United States Nuclear Regulatory Commission - Protecting People and the Environment

ACCESSION #: 9609120272

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

                                             James J.  Fisicaro
                                             Nuclear Safety
                                             Waterford 3


September 10, 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
          Follow-up Report: Part 21 Reporting of Defects and
          Noncompliance Interim Report


The purpose of this letter is to provide a follow-up report to the
Waterford 3 letter W3F1-96-0114 dated July 29, 1996, "Part 21, Interim
Report," regarding seven commercial grade Barksdale pressure switches
purchased by Waterford 3.  As communicated in the interim report, six of
the pressure switches were returned to the vendor because of a high
failure rate (three of seven) during dedication testing.  None of the six
switches were dedicated nor were they installed in the plant.  The
Waterford 3 dedication process did what it was designed to do.

One of the pressure switches that successfully passed the dedication test
had been installed in the plant.  There was no safety or operability
concern with that pressure switch.  However, Waterford 3 did further
evaluation of the installed switch prior to performing a conclusive
reportability determination.  Also, in an effort to exercise timely and
effective communications, Waterford 3 voluntarily chose to submit the
interim report under the 10 CFR Part 21 reporting guidelines.

This letter provides a final reportability determination and the basis
for having reached that determination.  There is no defect or
noncompliance reportable under 10 CFR Part 21 associated with the
Barksdale D1T-A150SS pressure switch dedicated and installed in the

Follow-up Report: Part 21 Reporting of Defects and Noncompliance Interim
Page 2
September 10, 1996

The vendor acknowledged that the same fault was common in three of the
six returned switches.  The identified fault was visual cracks in the
weld joining the diaphragm capsule together.  This data correlates with
Waterford 3's initial assessment of the defective instruments.  Two of
the three defective units had date codes of January 16, 1996; and, the
date code of the third defective unit was illegible.  The cause of the
defects have been identified by Barksdale as creepage in dimensions of
the two halves of the welded metal diaphragm pressure capsule.  Also,
contributing to the defect was a change in the weld schedule for the
welded metal diaphragm pressure capsule to facilitate manufacture.
Further, Barksdale has classified the defect as an "infant mortality"
type of failure.  This type failure should occur within the first two to
three cycles of a rated 1,000,000 cycle service life.  Although defective
date codes or lots have not been specifically identified, the period of
defective manufacture occurred sometime in late 1995 and in early 1996.
Barksdale believes that the defective capsule problem has been addressed
through testing and is not present in the units they are currently
manufacturing.  The pressure switch installed by Waterford 3 indicates a
manufacturing date of April, 1995 (e.g., outside of the suspect
manufacturing period).

Further, field conditions subject the installed switch to continuous
pressure from the instrument air system; and, this pressure is equal to
the operating pressure of the instrument air system.  The installed
switch has been operating for five months with no failure.  This
performance, along with the dedication testing and calibration,
demonstrates that the identified defect is not present in the installed
switch.  Waterford 3 has adequately and conclusively evaluated this issue
based on the information provided above.

Waterford 3 would like to take this opportunity to update the status of
corrective actions, thereby resolving any needed follow-up with regard to
this issue.  Corrective action associated with the seismic considerations
as set forth in the FSAR related to the installed application have been
identified.  Those actions include training of engineers performing
commercial grade dedications, procedural enhancements and the review of
similar dedication packages.  Waterford 3 Design Engineering is still
expecting shipment of the replacement pressure switch for the Barksdale
installed instrument.  And, as previously communicated in the

Follow-up Report: Part 21 Reporting of Defects and Noncompliance Interim
Page 3
September 10, 1996

interim report, this replacement package was initiated and approved
unrelated to the discovery of this issue.  Also, this information was
communicated to the industry through INPO's Nuclear Network Operating
Experience Program.

Waterford 3 appreciates and welcomes the opportunity to share concerns
with the NRC as well as with the industry.  We sincerely hope that by
promoting and exercising an open and forthcoming line of communications
amongst ourselves, with the NRC and with the industry that high standards
of communication and engineering will be evident.

Should you have any questions please contact me at (504) 739-6242 or Tim
Gaudet at (504) 739-6666.

Very truly yours,

J.J.  Fisicaro
Nuclear Safety


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


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