ML20217K156
| ML20217K156 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 04/29/1998 |
| From: | Dugger C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-98-0073, W3F1-98-73, NUDOCS 9805010112 | |
| Download: ML20217K156 (4) | |
Text
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y Entzrgy Operations, Inc.
KWona. LA 700f/F0751 Tel 504 739 6660 Charles M. Dugger
%ce Pres dent Owahons W3F1-98-0073 A4.05 PR April 29,1998 i
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 Supplemental Information for Quality Assurance Program Manual Update (Revision 19)
Gentlemen:
l Entergy personnel on March 10,1998, held a telephone conference call with NRC personnel regarding a Waterford 3 response submitted via Waterford 3 Letter W3F1-98-0024, dated February 26,1998. The letter addressed an NRC Request for Information (RAI) regarding the Quality Assurance Program Manual (QAPM) Update, Revision 19.
During the conference call, the NRC requested supplemental information to support the justification for the QAPM change related to insulation resistance testing of electrical motors. The purpose of this letter is to provide the revised QAPM change justificulon as descnbed below.
Currently the Quality Assurance Program Manual requires insulation resistance
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testing upon receipt, then on a periodic basis, and again prior to installation. The proposed QAPM change will eliminate the requirement to perform insulation resistance testing upon receipt and will limit periodic in-storage insulation resistance testing to motors which operate at greater than 4SOV. The justification for this 7
jj change is based on the following: (1) the insulation resistance testing performed at Ol CO 7 receipt is intended for investment protection; this testing is not a barrier relied upon i
to provide validation of future operability, (2) the operability of safety related motors which operate at greater than 460V will be verified by pre-installation operability tests, and (3) the elimination of the periodic in-storage insulation resistance tests, which are not relied upon to validate future operability, will achieve a desired work reduction.
9805010112 900429 PDR ADOCK 0500 2
Supplemental Information for Quality Assurance Program Manual Update (Revision 19)
W3F1-98-0073 Page 2 April 29,1998 Attached is the revised QAPM Change Review Form which includes the aforesaid information.
If you have any questions concerning this submittal, please contact Early Ewing at (504) 739-6242 or Tim Gaudet at (504) 739-6666.
Very truly yours,
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V C.M. Dugger Vice Presiden. Jperations Waterford 3 CMD/ PRS /rtk Attachments (w/ Attachments) cc:
E.W. Merschoff (NRC Region IV)
NRC Resident inspectors Office (w/o Attachments)
C.P. Patel (NRC-NRR)
J. Smith N.S. Reynolds
l l
J UNITED STATES OF AMERICA NUCl. EAR REGULATORY COMMISSION i
In the matter of
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Entergy Operations, incorporated
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Docket No. 50-382 Waterford 3 Steam Electric Station
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l Charles Marshall Dugger, being duly sworn, hereby deposes and says that he is Vice l
President, Operations - Waterford 3 of Entergy Operations, incorporated; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached i
l 10 CFR 50.54 Quality Assurance Program Change Review Form; that he is familiar l
with the content thereof; and that the matters set forth therein are true and correct to l
the best of his knowledge, information and belief.
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'G a m
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Charles Marshall Dugger of l
Vice President, Operations i
Waterford 3 I
STATE OF LOUISIANA
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) ss PARISH OF ST. CHARLES
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Subscribed and sworn t Public in and for the Parish and State above named this c6gbefore me, a Nota fh d
.1998.
day of V
(' ~Y
( W.N < <
1.'N Notary Public My Commission expires b
QUALITY ASSURANCE PROGRAM CHANGE REVIEW FORM TROPOSED CHANGE:
Re-word the second sentance of the second paragraph of section 6 to read, "Waterford 3 performs periodic in-storage insulation resistance tests only on motors greater than or equal to 460V. An extensive run-in test is performed on safety-related motors greater than 1 HP prior to installation to verify operability."
10CFR50.54 REVIEW:
- 1. Does the proposed change represent a reduction of commitment to the U Yes No QA Program description previously accepted by the NRC?
Explain:
Appendix A, Rev. 6.0 - section 6 (Now Chap. 2 Attach. 7.2 after format change) - This change represents a lessening of commitment. The current wording of this section implies that all motors will be tested for insulation resistance at receipt.
- 2. If item 1 above is YES, does the proposed change include the basis to
Yes No N/A conclude that the revised program incorporating the change continues to meet the criteria of 10CFR50 Appendix B and other previously accepted FSAR commitments?
4 Explain:
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Currently the Quality Assurance Program Manual requires insulation resistance testing upon receipt then on a periodic basis and again prior to installation. The proposed change eliminates the requirement to perform resistance testing upon receipt and limits periodic in-storage insulation tests to motors greater than 460V. The proposed change also clarifies that these requirements do not apply to fractional horsepower motors. The exclusion of fractional horsepower i
motors is consistent with the guidelines provided in IEEE 43.
Insulation resistance testing performed at receipt inspection is primarily iritended for investment protection; assurance 1
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that the motors can perform their safety-related function is provided by the pre-installation testing. Ceasing the in-storage testing of motors less than 460V will reduce the work load on plant personnel. The justification for this change is that the run-in tests performed prior to installation provide sufficient assurance of operability and that the in-storage insulation resistance tests do ot add significantly to that assurance for motors less than 460V.
law A. hawss and7 /997 Reviewed By:
' QA Reppffentgive U
'Date RECOMMENDATION:
Does not represent a lessening of commitment and it can be implemented immediately.
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Represents a lessening of commitment, however, the change has sufficient basis to demonstrate continued compliance with Appendix B and other FSAR commitments. Therefore,it should be submitted to the NRC for acceptance prior to implementation.
l Represents a lessening of commitment with insufficient basis to determine continued compliance.
Therefore, the change should not be processed.
l Recommended By:
Date DISPOSITION:
Approved for implementation Disapproved Approved for submittal to th/ RC for acceptance
'A W
kM2N Approved By:
Directbr, C[uality Date i