NL-02-163, Amended Response to Notice of Violation and Proposed Imposition of Civil Penalty
| ML030080384 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/31/2002 |
| From: | Dacimo F Entergy Nuclear Northeast, Entergy Nuclear Operations |
| To: | Borchardt R NRC/OE |
| References | |
| NL-02-163 | |
| Download: ML030080384 (6) | |
Text
AM Entergy Nuclear Northeast Entergy Nuclear Operations, Inc SEnhtergy Indian Point Energy Center 295 Broadway, Suite 1 PO Box 249 Buchanan, NY 10511-0249 December 31, 2002 Re: Indian Point Unit No. 2 Docket No. 50-247 NL-02-163 Mr. R. William Borchardt, Director, Office of Enforcement U.S. Nuclear Regulatory Commission One White Flint North, 11555 Rockville Pike Rockville, MD 20852-2738
SUBJECT:
Amended Response to Notice of Violation and Proposed Imposition of Civil Penalty REF: NRC Inspection Report Nos. 50-247/99-08, 99-13, and 99-14, and Letter to Mr.
Borchardt from Mr. Baumstark, dated March 27, 2000
Dear Mr. Borchardt:
This letter amends our previous letter dated June 5, 2000 on the subject notice. One of the commitments in the letter dated June 5, 2000 was changed. Attachment A describes the original commitment, the revised commitment and the justification for change.
Commitments made by the Licensee in this letter are listed in Attachment B to this letter.
The amended response does not include any personal, proprietary, or safeguards information.
Should you or your staff have any questions regarding this matter, please contact Mr. John F.
McCann, Manager, Licensing at (914) 734-5074.
Sincerely, Vice President - Operations Indian Point 2 Attachments cc: Next page
NL-02-163 cc: Document Control Desk US Nuclear Regulator Commission Mail Station P1-137 Washington, DC 20555 Mr. Hubert J. Miller Regional Administrator - Region I US Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Patrick D. Milano, Senior Project Manager Project Directorate I-1 US Nuclear Regulatory Commission Mail Stop 0-8-2C Washington, DC 20555 Mr. John L. Minns, Project Manager Division of Reactor Program Management US Nuclear Regulatory Commission Mail Stop 10-D4 Washington, DC 20555 Senior Resident Inspector US Nuclear Regulatory Commission PO Box 38 Buchanan, NY 10511
Attachment A NL-02-163 Page 1 of 2 ATTACHMENT TO NL-02-163 Change to Regulatory Commitment
Attachment A NL-02-163 Page 2 of 2 ATTACHMENT A ORIGINAL COMMITMENT The original commitment stated: Update and/or develop design basis documents to include current design and licensing basis information. Due date 12/31/02.
REVISION/JUSTIFICATION The revised commitment now states: Update/create Design Basis documents for AC Power, Fire Protection, Cable Separation. Due date 12/31/03.
The justification for change is: Under the Design Basis Initiative, upgrade work is being done on the electrical and fire protection areas. It is more logical to upgrade/create the design documents for these areas after the basis itself is upgraded. Therefore this work will be performed in 2003 after the basis work is complete.
The commitment is a defense in depth approach to human errors. Improving the design basis, training, Corrective action program and error reduction techniques such as questioning attitude and peer checks are all designed to improve human performance and remove any negative impacts on overall safety of the plant. Improvements in design basis itself are ongoing and the design basis document is just one of the tools used. The basis itself is being upgraded now.
This revised scheduled to prepare this reference document with the overall basis improvement is appropriate and will not diminish the plant's capabilities to understand and assure performance of all safety functions.
Attachment B NL-02-163 Page 1 of 2 ATTACHMENT TO NL-02-163 Summary of Change to Regulatory Commitment
Attachment B NL-02-163 Page 2 of 2 ATTACHMENT B Entergy ---Indian Point 2 Commitment The following identifies the action committed to by Entergy in this document. Any other actions discussed in the submittal represent intended or planned actions by Entergy and are described to the NRC herein for the NRC's information and are not regulatory commitments.
Commitment Due Date Update/create Design Basis documents for AC power, Fire 12/31/2003 Protection, Cable Separation.