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 Number Commitment Number Commitment Description Reason for Change/Deletion 2004-0023 P14664 Security department initiated a procedure for the purpose of establishing security requirements for penetrating protected area and vital area barriers, and the proper method for obtaining necessary approvals prior to making penetrations.
THIS COMMITMENT CAN BE CLOSED AS IT IS NOT A VALID COMMITMEN BASED ON THE DEFINITION OF A COMMITMENT AS DEFINED IN LI-110 AND NEI 99-05. THE SOURCE OF THIS COMMITMENT WAS NOT A DOCKETED LETTER SUBMITTED TO THE NRC, THE SOURCE OF THIS COMMITMENT IS NRC INSPECTION REPORT 86-23. BASED ON THIS, THIS ITEM IS NOT REQUIRED TO BE TRACKED IN CMS AND IS BEING DELTED.
ADDITIONALLY, THE WATERFORD 3 PHYSICAL SECURITY PLAN (PSP) REQUIRES THAT CONTROLS BE IN PLACE WHEN 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 accordance with commitment made per W3F192-0148 in response to violation 9205-01. (The response letter was safeguards therefore actual text will not be displayed.)
THE NEW PHYSICAL SECURITY PLAN GOVERNS MAINTENANCE ACTIVITIES ASSOCIATED WITH SECURITY EQUIPMENT. THE REQUIRED MAINTENANCE ACTIVITIES ARE IMPLEMENTED BY PS-012-109. SINCE THIS IS A REGULATORY OBLIGATION CONTAINED IN THE WATERFORD 3 PHYSICAL SECURITY PLAN THIS COMMITMENT IS REDUNDANT AND IS NOT NEEDED.
MAINTENANCE ACTIVITIES OF SECURITY EQUIPMENT ARE 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 Number Commitment Number Commitment Description Reason for Change/Deletion 2004-0025 P24965 Reconsideration of nucler power security requirements associated with an internal threat IT IS NOT A VALID COMMITMEN BASED ON THE DEFINITION OF A COMMITMENT AS DEFINED IN LI-110 AND NEI 99-05. THE SOURCE OF THIS COMMITMENT IS RECOMMENDED 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ADDITIONALLY, NRC ORDER EA-03-086 SUPERSEDED RECOMMENDATIONS CONTAINED IN THIS GENERIC LETTER.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 98-05 reply to notice of violation. Revise procedure PS-015-01 to require security officers to contact CAS or SAS upon discovery of a derailer deficiency.
WITH IMPLEMENTATION OF THE NEW PHYSICAL SECURITY PLAN, CONTROLS ARE REQUIRED TO BE IN PLACE TO ENSURE DERAILER IS SECURE. OBSERVATIONS TO DETERMINE DERAILER CONFIGURATION ARE PART OF SECURITY PATROLS.
SINCE THIS IS A REGULATORY OBLIGATION CONTAINED IN THE WATERFORD 3 PHYSICAL SECURITY PLAN A COMMITMENT IS REDUNDANT AND IS NOT NEEDED.
Tuesday, April 25, 2006 Page 2 of 12
CCEF Number Commitment Number Commitment Description Reason for Change/Deletion 2004-0027 P25242 P25243 SECURITY PROCEDURE PS-012-102 WILL BE REVISED TO INCLUDE STEPS REQUIRING SECURITY OFFICERS TO NOTIFY SECURITY SUPERVISION 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.
WITH IMPLEMENTATION OF THE NEW PHYSICAL SECURITY PLAN, THE.02 FT CANDLE LIGHTING REQUIREMENT HAS BEEN ELMINATED FROM THE WATERFORD 3 PHYSICAL SECURITY PLAN, THEREFORE, THIS COMMITMENT IS NO LONGER REQUIRED. LIGHTING REQUIREMENTS HAVE BEEN REVISED, CURRENT LIGHTING REQUIREMENTS ARE ADEQUATELY IMPLEMENTED IN SITE PROCEDURES.
Tuesday, April 25, 2006 Page 3 of 12
CCEF Number Commitment Number Commitment Description Reason for Change/Deletion 2004-0030 14665 W3SES SECURITY FORCE PORTABLE RADIO LOG" IS IN USE AT WATERFORD 3 TO DOCUMENT THE TESTING OF HAND-HELD RADIOS ISSUED BY ON-DUTY SHIFT PERSONNEL THIS COMMITMENT CAN BE CLOSED. THIS IS NOT A VALID COMMITMENT AS DEFINED IN LI-11O AND NEI-99-05. THE SOURCE OF THE COMMITMENT WAS NOT A DOCKETED LETTER SUBMITTED TO THE NRC. THE SOURCE OF THIS COMMITMENT IS NRC INSPECTION REPORT 86-14. THEREFORE, THIS ITEM IS NOT REQUIRED TO BE TRACKED IN CMS AND IS BEING DELETED. ADDITIONALLY, THE WATERFORD 3 PHYSICAL 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:
Meggering Inspections of Plant Equipment ME-004-703 was revised and will continue to be performed as part of the permanent preventive maintenance program. The procedyre now 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 -
HYDROGEN RECOMBINER Parent document is FSAR but with TS Amendement 192 Hydrogen Recominers are not required for Hydrogen mitigation. TS amendment 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 REACTOR COOLANT GAS VENT VALVES TS amendment 192, ER-W3-2004-0373 eliminated the requirement associated with the Hydrogen Recombiners. Implementing document ME-003-010 is being deleted and the requirement for demonstrating operability no longer exists.
