ML061280073
| ML061280073 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 04/25/2006 |
| From: | Entergy Nuclear South |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML061280073 (12) | |
Text
Commitment Summary Report CCEF Commitment Commitment Number Number Description Reason for Change/Deletion 2004-0023 P14664 Security department THIS COMMITMENT CAN BE CLOSED AS IT IS NOT A VALID initiated a procedure for the COMMITMEN BASED ON THE DEFINITION OF A COMMITMENT AS purpose of establishing DEFINED IN LI-110 AND NEI 99-05. THE SOURCE OF THIS security requirements for COMMITMENT WAS NOT A DOCKETED LETTER SUBMITTED TO penetrating protected area THE NRC, THE SOURCE OF THIS COMMITMENT IS NRC and vital area barriers, and INSPECTION REPORT 86-23. BASED ON THIS, THIS ITEM IS NOT the proper method for REQUIRED TO BE TRACKED IN CMS AND IS BEING DELTED.
obtaining necessary ADDITIONALLY, THE WATERFORD 3 PHYSICAL SECURITY PLAN approvals prior to making (PSP) REQUIRES THAT CONTROLS BE IN PLACE WHEN penetrations. PENETRATING PA AND VA BARRIERS. SINCE THIS IS A REGULATORY OBLIGATION CONTAINED IN THE WATERFORD 3 PHYSICAL SECURITY PLAN A COMMITMENT IS REDUNDANT AND IS NOT NEEDED.
2004-0024 P22312 Revise PS-012-109 in THE NEW PHYSICAL SECURITY PLAN GOVERNS MAINTENANCE accordance with ACTIVITIES ASSOCIATED WITH SECURITY EQUIPMENT. THE commitment made per REQUIRED MAINTENANCE ACTIVITIES ARE IMPLEMENTED BY W3F192-0148 in response PS-012-109. SINCE THIS IS A REGULATORY OBLIGATION to violation 9205-01. (The CONTAINED IN THE WATERFORD 3 PHYSICAL SECURITY PLAN response letter was THIS COMMITMENT IS REDUNDANT AND IS NOT NEEDED.
safeguards therefore actual MAINTENANCE ACTIVITIES OF SECURITY EQUIPMENT ARE text will not be displayed.) REQUIRED BY THE WATEFFORD 3 PHYSICAL SECURITY PLAN AND MUST BE PERFORMED. THESE ACTIVITIES ARE ADEQUATELY IMPLEMENTED IN SITE PROCEDURE PS-012-109.
Tuesday, April 25, 2006 Page 1 of 12
CCEF Commitment Commitment Number Number Description Reason for Change/Deletion 2004-0025 P24965 Reconsideration of nucler IT IS NOT A VALID COMMITMEN BASED ON THE DEFINITION OF A power security COMMITMENT AS DEFINED IN LI-110 AND NEI 99-05. THE requirements associated SOURCE OF THIS COMMITMENT IS RECOMMENDED with an internal threat ENHANCEMENTS TAKEN IN RESPONSE TO AN EVALUATION OF NRC GENERIC LETTER 96-02. THEREFORE, THIS ITEM IS NOT REQUIRED TO BE TRACKED IN CMS AND IS BEING DELTED.
ADDITIONALLY, NRC ORDER EA-03-086 SUPERSEDED RECOMMENDATIONS CONTAINED IN THIS GENERIC LETTER.
THE WATERFORD 3 PHYSICAL SECURITY PLAN (PSP) WAS DEVELOPED TO IMPLEMENT THE NRC ORDER REQUIREMENTS.
THESE ACTIONS ARE SUPERCEDED AND CAN BE CLOSED. NRC ORDER EA-03-086 SUPERSEDED RECOMMENDATIONS CONTAINED IN THIS GENERIC LETTER. CONTROLS ARE STILL IN PLACE TO IMPLEMENT REGULATORY RERQUIREMENTS REGARDING PERSONNEL ACCESS CONTROL.
2004-0026 P25094 NRC inspection report 98- WITH IMPLEMENTATION OF THE NEW PHYSICAL SECURITY 05 reply to notice of PLAN, CONTROLS ARE REQUIRED TO BE IN PLACE TO ENSURE violation. Revise DERAILER IS SECURE. OBSERVATIONS TO DETERMINE procedure PS-015-01 to DERAILER CONFIGURATION ARE PART OF SECURITY PATROLS.
require security officers to SINCE THIS IS A REGULATORY OBLIGATION CONTAINED IN THE contact CAS or SAS upon WATERFORD 3 PHYSICAL SECURITY PLAN A COMMITMENT IS discovery of a derailer REDUNDANT AND IS NOT NEEDED.
deficiency.
