ML20211F823
| ML20211F823 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 09/29/1997 |
| From: | Ewing E ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-382-97-15, W3F1-97-0229, W3F1-97-229, NUDOCS 9710010226 | |
| Download: ML20211F823 (7) | |
Text
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e-ntstgy Operations,Inc.
Mona LA 70066 Tel 504 739 6242 E
C. Ewing, in eg;gtp a sway em W3F1-97-0229 A4.05 PR September 29,1997 U.S. Nuclear Regulatory Commission
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ATTN: Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report 50-382/97-15 Reply to Notice of Violation Gentlemen:
In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in the response to the violations identified in Enclosure 1 of the subject inspec+ ion Report.
If you have any questions concerning this response, please contact me at (504) 739-6242 or Tim Gaudet at (504) 739-6666.
Very truly yours,
/
[,c o/
E.C. Ewing
- Director, Nuclear Safety & Regulatory Affairs ECE/DMU/ OPP /tjs Attachment 9710010226 970929 PDR ADOCK 05000382 O
NRC Inspection Report 97-15 Reply to Notice of Violation W3F1-97-0229 Page 2 September 29,1997 cc:
E.W. Merschoff (NRC Region IV)
C.P. Patel (NRC-NRR)
J. Smith N.S. Reynolds NRC Resident inspectors Office
ATTACHMENT TO W3F1-97-0229 PAGE 1 OF 5 r
ATTACHMENT 1 ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATIONS DENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 97-15 VIOLATION NO. 9715-03 10 CFR 50.65(a)(1) states, in part, that each holder of an ogerating license shall monitor the performance or condition of structures, systems, or components, against licensee-established goals and such goals shall be established commensurate with safety.
10 CFR 50.65(a)(2) states, in part, that monitoring under paragraph (a)(1) is not required where it has been demonstrated that the performance or condition of a structure, system, or component is being effectively controlled through the performance of appropriate preventive maintenance such that the structure, system, 1
or component remains capable of performing its intended safety function. Paragraph (c) states, "[t]he requirements of this section shall be imolemented by each licensee no later than July 10,1996. "
Contrary to the above, as of January 1997, for the emergency lighting system, the licensee: (1) failed to establish goals commensurate with safety as described in 10 CFR 50.65(a)(1); or (2) as an alternative, failed to demonstrate that the performance of the above specified system was effectively controlled through the performance of appropriate preventive maintenance and that the system remained capable of performing its intended function in that neither the unavailability of the function performed by the system was monitored nor an acceptable alternative method for compliance proposed.
This is a Severity L6 vel IV violation (Supplement 1) (50-382/9715-03).
RESPONSE
(1)
Reason for the Violation Entergy admits this violation and believeu it to be the result of inadequate management oversight, in September of 1996, the Maintenance Rule Expert Panel discussed the need to scope the Emergency Lighting System (LTE) into the Maintenance Rule. At the end of 1996, LTE was officially approved for
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entry into the Maintenance Rule by the Expert Panel. Subsequent to this,
ATTACHMENT TO W3F1-97-0229 -
PAGE 2 OF 5 performance criteria for LTE were prepared and presented to the Expert Panel. Differing interpretations of the industry's position on emergency lighting prevented the Expert Panel from reaching a consensus on the systems performance criteria. As a result of personnel turnover and an extended refueling outage, no further Expert Panel meetings were held.
Approval of LTE's Maintenance Rule function and criteria were therefore not '
completed in a timely manner.
A review of systems scoped in the Maintenance Rule was performed to identify any other systems whose historical review may not be complete or
- whose function and criteria were not approved, in addition to LTE, it was determined that the communication / paging (CMP) and communication / radio (CMR) systems did not yet have a Maintenance Rule function or criteria approveo by the Expert Panel. The maintenance history review of these-systems is also not complete.
(2)
Corrective Steps That Have Been Taken and the Results Achieved
- Condition Report 97-2038 was generated to place this event in the Waterford 3 corrective action program, (3)
Corrective Steps Which Will Be Taketi to Avoid Further Violations In accordance with 10 CFR50.65 paragraph (a)(2), provisions will be made to monitor the reliability performance of the emergency lighting and +.he -
communication systems.: Reliability criteria has been established, reviewed and__ approved by_the Expert Panel. The maintenance history review of these systems is in progress and once completed will be reviewed against their-
. respective (a)(2) reliability performance criteria. At that time, a system (a)(1) or (a)(2) categorization will be made. If determined that (a)(1) status is 1
warranted, then (a)(1) goals _will be established.
