ML20216B239
| ML20216B239 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 04/09/1998 |
| From: | Ewing E ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-382-98-05, 50-382-98-5, W3F1-98-0071, W3F1-98-71, NUDOCS 9804130398 | |
| Download: ML20216B239 (3) | |
Text
e y
Ente gy Opersti:ns,Inc.
Killona. LA 70066 Tel 504 739 6242 Early C. Ewing, til N
ety & Regulatory Affairs W3F1-98-0071 A4.05 PR April 9,1998 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 98-05 Reply to Notice of Violation Gentlemen:
In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in l the response to the violation identified in Enclosure 1 of the subject l
Inspection Report.
If you have any questions concerning this responso, please contact me at (504) 739-6242 cr Tim Gaudet at (504) 739-6666.
I Very truly yours, l
i E.C. Ewing
- Director, i
g l
Nuclear Safety & Regulatory Affairs t
1
\\
ECE/GCS/ssf fgD Attachment cc:
E.W. Merschoff (NRC Region IV), C.P. Patel (NRC-NRR),
J. Smith, N.S. Reynolds, NRC Resident inspectors Office 9804130398 980409 PDR ADOCK 05000382 O
I,y
..,v1.
Attachment to W3F1-98-0071 Page 1 of 2 ATTACHMENT 1 ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 98-05 VIOLATION NO. 9805-03 4
License Condition 2.E of the Waterford Steam Electric Station, Unit 3, Operating License NPF-38, dated December 19,1995, requires that the licensee fully implement and maintain in effect the Commission approved Physical Security Plan, including amendments and changes made pursuant to the authority of 10 CFR 50.54(p).
Waterford 3 Physical Security Plan, Revision 17, dated March 1996, Chapter 3, paragraph 3.2.6, " Vehicle Denial" states, in part, " Railroad derailers are installed inside the protected area on the railroad spurs that enter the site."
Plant Security Procedure PS-011-103, " Vehicle Access Control," Revision 8, Section
- 5. paragraph 5.6.1, states, in part, Railroad derailers are installed inside the protected area on rail spurs that allow entry into the protected area."
Plant Security Procedure PS-012-101, " Perimeter Barriers," Revision 9, Section 5.6, paragraph 5.6.1, states, " Security Officers will inspect the derailers to encure that they are locked in the derail configuration. This check will be made twice each shift."
Contrary to the above, on February 11,1998, the inspector identified that the derailer was not locked in the derail configuration. This degraded condition had existed since November 11,1997.
This is a severity level IV violation (Supplement 111) (382/98-05-03).
RESPONSE
(1)
Reason for the Violation The root cause for this violation is inadequate procedures, in that security procedures did not clearly define railroad derailers as security barriers and did not identify compensatory measures for a failed derailer. As a result, appropriate measures were not taken to address the deficiency.
On November 11,1997, security personnel identified that the train derailer located in the protected area had become unattached from the rail. On the q
same day, security personnel generated a corrective action document, Condition Identification (Cl) 313395, to have the derailer reattached to the rail.
Attachment to W3F1-98-0071 Page 2 of 2 However, security personnel failed to realize that the unattached derailer re' presented a failed security barrier. In consequence, the unattached derailer was not immediately repaired or compensated for within ten minutes. The derailer remained unattached and unposted until February 12,1998.
(2)
Corrective Steps That Have Been Taken and the Results Achieved The area near the unattached derailer was posted by security personnel and the derailer was repaired on February 12,1998.
As an interim measure, the Security Information database was updated to require compensating for a failed derailer by posting security personnel. This will remain in affect until appropriate procedures are revised.
l Security procedure PS-018-108, Loss or Degradation of Security Equipment and Systems, was revised on March 20,1998, to clearly define the railroad derailer as a security barrier. The procedure was piso revised to stipilate l
compensatory measures required when the derailer fails or is unavailable.
l A security sign has been attached to the railroad derailer, identifying it as security equipment. The sign requires that security be notified prior to removal or maintenance on the derailer.
(3)
Corrective Steps Which Will Be Taken to Avoid Fudher Violations l
Security procedure PS-015-101, Security Patrols, will be revised to require j
Security Officers to contact the Central Alarm Station or the Secondary Alarm Station Console Operator upon discovery of a derailer deficiency. The procedure will also require the Security Officer to post the affected area until fudher instructions are given.
Plant administrative procedure UNT-005-002, Condition Identification, will be l
revised to require that security personnel be notified prior to maintenance being performed on security equipment.
(4)
Date When Full Compliance Will Be Achieved Based on the completed corrective actions for Violation 98-05-03, Waterford 3 has restored compliance to requirements. Additional corrective steps to revise procedures PS-015-101 and UNT-005-002 will be completed by June 30, 1998.