Tuesday, April 25, 2006 Page 2 of 12
CCEF Commitment Commitment Number Number Description Reason for Change/Deletion 2004-0027 P25242 P25243 SECURITY PROCEDURE WITH IMPLEMENTATION OF THE NEW PHYSICAL SECURITY PS-012-102 WILL BE PLAN, THE .02 FT CANDLE LIGHTING REQUIREMENT HAS BEEN REVISED TO INCLUDE ELMINATED FROM THE WATERFORD 3 PHYSICAL SECURITY STEPS REQUIRING PLAN, THEREFORE, THIS COMMITMENT IS NO LONGER SECURITY OFFICERS TO REQUIRED. LIGHTING REQUIREMENTS HAVE BEEN REVISED, NOTIFY SECURITY CURRENT LIGHTING REQUIREMENTS ARE ADEQUATELY SUPERVISION IMPLEMENTED IN SITE PROCEDURES.
IMMEDIATELY UPON COMPLETION OF THEIR FIRST EVENING PATROL OF TEMPORARY LIGHTING DEFICIENCIES.
SECURITY WILL BE REQUIRED TO CONTACT THE RESPONSIBLE DEPARTMENT FOR REPAIRS AND REQUEST THE TEMPORARY LIGHTING PROBLEMS BE CORRECTED. A LIGHT METER WILL BE PROVIDED TO SECURITY PERSONNEL FOR USE IN SURVEYING AREAS FOR PROPER LIGHTING.
Tuesday, April 25, 2006 Page 3 of 12
CCEF Commitment Commitment Number Number Description Reason for Change/Deletion 2004-0030 14665 W3SES SECURITY THIS COMMITMENT CAN BE CLOSED. THIS IS NOT A VALID FORCE PORTABLE COMMITMENT AS DEFINED IN LI-11O AND NEI-99-05. THE RADIO LOG" IS IN USE SOURCE OF THE COMMITMENT WAS NOT A DOCKETED LETTER AT WATERFORD 3 TO SUBMITTED TO THE NRC. THE SOURCE OF THIS COMMITMENT DOCUMENT THE IS NRC INSPECTION REPORT 86-14. THEREFORE, THIS ITEM IS TESTING OF HAND-HELD NOT REQUIRED TO BE TRACKED IN CMS AND IS BEING RADIOS ISSUED BY ON- DELETED. ADDITIONALLY, THE WATERFORD 3 PHYSICAL DUTY SHIFT PERSONNEL SECURITY PLAN REQUIRES THAT CONTROLS BE IN PLACE TO TEST SECURITY COMMUNICATIONS EQUIPMENT. SINCE THIS IS A REGULATORY OBLIGATION CONTAINED IN THE WATERFORD 3 PHYSICAL SECURITY PLAN A COMMITMENT IS REDUNDANT AND IS NOT NEEDED.
2004-0032 P9791 EA-85-10 Response: ME-004-703 was revised and will continue to be performed as part of Meggering Inspections of the permanent preventive maintenance program. The procedyre now Plant Equipment requires that meggering inspections of plant equipment be performed prior to hot standby - mode 3 after planned outages and/or extended shutdown in excess of 30 days. An attachment to the procedure specifies the equipment. The intent of this inspection is to verify equipment operability and condition prior to equipment energization in Mde 3.
2004-0034 P15111 TEST AND INSPECTION - Parent document is FSAR but with TS Amendement 192 Hydrogen HYDROGEN Recominers are not required for Hydrogen mitigation. TS amendment RECOMBINER 192, ER-W3-2004-0373 elminated the requirement associated with the Hydrogen Recombiners. Implementing document ME-003-030 is being deleted and the requirement for demonstrating operability no longer exists.
2004-0035 P1513 LEAK TESTING TS amendment 192, ER-W3-2004-0373 eliminated the requirement REACTOR COOLANT associated with the Hydrogen Recombiners. Implementing document GAS VENT VALVES ME-003-010 is being deleted and the requirement for demonstrating operability no longer exists.
Tuesday, April 25, 2006 Page 4 of 12
CCEF Commitment Commitment Number Number Description Reason for Change/Deletion 2004-0036 P1515 CONTAINMENT TS amendment 192, ER-W3-2004-0373 eliminated the requirement ELECTRIC HYDROGEN associated with the Hydrogen Recombiners. Implementing document RECOMBINER - VISUAL ME-003-030 is being deleted and the requirement for demonstrating EXAMINING operability no longer exists.
