ML20211M440
| ML20211M440 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 10/09/1997 |
| From: | Harrell P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Dugger C ENTERGY OPERATIONS, INC. |
| References | |
| 50-382-97-15, NUDOCS 9710140205 | |
| Download: ML20211M440 (5) | |
See also: IR 05000382/1997015
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ARLINGTON. texas 740114e64
9 997
Charles M. Dugger, Vice President
Operations Waterford 3
Entergy Operations, Inc.
P.O. Box B
Killona, Louisiana 70066
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SUBJECT:
NRC INSPECTION REPORT 50 382/9715
Dear Mr. Dugger:
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Thank you for your letter of September 29,1997, in response to our letter and
Notice of Violation dated August 28,1997. We have reviewed your reply and, as
discussed with you during a telephone conference on October 2,1997, the information
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you provided for the corrective steps that have been taken and the results achieved for
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Violation 9715 03 did not fully address what was reque:sted, it is our understanding that
you will provide this information in a supplement to your previous response. Your
response to the concerno raised in Violation 9715-06 was adequate. We will review the
implementation of your corrective actions during a future inspection to det' ermine that full
compliance has been achieved and will be maintained.
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Sincorely,
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Pr) Ject Section D
Docket No.: 50 382
License No.: NPF 38
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Executive Vice President and
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Chief Operating Officer
Entergy Operations, Inc.
P.O. Box 31995
Jackson, Mississippi 39286-1995
9710140205 971009
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ADOCK 05000302
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Entergy Operations, Inc.
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Vice President, Operations bupport
Entergy Operations, Inc.
P.O. Box 31995
Jackson, Mississippl 3928610^7
Wise, Carter, Child & Caraway
P.O. Box 651
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Jackson, Mississippl 39205
General Manager, Plant Operations
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Waterford 3 SES~ ~
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Entergy Operations, Inc.
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P.O. Box B
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Killona, Loulslana 70066
Manager Licensing Manager
Waterford 3 SES
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Entergy Operations, Inc,
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P.O. Box B
Killona, Loulslana 70066
Chairman
Loulslana Public Service Commission
- One American Place, Suite 1630
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Baton Rouge, Louisiana 70825 1697
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Director, Nuclear Safety &
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Regulatory Affairs
Waterford 3 SES
~ Entergy Operations, Inc.
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. P.O. Box B
Killona, Louisiana - 70066
William H. Spell, Administrator
. Loulslana Radiation Protection Division
P.O. Box 82135 -
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Baton Rouge, Loulslana 70884 2135-
._ Parish President
St. Charles Parish
P.O. Box 302:
Hahnville, Loulslana 70057
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Entergy Operations, Inc.
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Mr. Williern A. Cross
Bethesda Licensing Office
3 Metro Center
Suite 610
Bethesda, Maryland 20814
Winston & Strawn
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1400 L Streeti N.W.-
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Washington, D.C.- 20005 3502-
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OCT - 91997
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DOCUMENT NAME: R:\\_WAT\\WT715AK.LAK
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OFFICIAL RECORD COPY
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September 29,.1997;
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.U.S. Nuclear Regulatory Commission -
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ATTN: Document Control Desk"
' Washington, D.CJ20555
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L Subject:
Waterford 3 SES
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Docket No. 50-382 -
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License No. NPF-38'
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NRC Inspection Report 50-382/97-15-
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Reply to Notice of Violation
Gentlemen:
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. In accordance with 10CFR2.201, Entergy Operation 3, Inc. hereby submits in .
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- Attachment.1 the msoonse to the violations identified in Enclosure 1 of the subject
C Inspection Report
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- If you have any questions concoming thle r6sponse, please contact me at (504) 739 -
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- 6242 or Tim Gaudet at (504) 739-6666.
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Very truly yours,-
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E.C. Ewing
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- Reply to Notice if Violation
_ Page 2
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September 29,1997 <
/E W Merschoff(NRC Region IV)
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C.P. Patel (NRC-NRR) -
. J. Smith
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N.S. Reynolds
NRC Resident inspectors Office
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PAGE 1 OF 5
ATTACHMENT 1
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ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATIONS IDENTIFIED IN
ENCLOSURE 1 OF INSPECTION REPORT 97-15
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VIOLATION NO. 9715-03
L10 CFR 50.65(a)(1) states, in part, that each holder of an operating license shall
monitor the performance or condition of structures, systems, or components, against
licensee-established goais 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,
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or component remains capable of performing its intended safety function. Paragraph
(c) states, "[t]he requirements of this section shall be implemented 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
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of the above specified system was effectively controlled through the performance of -
appropriati preventive maintenance and that the system remained capable of
pcrforming its intended function in that neither the unavailability of the function
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performed by the system was monitored nor an acceptable alternative method for
compliance proposed.
This is a Severity Level IV violation (Supplement 1) (50-382/9715-03).
RESPONSE-
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(1)'
Reason for the Violation
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Entergy admits this violation and believes it to be the result of inadequate
- mansgement 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
entry into the Maintenance Rule by the Expert Panel. Subsequent to this,
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performance criteria for LTE were prepared and presented to the Expert
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Panel. Differing interpretations of the industry's position on emorgency
lighting prevented the Expert Panel from reaching a consensus on the .
systems - performance criteria. As a result of personnel turncver 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.-
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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
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determined that the communication / paging (CMP) and communication / radio
(CMR) systems did'not yet have a Maintenance Rule function or criteria .
approved by the Expert Panel.- The maintenance history review of these
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systems is also not complete,
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'(2)
Corrective Steps That Have Been Taken and the Results Achieved
Condition Report g7-2038 was generated to place this event in the Waterford
3 corrective action program.
<(3)
LCorrective Steps Which Will Be Taken 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 the
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communication systems; Reliability critoria 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
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, igg 7, when system categorizations will have been made. If
warranted, (a)(1) goals will then be established. Upon completion'of the
above, Waterford 3 will be in full compliance.
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- ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOL.ATION 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, Supolement 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 battery power supply were not provided for the reactor auxiliary building
stainuell 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 l} (50-382/9715-06).
RESPONSE
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-(1)-
Reason for the Violation
Waterford 3 admits to the violation of the Appendix R requirement to provide a
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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
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hallway of the Control Room envelope. - During subsequent walkdowns, it was
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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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ATTACHMENT TO
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PAGE 4 OF 5
Also, it was determined that an Appendix R lighed path had not been
established to two ACCW valves.
(3)-
Corrective Steps Which Will Be Taken to Avold Further Violations
Based on results frorn 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 lighting 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
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in the path to two ACCW Valves (ACC 138A&B).
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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,
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near 4160 voit switchgear 3A-S, and
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near the Chilled Water isolation valves.
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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 partially 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 tours.
Operators will review this violation as pad 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 will be 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.
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ATTACHMENT TO
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- 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 described above) will be
completed by 3/31/98.'
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Upon completion of the above, Waterford 3 will be in full compliance.
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