ML20211P000
| ML20211P000 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 10/14/1997 |
| From: | Ewing E ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-382-97-15, W3F1-97-0239, W3F1-97-239, NUDOCS 9710200022 | |
| Download: ML20211P000 (4) | |
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A Ente per;tions, inc.
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Early C. Ewing, Ill a I ar a oty & Reyhtry Aff a4s W3F1-97-0239 A4.05 PR October 14,1997 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 Inspection Report 50-382/97-15 Revised Response to Notice of Violation Gentlemen:
As requested by the Staff in a telephone conversation on October 2,1997, Waterford 3 hereby submits in Attachment 1 the revised response to the violation 9715-03. The original violation response, which was provided in letter W3F1-97-0229, dated September 29,1997, listed corrective steps taken under the " Reason for the Violation" section instead of under the " Corrective Steps That Have Been Taken and the Results Achieved" section. This has been revised and revisions are annotated with revision bars. Additionally, we have added a statement under the " Corrective Steps Which Will Be Taken to Avoid Further Violations" section which supports why Waterford 3 is confident these corrective steps are adequate.
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NRC Inspection Report 97-15 Revised Response to Notice of Violation W3F1-97-0239 P9ge 2
' October 14,1997 We regret any inconvenience this may have caused. 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, b
E.. Ewing
- Director, Nuclear Safety & Regulatory Affairs ECE/DMUltjs
Attachment:
1.
Entergy Operations, Inc. Response to Violation 9715-03 Identified in of Inspection Report 97-15 cc:
E.W. Merschoff (NRC Region IV)
C.P. Patel (NRC-NRR)
J. Smith N.S. Reynolds NRC Resident inspectors Office
ATTACHMENT TO W3F1-97-0239 o
PAGE 10F 2 ATTACHMENT 1 ENTERGY OPERATIONS. INC. RESPONSE TO VIOLATION 9715-03 IDENTIFIED IN ENCL OSURE 1 OF INSPECTION REPORT 97-15 VIOLATION NO. 9715-03 10 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 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 reouired 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, 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 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 Level IV violation (Supplement 1) (50-382/9715-03).
RESPONSE
(1)
Reason for the Violatio_n Entergy admits this violation and believes 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 entry into the Maintenance Rule by the Expert Panel. Subsequent to this, performance criteria for LTE were prepared and presented to the Expert
ATTACHMENT TO W3F1-97-0239 PAGE 2 OF 2 Panel. Dif'ering interpretetions of the industry's position on emergency lighting prevented the Export 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 Ruit function and criteria were therefore not completed in a timely manner.
(2)
Corrective Steps That Have Been Taken and the Results Achieved 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 performance 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 approved by the Expert Panel. The maintenance history review of these systems 3 also not complete.
(3)
Corrective Steps Which Will Be Tcken to Avoid Further Violations in accordance with 10 CFR50.65 paragraph (a)(2), provisions will be made to l mon; tor the reliability performance of the emergency lighting and the communication systems. Reliability criteria have been established, reviewed and approved by the Expert F'anel. 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.
The review described above identified all remaining systems that, although scoped in the Maintenance Rule, were lacking a maintenance history review, an approved Maintenance Rule function and approved performance criteria.
Based on this review, Waterford 3 is confident that the corrective actions s
specified above will avoid further violations.
(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. If warranted, (a)(1) goals will then be established. Upon completicn of the above, Waterford 3 will be in full compliance.
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