ML20058F457
| ML20058F457 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/26/1993 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-93-0368, W3F1-93-368, NUDOCS 9312080124 | |
| Download: ML20058F457 (4) | |
Text
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~EE~ ENTERGY I"TP """ "'""*'
nan q rc, e p g7;;
R. F. Burs ki mm,
a W3F1-93-0368 A4.05 PR i
November 26, 1993 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk t
Washington, D.C. 20555 l
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report 93-29 Reply to Notice of Violation
-t Gentlemen:
1 i
in accordance with 10CFR2.201, Entergy 0parations, Inc. hereby submits in I
Attachment i the response to the violation identified in Appendix A of the subject Inspection Report.
If you have any questions concerning this response, please contact T.W. Gates at (504) 739-6697.
l Very truly yours, M
R.F. Burski Director Nuclear Safety RFB/TWG/ssf Attachment s
J.L. Milhoan (NRC Region IV), D.L. Wigginton (NRC-NRR),
A cg g g'";-
R.B. McGehee, N.S. Reynolds, NRC Resident Inspectors Office
{ l 9312080124 931126 EP 1
PDR ADOCK 05000382
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Attachment to W3F1-93-0368 Page 1 of 3 l
ATTACHMENT 1 i
ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN APPENDIX A 0F INSPECTION REPORT 93-29 V10l. ATION NO. 9329-02 f
Criterion V of Appendix B to 10CFR50 states, in part, that " Instructions, I
procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished." These activities are accomplished, in part, by Site Directive W4.101, "Nonconformance/Indeterminance Analysis Process," Revision 0, Steps 4.6.4 and 5.10.4, which specify, in part, that the Events Analysis Reporting and Response Manager is responsible for i
ensuring that Potential Reportable Event documentation is generated if j
necessary by processing the Potential Reportable Event as necessary in acccrdance with existing procedures.
Contrary to the above, during an inspection conducted September 27 through j
October 1,1993, NRC identified that Site Directive W4.101 was inadequate j
for initiating an evaluation to determine the reportability of an event or i
condition because there was no longer a position of Manager, Events
]
Analysis Reporting and Response, within the site' organization and there j
were no clearly specified criteria for initiating a reportability determination.
RESPONSE
(1)
Reason for the Violation j
Entergy Operations, Inc. admits this violation.
Site Directive W4.101, "Nonconformance/Indeterminance Analysis Process," has been inadequate for the purpose of ensuring that an evaluation was initiated te determine the reportability of a given event since July 1, 1992, when the Events Analysis Reporting and Response (EAR &R)
Group was disestablished.
Because the directive does not include specific criteria for j
initiating a reportability documentation, the directive became inadequate when Entergy Operations eliminated the position that was responsible for ensuring that evaluations were performed as necessary i
(EAR &R Manager) and did not reassign that responsibility.
Entergy i
Operations believes that this condition developed because of a lack i
of clear ownership responsibility for the site directive.after the organizational realignment.
~- --
i Attachment to W3F1-93-0368-Page 2 of 3 r
i However, the shortcomings of Site Directive W4.101 shnuld rot be..
taken as an indication that certain conditions have not been evaluated for reportability and, consequently, that required reports
.j may not have been made to the NRC or other regulatory agencies.
As j
part of the process governed by Administrative Procedure UNT-006-015, 1
" Identification, Evaluation, and Reporting of Defects and l
Noncompliances Under 10CFR21," the Shift Technical Advisor (STA) j Supervisor assigns individuals to review various plant documents, j
including Nonconformance Condition Identifications (NCI's) generated as an entering argument for the W4.101 process, for potential reportability under 10CFR Part 21' and general' reportability as specified in Administrative Procedure UNT-006 010, " Event Notification and Reporting."
(UNT-006-010 includes a compilation of the various event notification requirements established by the NRC as well as those specified by the State of Louisiana and other regulatory agencies.) This review is performed as part of the work j
package close-out process and ensures that reports are submitted as I
required.
Finally, it should be noted that in February,1993, Entergy l
Operations made significant changes to the Waterford 3 Corrective Action Program. One of the benefits provided by the new process was an increase in the scope of the events or conditions that would be specifically reviewed for reportability.
In the current process, every (non-hardware related) condition adver n to quality must receive a reportability review with varying levels of documentation required depending on the type of review. Under the previous process, a reportability determination was performed only if an f
individual first recognized that an event might be reportable and j
then took the necessary steps to initiate the separate reportability review process.
In short, for conditions other than hardware problems (which are documented via the NCI process described in UNT-005-002), the new process increases the scope of the events that are reviewed for reportability, requires doce~:r.tation of the reportability review, and thus greatly reduces the. potential' vulnerability for missing a required report.
i (2)
Corrective Steps That Have Been Taken and the Results Achieved First, as an interim measure until permanent procedural changes can be made, the General Manager-Plant Operations has directed that.the reportability determination for each condition that results in the generation of an NCI or entry into the W4.101 process be documented' on a Condition Report form in accordance with the guidance of Administrative Procedure UNT-006-Oll, " Condition Report."
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Attachment to W3F1-93-0368 Page 3 of 3 Secondly, all Waterford 3 Site Directives (Volume IV of-the Entergy-1 Operations Management Manual) have been reviewed for similar organizational discrepancies.
A number of minor discrepancies j
related to organizational realignments or title changes were identified.
Revisions to these directives are either in progress.or scheduled as part of a routine review process.
{3)
Corrective Steps Which Will Be Taken to Avoid Further Violations First, Site Directive W4.101 will be revised such that it reflects the structure of the current Waterford 3 organization.
{
Secondly, Administrative Procedure UNT-005-002, " Condition Identification," and Site Directive W4.101 will be revised to require that a Condition Report (CR) be generated each time an NCI is written (an NCI is used to document certain types of hardware deficiencies) i or the W4.101 process is utilized. Once a CR is written a documented reportability determination is required by Administrative Procedures UNT-006-Oll, " Condition Report," and UNT-006-010, " Event Notification and Reporting." These changes should ensure that the reportability:
determination performed for each of the Waterford 3 Corrective Action.
Program document's is adequately documented.
1 Finally, in order to establish clear responsibilities, a cross t
reference list will be developed which will assign each of the Site Directives to a specific group.
(4)
Date When Full Compliance Will Br ichieved Corrective action for 'this violation should be complete by April 13, 1994.
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