ML20217J016
| ML20217J016 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/31/1998 |
| From: | Ewing E ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-98-0049, W3F1-98-49, NUDOCS 9804060148 | |
| Download: ML20217J016 (9) | |
Text
k.
y Ente gy Operations,inc.
Killona. LA 70066 Tel 504 739 6242 j
harly C. Ewing, til le Sawy & Regulatory Affairs W3F1-98-0049 A4.05 PR March 31,1998 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 Performance Improvement Plan Action Item Completion Due Date Changes Gentlemen:
The purpose of this letter is to provide the NRC with adjustments to docketed completion due dates for specific Performance improvement Plan (PIP) action items that will not be completed by the due date. Several of the changes are administrative and simply tie PIP item completion due dates to the upcoming Refuel 9 outage. Two items are evaluated as no longer necessary due to a combination of changes in chemistry sampling requirements and alternate measures to be taken.
l One change resulted from a reevaluation of plant priorities by the plant Project
)
l Review Committee (PRC). The PRC was formed as a measure associated with PIP i
Item 4.A.3, to improve project management and prioritization and is functioning in I
that capacity. Attached is a summary of the changes and justifications, i
l The management team at Waterford 3 and Senior Entergy Operations management l
continue to be committed to improving our regulatory performance. Management believes that many improvements are being achieved as a result of the PIP program and is committed to completing the action items identified. Our goal is sustained superior performance at Waterford 3.
\\
..s0 9 l
9804060148 980331 PDR ADOCK 05000382 P
PDR J
d Performance Improvement Plan Action item
- - Coinpletion Due Date Changes W3F1-98-0049 Page 2 March 31,1998 If you have any questions concerning the above, please contact me at (504) 7394242 or Tim Gaudet at (504) 739-6666.
Very truly yours, E.C. Ewing Director Nuclear Safety & Regulatory Affairs ECE/ OPP /rtk Attachmentsi Performance improvement Plan (PIP) Completion Due Date Changes.
E.W.'Merschoff, NRC Region IV i
cc:
C.P. Patel, NRC-NRR j
J. Smith l
N.S. Reynolds NRC Recident Inspectors Office l
t.
Attachment to W3F1-98-0049 Page 1 cf 7 PERFORMANCE IMPROVEMENT PLAN (PIP)
COMPLETION DUE DATE CHANGES PIP ltem No.: 1.D.3 (Commitment No. A-24086)
==
Description:==
Submit a full conversion to the new Combustion Engineering (CE) Standard Technical Specifications (STS) (NUREG-1432).
Change: Move due date from second quarter 1998 to first quarter 2000.
Justification: The due date for this item needs to be extended as indicated above due to -
the extended Refuel 8 outage of 1997, the need to complete ongoing engineering programs to e
validate our design basis, the need to complete the Tec' nical Specification instrument uncertainty project, and 4
the need to support the upcoming NRC Architectural /
H Engineering inspection.
The above factors impact the resources and work flow required to perform engineering technical reviews of improved Technical Specification (ITS) packages. It is estimated that this item can be completed by the end of the first quarter 2000.
PIP ltem No.: 2.B.3 (Commitment No. A-24106)
==
Description:==
Perform assessment of the Motor Operated Valve (MOV)
Program and implement improvements.
Change: Move due date from first quarter 1998 to third quarter 1998.
Justification: The MOV Program assessment is complete. Implementation of assessment recommendations will require more resources than had originally been anticipated. Therefore, completion of implementation of improvements will require extending the due date from first quarter 1998 to third quarter 1998.
Attachm:nt to W3F1-98-0049 Page 2 of 7-PIP ltem No.: 2.B.4 '(Commitment No. A-24107)
==
Description:==
Perform assessment of the Air Operated Valve (AOV) Program
)
and implement improvements.
