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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217L0421999-10-21021 October 1999 Forwards Insp Rept 50-382/99-20 on 990815-0925 & Notice of Violation.Two Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20217N2111999-10-19019 October 1999 Forwards Insp Rept 50-382/99-14 on 990913-17 & 1004-08.No Violations Noted.Licensed Operator Requalification Program, Effective,Utilized Systems Approach to Training & Showed Continued Improvements Over Previous Insp Findings ML20217L0101999-10-18018 October 1999 Provides Update of Waterford 3 Effort for Review of Ufsar. Info Listed Includes Background Mgt Expectations,Review Status & Results,Clarifications Re Review & Conclusions ML20217L0141999-10-18018 October 1999 Submits Update to NRC Staff Re Circumstances & Plans for Submitting Certification Rept on Waterford 3 Plant Specific Simulator ML20217G7051999-10-14014 October 1999 Forwards Comments on Four of NRC RO Examination Questions for Exam Administered During Week of 991004 05000382/LER-1999-014, Forwards LER 99-014-00,providing Details of Reactor Shutdown Due to Loss of RCP Controlled bleed-off Flow.Attached Commitment Identification/Voluntary Enhancement Form Identifies All Commitments Contained in Submittal1999-10-12012 October 1999 Forwards LER 99-014-00,providing Details of Reactor Shutdown Due to Loss of RCP Controlled bleed-off Flow.Attached Commitment Identification/Voluntary Enhancement Form Identifies All Commitments Contained in Submittal ML20217D5151999-10-0707 October 1999 Forwards Application for Renewal of SRO License for C Fugate License SOP-43039-3,IAW 10CFR55.57.Without Encls ML20217C6251999-10-0505 October 1999 Informs That NRC Reviewed Util Ltr & Encl Exercise Scenario Package for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Based on Review,Nrc Determined That Exercise Appropriate to Meet Objectives ML20212J6921999-09-29029 September 1999 Forwards Insp Rept 50-382/99-18 on 990830-0902.One Noncited Violation Identified Re Failure to Follow Procedural Instructions to Ensure That Members on Fire Brigade Shift Were Qualified ML20216G2441999-09-27027 September 1999 Forwards Insp Rept 50-382/99-19 on 990830-0903.No Violations Noted 05000382/LER-1999-013, Forwards LER 99-013-00,providing Details of Exceeding TS Limits for RCS Cooldown Rates.All Commitments Contained in Submittal Are Identified on Encl Commitment Identification/ Voluntary Enhancement Form1999-09-23023 September 1999 Forwards LER 99-013-00,providing Details of Exceeding TS Limits for RCS Cooldown Rates.All Commitments Contained in Submittal Are Identified on Encl Commitment Identification/ Voluntary Enhancement Form IR 05000382/19993011999-09-21021 September 1999 Informs That NRC License Exam Previously Associated with NRC Insp Rept 50-382/99-301 Will Be Incorporated Into NRC Insp Rept 50-382/99-14 ML20212D8761999-09-16016 September 1999 Informs That on 990818,NRC Staff Completed Midcycle PPR of Waterford 3.During Assessment Period,Number of Personnel Errors Occurred,Which Demonstrated Lack of Attention to Detail by Plant Personnel.Historical Listing of Issues,Encl ML20212C2471999-09-16016 September 1999 Forwards Five Final Applications for RO Licenses for G Esquival,Jm Hearn,Md Lawson,Re Simpson & PI Wood.Written Exam & Operating Test to Be Administered,Is Requested. Encls Withheld ML20212C2391999-09-16016 September 1999 Requests Cancellation of SRO Licenses for Bn Coble,License SOP-43835,due to Job Assignment Location & CA Rodgers, License SOP-43537-1,due to Resignation