United States Nuclear Regulatory Commission - Protecting People and the Environment

ACCESSION #:  9608010076

                                        Entergy Operations, Inc.
                                        P.O. Box B
Entergy                                 Killona, LA 70066
                                        Tel 504 739 6242

                                        James J.  Fisicaro
                                        Nuclear Safety
                                        Waterford 3


July 29, 1996

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
          Part 21 Reporting of Defects and Noncompliance Interim Report


The purpose of this letter is to comply with 10CFR 21.21(a)(2) which
states that if an evaluation of an identified deviation or failure to
comply potentially associated with a substantial safety hazard cannot be
completed within 60 days from discovery of the deviation or failure to
comply, an interim report is to be submitted describing the deviation
under evaluation and the date for completion of the evaluation.

Seven commercial grade Barksdale pressure switches, Model D1T-A150SS were
purchased as quality class 3 through Alpha Process Sales.  A commercial
grade dedication evaluation was approved for use on accumulators for the
Feed Water Isolation Valves and Component Cooling Water Isolation Valves
to the Dry Cooling Towers.  The Feed Water and Component Cooling Water
Isolation Valves are active safety related components.  The function of
the pressure switch is to indicate when instrument air accumulator
pressure for these valves falls below an acceptable value.  This
indication is not a safety related function.  The pressure switch
interfaces with a non-safety annunciator power supply.  The pressure
switch forms part of the pressure boundary of the accumulator.  This is a
passive safety related function.  Thus, the pressure switch is classified
as a passive safety related component with a safety function of
maintaining pressure integrity.

Part 21 Reporting of Defects and Noncompliance Interim Report
Page 2
July 29, 1996

One of the seven switches received was successfully tested by Waterford 3
for its intended use, dedicated and installed on Component Cooling Water
to the Dry Cooling Tower Isolation Valve during a component outage.  The
dedication test required the switch to be connected to a clean source of
instrument air and pressurized to 187.5 psig.  The switch was then
inspected for leakage from the diaphragm housing after a hold time of
fifteen minutes.  The test was conducted within the limits of the
manufacturer's (Barksdale) published specification.  The test
was designed to demonstrate the items function of maintaining pressure
boundary.  No discrepancies were identified.

A field inspection has been performed to determine in-service leakage.
The switch was carefully examined along the process inlet connection,
lower housing and conduit opening.  There was no presence of leakage.
Because the pressure switch functions to detect any abnormalities in the
accumulator supply for the CCW Isolation Valve, leakage of the magnitude
observed when testing the defective switches would likely cause an
actuation of the alarm point controlled by this switch.  This alarm would
be noted and the condition of the accumulator and pressure would be
investigated and evaluated.  No operability concerns have been posted
against this pressure switch.  Also, a periodic task to calibrate this
switch every 18 months provides a further opportunity to note failure of
this switch.  At this time, there is no evidence to dispute performance
of the pressure switch installed.

The seismic qualification of the switch was justified by comparison to
similar Barksdale pressure switches which had undergone seismic prototype
testing.  However, this method has been identified as a nonconformance
with the requirements of FSAR Appendix 3.10A.  This switch is subject to
FSAR criteria for seismic qualification of non-nsss seismic category 1
instrument considerations.  It has been determined that this dedication
did not adequately address seismic considerations as set forth in the
FSAR.  Corrective action to address this nonconformance is in progress.

Unrelated to the discovery of this potential Part 21, Design Engineering
has initiated documentation to replace the installed Barksdale pressure
switch.  This change is based on Setpoint Document Change Package SPC 95-
003-0 which has been approved.  Design Engineering is currently awaiting
receipt of the new pressure switch.

Part 21 Reporting of Defects and Noncompliance Interim Report
Page 3
July 29, 1996

While testing the remaining six switches, three of the six failed at
approximately 30 psig of pressure.  The test was terminated at this point
and inspection showed that the leakage was along the diaphragm seam.  The
failures were documented in accordance with the Waterford 3 corrective
action program.  All six pressure switches were then removed from
inventory and placed on hold.  None of the six switches were dedicated
nor were they installed in the plant.  The dedication process did what it
is designed to do.

The failures identified by the Waterford 3 dedication testing process
were reviewed for 10CFR Part 21 reportability on May 28, 1996.  This
review was recorded as a potential Part 21 and the reportability
determination was categorized as "indeterminate." Waterford 3 returned
the six pressure switches to Barksdale Inc. on June 6, 1996 and requested
that a detailed failure analysis be forwarded to Waterford 3 by August 6,
1996.  Since the failure analysis has yet to be received, Waterford 3 is
submitting this interim report.  Upon receipt of the vendor's evaluation,
results will be evaluated and immediately followed by a final part 21
reportability determination.  As of July 26, the vendor was still
gathering information from Waterford 3.  Nevertheless, we anticipate
providing the necessary follow-up to this interim report by September 10,

Since Waterford 3 purchased these parts as commercial grade we realize
that the responsibility for assuring quality in a safety related
application lies with us.  Given that the intent of part 21 was to invoke
accountability primarily upon vendors and suppliers for the nuclear
industry we feel that this interim report is conservative in nature.
However, at this time the part 21 guidelines appear to be the most
effective way of communicating this issue and in an effort to present
this information in a timely manner we have chosen to apply the 60 day
interim report submittal.

Part 21 Reporting of Defects and Noncompliance Interim Report
Page 4
July 29, 1996

This information will be communicated to the industry through INPO's
Nuclear Network Operating Experience Program.  Should you have any
questions please contact me at (504) 739-6242 or Tim Gaudet at (504) 739-

Very truly yours,

J.J.  Fisicaro
Nuclear Safety


cc:  L. J.  Callan, NRC Region IV
     C. P.  Patel, NRC-NRR
     R. B.  McGehee
     N. S.  Reynolds
     NRC Resident Inspectors Office


Page Last Reviewed/Updated Thursday, March 29, 2012