ML20091A602
| ML20091A602 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/25/1992 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-92-0132, W3F1-92-132, NUDOCS 9203300019 | |
| Download: ML20091A602 (3) | |
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W3F1-92-0132 A4. 05 QA March 2S, 1992 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20f i5 Subject :
Wnterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report 92-04 Reply to Notice of Violation Gentlemen:
In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in the response to the violation identified in Appendix A of the subject Inspection Report.
If you have any questions concerning this response, please contact C.J. Thomas at (501) 739-6531.
Very truly yours, hw RFB/CJT/ssf Attachment ec:
R.D. Martin, NRC Region IV D.L. Wigginton, NRC-NRR R.B. McGehee N.S. Reynolds NRC Resident inspectors Office
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9203300019 920325 PDR ADOCK 03000382
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Attachment to t
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Page 1 of 2 ATTACllMENT1 FNTERGY OPERATIONS, INC. RESPONSE TO Tile VIOLATION IDENTIFIED IN 3
APP'sNDIX A OI; INSPECTION REPORT 92-04 VIOLATION NO. 9204-01 The Waterford Technical Sp9eifications state, in part, in Section G.8.1 that written procedures covering surveillance and test activities of safety-related equipment shall be established, implemented, and maintained. The licensee had establisi ed and was maintaining Administrative Procedure UNT-007-004, Revision 7 " Technical Specification Surveillance Control," in accordance with the above requirem ent. Section 5.3.7 of Administrative Procedure UNT-007-004 required the shift supervisor or control room supervisor, or at either's discretion, the shift technical advisor to perform post-test reviews of surveillance and test work packages to ensure ecgnizance of the results and whether or not all of the acceptance criteria were met. Work Authorization 01063159 covered a surveillance and test activity of safety-related equipment, which involved determination of the reactor moderator temperature coefficient.
Contrary ta the above, the licensee failed to have the shif t supervisor, control room supervisor, or shift technical advisor perform the required post-test review for Work Anthorization 01063159.
RESPONSE
y, (1)
Reason for C e Violation Entergy Operations, Inc. admits this violation and believes that the root cause of the event is an inadequate procedure in that Administrative Procedure UNT-007-004 failed to clearly define conditions for controlled maintenance and uncontrolled maintenance as they relate to surveillance test activities, At present, these terms are defined in relation to maintenance activities and aie silent with respect to surveillance testing.
J Work Authorization (WA) 01063159 required that-Reactor Engineering and Performance (RELP) collect data per NE-002-002, " Variable Tavg Test,;"
while plant operators varied plant conditions within the bounds of normal operating procedures.. Since the engineers only gathered data and did not manipulate any plant equipment,, they considered the test to not involve maintenance activities. _ Thus, per UNT-007-004, if the test results revealed that the acceptance criteria were satisfied, the WA package would not have to be submitted to the Shift Supervisor / Control Room Supervisor (SS/CRS) for post-test reviews, llowevet, if.the test results were questionable or any acceptance criteria not satisfied,.UNT-007-004. requires that the SS/CRS be notified. Consequently, when the test results revealed that the acceptance criteria were satisfied, the lead worker processed the WA package for closure without submitting it to;the SS/CRS for post-test reviews. Nevertheless, since plant conditions were varied during the surveillance test, the WA package should have been consid; red controlled maintenance and submitted to the SS/CRS for post-test re.lews.
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Attachment to a
W3F1-92-0132 Page 2 of 2 (2)
Corrective Steps That llave Been Taken and the Results Achieved A review of a random sample of surveillance tests was performed to verify that post-test reviews were performed when required. No discrepancies were identified. In addition, a memorandum was issued to RE&P personnel to inform them of this event and to accentuate lessona learned.
(3)
Corrective Steps Which Will Be Taken to Avoid Further Violations The definitions in UNT-007-001 for controlled maintenance and uncontrolled mtdntenance will be revised e,o that they include guidance for surveillance testing.
(4)
Date When Full Compliance Will Be Achieved UNT-007-004 will be revised by June 5,1992.
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