from Company, Effective 990901 ML20212C5881999-09-14014 September 1999 Forwards Insp Rept 50-382/99-15 on 990719-23 with Continuing in Ofc Insp Until 0819.No Violations Noted ML20211Q4421999-09-0909 September 1999 Forwards Insp Rept 50-382/99-07 on 990601-11.Three Violations Being Treated as Noncited Violations ML20211P4121999-09-0707 September 1999 Requests NRC Staff Review & Approval of Integrated Nuclear Security Plan (Insp) & Integrated Security Training & Qualification Plan (Ist&Q), for Use by All Entergy Operations,Inc.Encl Withheld,Per 10CFR2.790(d) ML20211M8391999-09-0303 September 1999 Forwards Revised Epips,Including Rev 25 to EP-001-020,rev 24 to EP-001-030,rev 25 to EP-001-040,rev 30 to EP-002-100,rev 22 to EP-001-010,rev 27 to EP-002-010,rev 26 to EP-002-102 & Rev 16 to EP-002-190.Listed Proprietary Revs to Epips,Encl ML20211L3681999-09-0202 September 1999 Forwards Five Preliminary Applications for Reactor Operator Licenses for Individuals Listed,Iaw 10CFR55.31.Encls Withheld ML20211K9741999-09-0101 September 1999 Forwards Insp Rept 50-382/99-16 on 990704-0814.Two Severity Level IV Violations Identified & Being Treated as Noncited Violations,Consistent with App C of Enforcement Policy 05000382/LER-1999-011, Forwards LER 99-011-00,providing Details of Reactor Shutdown Due to Loss of Controlled bleed-off Flow.All Commitments Contained in Submittal Identified on Attached Commitment Identification/Voluntary Enhancement Form1999-08-31031 August 1999 Forwards LER 99-011-00,providing Details of Reactor Shutdown Due to Loss of Controlled bleed-off Flow.All Commitments Contained in Submittal Identified on Attached Commitment Identification/Voluntary Enhancement Form ML20211M3641999-08-30030 August 1999 Forwards Written Examination,Operating Tests & Supporting Ref Matl Identified in Attachment 2 of ES-210,in Response to NRC .Encl Withheld ML20211G5751999-08-27027 August 1999 Forwards RAI Re IPEEE Submittal.Please Provide RAI within 60 Days of Receipt of Ltr,Per Util Response to GL 88-20,suppl 4 ML20211E3281999-08-26026 August 1999 Forwards fitness-for-duty Performance Data for Period of 990101-0630,IAW 10CFR26.71(d).Ltr Does Not Contain Commitments 05000382/LER-1999-009, Forwards LER 99-009-00 Re Discovery of Condition of Noncompliance with App R Involving Inadequate Separation of Essential Cables Routed in Fire Area RAB-30 in Rab. Compensatory Measures Were Established Immediately1999-08-26026 August 1999 Forwards LER 99-009-00 Re Discovery of Condition of Noncompliance with App R Involving Inadequate Separation of Essential Cables Routed in Fire Area RAB-30 in Rab. Compensatory Measures Were Established Immediately 05000382/LER-1999-010, Forwards LER 99-010-00,providing Details of Inadequate Pumping Capacity in Dry Cooling Tower Area.All Commitments Contained in Submittal Are Identified on Attached Commitment Identification Voluntary Enhancement Form1999-08-26026 August 1999 Forwards LER 99-010-00,providing Details of Inadequate Pumping Capacity in Dry Cooling Tower Area.All Commitments Contained in Submittal Are Identified on Attached Commitment Identification Voluntary Enhancement Form ML20211F5421999-08-24024 August 1999 Forwards Proposed marked-up TS Page Xviii, Index Administrative Controls, Correcting Page Number Re TS Change Request NPF-38-220.Editorial Changes for TS Change NPF-38-221 Discussed ML20211F3561999-08-24024 August 1999 Forwards CTS Pages & TS Proposed marked-up Pages for Insertion Into TS Change Request NPF-38-207 Re Efas, Originally Submitted on 980702.Original NSHC Determination