Tuesday, April 25, 2006 Page 4 of 12
CCEF Number Commitment Number Commitment Description Reason for Change/Deletion 2004-0036 P1515 CONTAINMENT ELECTRIC HYDROGEN RECOMBINER - VISUAL EXAMINING TS amendment 192, ER-W3-2004-0373 eliminated the requirement associated with the Hydrogen Recombiners. Implementing document ME-003-030 is being deleted and the requirement for demonstrating operability no longer exists.
2004-0037 P1517 CONTAINMENT ELECTRIC HYDROGEN RECOMBINER -
RESISTANCE TO GROUND TEST TS amendment 192, ER-W3-2004-0373 eliminated the requirement associated with the Hydrogen Recombiners. Implementing document ME-003-030 is being deleted and the requirement for demonstrating operability no longer exists.
2005-0001 14666 Procedure for security reporting requirements and the safeguards contingency plan has been revised to include requirements for rerporting security related events The requirement for reporting Security related events is a regulatory requirement contained in 10CFR 73 Appendix G. Actions intiated by commitment P14666 were made to ensure compliance with this regulatory requirement. 10CFR73 is the regulatory obligation the legal authority for the reporting security related events and a sperate commitment is redundant and is not nceccessary. Therefore this commitment is not needed and can be deleted.
Tuesday, April 25, 2006 Page 5 of 12
CCEF Number Commitment Number Commitment Description Reason for Change/Deletion 2005-0003 26728 W3F1-2004-0058, dated July 27, 2004, Response to NRC Bulletin 2004-01 Regarding Inspection of Alloy 82/182/600 Materials Used In Pressurizer Penetrations and Steam Space Piping Connections This change is acceptable because commitment 26728's intent will be maintained, that is, NOECP-107 will be revised to ensure all Alloy 600 pressurizer nozzle to safe end welds and large bore steam space welds documented in the response to NRC Bulletin 2004-01 have been incorporated into the procedure. Of the 41 Alloy 600 welds identified in the response to NRC Bulletin 2004-01, 37 are presently captured in the procedure. The pressurizer large bore steam space 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 temporary modifications to safety related systems Deletion of commitment P16838, P16838 duplicates P17241, therefore, P16838 should be deleted.
2005-0005 P22346 Observation: Review NRC comments on 10CFR 50.59 guidance documents and take action as appropriate.
Delete P-22346, does not meet the definition of a commitment or an obligation as defined in NMM procedure ENS-LI-110. This item docements observations made by NRC Inspectors. These 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 Number Commitment Number Commitment Description Reason for Change/Deletion 2005-0006 P-2104 Proprietary Information marking of emergency plans and implementing procedures The generic letter provides information related to emergency plans and implementing procedures or changes thereto that include personal information such as homephone numbers and home addresses. The 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 FACILITY AS DESCRIBED IN THE FSAR, CHANGES IN PROCEDURES AS DESCRIBED IN THE FSAR, CONDUCT TESTS OR EXPERIMENTS NOT DESCRIBED IN THE FSAR P1301 duplicated P1293 therefore P-1301 is being closed to historical.
2005-0008 P-17733 PLANT PROCEDURES -
ESTABLISHED MECHANISMS WHICH MAINTAIN PROCEDURES CURRENT - 50.59 EVALUATIONS Commitment P-17733 was identified in letter W3F1-91-0383. This letter was written in 1991, proposed changes to the W3 QAPM. In 1997, the W3 QPM was superceded by the NRC approved Entergy QAPM, thereforem this commitment is no longer applicable to W3.
Tuesday, April 25, 2006 Page 7 of 12
CCEF Number Commitment Number Commitment Description Reason for Change/Deletion 2005-0009 P-21726 VIOLATION RESPONSE:
NOAP-047 ENSURES THAT MATERIAL STATMENTS MADE IN CORRESPONDENCE WITH REGULATORY AGENCIES ARE FACTUAL AND ACCURATE 10CFR 50.9, "Completeness and accuracy of information" requires that information provided to the Commission be complete and accurate in all material respects. The Waterford 3 commitment P-21726 closed the violation reported by the NRC; however, it was not necessary.
Waterford 3 is obligated to comply with 10 CFR 50.9. Therefore, the commitment is redundant to Waterford 3's obligation and can be deleted.
