ML20249A470
| ML20249A470 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 06/10/1998 |
| From: | Dugger C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-98-0113, W3F1-98-113, NUDOCS 9806160469 | |
| Download: ML20249A470 (4) | |
Text
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,y Ente gy Opections,Inc.
l Kiliona, LA 70006-0751 Tel 504 739 (400 Vce resi n Ope a Kns Waterford 3 W3F1-98-0113 A4.05 PR June 10,1998 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 Supplemental Information for Quality Assurance program Manual Update (Revision 19)
' Gentlemen:
On May 28,1998, Entergy personnel held a telephone conference call with NRC personnel regarding Waterford 3 Letter W3F1-98-0073, dated April 29,1998. The letter addressed an NRC Request for Information (RAI) regarding the Quality Assurance Program Manual (OAPM) Update, Revision 19 related to insulation resistance testing of electrical motors.
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During the conference call, the NRC noted a discrepancy between the proposed QAPM change and its justification. The purpose of this letter is to provide the revised QAPM Change Review Form wherein the noted discrepancy has been corrected.
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Specifically, in'the QAPM Change Review Form, the phrase, " periodic in-storage insulation resistance testing to motors which operate at greater than 460V" was revised to " periodic in-storage insulation resistance testing to motors which operate at greater than or equaI to 460V" to exactly match the wording in the proposed change.-
9906160469 980610 f
PDR ADOCK 05000382 P-PDR
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4 Supplemental Information for Quality Assurance Program Manual Update (Revision 19)
W3F1-98-0113 Page 2 June 10,1998 Attached is the revised QAPM Change Review Form. 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,
/
ar C.M. Dugger Vice President, Operations Waterford 3 CMD/ PRS /rtk Attachments (w/ Attachments) cc:
E.W. Merschoff (NRC Region IV)
C.P. Patel (NRC-NRR)
NRC Resident inspectors Office (w/o Attachments)
J. Smith N.S. Reynolds i
a
d UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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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AFFIDAVIT Charles Marshall Dugger, being duly sworn, hereby deposes and says that he is Vice President, Operations - Waterford 3 of Entergy Operations, incorporated; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached 10 CFR 50.54 Quality Assurance Program Change Review Form; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.
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Charles Marshall Dugger Vice President, Operations Waterford 3 STATE OF LOUISIANA
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) ss PARISH OF ST. CHARLES
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Subscribed and sworn to before me, a Notag Public in and for the Parish and State above named this -ce day of
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.1998.
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Notary Public L
_ My' _ Commission expires d2d/.
QUALITY ASSURANCE PROGRAM CHANGE REVIEW FORM PROPOSED CHANGE:
Re-word the second sentence 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
'A 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
'A 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?
Explain:
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 or equal to 460V. The proposed change also clarifies that these requirements do not apply to fractional horsepower motors. The exclusion of fractional horsepower motors is consistent with the guidelines provided in IEEE 43.
Insulation resistance testing performed at receipt inspection is primarily intended for investment protection; assurance 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 n t dd significantly to that assurance for motors less than 460V.
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8 Reviewed By:
'QA Repfen Ive d
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Elate RECOMMENDATION:
Does not represent a lessening of commitment and it can be implemented immediately.
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
'A submitted to the NRC for acceptance prior to implementation.
Represents a lessening of commitment with insufficient basis to determine continued compilance.
g Therefore, the change ethanid nnt be processed.
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Recommended By:
QA S%isor #
Date 3
DISPOSITION:
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Approved for implementation Disapproved Approved for submittal the NRC for acceptance
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- Approved By
Diirecdor, Quality Date
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