W3F1-2009-0066, Clarification of Response to Generic Letter 2007-01 Question 2

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Clarification of Response to Generic Letter 2007-01 Question 2
ML093310414
Person / Time
Site: Waterford Entergy icon.png
Issue date: 11/25/2009
From: Kowalewski J
Entergy Nuclear South, Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-07-001, W3F1-2009-0066
Download: ML093310414 (3)
v • d • e


Text

Entergy Nuclear South Entergy Operations, Inc.

17265 River Road Killona, LA 70057-3093 Tel 504 739 6660 Fax 504 739 6678 jkowale@entergj,.com Joseph A. Kowalewski Vice President, Operations Waterford 3 W3F1 -2009-0066 November 25, 2009 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Clarification of Response to Generic Letter 2007-01 Question 2 Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NFP-38

References:

1. NRC Generic Letter 2007-01, Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients, dated February 7, 2007
2. Waterford Steam Electric Station, Unit 3, response to Generic Letter 2007-01, dated May 3, 2007 (W3F1 -2007-0017)
3. NRC Inspection Report, dated November 2, 2009, Waterford Steam Electric Station, Unit 3 - NRC Component Design Bases Inspection Report 05000382/20090099

Dear Sir or Madam:

In Reference 1, the .NRC requested that facilities submit the following information to the NRC within 90 days of the date of the Generic Letter:

Describe inspection, testing, and monitoring programs to detect the degradation of inaccessible or underground power cables that support emergency diesel generators, offsite power, essential service water, service water, component cooling water, and other systems that are within the scope of 10CFR50.65 (the maintenance rule).

In Reference 2, Waterford 3 responded to this request as follows: "Waterford 3 inspection, testing and monitoring practices presently include visual cable inspection during meggering of cables and connected equipment during maintenance activities. Plant condition reporting is used to determine root cause and extent of conditions and would be the process for determining the need for and the extent of any increased cable monitoring."

W3F1 -2009-0066 Page 2 The Waterford 3 response to this Generic Letter request has been viewed by the NRC as lacking clarity as documented in NRC Inspection Report No. 05000382/2009009 (Reference 3). This condition was documented in the Waterford 3 Corrective Action Program as Condition Report CR-WF3-2009-04935.

This correspondence clarifies the intent of the Waterford 3 initial response to the Generic Letter. The Waterford 3 initial response was not intended to describe any "formal" process or program, but rather was a statement of generic practices employed during maintenance activities. The initial response was intended to communicate the fact that any cable failures or degradation identified during routine maintenance or observation is expected to be entered into the corrective action program. The visual inspection referred to in the initial response to the Generic Letter was referring to the approximate two foot section of cable in the switchgear that the megger equipment was connected to during the test. The visual inspections referred to in the initial response were not intended to mean end to end cable inspections. The Waterford 3 current practices regarding submerged cables are consistent with the above clarifying statements.

There are no regulatory commitments contained in this letter.

Please contact me or Robert J. Murillo at 504-739-6715, Manager, Licensing should you have any questions.

This information is being provided pursuant the requirements of 10CFR50.54(f). I declare under the penalty of perjury that the foregoing information is true and correct. Executed on November 25, 2009.

Sincerely, JAK/PRR

W3F1 -2009-0066 Page 3 cc: Mr. Elmo E. Collins, Jr.

Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Senior Resident Inspector Waterford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751 U. S. Nuclear Regulatory Commission Attn: Mr. N. Kalyanam Mail Stop O-07D1 Washington, DC 20555-0001 Wise, Carter, Child & Caraway ATTN: J. Smith P.O. Box 651 Jackson, MS 39205 Winston & Strawn ATTN: N.S. Reynolds 1700 K Street, NW Washington, DC 20006-3817 Morgan, Lewis & Bockius LLP ATTN: T.C. Poindexter 1111 Pennsylvania Avenue, NW Washington, DC 20004

Text

Entergy Nuclear South Entergy Operations, Inc.

17265 River Road Killona, LA 70057-3093 Tel 504 739 6660 Fax 504 739 6678 jkowale@entergj,.com Joseph A. Kowalewski Vice President, Operations Waterford 3 W3F1 -2009-0066 November 25, 2009 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Clarification of Response to Generic Letter 2007-01 Question 2 Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NFP-38

References:

1. NRC Generic Letter 2007-01, Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients, dated February 7, 2007
2. Waterford Steam Electric Station, Unit 3, response to Generic Letter 2007-01, dated May 3, 2007 (W3F1 -2007-0017)
3. NRC Inspection Report, dated November 2, 2009, Waterford Steam Electric Station, Unit 3 - NRC Component Design Bases Inspection Report 05000382/20090099

Dear Sir or Madam:

In Reference 1, the .NRC requested that facilities submit the following information to the NRC within 90 days of the date of the Generic Letter:

Describe inspection, testing, and monitoring programs to detect the degradation of inaccessible or underground power cables that support emergency diesel generators, offsite power, essential service water, service water, component cooling water, and other systems that are within the scope of 10CFR50.65 (the maintenance rule).

In Reference 2, Waterford 3 responded to this request as follows: "Waterford 3 inspection, testing and monitoring practices presently include visual cable inspection during meggering of cables and connected equipment during maintenance activities. Plant condition reporting is used to determine root cause and extent of conditions and would be the process for determining the need for and the extent of any increased cable monitoring."

W3F1 -2009-0066 Page 2 The Waterford 3 response to this Generic Letter request has been viewed by the NRC as lacking clarity as documented in NRC Inspection Report No. 05000382/2009009 (Reference 3). This condition was documented in the Waterford 3 Corrective Action Program as Condition Report CR-WF3-2009-04935.

This correspondence clarifies the intent of the Waterford 3 initial response to the Generic Letter. The Waterford 3 initial response was not intended to describe any "formal" process or program, but rather was a statement of generic practices employed during maintenance activities. The initial response was intended to communicate the fact that any cable failures or degradation identified during routine maintenance or observation is expected to be entered into the corrective action program. The visual inspection referred to in the initial response to the Generic Letter was referring to the approximate two foot section of cable in the switchgear that the megger equipment was connected to during the test. The visual inspections referred to in the initial response were not intended to mean end to end cable inspections. The Waterford 3 current practices regarding submerged cables are consistent with the above clarifying statements.

There are no regulatory commitments contained in this letter.

Please contact me or Robert J. Murillo at 504-739-6715, Manager, Licensing should you have any questions.

This information is being provided pursuant the requirements of 10CFR50.54(f). I declare under the penalty of perjury that the foregoing information is true and correct. Executed on November 25, 2009.

Sincerely, JAK/PRR

W3F1 -2009-0066 Page 3 cc: Mr. Elmo E. Collins, Jr.

Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Senior Resident Inspector Waterford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751 U. S. Nuclear Regulatory Commission Attn: Mr. N. Kalyanam Mail Stop O-07D1 Washington, DC 20555-0001 Wise, Carter, Child & Caraway ATTN: J. Smith P.O. Box 651 Jackson, MS 39205 Winston & Strawn ATTN: N.S. Reynolds 1700 K Street, NW Washington, DC 20006-3817 Morgan, Lewis & Bockius LLP ATTN: T.C. Poindexter 1111 Pennsylvania Avenue, NW Washington, DC 20004

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