ML20133E334
| ML20133E334 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 01/09/1997 |
| From: | Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Sellman M ENTERGY OPERATIONS, INC. |
| References | |
| NUDOCS 9701130007 | |
| Download: ML20133E334 (5) | |
See also: IR 05000382/1996024
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UNITE o STATES
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.. . NUCLEAR REGULATORY COMMISSION
REGloN IV
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S'* f 611 RYAN PLAZA DRIVE, SulTE 400
b # O' AR LINGTON, T E XAS 76011 -8064
9.....
JAN - 91997
Michael B. Sellman, Vice President
Operations - Waterford
Entergy Operations, Inc.
P.O. Box B
Killona, Louisiana 70066
SUBJECT: NRC INSPECTION REPORT 50-382/96-24
Thank you for your letter of December 26,1996,in response to our letter and
Notice of Violation dated November 13,1996. We have reviewed your reply to the first
violation and find it responsive to the concerns raised in our Notice of Violation. In regards
to the second violation, we have reviewed your position on the violation and agree that
Violation 50-382/9624-02 was mischaracterized. Violation 50-382/9624-02 was
changed to reflect the appropriate regulation (refer to Violation B in the enclosed Notice of
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Violation). As specified in the enclosed Notice, no response is required for the violation
because your letter of December 26,1996, was considered appropriate by the NRC staff.
We will review the implementation of your corrective actions during a future inspection to
determine that full complia - has been achieved and will be maintained.
Sincerely, i
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$lb1lDV
J. E. Dyer, Director
Divis o of Reactor Projects
Enclosure:
as stated
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Docket No.: 50-382 ]
License No.: NPF-38
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9701130007 970109
PDR ADOCK 05000382
G PDR
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Entergy Operations, Inc. -2-
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Executive Vice President and
Chief Operating Officer
Entergy Operations, Inc.
P.O. Box 31995
Jackson, Mississippi 39286-1995 )
Vice President, Operations Support
Entergy Operations, Inc.
P.O. Box 31995
Jackson, Mississippi 39286 1995
Wise, Carter, Child & Caraway
P.O. Box 651
Jackson, Mississippi 39205
General Manager, Plant Operations
Waterford 3 SES
Entergy Operatiuns, Inc.
P.O. Box B
Killona, Louisiana 70066
Manager - Licensing Manager
Waterford 3 SES
Entergy Operations, Inc.
P.O. Box B
)
Killona, Louisiana 70066
Chairman
Louisiana Public Service Commission
One American Place, Suite 1630
Baton Rouge, Louisiana 70825 1697
Director Nuclear Safety 1
Waterford 3 SES I
Entergy Operations, Inc. I
P.O. Box B
Killona, Louisiana 70066 l
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William H. Spell, Administrator
Louisiana Radiation Protection Division
P.O. Box 82135
Baton Rouge, Louisiana 70884-2135
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JAN - 91997
Entergy Operations, Inc. -4-
bec to DMB (IE01)
bec distrib. by RIV:
L. J. Callan Resident inspector
DRP Director DRS-PSB
Branch Chief (DRP/D) MIS System
Project Engineer (DRP/D) RIV File
Branch Chief (DRP/TSS) Leah Tremper (OC/LFDCB, MS: TWFN 9E10)
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To receive copy of document, indicate in box: "C" = Copy without enclosures *E" = Copy wth enclosures "N" = No copy
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OFFICIAL RECORD COPY
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JAN - 91997
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Entergy Operations, Inc. -4-
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L. J. Callan Resident Inspector
DRP Director DRS-PSB ,
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Project Engineer (DRP/D) RIV File
- Branch Chief (DRP/TSS) Leah Tremper (OC/LFDCB, MS
- TWFN 9E10)
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To receive copy of document, Indicate in box: "C" = Copy without enclosures *E" = Copy with enclosures "N" = No copy
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Entergy Operations, Inc. -3-
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- Parish President l
St. Charles Parish
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P.O. Box 302
Hahnville, Louisiana 70057
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Mr. William A. Cross i
Bethesda Licensing Office
3 Metro Center
Suite 610
Bethesda, Maryland 20814
Winston & Strawn
1400 L Street, N.W.
Washington, D.C. 20005-3502
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ENCLOSURE
NOTICE OF VIOLATION
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l Entergy Operations, Inc. Docket No.: 50-382
Waterford Steam Electric Station, Unit 3 License No.: NPF-38 '
During an NRC inspection conducted on October 2125,1996, two 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:
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A. 10 CFR Part 50, Appendix B, Criterion XVI, requires, in part, that conditions adverse
l 0 quality be promptly identified and corrected.
