ML20083K900
| ML20083K900 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 05/11/1995 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-95-0072, W3F1-95-72, NUDOCS 9505150222 | |
| Download: ML20083K900 (4) | |
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& g, F ENTERGY 4"'*a's"""*"*""*'
Kfm1 LA 70066 Tel 504 739 6774 R. F. Burski Dwicr.
' Nudcar Seitety Waterford 3 W3F1-95-0072 A4.05 PR-May 11, 1995
' 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 95-03 Reply to Notice of Violation Gentlemen:
In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in Attachment I the response to the violation identified in Appendix A of the subject Inspection Report.
If ycu have any questions concerning this response, please contact W.H. Pendergrass at (504) 739-6254.
Very truly yours, I Q cM
's R.F. Burski j
Director Nuclear Safety RFB/WHP/tjs Attachment cc:
L.J. Callan (NRC Region IV), C.P. Patel (NRC-NRR),
R.B. McGehee, N.S. Reynolds, NRC Resident Inspectors Office 9505150222'950511 PDR' ADOCK 05000382 Q
PDR d\\
U c Attachment to W3F1-95-0072 3
Page 1 of 3 ATTACHMENT 1 ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN APPENDIX A 0F INSPECTION REPORT 95-03 VIOLATION NO. 9503-01 During an NRC inspection conducted on February 5 through March 18, 1995, one violation of NRC requirements was identified.
In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:
A.
Technical Specification 6.8.1.a requires, in part, that written procedures be established, implemented, and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A,
" Quality Assurance Program Requirements," Section 3.s.2.a requires the licensee to develop procedures for the emergency diesel generator.
Contrary to the above, the licensee's Operating Procedure OP-600-007,
" Annunciator Response - Diesel Generator A or B Local Panel,".7, " Engine Overspeed," and Attachment 4.9, " Generator Differential," and Operating Procedure OP-009-002, " Emergency Diesel Generator," related to operation of the emergency diesel generator did not specify how to reset the emergency diesel generator following a trip during a safety injection actuation signal.
This is a Severity Level IV violation.(VIO 382/9503-02)
BLSPONSE (1)
Reason for the Violation Entergy Operations Inc. admits this violation but has determined that the problem identified by the violation was not due to a procedural deficiency.
The root cause of this violation is believed to be an operator knowledge weakness due to a deficiency in maintaining Nuclear Auxiliary Operator (NAO) proficiency in resetting Emergency Diesel Generator trips.
It was believed that the task of resetting the Emergency Diesel Generator could be accomplished using " toolbox" or " skill-of-the-trade" knowledge. While this is probably true in the case of licensed personnel, who undergo rigorous Job Performance Measure (JPM) based qualification and refresher training,
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Page 2 of 3
-it-has not been the case for Nuclear Auxiliary Operators (NA0's).
Operations-. Training ' department personnel had identified the need for a,more consistent method for NA0's to demonstrate their ability'to perform vital-tasks (2)
Corrective Steps That Have Been Taken and the Results Achieved When.it.was understood that a deficiency existed, a Condition Report (CR 95-225) was written to enter the event into the corrective action program, and the Operations Superintendent issued a Daily Instruction requiring NA0's to discuss Emergency Diesel Generator (EDG) reset' processes with their int ividual supervisors during' field walkdowns.
Additionally, Operations Training began additional field walkdowns with NA0's to ensure a complete understanding of the EDG resetting process.
This was completed by 4/18/95.
For procedural enhancement, operations personnel implemented a change to OP-600-007, " Annunciator Response - Diesel Generator A or B Local Panel."
This procedure change provided specific guidance for the resetting of the EDG.
Additionally, controlled copies of these response procedures were placed in each EDG room to allow for easy operator reference.
This was completed on 4/15/95.
(3)
Corrective Steos Which Will Be Taken to Avoid Further Violations The initial NA0 training provides NA0's with sufficient knowledge to perform desired EDG evolution's. Over time, these abilities may degrade in some cases. Operations Training is in'the process.of performing a detailed-review of Nuclear Auxiliary Operator training for Emergency Diesel Generator tasks, per training request TR-95-050, and will determine if enhancements are desirable. This review will cover content of lesson plans, frequency of refresher training, walkdown guides, and qualification cards as applicable. These reviews, in addition to the actions undertaken by Operations will ensure that appropriate attention is applied to the issue of classroom and on-shift training and knowledge retention.
In order to determine if other operator knowledge concerns need to be addressed, Operations will review the effectiveness of the NA0 Observation-Program, and implement improvements if needed.
q Additionally, Operations Training will provide EDG refresher training to Nuclear Auxiliary Operators.
E' l
1 Attachment to l
5 W3F1-95-0072 Page 3 of 3 A combined effort will be made by Operations and Operations Training to review classroom and on-shift NA0 training philosophies and practices, and make improvement recommendations, as necessary.
Operations department personnel will review existing guidance to determine whether procedures are properly checked for level of detail during technical reviews.
(4)
Date When Full Compliance Will Be Achieved Based on the completed immediate corrective measures Waterford is in full compliance. Although not part of the specific corrective actions for this violation, the additional conservative measures listed in Item (3) above are scheduled to be completed by 12/15/95.