ML20199H440
| ML20199H440 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/24/1997 |
| From: | Ewing E ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-382-97-17, W3F1-97-0260, W3F1-97-260, NUDOCS 9711260116 | |
| Download: ML20199H440 (3) | |
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Ente peratbns,Inc.
j y-Kilbna, LA 70(E Tel %4 739 6242 Early C. Ewing,111 a ety & Regulatory AMa,rs W3F1-97-0260 A4.05 PR November 24,1997-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 Inspect;on Report 50-382/97-17 s
Reply to Notice of Violation Gentlemen:
In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in the response to the violation identified in Enclosure 1 of the subject inspection Report.
If you have any questions concerning this response, please contact me at (504) 739-6242 or T.J. Gaudet at (504) 739-6666.
Very truly yours, O,
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j E.C, Ewing
- Director, Nuclear Safety & Regulatory Affairs ECE/ OPP /ssf
'j j U 1 O Attachment cc:
E.W. Merschoff (NRC Region IV), C.P. Patel (NRC-NRR),
J. Smith, N.S. Reynolds, NRC Resident inspectors Office 9711260116 971124
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Attachm:nt to
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W3F197-0260 P:g]1 of 2 ATTACHMENT 1 ENTERGY OPERATIONS. INC. RESPONSE TO THE VIOLATION IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 50-382/97-17 VIOLATION NO. 9717-01 Technical Specification 6.8.1.a states, in part, that written procedures shall be established, implemented, and maintained covering emergency operating procedures.
Subprocedure V, " Containment isolation," of the licensee's Emergency Operating Procedure OP-902-008, Revision 10, contained instructions necessary to satisfy the success path for the containment isolation safety function.
The licensee had completed recent modifications to the plant, which permitted overriding a containment spray permissive signal to allow the operators to close Containment Spray Valves CS-125A(B) in order to isolate the containment and satisfy the safety function success path.
Contrary to the above, written procedures were not maintained for emergency operating procedures in that the licensee failed to revise the Emergency Operating Procedure OP-902-000 following valve modifications to provide the operators with adequate instruction for closing Containment Spray Valves CS125A(B) to isolate the Containment.
This is a Severity Level IV violation (Supplement l} (50-382/9717-01).
RESPONSE
(1)
Reason for the Violation Entergy attributes the violation to a combination of the inefficient location of procedural guidance and to the lack of clearly defined management expectations for Operations in this area. Entergy agrees that appropriately located procedural guidance is needed to ensure the proper and appropriate operation of Containment Spray Valves (CS-125A(B)). The location of the procedural guidance in an Emergency Planning Procedure (EP-002-100, Revision 25, Attachment 7.12) versus in an Emergency Operating Procedure l
(OP-902-008) was a conscious decision, which had been reached after much l
deliberation. Waterford 3 is committed to meeting the strategies for Emergency Operating Procedures outlined in CEN-152, CE Emergency Operating Procedure Guidelines. The NRC approved the use of the strategies in CEN-152 Revisions 03 and 04. The strategies that CE i
recommends in the guidelines do not include specific st.eps to isolate containment in the case of equipment failure (e.g. a Containment Spray Pump
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Att:chment to W3F1-97-0260 Pcg3 2 of 2
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not runnir.g).. The Safety Function Success Path for containment isolation in the Functional Recovery Guideline (CEN-152) states to ensure an isolation
- valve is closed for each containment penetration required to be closed. The Waterford 3 Safety Function Recovery Procedure (OP-902-008) states that at least one containment isolation valve must be closed for each containment penetration not in use. The EOPs are written assuming that safety-equipment is operable and will perform its intended function. To assume safety-related equipment failures in developing EOPs would drastically increase the volume of information necessary in the body of the EOPs, thus potentially increasing operator complication and response time. Based on the above considerations, we have assessed that the procedural guidance would more appropriately be located in a standard appendices to the EOPs rather than in the body of the EOPs.
It should be noted that the NRC is currently evaluating Entergy's position on the Containment Spray Containment isolation Valves presented at the Enforcement Conference held in Arlington, Texas on July 29,1997. Final resolutfor; on that issue is pending. Waterford 3 will address the results accord ngly.
1 (2)
Corrective Steps That Have Been Taken and the Results Achieved Operating crews have been briefed on the violation scenario in various Operations Department meetings and are aware of the current location of the subject procedural guidance and management's expectations in that regard.
(3)
Corrective Steps Which Will Be Taken to Avoid Further Violations Waterford 3 has plans to develop a standard appendices to the EOPs wherein guidance will be included to provide direction to the operators for closing Containment Spray Valves CS 125A(B) with Containment Spray Pumps not running. The Operator training program will include training for the Operators on the new standard appendices.
(4)
Date When Full Compliance Will Be Achieved The EOP standard appendices will be completed by June 30,1998.
Operations Training inclusion of the appendices in the training program will be completed by August 31,1998.
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