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Proce OP 901-511," Instrument Air Malfunction," Attachment 5, Note 1,
( required th accumulators for Valves CC-135A(B), Dry Cooling Tower A(B) inlet
isolation valve, ve pre-staged motive cylinders (nitrogen bottle) to allow a backup
air source to be co ecte the accumulators on a loss of instrument air,
i Contrary to the above, con ' ions % verse to quality were not promptly identified
I and corrected in that: L
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1. As of October 22,1996, the lic
water usage sources from d the con
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torage %poolfailed to determine
following a design all of the
basis tornado event, as required by Con on Report 96-0086, dated
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January 22,1996.
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2. From October 14-21,1996, the licensee did not imp ent immediate
corrective actions specified in Condition Report 96-163 prestaging a
nitrogen cylinder for Valve CC-1358, as required in Procedur P-901 -511. l
This is a Severity Level IV violation (Supplement l} (50-382/9624-01). l
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B. 10 CFR Part 50, Appendix B, Criterion XI, requires, in part, that a testing program ;
be established to demonstrate components will perform satisfactorily in service and
be performed in accordance with procedures. It also requires that the test be
performed under suitable environmental conditions.
Contrary to the above, as of October 22,1996, a testing program was not
established to demonstrate that Valves CC-134A(B) and CC-135A(B) would perform
F.atisf actorily in service. Specifically, the licensee failed to perform testing that
ensured the valves would stroke to their required safety positions using the
safety-related air accumulators.
This is a Severity Level IV violation (Supplement 1) (50-382/9624-02).
The NRC staff has determined that the actions taken, by Entergy Operations, Inc. to
address this issue, were satisfactory; therefore, no written response to the
violations discussed above are required. The NRC staff has reviewed your response letter
of December 26,19p,in response to our letter and Notice of Violation dated
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November 13,1996, We have reviewed your reply and find it responsive to the concerns
raised in our Notice of Violation.
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Dated at Arlington, Texas i
l this 9th day of January 1997
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g O Ent:rgy Oporttiins, Inc.
lJ PO Boe 8
l Killona. LA 70066
Tel 504 739 6242
_ James J. Fisicato
01recer
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DEC I '
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December 26,1996
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U.S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Washington, D.C. 20555
Subject: Waterford 3 SES
Docket No. 50-382
License No. NPF-38
NRC Inspection Report 50-382/96-24
Reply to Notice of Violation
Gentlemen:
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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.
Waterford 3 agrees with the NRC's assessment that the two examples of the first
violation indicate a less than rigorous resolution of identified deficiencies in a timely
manner. We believe the timeliness and thoroughness of our response was not
typical of Waterford 3 expectations and performance.
With regards to the second violation, we have performed a critical examination of the
inspection report and related NRC correspondence, held numerous discussions with
other utilities, and challenged our position repeatedly. As a result, we still believe
that our testing methodology for CC-134A(B) and CC-135A(B) is in compliance with
all ASME section XI requirements and 10CFR50.55a(g). Additional details are
provided in Attachment 1.
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NRC Inspection Report 96-24 i
Reply to Notice of Violation
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December 26,1996
If you have any questions concerning this response, please contact
Tim Gaudet at (504) 739-6666.
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Very truly yours,
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J.J. Fisicaro
Director
Nuclear Safety
JJF/WDM/tjs
Attachment
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cc: L.J. Callan (NRC Region IV), C.P. Patel (NRC-NRR),
R.B. McGehee, N.S. Reynolds, NRC Resident Inspectors Office
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Attachment to
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ATTACHMENT 1
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ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN
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ENCLOSURE 1 OF INSPECTION REPORT 50-382/96-24
.d
VIOLATION NO. 9624-01
10 CFR Part 50, Appendix B, Criterion XVI, requires, in part, that conditions adverse
- to quality be promptly identified and corrected.
Procedure OP-901-511, " Instrument Air Malfunction," Attachment 5, Note 1, requires
l that accumulators for Valves CC-135A(B), Dry Cooling Tower A(B) Inlet Isolation
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Valve, have pre-staged motive cylinders (nitrogen bottle) to allow a backup air !
source to be connected to the accumulators on a loss of instrument air. l
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Contrary to the above, conditions adverse to quality were not promptly identified and
corrected in that.
