ML20082F882
| ML20082F882 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/12/1991 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-91-0390, W3F1-91-390, NUDOCS 9108160105 | |
| Download: ML20082F882 (4) | |
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e.==" ENTERGY l " "" " " " " " ' ' ' " * '
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H. F. Durski W3F1-DI-0300 A4.05 QA August 12, 1991 tl.S. Nuclear Regulatory Commission ATTN: Document Control Desk washington, D.C.
2055 Subject t Waterford 3 SES Docket No. 50-382 Lleenso No. NpF-38 Response to initial SALp Report for the Period of November 1,1983 through April 30, 1991 Gentlemen:
The purpose of this letter is to respond to the Initial Systematic Assorsment of Licensee Performanco (SALp) Report for Waterford 3 for the period of November 1,1989 through April 30, 1901, whlon was transmitted in the NRC letter from
?l.D. Martin to R.P. liarkhurst, dated.luly 5,1991.
Entergy Operaticna, Inc. was impressed by the candor of the NRC during the presentation and discussion of Waterford 3's performance at the July 22, 1991 management meeting. We agree with the NRC's overall perforucae assessments and the recommended actions made in the report and discussed dur. 'y the meeting. We apprecinto the comment that although the scoren for this most recent SALP report are the :amo as those for the last report, the overall perft maace trend is improving. We also agree that Waterford 3 is t. " safe" and "wel. *run" plant.
The Waterford 3 goal is to achlove "World Class Performanco" through excellence in operations, it is recognized that the only way to achlove that goal la through top lovel SALP ratings. Therefore, the Waterford 3 objectivo for SALP is to Jachlovo Category l's across the board in overy functional area.
Although Category l's are being proposed for Plant Operations, Radiological Controis, Emergency Preparedness and Security, we will make every effort to continuo our improving trends in these functional areas.
We are pleased with the recogn17ed improvements mado in the functional area of
- Maintenance / Surveillance and will continue with the ongoing and projected initiatives with the intent of achieving a Category 1 in this area.
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'4"lF1 0390 Responso to inillal SALP Report for the Period of November 1,1989 through April 30, 1991 l
Page 2 August 12, 1991 j
The recognition given to the recent programs und steps that are being taken to achlovo improvement in the functional aren of Engineering / Technical Support is acknowledged. it is realized that work has to be dono, but we uro committed to Improvement in this functional aren also.
l Iloistralng the functional area of Safety Assessment / Quality Verlflention, wo feel the improving trend in this aren will continuo an the other arens improvo.
The Attachment to this letter provides some additional comments and clarifying information for the functional areas of Maintenance /Surveillanco, Engineering /
Technlent Support and Safety Assessment / Quality Vorification.
Wo will continuo to be proactivo in NRC communtentions and try to improve in that regard by scheduling periodic meetings to make the NRC nware of new initiativos and areas of improvement.
- We uro pleased to note that our nanossment of the status of implementing the recommendations in the last SALP report and noteworthy achlovements mudo during the most recent SALP period, as presented in the Waterford 3 SALP Progress Report (W3'71-91-0297), are generally in agreement with the initial SALP i
report. In conclusion, we feel that the initial SALP report is a fair overall
- nasessment of Waterford 3's performance and we will certainly heed the recommendations for lleonseo netion lu the report.
Very truly youre, d'
RFil/RWP/dc Attachment : -
( Additional Comments and Clarifying Information Regarding initial SALP lleport) cet R.D. Martin, NitC Region IV D.L. Wigginton. NitC NltR R.ll McGeheo-N.S. Ruynolds j-NRC Resident inspectors Offlec
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4 Attachment to W 31'l 0390 page 1 of 2 ADDITIONAL COMMENTS AND CLAltlFYING INF61thWMUWiiEdX1tiHRdT91tl AL SAWIWir it7 o
The following provides additional comments and clarifying information for the indleated SAhp functional areas:
Adntennnee/ Surveillance Waterford 3 la striving to improve in the area of human performance and procedure compliance. llecently, a corporate program entitled Total Quality Improvement (TQl) luts been initiated. it is expected tlutt the TQ1 progntm, when fully implemented, will achieve positive results in the areas of procedure compliance, self-checking, and self-identification.
Waterford 3 would like to reiterate its commitments to the development of selected compcnent-speelfic maintenance procedures and to the restoration of the timeliness of procedure review / revision.
11ngineerinit/ Technical Support Our intent is to significantly improve the functional area of Engineering /
Technical Support. Sevend of our proposed initiatives are well in progress, such as the Electrical Calculational Upgnide prognun, the enhancement efforts in design modifications and validation of calculations, the assessment of Design Engineering programs, the electrical distribution system setpoint review, and improved training for Design Engineering staff. In addition, more advanced pinject management technhpies involving Design Engineering activities are being implemented which will result in a smoothing-out of the work and greater awareness of commitment dates. Collectively, the above initiatives should result in improved quality, depth, and timeliness of work.
Also, the initial SALP report indicates (page 19) that the Waterford 3 EQ program is marginal. We disagree with this perception and feel that it is based on an isolated issue, involving Okontto splices, that was resolved in a satisfactory manner. We have recently conducted an internal assessment of the Waterford 3 EQ prognim, using peer personnel from ANO and GGNS ne well as Waterford 3 personnel. Soma of the areas reviewed by the assessment team included staffing, general prognun responalutlities and scope, determination of EQ parameters, plant temperature monitoring, material aging database and calculation sof tware, d sign change package review, purchase requisition review, work authorizations, FQ determinations on new equipment, EQ checklists, and harsh environment Jefinition. The results of the asse:,sment indicate that Waterford 3 has a well run and effective EQ program. The assessment also identified several "ltest Pnictices" associated with the Waterford 3 program, which includes: adding EQ test report summaries (based on NUREG-05B8 type report submittals) into the
" Additional Information Screen" of the SIMS database; a comprehensive
Attachment to w wl-91-0390 page 2 of 2 temperature monitoring pivgram that relocates itTDs in the contaltunent during each refueling outage and with monitoring results becotring part of the permanent plant record; and, Waterford 3 is cotulucting an EQ file upgnute effort whleh involven the review of existing EQ assessments to upgnule file inf ormation to uscure completenesu.
Safety Annessment/Qunlity Verification Waterford 3 expects the quality of LElla to continue to improve because of enhancements implemented during this past SALP period; however, further refinements to the correctivo netion program will be mudo through the TQ1 process. Additional personnel will he trained in lluman Performance Enhancement Syntem root cause techniques which will also have a positive impact on LElt quality.
Over the past few years Waterford 3 has made improvements in the area of timeliness of corrective action. We recognize, however, that more attention in this area is warranted. In addition to the above initiatives, we believe improvements in the Engineering / Technical Support functional area, and in PoltC praettees and procedures shouhl have a posiduo impact on the corrective action proeOSH.
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