1 Change: Move due date from first quarter 1998 to fourth quarter 1999.
Justification: The AOV program assessment will be delayed to allow time for further program development. Several efforts are underway in j
Design Engineering to enhance the AOV program. Design 1
basis review calculations are currently being performed by Design Engineering on over a hundred safety related valves.
i When these calculations are complete, this information will be linked with the maintenance effort to establish valve setup settings used by the maintenance craft. This will tie the i
design effort to the maintenance side of the AOV Program.
~ When this link is completed, this committed AOV assessment will be performed on the overall AOV program. The start date of the assessment is estimated to be the end of the second -
quarter of 1999. The completion date for implementing recommendations from the assessment is estimated to be the end of the fourth quarter of 1999.
PIP ltem No.: 2.B.5 (Commitment No. A-24108)
==
Description:==
Perform assessment of the check valve program and implement improvements.
Change: Move due date from first quarter 1998 to RF10.
Justification: The assessment associated with this PIP item is complete.
]
The scope of improvements recommended, as a result of the assessment, requires more resources than was anticipated.
Therefore, it is necessary to extend the docketed due date for implementing improvements it is now estimated that implementation will be complete by RF10. Management is currently evaluating the recommendations; however, it is clear that the time required to complete the PIP item will exceed the docketed due date (first quarter 1998). For the most part, recommendations include activities that will improve documentation.
i
Attachment to W3F1-98-0049 Page 3 of 7 PIP ltem No.: 4.B.33 (Commitment No. A-24161)
==
Description:==
Implement modification to reduce Wet Cooling Tower overspray.
Change: Move due date from fourth quarter 1998 to RF10.
Justification: The priority of this item was reviewed by the Project Review Committee (PRC) and rescheduled to RF10. The change is primarily based on consideration of relative significance of the item as well as business considerations. The problem being addressed by this item is overspray from the Auxiliary Component Cooling Water system falling on equipment and.
personnel passing on a walkway used to access the sewage lift station and Emergency Fuel Oil Storage Tank "B". An industrial hygienist has sampled the system water and has determined that the water poses no health threat to workers g
who may be exposed. Many of the components exposed to i
the overspray have been refurbished and painted, or are in the process of being refurbished, to improve material condition.
The PRC has developed a pnoritized list of projects to be implemented during the current cycle and during the next refueling outage. This prioritization effort coupled with the ongoing efforts which address most of the issues associated with the wet cooling tower overspray justiry deferring the subject design change (DC-3499). The change in schedule will facilitate focusing current resources on higher priority ~
projects to maintain safe reliable operation of Waterford 3.
PIP ltem No.: 4.B.34 (Commitment No. A-24162) i
==
Description:==
Implement modification to resolve the fuel oil storage capacity issue for the Emergency Diesel Generators (EDGs).
Change: Move due date from fourth quarter 1998 to RF9.
t Justification: This is an administrative change to tie the completion of this item to RF9 rather than to a specific date. The docketed due date coincided with a previous estimated RF9 date, which has changed.
2
Attachm::nt to W3F1-98-0049 ~
Page 4 of 7 PIP ltem No.: 4.B.35 (Commitment No. A-24163)
==
Description:==
Implement modification to change the valve operator / power supply on MS-407 (Emergency Feedwater (EFW) steam line emergency drain valve) to Direct Current (D/C).
Change: Move due date from fourth quarter 1998 to RF9.
Justification: This is an administrative change to tie the completion of this item to RF9 rather than to a specific date. The docketed due
'date coincided with a previous estimated RF9 date, which has changed.
PIP ltem No.: 4.B.36 (Commitment No. A-24164)
==
Description:==
Implement modification to provide backup cooling water supply to the Primary Sampling System.
Change: Delete this item.