1. As of October 22,1996, the licensee failed to determine all of the potential water
usage sources from the Condensate Storage Pool (CSP) following a design basis
tornado event, as required by Condition Report (CR) 96-0086, dated January 22,
1996.
, 2. From October 14-21,1996, the licensee did not implement immediate corrective
actions specified in CR 96-1603 by prestaging a nitrogen cylinder for valve CC-
135B, as required in procedure OP-901-511.
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This is a Severity Level IV violation (Supplement 1) (50-382/9624-01).
RESPONSE
(1) Reason for the Violation (Example 1)
Entergy believes that the root cause of this condition is that design documents
are inadequate for the design basis tornado accident. Contributing causes
were personnei error, poor verification and testing techniques, and
inadequate procedures and instructions.
Design basis document W3-DBD-003, Emergency Feedwater (EFW), states
that the Component Cooling Water (CCW) Makeup Pumps will require a
minimal amount of CSP volume following any design basis accident. An
existing calculation which stated that the CCW Surge Tank would require 116
gallons of makeup from the CSP following a design basis tornado event was
overlooked in calculation MN(Q)-9-17 and therefore, subsequently in the
W4.101 evaluation performed for CR 96-0086. Weaknesses were discovered
in procedural guidance to direct engineering personnel in determining if otner
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Paga 2 of 7
information exists that would affect calculations being performed or to pursue l
in what documents 1
(i.e., procedures, other calculations, etc.) information obtained from
calculations should be placed.
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l (2) Corrective Steps That Have Been Taken and the Results Achieved
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Upon discovery, calculations were performed to include the additiorial
makeup requirements. Based on Technical Specification (TS) minimum
levels, the WCT and CSP contain 344,000 gallons of water. During the first l
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the design basis tornado event, a total of 343,976 gallons of water
would be needed for EFW consumption, Ultimate Heat Sink (UHS)
consumption, and CCW Surge Tank makeup. Based on these numbers, the
WCT and CSP provided a 24 gallon margin. This margin, however, was
based on the DCT outlet isolation valves, CC-181 A(B) and CC-135A(B),
being leak tight. Since these valves had not been leak tested, an assumed
leakage of 5 gpm per valve was made. Recommendations were made to the
Control Room to maintain CSP level greater than 92% to provide added
volume. Operations management directed the Control Room staff to maintain
CSP level greater than 96%.
With CSP level at 96%, the available margin for the tornado event, not I
considering seat leakage through the Dry Cooling Tower (DCT) inlet isolation
valves, CC-135A(B), discharge check valves, CC-181 A(B), and bundle i
isoletion valves, is 10,555 gallons. Assuming a combined leak rate of 10 gpm !
for CC ",35A(B) and CC-181 A(B) for the initial two hours prior to isolation of
the damaged bundles, the remaining margin is 9,355 gallons. The combined l
leakage to the damaged bundles through the bundle isolation valves for the
remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> could not exceed 7 gpm. The DCT bundle inlet and outlet
isolation valves ware used as isolations during two maintenance activities
(Work Authorization (WA) #'s 01142260 & 01144162) with no appreciable
leakage.
Testing produced the following results:
CC-181 A/CC-135A 0.04 gpm
CC-181B/CC-135B 0.008 gpm
(3) Corrective Steos Which Will Be Taken to Avoid Further Violations
. Research all licensing and design documents pertaining to the design
basis tornado event. Detail the design basis tornado event similar to
Calculation MN(Q)-9-3 that details the LOCA event. Revise design
l documents and issue a Licensing Document Change Request (LDCR)
to clarify the FSAR if required. Determine leakage criteria for valves
required to be leak tight during a design basis tomado event. The IST
Program will be updated with these results. ECD, July 31,1997.
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. Develop a design basis for CCW Makeup following design basis
accident. Revise DBD-003, Emergency Feedwater, and update
Calculation EC-191-003 with results. ECD, March 31,1997.
. The WCT cross-connect line will be tested during RF8 to ensure make- j
up capability from one basin to another (corrective action from CR 96- l
0086). ECD, July 31,1997. l
. Revise Calculation MN(Q)-9-17 to take into account the CCW makeup
from the CSP. ECD, July 31,1997.
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. Revise NOECP-011, Performance of Calculations, to strengthen the i
design input and verification process for calculations. ECD, January l
31,1997.
