ML20236F626
| ML20236F626 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 06/30/1998 |
| From: | Ewing E ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-98-0121, W3F1-98-121, NUDOCS 9807020257 | |
| Download: ML20236F626 (5) | |
Text
-
y Entsrgy Operations,Inc.
Killona, LA 70066 Tel 504 739 6242 Early C. Ewing, til i
ety & Regulatory AHairs l
W3F1-98-0121 A4.05 PR June 30,1998 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 Completica Due Date Changes Gentlemen:
The purpose of this letter is to provide the NRC with changes to the docketed completion due dates for five Performance improvement Plan (PIP) action items.
/
These changes are necessary due to resource limitations and re-prioritization of
/'
pending work to ensure issues are addressed on a schedule that is commensurate with their safety significance. Attached is a summary of these changes and their associated justifications. The need for these changes and their revised due dates were discussed in a telephone conference call with the Waterford 3 NRC Region IV Branch Chief on June 29,1998.
The management team at Waterford 3 continues to be committed to improving our regulatory performance. Management believes many improvements are being achieved as a result of the PIP program and is committed to completing the action items identified. Our goalis sustained superior performance at Waterford 3.
9807020257 980630 PDR ADOCK 05000302 P
j.
Performance improvement Plan Action item Completion Due Date Changes W3F1-98-0121 Page 2
'. June 30,1998 If you have any questions concerning the above, please contact me at l
(504) 739-6242.
- Very truly yours, l
A.
E.C. Ewing Director -
l
' Nuclear Safety & Regulatory Affairs ECE/MKB/ssf
Attachment:
Performance improvement Plan (PIP) Completion Due Date Changes cc:
E.W. Merschoff, NRC. Region IV P.H. Harrell, NRC Region IV.
I C.P. Patel, NRC-NRR J. Smith N.S. Reynolds NRC Resident inspectors Office I
l L
i e
L________.____.
._1.
)
Attachment to W3F1-98-0121 Page 1 of 3 PERFORMANCE IMPROVEMENT PLAN (PIP)
COMPLETION DUE DATE CHANGES PIP ltem No.: 1.D. 6 (Commitment No. A-24089)
==
Description:==
Complete the discovery phase of the Design Bases Review Program for the balance of the selected mechanical systems Change:
Move due date from first quarter 1999 to second quarter 1999.
Justification: This extension is needed as a result of the current Engineering werkload and the impact of the NRC AE inspection. This change will not adversely impact the ability of the plant to operate safely. It will only allow additional time to complete the scope ofidentified reviews. It should be noted this scope includes six systems, and five of the six are still currently scheduled internally to be completed by the original due date.
Based on our current workload, the completion of this part of this activity associated with the Fuel Building Ventilation system will need to be extended by one quarter. This system is considered to be of low safety importance.
PIP ltem No.: 1.D.7 (Commitment No. A-24090)
==
Description:==
Complete the upgrade of me.:hanical calculations identified as unsatisfactory in the discovery phase of the Design Bases Review Program.
Change:
Move due date from December 15,1999 to first quarter 2000.
Justification: This extension is needed as a result of the current Engineering workload and the impact of the NRC AE inspection. This change will not adversely impact the ability of the plant to operate safely. It will only allow additional time to complete the upgrade of mechanical calculations. Corrective actions for l
discrepancies will continue to be performed on a schedule that is commensurate with their safety significance. Those items that will be completed beyond the original schedule will be those items that have minimal safety importance.
l l
Attachm:mt to W3F1-98-0121
{
Page 2 of 3 PIP ltem No.: 1.D.9 (Commitment No. A-24092)
Descripiton:
Upgrade design and testing bases for selected areas.
Change:
Move due date from third quarter 1998 to first quarter 1999.
Justification: This item encompasses six subparts that were described in the Waterford 3 February 6,1997 submittal (W3F1-97-0025) in response to the NRC's October 9,1996 50.54(f) letter. The committed date from our 50.54(f) letter was June 30,1998 vice the third quarter 1998 date provided in our original PIP submittal. Since our 50.54(f) submittal had the more restrictive l
date, the needed schedule extension and its justification are being provided under separate cover to explicitly address this item for the 50.54(f) letter. See Waterford 3 letter W3F1 0122 cated June 30,1998.
Note that a docketed commitment tied to the implementation of the Technical Specification LCO Uncertainty Evaluation project (one of the six subparts under this item) was also made in the Waterford 3 July 21,1997 submittal (W3F1-97-0177)
"NRC Inspection Report 97-08 Reply to Notice of Violation."
l The July 21,1997 letter commits to a review of the Technical Specifications for instrument uncertainty by June 30,1998 as part of the generic corrective action for the violation. The specific issue addressed in this violation response involved the 1
uncertainty associated with the containment spray riser level specified in the TS. This commitment will now be completed by the revised date shown above for this PIP item.
1 a
Attachmsnt to W3F1-98-0121 Page 3 of 3 Pf P lterb No.: 4.B.38 (Commitment No. A-24166) l
==
Description:==
Implement modification to enhance security lighting.
Change:
Move due date from third quarter 1998 to fourth quarter 1999.
Justification: The priority of this item was reviewed by the Project Review Committee (PRC) and rescheduled from cycle 9 to cycle 10.
The change is primarily based on consideration of relative significance of the item as well as business considerations.
The delay of this modification will not adversely impact the safe operation of Waterford 3.
PIP ltem No.: 9.B.4 (Commitment No. A-24219)
==
Description:==
Revise the Emergency Operation Procedures (EOPs) to incorporate revised CEN-152 standards.
Change:
Move due date from second quarter 1998 to third quarter 1998.
Justification: The delay in our progress is largely due to the unavailability of the required Engineering resources to complete our review of the Parameter Values Basis Document. This effort has been impacted by the diversion of resources due to the AE Inspection and other emerging Engineering issues.
Note that docketed commitments tied to the completion of this EOP revision effort were also made in Waterford 3 submittats dated May 14,1998 (W3F1-98-0087) " Emergency Plan Implementing Procedure" and November 24,1997 (W3F1 0260) "NRC Inspection Report 50-382/97-17 Reply to Notice l
of Violation." The May 14,1998 letter discusses the addition of an action regarding the closure of the Safety injection System Sump Isolation Valves SI-602A(B) in the revised EOPs by June 30,1998. The November 24,1997 letter discusses the addition of an action regarding the closure of the Containment Spray Valves CS-125A(B), with the Containment Spray Pumps not running, in the appendices to the revised EOPs by June 30,1998. Both of these commitments will now l
be completed by the revised date shown above for this PIP item.
_ _ - - _ - - _ - _ _ _ _ - _ - - -