Justification: PIP items 4.B.36 and 4.B.37 (below) were initiated to provide sources of cooling water to obtain chemistry samples following certain design basis accidents, to meet Emergency Operating Procedure (EOP) requirements. Upon initiation of a Safety injection Actuation Signal (SIAS), the cooling water supply for the Primary and Secondary Sampling Systems (PSL and SSL, respectively), supplied from the non-safety loop of Component Cooling Water (CCW), is isolated. This prohibits sampling of steam generators and reactor coolant systems via normal methods. EOP's required samples to be obtained during various accident conditions based on guidelines from Combustion Engineering CEN-152,
" Emergency Procedure Guidelines", Revision 4. Design Changes DC-3519 and DC-3520 were approved to provide an alternate cooling water supply to the PSL and SSL sample panels. PIP commitments A24164 and A24165 were established to track implementation of these design changes.
The Combustion Engineering Owners Group (CEOG) made changes (effective 10/31/97) to CEN-152, Revision 4 which made these diagnostic samples suggested, but not required
\\
Att chm::nt to W3F1-98-0049 Page 5 of 7 depending on plant condition and design. In addition to sampling requirements changing, Chemistry has revised procedures for PSL and SSL to include a section which details providing an alternate supply of cooling water to these panel heat exchangers using temporary hoses if needed. It is now no longer necessary to perform permanerit plant modifications to provide cooling water to the panels.
Therefore PIP ltems 4.B.36 and 4.B.37 are being deleted.
PlP ltem No.: 4.8.37 (Commitment No. A-24165)
==
Description:==
Implement modification to provide backup cooling water supply to the Secondary Sampling System.
Change: Delete this item.
Justification: See the justification for PIP ltem 4.B.36 above.
PIP ltem No.: 4.B.39 (Commitment No. A-24167) i
==
Description:==
Implement modification to add remote manual operating capability for Containment isolation Valve CVC-209.
Change: Move due date from fourth quarter 1998 to RF9.
Justification: This is an administrative change to tie the completion of this l
item to RF9 rather than to a specific date. The docketed due i
[
date coincided with a previous estimated RF9 date, which has j
changed.
PIP ltem No.: 4.B.41 (Commitment No. A-24169)
==
Description:==
Implement modification to replace Broad Range Toxic Gas Monitor.
Change: Move due date from third quarter 1998 to fourth quarter 1998.
Justification: Completion of this item has been delayed due to unanticipated delays in resolving items with the equipment vendor (e.g., gas detection discrimination discrepancies). Additional
]
Att: chm:nt to W3F1-98-0049 Page 6 of 7 calculations and evaluations were required, which resulted in extending the modification schedule.
PIP ltem No.: 4.B.42 (Commitment No. A-24170)
==
Description:==
Implement modification to provide CCW design pressure re-rate.
Change: Move due date from third quarter 1998 to RF9.
]
Justification: This is an administrative change to tie the completion of this item to RF9 rather than to a specific date. The docketed due date coincided with a previous estimated RF9 date, which has changed.
PIP lton No.: 4.B.44 (Commitment No. A24401) l
==
Description:==
Implement modification to reduce CCW hydraulic transients to below system design pressure.
Change: Move due date from first quarter 1999 to RF9.
Justification: This is an administrative change to tie the completion of this item to RF9 rather than to a specific date. The docketed due date coincided with the current schedule for RF9.
PIP ltem No.: 10.A.2 (Commitment No. A-24221)
==
Description:==
Improve access to plant equipment and reduce long-term scaffolding.
Change: Move due date from fourth quarter 1998 to fourth quarter 1999.
Justification: Presently 16 of the 26 scaffolds originally identified have been removed from the plant and have been replaced with permanent equipment access provisions. Five more scaffolds are scheduled to be replaced with permanent access provisions in 1998. The remaining five will be replaced in 1999.
b
^
Attachm:nt to W3F1-98-0049 Page 7 of 7 In addition to the original PIP items completed, Waterford 3 has installed 21 ladders / platforms to alleviate personnel safety concerns. During RF8, a project to improve personnel safety inside Containment was completed and prefabrication of a permanent handrail for the Refueling Pool was completed. The extended RF8 outage along with the additional scope items being addressed contributed to the need to extend the due date on this item from fourth quarter 1998 to fourth quarter 1999.
1 l
f l'