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. Add DCT bundle isolation valves, CC-137A(B)/CC-179A(B), CC- i
141 A(B)/CC-175A(B), CC-139A(B)/CC-177A(B), CC-143A(B)/CC-
173A(B) and the CCW Makeup Pumps to the IST Plan to ensure these
components will be able to perform their specific function during a
design basis tornado event. ECD, January 31,1997. l
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(4) Date When Full Compliance Will Be Achieved I
Waterford 3 is in full compliance in that all potential water usage sources ;
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during a design basis tomado accident have been identified. Estimated
completion dates are provided, above, for corrective actions aimed at
reducing the potential for future violations. Those corrective actions will be
completed by July 31,1997.
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(1) Reason for Violation (Example 2)
The cause for the second cited condition in this violation is personnel error.
Incorrect assumptions, inadequate follow-up of task status, lack of task
ownership, and inadequate communications between Operations and System
Engineering led to the temporary nitrogen bottle not being staged.
A Condition Report (CR) was written on 10/14/96 when it was discovered that
a temporary nitrogen bottle was not staged for CC-1348 and CC-135B as
directed by Operations Off-Normal Procedure OP-901-511, " Instrument Air
Malfunction." The nitrogen bottles are staged locally for the A and B train
CCW DCT isolation and bypass valves to minimize shift effort in the event of
an instrument air malfunction after normal working hours. This requirement is
administrative in nature. There is no design or safety requirement that
requires the bottles to be staged in the DCT areas.
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A series of communication errors and incorrect assumptions led Operations i
personnel to assume that System Engineering would stage the bottle.
Engineering personnel informed the Control Room of the lack of requirements
for the bottles and believed that Operations would stage the bottle as a
requirement of OP-901-511. No one person took ownership of the issue and
acted as the coordinator to ensure replacement of the bottle. )
On 10/21/96, NRC inspectors discovered that a nitrogen bottle was staged in
the A DCT area but not in the B.
(2) Corrective Steos that Have Been Taken and Results Achieved
Once informed, the shift superintendent directed personnel to immediately
place a nitrogen bottle along with the necessary equipment in the area of
CC-1358.
(3) Corrective Steos Which Will Be Taken to Avoid Further Violations
. A review will be done of the need for the temporary nitrogen bottles to
be staged in the DCT areas. If the bottles are left in the area, they will
be identified with an OPS AID.
. As an enhancement, OP-901-511 will be revised to remove
requirements for staging the nitrogen bottles in the DCT area.
. Operations management will review this CR with personnel with
emphasis on the necessity for thorough communications and proper
follow up of assigned task completion. Also stressed will be the
consequences of incorrect assumptions during problem solving.
(4) Date When Full Comoliance Will Be Achieved
Waterford 3 is currently in full compliance in that the temporary nitrogen bottle
has been staged in the DCT area. Estimated completion dates are provided,
above, for corrective actions aimed at reducing the potential for future
violations. Those corrective actions will be completed by July 31,1997.
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l VIOLATION NO. 9624-02
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10CFR50.55a(g) requires, in part, that inservice testing to verify operational
readiness of pumps and valves whose function is required for safety be
accomplished in accordance with Section XI of the ASME Boiler and Pressure
Vessel Codo.
l Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components,"
Subsection IWV-1100, includes within the scope of inservice testing, Class 1, 2, and
3 valves (and their actuating and position indicating systems), that are required to
perform a specific function in shutting down the reactor or in mitigating the
consequences of an accident.
Contrary to the above, as of October 22,1996, the licensee failed to verify the
operational readiness of valves whose function is required for safety in accordance
with Section XI of the ASME Boiler and Pressure Vessel Code. Specifically, the
licensee failed to perform testing that ensured operational readiness of the safety-
related air accumulators of ASME Class 3 volves.
RESPONSE
Basis for Disputina the Violation
Waterford 3 disputes the NRC's position that the failure to stroke fail-as-is valves
CC-134A(B) and CC-135A(B) using their air accumulators as the source of air
constitutes a violation of 10CFR50.55a(g) and ASME Section XI.
As noted in your inspection report, the operation of ASME Class 3 valves
CC-134A(B) and CC-135A(B) mitigate the consequences of the design basis tornado
event. Therefore, Waterford performs the following tests to verify the operational
readiness of each valve and its actuating device:
. Quarterly IST stroke time test using the IA system as the motive force for the
valves. Both valve- 're timed in the open and closed directions.
