUDOCS 9010240058
Download: ML20062B125 (3)

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' Doc'ket: '50-382/90-151 .

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Entergy Operations, In : ATTN: Ross P.'Barkhurst, Vice President ,

0perations, Waterford

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s P.O. Box B

.Killona,' Louisiana 70066 Gentlemen:

Thank you for your letter of August 31, 1990, in response to our letter and

Notice of Violation dated August 1,1990.: We have reviewed your reply and

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were unable to clearly. determine what. actions you intended to take to address the concerns we have had over the past year ~ on your overall retest program weaknesses. Our resident inspectors met with your staff on September 28 and .

< October 4,1990, and discussed our concerns on this issue. From those _1'

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- discussions, we understand that you have committed to implement an improved postmodification and postmaintenance retest program by November 30, 1990.-

-We.also understand that by December 31, 1990, you will complete training of

,your personnel involved in the improved progra We will review the implementation of your corrective actions during a future

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inspection to determine that full compliance has been achieved and will be ';

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Sincerely, OrloinalSloned By:

Thomas P.Gwyrm Samuel J. Collins, Director Division of Reactor Projects Jcc':

Enter 9y Operations In i ATTN: Donald C. Hintz, Executive Vice President & Chief Operating Officer P.O. Box 31995

Jackson, Mississippi 39286 ,

Entergy Operations, Inc.

s ATTN: Gerald.W. Muench, Vice President Operations Support

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P.O. Box 31995

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i Jackson, Mississippi 39286

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Entergy Operations, In Wise, Carter, Child & Caraway ATTN: Robert B. McGehee, Es P.O. Box 651 Jackson, Mississippi 39205 Entergy Operations, In ATTN: J. R. McGaha, Jr. , General Manager Plant Operations P.O. Box B Killona, Louisiana 70066

Entergy Operations, In ATTN: J. G. Dewease, Senior Vice President, Planning & Assurance L P.O. Box 31995 Jackson, Mississippi 39286-1995

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Entergy Operations, In ATTN: L. W. Laughlin, Site Licensing Support Supervisor P.O. Box B Killona, Louisiana 70066 Monroe & Leman ATTN: W. Malcolm Stevenson, Es St. Charles Avenue, Suite 3300 New Orleans, Louisiana 70170-3300 Shaw, Pittman, Potts & Trowbridge ATTN: Mr. E. Blake 2300 N Street, NW Washington, Chai rman Louisiana Public Service Commission One American Place, Suite 1630 Baton Rouge, Louisiana 70825-1697 Entergy Operations In ATTN: R. F. Burski, Director Nuclear Safety 317 Baronne Street New Orleans, Louisiana 70112 Department of Environmental Quality ATTN: William H. Spell, Administrator .

Radiation Protection Division P.O. Box 14690

, Baton Rouge, Louisiana 70898 "' '~

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.Entergy Operations In f President Parish Council St.. Charles Parish Hahnville, Louisiana 70057 ,

Mr;' William A. Cross Bethesda Licensing Office 3 Metro Center-Suite 610-

.Bethesda, Maryland 20814 U.S. Nuclear Regulatory Connission

' ATTN: Resident Inspector

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P.O. Box 822 .

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-Killona, Louisiana .70066

. U.S. Nuclear, Regulatory Comission .

-ATTN: Regional Administrator, Region IV 611 Ryan Plaza Drive. Suite 1000

' Arlington Texas 76011

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.bcc'toDMB(IE01)4 bec distrib. by RIV:'

R. D; Martin * Resident Inspector >

-Section. Chief =(DRP/A) *DRP DRSS-FRPS , * MIS System ,

Project Engineer (DRP/h) *RSTS Operator

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RIV File - . . *DRS D. Wigginton. .NRR Project Manager (MS:

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W3P90-1191-A4.05 QA >

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U.S. Nuclear Regulatory Commission ATTN: Document Control Desk $4 g o I l'

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Subject: Waterford 3 SES ' '

Docket No. 50-382 License No. NPF-38 *

NRC Inspection Report 90-15 Reply to Notices of Violations

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Gentlemen:

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In accordance with 10 CFR 2.201, Entergy Operations, Inc. hereby submits in Attachment 1 the responses.to the Notices of Violations identified in Appendix A of the subject Inspection Repor If you have any questions concerning these responses, please ' contact ;

Laughlin at -(504) 739-672 !