(4)-
Date When Full Compliance Will Be Achieved
--The above corrective actions are in progress and will be completed by
- December 18,1997, when system categorizations will have been made. f warranted, (a)(1) goals will then be established. Upon completion of the above, Waterford 3 will be in full compliance.-
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ATTACHMENT TO W3F1-97-0229 PAGE 3 OF 5 ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 97-15 VIOLATION NO. 9715-06 10 CFR Part 50, Appendix R, Section Ill(J), states that emergency lighting units with at least an 8-hour battery power supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto.
Safety Evaluation Report, Supplement 8, Section 9, and Updated Final Safety Analysis Report, Table 9.5.1-4, both indicate that the chilled water system is required for safe shutdown following a fire.
Contrary to the above, as of August 9,1997, emergency lighting units with at least an 8-hour battey power supply were not provided for the reactor auxiliary building stairwell leading to the +46-foot Chilled Water System room, an access and egress route for an area needed for operation of safe shutdown equipment.
This is a Severity Level IV violation (Supplement I) (50-382/9715-06).
RESPONSE
(1)
Reason for the Violation Waterford 3 admits to the violation of the Appendix R requirement to provide a lighted path to equipment required for safe shutdown. The violation resulted from an apparent inadequate initial evaluation. In the case cited in the violation (Essential Chillers), an Appendix R path had been established to the equipment. However, access via the path could be blocked by smoke in the hallway of the Control Room envelope. During subsequent walkdowns, it was determined that an Appendix R lighted path had not been established to ACCW valves required for safe shutdown.
(2)
Corrective Steps That Have Been Taken and the Results Achieved A plant walkdown was conducted in applicable areas to assess the adequacy of Appendix R emergency lighted pathways to equipment required for safe shutdown. Based on results from the walkdown, a more appropriate pathway (a stairwell leading from the +21 to the +46 elevation) was selected to facilitate Operator access to the Essential Chillers during a Control Room fire.
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4 ATTACHMENT TO W3F1-97-0229 PAGE 4 0F 5 Also, it was determined that an Appendix R lighted path had not been established to two ACCW valves.
3 (3)
Corrective Steps Which Will Be Taken to Avoid Further Violations Based on results from the plant walkdown,8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Appendix R tighting units are being installed in the following locations to establish required lighted paths:
in the stairway from +21 to +46 to the Essential Chillers, and e
in the path to two ACCW Valves (ACC 138A&B).
e In addition to the above installations,8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Appendix R lighting units are being installed in the following locations as enhancements to other paths:
in front of the Reactor Trip Breakers, near 4160 volt switchgear 3A-S, and e
near the Chilled Water isolation valves.
While these corrective actions are being implemented, the Operators have flash lights available for lighting their path to the applicable safe shutdown equipment. The paths are partial ly illuminated via emergency diesel generator backed lighting units. The majority of the path to the east side ACCW valve is located outside of the building and is therefore illuminated during daylight hours.
Operators will review th:3 violation as part of their required reading to increase awareness of the potential need for use of flashlights in the identified areas during the interim until the required lighting units are installed.
Established lighted Appendix R paths wil! Se identified in the Operations safe shutdown procedure.
Permanent, controlled documentation of established Appendix R emergency lighted pathways will be prepared.
(4)
Date When Full Compliance Will Be Achieved Installation of the Appendix R lighting in the areas listed above will be completed by 1/30/98, with the exception of the ACCW valve path, which will be complete by 6/30/98.
ATTACHMENT TO W3F1-97-0229 PAGE 5 0F 5 Operator required reading will be complete by 10/20/97.
Preparation of controlled documentation of established Appendix R paths will be completed by 1/30/98.
The revision of the safe shutdown procedure (as descrioed above) will be completed by 3/31/98.
Upon completion of the above, Waterford 3 will be in full compliance.
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