2004-0037 P1517 CONTAINMENT TS amendment 192, ER-W3-2004-0373 eliminated the requirement ELECTRIC HYDROGEN associated with the Hydrogen Recombiners. Implementing document RECOMBINER - ME-003-030 is being deleted and the requirement for demonstrating RESISTANCE TO operability no longer exists.
GROUND TEST 2005-0001 14666 Procedure for security The requirement for reporting Security related events is a regulatory reporting requirements and requirement contained in 10CFR 73 Appendix G. Actions intiated by the safeguards contingency commitment P14666 were made to ensure compliance with this plan has been revised to regulatory requirement. 10CFR73 is the regulatory obligation the legal include requirements for authority for the reporting security related events and a sperate rerporting security related commitment is redundant and is not nceccessary. Therefore this events commitment is not needed and can be deleted.
Tuesday, April 25, 2006 Page 5 of 12
CCEF Commitment Commitment Number Number Description Reason for Change/Deletion 2005-0003 26728 W3F1-2004-0058, dated This change is acceptable because commitment 26728's intent will be July 27, 2004, Response maintained, that is, NOECP-107 will be revised to ensure all Alloy 600 to NRC Bulletin 2004-01 pressurizer nozzle to safe end welds and large bore steam space Regarding Inspection of welds documented in the response to NRC Bulletin 2004-01 have Alloy 82/182/600 Materials been incorporated into the procedure. Of the 41 Alloy 600 welds Used In Pressurizer identified in the response to NRC Bulletin 2004-01, 37 are presently Penetrations and Steam captured in the procedure. The pressurizer large bore steam space Space Piping Connections welds, consisting of the 3 safety relief nozzles and 1 spray nozzle, have not been incorporated into the procedure at this time. However, the bare metal inspection of these 4 welds will be documented in the procedure as additional welds inspected to ensure inspection of all applicable Alloy 600 welds and compliance with commitment 26727.
Commitment 26727 documents the performance of the bare metal inspection of all applicable Alloy 600 welds for this outage and future refueling outages. The Mode 4 entry (containment closeout) completion date during plant startup will ensure the inspection of all the applicable Alloy 600 welds have been accomplished prior to plant restart.
2005-0004 P16838 Inadequate control of Deletion of commitment P16838, P16838 duplicates P17241, temporary modifications to therefore, P16838 should be deleted.
safety related systems 2005-0005 P22346 Observation: Review NRC Delete P-22346, does not meet the definition of a commitment or an comments on 10CFR 50.59 obligation as defined in NMM procedure ENS-LI-110. This item guidance documents and docements observations made by NRC Inspectors. These take action as appropriate. observations are not regulatory requirements that the licensee is required to meet, there are suggestions and recommendations only.
Tuesday, April 25, 2006 Page 6 of 12
CCEF Commitment Commitment Number Number Description Reason for Change/Deletion 2005-0006 P-2104 Proprietary Information The generic letter provides information related to emergency plans and marking of emergency implementing procedures or changes thereto that include personal plans and implementing information such as homephone numbers and home addresses. The procedures concern voiced in the generic letter has been included in 10CFR 2.390 which is referenced in LI-106 as the source document for handling proprietary information. 10CFR 2.390 is the allowance to withhold personal informatio if it could reasonably be expected to constitute an unwarranted invasion of personal privacy, therefore this obligation associated with GL 81-27 can be deleted.
2005-0007 P-1301 CHANGES IN THE P1301 duplicated P1293 therefore P-1301 is being closed to historical.
FACILITY AS DESCRIBED IN THE FSAR, CHANGES IN PROCEDURES AS DESCRIBED IN THE FSAR, CONDUCT TESTS OR EXPERIMENTS NOT DESCRIBED IN THE FSAR 2005-0008 P-17733 PLANT PROCEDURES - Commitment P-17733 was identified in letter W3F1-91-0383. This ESTABLISHED letter was written in 1991, proposed changes to the W3 QAPM. In MECHANISMS WHICH 1997, the W3 QPM was superceded by the NRC approved Entergy MAINTAIN PROCEDURES QAPM, thereforem this commitment is no longer applicable to W3.
CURRENT - 50.59 EVALUATIONS Tuesday, April 25, 2006 Page 7 of 12
CCEF Commitment Commitment Number Number Description Reason for Change/Deletion 2005-0009 P-21726 VIOLATION RESPONSE: 10CFR 50.9, "Completeness and accuracy of information" requires NOAP-047 ENSURES that information provided to the Commission be complete and accurate THAT MATERIAL in all material respects. The Waterford 3 commitment P-21726 closed STATMENTS MADE IN the violation reported by the NRC; however, it was not necessary.
