IR 05000382/1997015

Ack Receipt of 971014 Suppl Response Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/97-15

ML20212B603
Person / Time
Site:	Waterford
Issue date:	10/22/1997
From:	Harrell P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dugger C ENTERGY OPERATIONS, INC.
References
50-382-97-15, NUDOCS 9710280146
Download: ML20212B603 (5)

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%,, ' " * * , ' AnLINGToN.11XAs 760114064 OCT 2 21997 Charles M. Dugger, Vice President Operations Waterford 3 Entergy Operations, Inc. i P.O. Box B

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Killona, Louisiana 70000 SUBJECT: NRC INSPECTION REPORT 50 382/9715

Dear Mr. Dugger:

Thank you for your supplemental response letter of October 14,1997, as requested

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in our letter dated October 9,1997, and discussed with your staff on October 2,1997.

We have reviewed the corrections to your previous reply dated September 29,1997,and find them iesponsive to the concerns raised in our letter. We will review the implementation of your corrective actions during a future insp3ction to determine that full compliance has been echieved and will be mainta'ned.

Sincerely, 8 . Harrell, Chief Pro ict Branch D Division of Reactor Projects Docket No.: 50 382 License No.: NPF 38 ,

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I Executive Vice President and Chief Operating Officer (}

Entergy Operations, Inc.

P.O. Box 31995 Jackson, Mississippi 39280 1995 Vice President, Operations Support Entergy Operations, Inc. .

P.O. Box 31995 -

Jackson. Mississippi 39280 1995

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Director, Nuclect Sefety & l

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William H. Spell, Administrator Loulslana Radiation Protection Division P.O. Box 82135 j i

Baton Rouge, Loulslana 708d4 2135 Parish President

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October 14,1997

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U.S. Nuclear Regulatory Commission ATTN: Docume.it Control Desk Washington, D.C. 20555 Subject: .Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report 50 382/97-15 Revised Response to Notice of Violation Gentlemen:

As requested by the Staff in a telephone conversation on October 2,1997, Waterford 3 hereby submits in Attachment 1 the revised response to the violation 9715-03. The original violation response, which was provided in letter W3F1-97-0229, dated September 29,1997, listed corrective steps taken under the " Reason for the Violation" section instead of under the " Corrective Steps That Have Been Taken and the Results Achieved" section. This has been revised and revisions are annotated with revision bars. Additionally, we have added a statement under the " Corrective Steps Which Will Be Taken to Avoid Further Violations'section which supports why Waterford 3 is confident these corrective steps are adequate.

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NRC Inspection Report 9715 Revised Response to Notice of Violation W3U197 0239 Page 2 October 14,1997 We regret any inconvenience this may have caused. If you have any questions concerning this response. please contact me at (504) 739-6242 or Tim Gaudet at (504)739 6666.

Very truly yours,

E. . Ewing Director, .

Nuclear Safety & Regulatory Affairs ECE/DMUltjs Attachment:

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1. Entergy Operations, Inc. Response to Violation 9715-03 Identified in Enclosure 1 of Inspection Report 97-15 ,

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cc: ..E.W. Morschoff (NRC Region lV)

' ~ C.P. Patel(NRC-NRR)

J. Smith N.S. Reynolds NRC Resident inspectors Office

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ATTACHMENT TO 5 W3F197-0239 PAGE 1 OF 2 ATTACHMENT 1 ENTERGY OPERATIONS. INC. RESPONSE TO VIOLATION 9715-03 IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 97-15

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VIOLATION NO. 9715-03 10 CFR 50.65(a)(1) states, in part, that each holder of an operating license shall

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monitor the performance or condition of structures, systems, or components, against licensee-estehlished goals and such goals shall be established commensurate with safety.

10 CFR 50.65(a)(2) states, in part, that monitoring under paragraph (a)(1) is not required where it has been demonstrated that the performance or condition of a -

structure, system, or component is being effectively controlled through the performance of appropriate preventive maintenance such that the structure, system, or component remains capable of performing its intended safety function. Paragraph (c) states, "[t]he requirements of this section shall be implemented by each licensee no later than July 10,1996. "

Contrary to the above, as of January 1997, for the emergency lighting system, the licensee: (1) failed to establish goals commensurate with safety as described in 10 CFR 50,65(a)(1); or (2) as an alternative, failed to demonstrate that the performance of the above specified system was effectively controlled through the performance of appropriate preventive maintenance and that the system remained capable of performing its intended function in that neither the unavailability of the function performed by the system was monitored nor an acceptable alternative method for compliance proposed.

This is a Severity Level IV violation (Supplement 1) (50-38?J9715-03).

BESPONSE (1) Reason for the Violation Entergy admits this violation and believes it to be the result of inadequate manageme nt oversight. In September of 1996, the Maintenance Rule Expert Panel discussed the need to scope the Emergency Lighting System (LTE) into the Maintenance Rule. At the end of 1996, LTE was officially approved for entry into the Maintenance Rule by the Expert Panel. Subsequent to this, performance criteria for LTE were prepared and presented to the Expert

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I ATTACHMENT TO

W3F197-0239 ;

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, Panel. Differing interpretations of the industry's position on emergency lighting prevented the Expert Panel from reaching a consensus on the systems performance criteria. As a result of personnel turnover and an extended refueling outage, no further Expert Panel meetings were held.

Approval of LTE's Maintenance Rule function and criteria v e therotore not completed in a timely manner.

(2) Corrective Steps That Have Been Taken and the Results Achieved A review of systems scoped in the Maintenance Rule was performed to identify any other systems whose historical review may not be complete nr whose function and performunce criteria were not approved. In addition to LTE, it was determined that the communication / paging (CMP) and communication / radio (CMR) systems did not yet have a Maintenance Rule function or criteria approved by 'ht, Expert Panel. The maintenance history review of these systems is also not complete.

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(3) Corrective Steps Which Will Be Taken to Avoid Furthe Violations In accordance with 10 CFR50.65 paragraph (a)(2), provisions will be made to i monitor the reliability performance of the emergency lighting and the communication systems. Reliability criteria have been established, revie ved and approved by the Expert Panel. The maintenance history review of these systems is in progress and once completed will be reviewed against their respective (a)(2) reliability performance criteria. At that time, a system (a)(1)

or (a)(2) categorization will be made. If determined that (a)(1) status is warranted, then (a)(1) goals will be established.

The review described above identified all remaining systems that, although scoped in the Maintenance Rule, $ vere lacking a maintenance history review, an approved Maintenance Rule function and approved performance criteria.

Based on this review, Waterford 3 is confident thr.t the corrective actions specified above will avoid further vio!stions.

(4) Date When Full Compliance Will Be Achieved The above corrective actions arc in progress and will be completed by December 18,1997, when system categorizations will have been made. If warranted, (a)(1) goals will then be established. Upon completion of the above, Waterford 3 will be in full compliance.

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