Very truly yours, l rd 1 RFB/DAR/ssf Attachment ... . .. . . . .. - ,.

cc: . Messrs'. rid. ? Martin f NRCi Region; IV,. i D.L. Wigginton, NRC-NRR

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E.L. . Blake -

. W.M. Stevenson R.B. McGehee

. NRC Resident Inspectors Office T

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ATTACHMENT 1 j I ENTERGY OPERATIONS, INC. RESPONSE TO THE NOTICE OF VIOLATION IDENTIFIED IN APPENDIX A OF INSPECTION REPORT 90-15 i

VIOLATION NO. 9015-02 Failure to Provide Adequate Retest

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Criterion XI of 10 CFR 50, Appendix B requires, in part, that all testing

! required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures, which incorporate the requirements and acceptance limits contained in applicable design document Contrary to the above, on June 20, 1990, the inspector observed that the retest, Section 8.3 of PE-005-004,- Revision 4, " Control Room Air .

Conditioning System Surveillance," which was designated to be performed as t the result of a design change (DC 3300) to the A train of the control room air conditioning (CRAC) system, failed to demonstrate that all of the valves affected by the modification would perform satisfactorily in. service. CRAC-Valves HVC-201A and -203A would not have been operated by this' test procedure, representing two of the four valves affecte This is a Severity Level IV violatio ,

Response

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(1) Reason for the Violation I

Entergy Operations, Inc. admits this violation and believes the root

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cause to be an inadequate test procedure used to verify operability following a. modification. As indicated in the inspection report, DC 3300 was initiated to correct an inappropriate application of certain Potter - Brumfield rotary latching relays. The work consisted of ,

rewiring the relays to bypass internal contacts that were in series with the closing and reset coils. These were lockout relays in the f control circuits for valves in the safety-related CRAC system. In preparation .for DC 3300 acceptance teating,- Waterford 3 personnel noted that a surveillance test procedure for Technical Specification 4.7.6.e 5 already. existed (PE-005-004, Control Room Air Conditioning System Surveillance). Since the purpose of both PE-005-004 and the DC 3300 acceptance test was to verify that the CRAC system would switch to the isolation mode of operation in response to a toxic gas L signal, engineering personnel concluded that PE-005-004 was suitable as the acceptance test.

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PE-005-004 did ' verify the operability of the CRAC system in its normal configuration. - However, as written, it did not cycle all of the valves

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affected in the modification. Two of the four valves in each train are closed in normal configuration. The retest generates a toxic gas signal to induce the valves. to close. Since two of the valves were not opened before the retest, operability is not established- for those valves. Although the Design Change Package gave correct recommendations for retest, and the Work Authorization specified the correct test criteria,'the chosen procedure did not suitably demonstrate the operability of all safety-related equipment affected by

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the design chang ' "

(2) Corrective Steps That Have Been Taken and the Results Achieved Two corrective steps have been taken to date. A Potentially Reportable Event, PRE 90-032, was initiated following discovery that PE-005-004 did not cycle the two normally closed valves. In evaluating this suspected deficiency for violation of technical specifications, PRE 90-032 determined that Technical Specification , 4.7.6.e.5. was satisfied since the system was verified to automatically switch to the isolation mode of operation following a toxic gas signa However, it is concluded that a procedure enhancement is desireable to address this issue. Consequently, suggested corrective actions, as indicated below, are to improve the PE-005-004 methodology and to review the other HVAC surveillance procedures for similar deficiencies and revise them as necessary. These reviews and possible revisions  ;

will be completed in accordance with the schedule specified in Section  !