CORRESPONDENCE Waterford 3 is obligated to comply with 10 CFR 50.9. Therefore, the WITH REGULATORY commitment is redundant to Waterford 3's obligation and can be AGENCIES ARE deleted.
FACTUAL AND ACCURATE 2005-0010 P-15322 REACTOR TRIP SYSTEM Change frequency of maintenance interval from 12 months to 24 RELIABILITY - months. Documented maintenance history for reactor trip breakers for MAINTENANCE the last 4 years, a search of maintenance rule data base indicated PROGRAM FOR there have been no functional failures or maintenance preventable REACTOR TRIP functional failures for the last 4 years (Jan 30 2000) for reactor trip BREAKERS breakers. The safey function of the reactor trip breakers are to open following activation of the CED mechanism by a reator trip signal. The reactor trip circuit breakers ability to close is not a safety function fo the breaker. Based on a historical review and justifacion provided in the CCEF it is Electrical;s position that the frequency can be changed to 24 months.
2005-0011 P-4398 REACTOR TRIP SYSTEM Change frequency of maintenance interval from 12 months to 24 RELIABILITY months.
(PREVENTATIVE MAINTENANCE AND SURVEILLANCE PROGRAM FOR REACTOR TRIP BREAKERS)
Tuesday, April 25, 2006 Page 8 of 12
CCEF Commitment Commitment Number Number Description Reason for Change/Deletion 2005-0012 P4689 PROJECT FILES<<1>>: Quality Assurance Program Manual (QAPM) contains station STORAGE AND requirements that must be implemented. The QAPM implements MAINTENANCE OF 10CFR50 Appendix B, Regulatory Guide 1.88 and ANSI N45.2.9.
UNCONTROLLED ANSI N45.2.9 addresses storage and maintenance of uncontrolled RECORDS records. The QAPM is implemented through the use of approved procedures, therefore, commitment P-4689 is no longer needed as it was issued to restore an obligation.
2005-0013 P-4690 DOCUMENT CONTROL: Quality Assurance Program Manual (QAPM) contains station MAINTENANCE OF requirements that must be implemented. The QAPM implements CONTROLLED 10CFR50 Appendix B, Regulatory Guide 1.88 and ANSI N45.2.9.
DOCUMENTS ANSI N45.2.9 addresses storage and maintenance of controlled documents. The QAPM is implemented through the use of approved procedures, therefore, commitment P-4690 is no longer needed as it was issued to restore an obligation.
2005-0014 P-9792 EA 85-10 RESPONSE: Quality Assurance Program Manual (QAPM) contains station MAINTENANCE OF QA requirements that must be implemented. The QAPM implements RECORDS DURING 10CFR50 Appendix B, Regulatory Guide 1.88 and ANSI N45.2.9.
OPERATIONS PHASE ANSI N45.2.9 addresses storage and maintenance of controlled documents. The QAPM is implemented through the use of approved procedures, therefore, commitment P-4690 is no longer needed as it was issued to restore an obligation.
2005-0015 A17781 EDSFI/DESIGN ENGR W3 nuc engineering analysis owns the DADBDs. It has been PROG ASSESS determined that the docs are no longer needed and will not be (ENHANCE) 3 EVENTS maintained. W3 now receives core core reload calcs from the fuel TO DEVELOP SADBD BY vendor as well as other calculations that contain inputs, assumptions 12/31/91; 6 EVENTS PER and results for safety analyses tht support design and licensing basis YR COMPLETE for W3. The cals provide necessary information for W3 engineers to DOCUMENTS BY perform day to day duties such that it is not necessary to maintain the 1995/CHNG TO 3 IN 92' SADBDs. The docs are being voided (made historical) in IDEAS and will no longer be used.
Tuesday, April 25, 2006 Page 9 of 12
CCEF Commitment Commitment Number Number Description Reason for Change/Deletion 2005-0018 A-2881 EMERGENCY PLAN NEI guidance states action taken to restore compliance with an APPRAISAL: DEVELOP obligation in not a commitment, therefore this action can be closed.
AND IMPLEMENT AN The commitment involves an Annual Training session for the media in ANNUAL MEDIA SEMINAR the Waterford 3 area on elements of the site Emergency Plan. It is addressed in secion 8.1.1.4 of the Waterford 3 Emergency Plan.
2005-0019 A24804 SUBMIT TSCR 97-09 FOR This is not an NRC commitment. It is being used as a place holder for ESFAS SUBGROUP a TSCR which is on the TSCR list maintained by Corporate Licensing.
RELAY TESTING The parent document is 10 FR 50.90 which is the regulation for INTERVAL EXTENSION submitting license changes.
