ML20086R855
| ML20086R855 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 07/05/1995 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20086R836 | List: |
| References | |
| A4.05, W3F1-95-0097, W3F1-95-97, NUDOCS 9508010018 | |
| Download: ML20086R855 (5) | |
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W3F1-95-0097 JUL 635 jjl A4.05 PR 3
I July 5, 1995 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report 95-04 Reply to Notices of Violations Gentlemen:
In accordance with 10CFR2.201, Entergy Operations, Inc. here!y submits in Attachment I the responses to the violations identified in.ppendix A of the subject Inspection Report.
If you have any questions concerning this response, please contact G.C.
Scott at (504) 739-6703.
Very truly yours, s
R.F. Burski Director Nuclear Safety RFB/GCS/tjs Attachment
[L.J. Callan. (NRC Region IV),i c.P. Patel (NRC-NRR),
cc:
R.B. McGehee, N.S. Reynolds, NRC Resident Inspectors Office
)
i 9500010018 950727 PDR ADOCK 05000382
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1 0
PDR m
y, Attachment to W3F1-95-0097
'0 Page 1 of 4 1
ATTACHMENT 1
.ENTERGY OPERATIONS. INC. RESPONSES TO THE VIOLATIONS IDENTIFIED IN APPENDIX A 0F INSPECTION REPORT 94-04 l
5 VIOLATION NO. 9504-01 Technical Specification 6.8.1.f requires the licensee to develop procedures for fire protection program implementation. Administrative Procedure UNT-005-013, " Fire Protection Program," Section 6.1, " Fire Detection Instrumentation," requires, in part, that hourly containment fan cooler intake temperatures be recorded when containment fire detection instruments l'
are inoperable.
i Contrary to the above, as of March 31, 1995, Administrative Procedure UNT-l 005-013, " Fire Protection Program," Section 6.1, " Fire Detection Instrumentation," did not specify the operator actions to be taken if containment fan cooler intake temperatures increased.
RESPONSE
(1)
Realga For the Violation I
i Entergy Operations, Inc. admits this violation and believes that the root cause was over reliance on operator knowledge of the Containment Fire Protection System in a non-standard configuration.
4 However, we do not agree with the premise that the Operators would not have conducted the correct actions in association with Containment temperatures trending upward. The Operators are knowledseabe of the 120 degree F Technical Specification limit for average Containment temperatures.
If logged temperatures were to be observed trending upwards toward the Technical Specification Limit, we are confident that the Operators would have brought this condition to the attention of the Shift Supervisor and i
subsequent investigation would have considered fire in Containment as a possible cause.
(2)-
Corrective Steos That Have Been Taken and the Results Achieved As an immediate action.taken until such time that the matter could be investigated, Operations added a note to the remarks section of the form being used to record (compensatory) hourly logging of Containment fan cooler temperatures. The note states that if either of the following u
Attachment to
.W3F1-95-0097 r.:
Page 2 of 4 occurs, notify the Shift Supervisor (SS) or Control Room Supervisor (CRS) for investigation of-possible fire in Containment:
o any Containment Fan Cooler inlet temperature rises without' explanation, or o any Containment Fan Cooler inlet temperature approaches 120 degrees F.
The note will remain in effect until the revisions to UNT-005-013 discussed in section (3), below, are implemented. Also, Operations management has raised the awareness level within Operations concerning the above through staff discussions with Operations supervisory personnel.
4 (3)
Corrective Steos Which Will Be Taken to Avoid Further Violations i
A note will be added to the Procedure UNT-005-013, cautioning that when
. isolation valves 601 A and 601 B are closed, the supervisory air system will not provide an indication that sprinkler spray heads are open. This will reduce reliance upon Operator knowledge of the non-standard configuration of the Containment Fire Protection System.
As an additional enhancement to ensure consistency, Procedure UNT-005-013 will be revised to include operator actions to be taken:
o if any Containment Fan Cooler intake temperature increases unexplainably.
r o if containment fan cooler (average) intake 4
temperatures increase beyond the specified limit based on Technical Specification 3.6.1.5 allowable average Containment temperature level (120 l
degrees F)
Procedure UNT-005-013 will also be revised to provide guidance explaining the purpose of the compensatory measure of recording hourly containment fan cooler intake temperatures.
(4)
Date When Full Comoliance Will Be Achieved Full compliance will be achieved by August 31, 1995.
1 L
Attachment to W3F1-95-0097 g..
Page 3 of 4 I
VIOLATION NO. 9504-02 Technical Specification 6.8.1.d requires the licensee to develop written procedures for security plan implementation.
Security Procedure PS-Oll-102, " Personnel Access and Exit," requires, in part, that individuals requesting access to the protected area have their identity verified by a comparison to the photo badge / key card.
The individual should provide their photo badge number and last name, which will be used to find the appropriate photo badge /keycard.
Contrary to the above, on April 18, 1995, the inspector identified that security personnel responsible for issuing site badges / key cards issued four badges without confirming the individual's name or badge number.
RESPONSE
(1)
Reason for the Violation Entergy Operations, Inc. admits this violation and believes that the root cause was inappropriate action in that personnel responsible for the issuance of the badge /keycard failed to comply with Plant Security Procedure PS-011-102, " Personnel Access and Exit." PS-011-102 requires, as a condition for admission to the Protected Area, that security personnel verify an individual's authorized unescorted access by comparing the individual's face with his/her badge /keycard.
If there is any doubt as to an individual's identity, the Badge Issue Officer (BIO) should verify the person's identity by checking his/her Plant Controlled /0wner Controlled area badge.
It is felt that because Security Badge Issue Personnel are familiar with many individuals requesting badge /keycards, the requirement to perform a badge /keycard comparison with these individuals was missed.
Attachment to W3F1-95-0097 Page 4 of 4
)
(2)
Corrective Steos That Have Been Taken and the Results Achieved Security personnel issued Condition Report CR-95-0322 to ensure that appropriate corrective actions would be taken to address these concerns.
Additionally, Security issued memos dated April 20 1995 to all Security Force personnel re-emphasizing the importance of following steps as stated in Procedure PS-011-102. Appropriate personnel were required to review the affected sections of procedure PS-011-102 and sign a security re-training roster.
Because the Badge Issue Officer involved in the event described in the violation could not be identified, individual counseling per the Improving Human Performance Program was not performed.
(3)
Corrective Steos Which Will Be Taken to Avoid Further Violations Waterford 3 believes that this event as well as other more recent instances of substandard performance in the area of access controls at the primary access point indicate a need for additional review and follow-up.
l Accordingly, the site quality assurance group shall perform an assessment of the badge /keycard issuance process.
In the long term, Waterford 3 is planning to implement a hand geometry biometrics system to identify personnel prior to their entry into the PA.
l Installation of this system will preclude the requirement to match an individual's face with his badge /keycard image.
Badge /keycards will no longer be issued by security personnel.
In addition to enhancing access to the plant's protected area, the hand geometry system is expected to eliminate badging errors as documented in this violation.
(4)
Date When Full Como11ance Will Be Achieved With regard to the specifics of the violation, Waterford 3 is currently in full compliance.
Quality Assurance assessment of the badge /keycard issuance pocess shall be completed by 8/31/95.
Installation of the hand geometry biometrics system is expected to be completed by 12/31/96.
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