4, below. Its closure will coincide with the completion of these item Additionally, retest work instructions were written to test the normally closed valves in the A train. These work instructions were completed on June 21, 1990 and the valves. operated satisfactoril (3) Correctiva Steps Which Will Be Taken to Avoid Further Violations

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To address root cause and contributing factors, Entergy Operations, Inc. is pursuing two action First, the Technical Specification surveillance procedure, PE-005-004, will be revised to ensure that the normally closed valves are opened and verified to close on the initiation of a toxic gas signa WithLthis complete, all other Technical Specification surveillance procedures relating to HVAC systems will be .

reviewed to ensure' that no similar condition exists in those procedures. Specifically, these procedures will address the surveillances of the shield building ventilation system, the controlled ventilation area rystem, and the fuel handling building ventilation system. Should it be necessary, these surveillance procedures will also be revise .

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(4) Date when Full Compliance Will Be ' Achieved

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, The revision of .the CRAC surveillance procedure, PE-005-004, will be

complete by October 131,1990 or prior to its next use, whichever occurs first. The review of the remaining Technical Specification '

surveillance procedures will be complete by October 31, 1990. If

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revision is necessary, the revisions will be completed by December 31, 1990 or prior to their next use, whichever occurs firs '

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VIOLATION- 9015603 Failure to Properly Review and Approvo a Test Procedure o

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TechnicalsSpecification 6.8.1.c requires, in part, that written procedures she'.1 be established, implemented, and maintained covering test activities of f, safety-related equipmen m

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Technical Specification 6.5.1.6.a requires, in part, that all procedures-a required :by Technical Specification 6.8 shall be reviewed by the plant operations review committee (PORC).

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o Technical Specification 6.5.1.7 requires, in part, the PORC to recommead in writing to the plant manager, approval of the above procedures prior to

Implementation. .

. Contrary to the above,- on June 21, 1990, the inspector observed that the

+ .postmodification testing of the control room air conditioning system response to a toxic gas detection signal which was performed in accordance with Wor Authorization 99000342 (Condition Identification Report 263976) was not reviewed by. the PORC or recommended for approval in writing to the plant-manage This is a Severity Level IV- violatio ~

Response

g  :(1) . EReason for the Violation

. Entergy Operations', Inc. admits this violation and believes the root-

!cause to be a failure to comply with an existing procedure,

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UNT-001-004, which defines the circumstances requiring a r~ormal

procedure < and which of these . procedures require review by POR , After acknowledging PE-005-004 did not cycle;all the necessary valves,

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ast described in- the response to the previous violation, a' work -

' authorization,- WA99000342 (Condition Identification Report 269976), was

. prepared to perform the necessary testing. It confirmed that all valves- that should be cycled in the retest to prove operability were opened before the toxic gas signal was initiated. The Waterford. 3 staff viewed this as an elementary post modification retest 'which did not affect plant safety and overlooked the technical specification

! . requirement (and UNT-001-004 requirement) for PORC review and g General Manager approval.

ll '(2). Corrective Steps That Have Been Taken and the Results Achieved -

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.WA99000342- was completed on June 21, 1990, verifying satisfactory

. operation on the valves. The requirement for PORC review and

. General Manager approval were not discovered until after completing WA99000342. Inspection Report 90-15 states that the test procedure h was adequate and clearly written. Since this work had already been performed, the completed work instructions were reviewed by' PORC. on

' August - 23, 1990. PORC concurred that the test was adequate and was satisfactorily performed.

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k L Additionally, a letter, . W3Y90-0082, has been sent to Waterford 3 (

System Engineering personnel alerting. them. to the circumstances of this ' violation as an effort to prevent similar errors. - ,

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Corrective Steps Which Will Be Taken to Avoid Further' Violations

+ To : assure protection against- similar. occurrences, the plan f administrative procedure that governs postmodification: tes . .

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requirements '(UNT-007-028) .will be changed to more clearly identify ',

the = conditions under which a postmodification -test requires PORC review and approval by .the General Manage Discussions held with the NRC senior resident addressed the potential,

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for a similar occurrence in' the area of postmaintenance testing. This discussion is being taken into consideration as part ~of an ongoing i review of postmaintenance testing administrative controls. The results I will be incorporated into a postmaintenance retest procedure which had

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been under ' development for some time. -

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[ (4)- ' Date when Full Compliance Will Be Achieved

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UNT-007-028 will .be revised by October 31,:1990. The_ development of t a guidance procedure -to formulate postmaintenance retest instructions will' be complete by November 30,: 199 :

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