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RIV: 98-23
June 18, 1998
The U.S. Nuclear Regulatory Commission Staff has proposed a civil penalty of $110,000 against Entergy Operations, Inc., operator of Waterford Steam Electric Station, Unit 3, a nuclear power plant near Taft, Louisiana, for violations of NRC requirements concerning cooling water flow in the high pressure safety injection system (HPSI). The HPSI system provides an emergency source of water during a loss-of-coolant accident to keep the nuclear fuel from overheating.
The violations were identified during an engineering team inspection completed February 5, and were the subject of a predecisional enforcement conference on March 26.
As a result of questions raised by NRC during the inspection, Entergy engineers realized on December 5, 1997, that their design analysis did not demonstrate that the flow of cooling water in the HPSI system would be sufficient to cool the nuclear core during certain accidents. Entergy engineers had not adequately accounted for uncertainties in test instrumentation used to measure HPSI flow rate when the system was tested the previous summer.
HPSI flow is one component in the analysis of emergency core cooling capability. This assessment is part of the plant's safety analysis, which is used as the basis for granting an operating license. Any potential failure to meet the requirements for emergency core cooling capability, as determined using approved analysis techniques, must be reported to the NRC within one hour. Entergy did not communicate that conclusion to the NRC until specifically asked by the NRC team on December 18, 1997. It sent the required formal report the same day.
On December 17, 1997, the NRC approved a new method of analyzing emergency core cooling capability during accidents. Using an evaluation based on the new method, Entergy engineers demonstrated to the NRC's satisfaction that flow in the HPSI system had been adequate to maintain plant safety, and there likely were no safety consequences. A complete re-analysis of the emergency core cooling system function during a small break loss of coolant accident using the new method has been submitted for NRC review.
NRC also found there had been several earlier opportunities for Entergy personnel to have identified and corrected the HPSI problem. The NRC concluded that there was a failure of the Waterford-3 engineering program to: (1) aggressively pursue such issues when first identified, and (2) to pursue such issues without prompting by the NRC.
NRC staff classified these violations as a Severity Level III problem, which carries a base civil penalty of $55,000. Because discovery of the problem was prompted by NRC's engineering team inspection, and the licensee's initial actions upon recognizing the problem were not prompt and not in compliance with reporting requirements, and because Waterford has been the subject of other civil penalties during the past two years (May 1997 -- $55,000) the base civil penalty in this case was doubled to $110,000.
In a letter to Entergy, NRC Regional Administrator Ellis Merschoff said, ". . . to emphasize the importance of maintaining the integrity of the licensing basis and aggressively pursuing indications that key assumptions in the licensing basis may have been flawed in a manner important to safety, I have been authorized . . . to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of $110,000 for the violations involving HPSI flow uncertainties."
The NRC uses a four-level scale to rate the severity of violations, with Severity Level I being the most serious. Entergy Operations, Inc. has 30 days to respond in writing to the NRC's Notice of Violation. The response must document specific actions taken to prevent recurrence of the violations. During this time the company may pay the fine or file a protest.
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