2005-0020 P15140 TRAINING OF CONTRACT This is a duplicate of obligations delineated in the Entergy Quality PERSONNEL WORKING Assurance Program Manual (QAPM), section A.3.e and Table 1.g.2.
UNDER LP&L'S QA These sections of the QAPM continue to be listed in section 8.0 of En-PROGRAMTO 100 QV-111, "Training and certification of Inspection/Verification and PERCENT OF MEDP Examination Personnel."
2005-0022 P-9805 EA 85-10 RESPONSE: This is a duplicate of obligations delineated in the Entergy Quality CERTIFICATION OF Assurance Program Manual (QAPM), sections A.5, B.15. These INSPECTION sections of the QAPM continue to be listed in section 8.0 of EN-QV-PERSONNEL DURING 111, "Training and Certification of Enspections/verifcation and OPERATIONS PHASE Examination Personnel."
Tuesday, April 25, 2006 Page 10 of 12
CCEF Commitment Commitment Number Number Description Reason for Change/Deletion 2005-0023 P17326 POTENTIAL PROBLEMS Change frequency of disassembly and overhauling of AK type WITH METAL CLAD breakers from 5 years to 10 years. The safety function of the reactor CIRCUIT BREAKERS, trip circuit breaker is to open following activation of the Control GENERAL ELECTRIC Element Drive Mechanism by a reactor trip signal. The reactor trip TYPE AKF-2-25 circuit breakers ability to close in not a safety function of the breaker.
GE issued SIL number 448 rev 2 dated 3/9/04. GE states that most breaker failures were found to be due to misadjustment, lubrication or both. Ge recommends action for AK breakers to be lubricated with Mobil 28 grease and to perform breaker maintenance overhaul every 12 years. A search of the Maintenance Rule databse has found no Functional Failures or maintenance preventable functional failures for over 5 years for Reactor Trip breakers.
2005-0024 P15645 P16526 P165 VIOLATION: FAILURE TO These commitments were generated due to the non-conforming JUSTIFY THE condition of nonqualified 600 volt molded case circuit breakers ACCEPTABILITY OF installed in a safety related application for conrol room lighting. The NONCONFORMING bases for all actions associated with this event was the development of CIRCUIT BREAKERS FOR a procedure which would require the identification, operability CONTINUED USE determination, engineering evaluation, and development of corrective actions to resolvethe non-conforming condition. W3 developed and implemented procedure NOP-019 to handle non-conforming conditions such as this event. Subsequently, the NRC issued GL 91-18, W3 endhanced NOP-019 which was subsequently replaced by W4.101.
On 8/25/05 Entergy Copr proc EN-OP-104, Operability Determinations ws issued. This procedure incorporates all elements of W4.101 and ensures an overall fleet compliance with the regulations contained in GL 91-18. The GL 98-18 resolution of degraded and non-conforming conditions, philosophy has been ingrained into plant operations and procedures since its issuance in 1991. With the issuance of GL 91-18 and its incorporation into Entergy procedures these commitments not longer serve any purpose for insuring that evaluations of non-conforming equipment are completed in a timely manner and therefore are no longer necessary. There is reasonable assurance that procedures (e.g. EN-OP-104) that contain the guidance for evaluating nonconforming equipment will not be deleted following closure of the these commitments.
Tuesday, April 25, 2006 Page 11 of 12
CCEF Commitment Commitment Number Number Description Reason for Change/Deletion 2005-0025 A-15411 THERMAL STRESSES IN Commitment is being deleted..W3 calculation ECM-99-005 determined PIPING CONNECTED TO the portions of the Auxillary Spray piping which could be subjected to REACTOR COOLANT thermal stratification due to leakage of the control and check valves in SYSTEMS/UT SAME 30 the aux spray piping. (this info is included in RN-04-139 to piping WELDS EACH 10 YR design specification 1564.100B). The information from this calc was INTERVAL/RF 10 used in piping qual calc Im-2606, Rev. 1 and CN-CI-03-22 which is included as DRN 04-79 to piping qualification IM-1271-2). Note that DRN 03-429 to IM-2606 concluded that EPU did not have an effect on the thermal stratification transients. The results of these qualifications show that all of the piping meets the applicable design acceptance criteria. Furthermore, none of the welds in the region potentially subjected to thermal stratification would be considered high stressed as defined in Table IWB-2500-1 of ASME Section XI (see report ECP03-001 including DRN 03-2216). Since the effects of thermal stratification resulting from potential leakage have been included in the design of the piping with acceptable results, continued inspection of the affected pipe is not required.
Tuesday, April 25, 2006 Page 12 of 12