Continues to Be Applicable ML20211F4611999-08-24024 August 1999 Informs That NRC Reviewed Ltr & Encl Objectives for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Exercise Objectives Appropriate to Meet Emergency Plan Requirements ML20211G1731999-08-23023 August 1999 Informs That Info Submitted in ,B&W Rept 51-1234900-00,will Be Withheld from Public Disclosure,Per 10CFR2.790 ML20211C5101999-08-19019 August 1999 Forwards Certified Copies of Liability Insurance Policy Endorsements Issued in First Half of 1999 for Each Entergy Operations,Inc Nuclear Unit,Per 10CFR140.15 ML20210T9791999-08-18018 August 1999 Discusses Which Responded to Reconsideration of Violation Denial (EA 98-022) Enforcement Action Detailed in .Concludes That Violation Occurred as Stated ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210S0561999-08-12012 August 1999 Submits Voluntary Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for NRC Fys 2000 & 2001 for Waterford 3 ML20210Q6161999-08-12012 August 1999 Forwards Corrected Copy of Monthly Operating Rept for July 1999 for Waterford 3.Original Rept,Submitted with ,Contained Typos ML20217F2661999-08-12012 August 1999 Forwards Copy of 1999 Waterford 3 Biennial Exercise Package to Be Performed Using Waterford 3 CR Simulator ML20210R9231999-08-11011 August 1999 Forwards Insp Rept 50-382/99-10 on 990719-23.Violations Noted.Nrc Has Determined That One Severity Level IV Violation of NRC Requirements Occurred ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams 05000382/LER-1999-008, Forwards LER 99-008-00,re Failure to Perform Testing of ESF Filtration Units Per TS Srs.Commitments Made by Util Also Encl1999-07-29029 July 1999 Forwards LER 99-008-00,re Failure to Perform Testing of ESF Filtration Units Per TS Srs.Commitments Made by Util Also Encl ML20210H4291999-07-29029 July 1999 Forwards Response to NRC Rai,Associated with TS Change Request NPF-38-208,proposing to Replace Ref to Supplement 1 with Ref to Supplement 2 of Calculative Methods for CE Small Break LOCA Evaluation Model, in ACs Section of TSs ML20210F9451999-07-27027 July 1999 Forwards Proprietary & non-proprietary Version of Rev 29 to EPIP EP-002-100, Technical Support Ctr Activation,Operation & Deactivation. Proprietary Info Withheld,Per 10CFR2.790 ML20210D3171999-07-23023 July 1999 Submits Proposal for Final Resolution of Reracking Spent Fuel Pool at Plant,Per License Amend 144,issued by NRC in .No New Commitments Are Contained in Ltr 05000382/LER-1999-007, Forwards LER 99-007-00,providing Details of Operation Outside Tornado Missile Protection Licensing Basis for turbine-driven Emergency Feedwater Pump Exhaust Stack & Steam Supply Piping.All Commitments Identified on Attached1999-07-23023 July 1999 Forwards LER 99-007-00,providing Details of Operation Outside Tornado Missile Protection Licensing Basis for turbine-driven Emergency Feedwater Pump Exhaust Stack & Steam Supply Piping.All Commitments Identified on Attached ML20210D8701999-07-23023 July 1999 Forwards Safety Evaluation Re First 10-yr Interval Inservice Insp Plan Requests for Relief ISI-018 Through ISI-020 for Entergy Operations,Inc,Unit 3 ML20210B1521999-07-15015 July 1999 Forwards Insp Rept 50-382/99-13 on 990523-0703.Three Violations Being Treated as Noncited Violations ML20209G9771999-07-13013 July 1999 Forwards Objectives & Guidelines for Waterford 3 Emergency Preparedness Exercise Scheduled for 991013.List of Objectives cross-referenced Where Applicable to Relevant Sections of NUREG-0654 IR 05000382/19990081999-07-12012 July 