. Accumulator drop r o ' n refueling outage to meet 10CFR Appendices A and B
operational readiness criteria.
Inspection Report 95-24 cites Information Notices (IN) 85-84 and 86-50 which
describe the failure to test valves that have been identified as fail-safe (i.e., valves
that fail to either the open or closed position on a loss of control air or power).
ASME Section XI, Subsection IWV-3415, also addresses fail-safe valves. This
section states that when practical, valves with fail-safe actuators shall be tested by
I observing the operation of the valves upon loss of actuator power.
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Valves CC-134A(B) and CC-135A(B) are not fail-safe valves. These valves are fail-
as-is valves (i.e., valves that do not change position on loss of control air or power).
Because they fail-as-is, these valves do not change position on loss of control air or
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power. These valves are therefore not subject to testing in accordance with l
subsection IWV-3415.
1 Engineering inspection report 96-202 also comments on Waterford 3's position on I
l testing of fail-safe valves in accordance with IWV-3415. The inspection report states
l that the licensee did not interpret the ASME quarterly test specified in the ASME
l Code Section XI, Article IWV-3415 for fail-safe valves, to include valves that relied
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on air accumulators to change position on loss of normal non-safety lA.
The IST Program monitors valves for degradation so that corrective action may be ,
taken in a timely manner should problems with the valves develop. Valves CC-
134A(B) and CC-135A(B) are in Waterford's IST Program. The testing currently i
performed on these valves satisfies all applicable ASME Section XI requirements.
Consistent with the definitions from Regulatory Guide 1.22, the actuator or actuating
system of the code class valve is taken to be, "A component or assembly of
components that directly controls the motive power (electricity, compressed air, etc.)
for actuated equipment." An air accumulator does not " control the motive power";
rather, it provides the motive power which is controlled by the actuator. An air
accumulator is therefore not part of the actuator or actuating system. There is no
requirement in ASME Section XI, Subsection IWV, to test accumulators on fail-as-is
. valves.
Waterford 3 does believe, however, that periodic testing of accumulators for
CC-134A(B) and CC-135A(B) should be conducted in accordance with 10CFR50
Appendix B Criterion XI, Test Control, to duplicate, as closely as practicable, the
performance required of the valves in the event of an accident. This has been
addressed in Condition Report CR-96-1978. Therefore, stroke testing CC-134A(B)
and CC-135A(B) using the accumulator as the motive source will be added to STA-
001-005, " Leakage Testing of Air and Nitrogen Accumulators for Safety Related
Valves.' Initial testing will be completed by January 15,1997, with subsequent
testing being performed on a refueling outage basis. Waterford 3 believes that
stroke testing these valves each refueling outage will verify their operational
readiness under all conditions.
In addition, it has also been determined and documented in CR-96-1978 that
periodic testing of the accumulators for the following valves should be conducted.
These valves will be stroke tested with their respective accumulators each refueling
outage beginning with RF8:
. CC-641, CCW to Containment Outside Containment isolation
. CC-710, Containment CCW Return Header Inside Containment Isolation
. CC-713, Containment CCW Return Header Outside Containment isolation
. CC-963A, Shutdown Heat Exchanger A CCW Flow Control Valve
. CVR-101, Containment Vacuum Relief Train B Control Valve
. CVR-201, Containment Vacuum Relief Train A Control Valve
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A preliminary evaluation has been performed regarding the above valves. It has
been determined that the accumulators for CC-134B and CC-135B are free from
moisture accumulation. Since these valves are located in the -35 wing area at the
lowest point of the IA system, this is strong evidence that IA accumulators in general
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will not experience air volume reduction due to moisture buildup. Accumulator
l volume reduction could result in degradation or loss of function of the associated
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valve if the accumulator was needed during a loss of instrument air event.
l Further review has shown that there is a high degree of confidence that listed valves
will perform if needed based on:
1 1. all of the listed valves are tested periodically as required by ASME Section XI
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l 2. the lA system dewpoint is maintained at s -10 'F and is therefore very dry and
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will not promote corrosion
3. a maintenance history search was performed and only one recorded event was
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accumulator testing
Given the above, Waterford 3 believes there is a high degree of certainty that the
subject will perform as designed. This, coupled with the stroke testing of these
valves each refueling outage will verify operational readiness for air-operated safety-
related valves supplied with air accumulators under all conditions.
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