2005-0010 P-15322 REACTOR TRIP SYSTEM RELIABILITY -
MAINTENANCE PROGRAM FOR REACTOR TRIP BREAKERS Change frequency of maintenance interval from 12 months to 24 months. Documented maintenance history for reactor trip breakers for the last 4 years, a search of maintenance rule data base indicated there have been no functional failures or maintenance preventable functional failures for the last 4 years (Jan 30 2000) for reactor trip 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 RELIABILITY (PREVENTATIVE MAINTENANCE AND SURVEILLANCE PROGRAM FOR REACTOR TRIP BREAKERS)
Change frequency of maintenance interval from 12 months to 24 months.
Tuesday, April 25, 2006 Page 8 of 12
CCEF Number Commitment Number Commitment Description Reason for Change/Deletion 2005-0012 P4689 PROJECT FILES<<1>>:
STORAGE AND MAINTENANCE OF UNCONTROLLED RECORDS Quality Assurance Program Manual (QAPM) contains station requirements that must be implemented. The QAPM implements 10CFR50 Appendix B, Regulatory Guide 1.88 and ANSI N45.2.9.
ANSI N45.2.9 addresses storage and maintenance of uncontrolled 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:
MAINTENANCE OF CONTROLLED DOCUMENTS Quality Assurance Program Manual (QAPM) contains station requirements that must be implemented. The QAPM implements 10CFR50 Appendix B, Regulatory Guide 1.88 and ANSI N45.2.9.
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:
MAINTENANCE OF QA RECORDS DURING OPERATIONS PHASE Quality Assurance Program Manual (QAPM) contains station requirements that must be implemented. The QAPM implements 10CFR50 Appendix B, Regulatory Guide 1.88 and ANSI N45.2.9.
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 PROG ASSESS (ENHANCE) 3 EVENTS TO DEVELOP SADBD BY 12/31/91; 6 EVENTS PER YR COMPLETE DOCUMENTS BY 1995/CHNG TO 3 IN 92' W3 nuc engineering analysis owns the DADBDs. It has been determined that the docs are no longer needed and will not be maintained. W3 now receives core core reload calcs from the fuel vendor as well as other calculations that contain inputs, assumptions and results for safety analyses tht support design and licensing basis for W3. The cals provide necessary information for W3 engineers to perform day to day duties such that it is not necessary to maintain the 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 Number Commitment Number Commitment Description Reason for Change/Deletion 2005-0018 A-2881 EMERGENCY PLAN APPRAISAL: DEVELOP AND IMPLEMENT AN ANNUAL MEDIA SEMINAR NEI guidance states action taken to restore compliance with an obligation in not a commitment, therefore this action can be closed.
The commitment involves an Annual Training session for the media in 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 ESFAS SUBGROUP RELAY TESTING INTERVAL EXTENSION This is not an NRC commitment. It is being used as a place holder for a TSCR which is on the TSCR list maintained by Corporate Licensing.
The parent document is 10 FR 50.90 which is the regulation for submitting license changes.
2005-0020 P15140 TRAINING OF CONTRACT PERSONNEL WORKING UNDER LP&L'S QA PROGRAMTO 100 PERCENT OF MEDP This is a duplicate of obligations delineated in the Entergy Quality Assurance Program Manual (QAPM), section A.3.e and Table 1.g.2.
These sections of the QAPM continue to be listed in section 8.0 of En-QV-111, "Training and certification of Inspection/Verification and Examination Personnel."
2005-0022 P-9805 EA 85-10 RESPONSE:
CERTIFICATION OF INSPECTION PERSONNEL DURING OPERATIONS PHASE This is a duplicate of obligations delineated in the Entergy Quality Assurance Program Manual (QAPM), sections A.5, B.15. These sections of the QAPM continue to be listed in section 8.0 of EN-QV-111, "Training and Certification of Enspections/verifcation and Examination Personnel."
Tuesday, April 25, 2006 Page 10 of 12
CCEF Number Commitment Number Commitment Description Reason for Change/Deletion 2005-0023 P17326 POTENTIAL PROBLEMS WITH METAL CLAD CIRCUIT BREAKERS, GENERAL ELECTRIC TYPE AKF-2-25 Change frequency of disassembly and overhauling of AK type breakers from 5 years to 10 years. The safety function of the reactor trip circuit breaker is to open following activation of the Control Element Drive Mechanism by a reactor trip signal. The reactor trip 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 JUSTIFY THE ACCEPTABILITY OF NONCONFORMING CIRCUIT BREAKERS FOR CONTINUED USE These commitments were generated due to the non-conforming condition of nonqualified 600 volt molded case circuit breakers installed in a safety related application for conrol room lighting. The bases for all actions associated with this event was the development of a procedure which would require the identification, operability 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 Number Commitment Number Commitment Description Reason for Change/Deletion 2005-0025 A-15411 THERMAL STRESSES IN PIPING CONNECTED TO REACTOR COOLANT SYSTEMS/UT SAME 30 WELDS EACH 10 YR INTERVAL/RF 10 Commitment is being deleted..W3 calculation ECM-99-005 determined the portions of the Auxillary Spray piping which could be subjected to thermal stratification due to leakage of the control and check valves in the aux spray piping. (this info is included in RN-04-139 to piping design specification 1564.100B). The information from this calc was 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