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/99-08 Issued on 990503 ML20209E5231999-07-0909 July 1999 Informs That as Result of NRC Review of Util Responses to GL-92-01,rev 1 & Suppl 1,staff Revised Info in Reactor Vessel Integrity Database & Releasing Database as Rvid Version 2.This Closes Staff Efforts Re TAC MA0583 ML20209D4051999-07-0707 July 1999 Forwards Revised TS Pages to Replace Attachment C,Entirely in Original TS Change Request NPF-38-207,per 990519 Discussion with C Patel of Nrc.Changes to Action 20 Delete Word Requirement & Revise Word Modes to Mode 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217L0101999-10-18018 October 1999 Provides Update of Waterford 3 Effort for Review of Ufsar. Info Listed Includes Background Mgt Expectations,Review Status & Results,Clarifications Re Review & Conclusions ML20217L0141999-10-18018 October 1999 Submits Update to NRC Staff Re Circumstances & Plans for Submitting Certification Rept on Waterford 3 Plant Specific Simulator ML20217G7051999-10-14014 October 1999 Forwards Comments on Four of NRC RO Examination Questions for Exam Administered During Week of 991004 05000382/LER-1999-014, Forwards LER 99-014-00,providing Details of Reactor Shutdown Due to Loss of RCP Controlled bleed-off Flow.Attached Commitment Identification/Voluntary Enhancement Form Identifies All Commitments Contained in Submittal1999-10-12012 October 1999 Forwards LER 99-014-00,providing Details of Reactor Shutdown Due to Loss of RCP Controlled bleed-off Flow.Attached Commitment Identification/Voluntary Enhancement Form Identifies All Commitments Contained in Submittal ML20217D5151999-10-0707 October 1999 Forwards Application for Renewal of SRO License for C Fugate License SOP-43039-3,IAW 10CFR55.57.Without Encls 05000382/LER-1999-013, Forwards LER 99-013-00,providing Details of Exceeding TS Limits for RCS Cooldown Rates.All Commitments Contained in Submittal Are Identified on Encl Commitment Identification/ Voluntary Enhancement Form1999-09-23023 September 1999 Forwards LER 99-013-00,providing Details of Exceeding TS Limits for RCS Cooldown Rates.All Commitments Contained in Submittal Are Identified on Encl Commitment Identification/ Voluntary Enhancement Form ML20212C2391999-09-16016 September 1999 Requests Cancellation of SRO Licenses for Bn Coble,License SOP-43835,due to Job Assignment Location & CA Rodgers, License SOP-43537-1,due to Resignation from Company, Effective 990901 ML20212C2471999-09-16016 September 1999 Forwards Five Final Applications for RO Licenses for G Esquival,Jm Hearn,Md Lawson,Re Simpson & PI Wood.Written Exam & Operating Test to Be Administered,Is Requested. Encls Withheld ML20211P4121999-09-0707 September 1999 Requests NRC Staff Review & Approval of Integrated Nuclear Security Plan (Insp) & Integrated Security Training & Qualification Plan (Ist&Q), for Use by All Entergy Operations,Inc.Encl Withheld,Per 10CFR2.790(d) ML20211M8391999-09-0303 September 1999 Forwards Revised Epips,Including Rev 25 to EP-001-020,rev 24 to EP-001-030,rev 25 to EP-001-040,rev 30 to EP-002-100,rev 22 to EP-001-010,rev 27 to EP-002-010,rev 26 to EP-002-102 & Rev 16 to EP-002-190.Listed Proprietary Revs to Epips,Encl ML20211L3681999-09-0202 September 1999 Forwards Five Preliminary Applications for Reactor Operator Licenses for Individuals Listed,Iaw 10CFR55.31.Encls Withheld 05000382/LER-1999-011, Forwards LER 99-011-00,providing Details of Reactor Shutdown Due to Loss of Controlled bleed-off Flow.All Commitments Contained in Submittal Identified on Attached Commitment Identification/Voluntary Enhancement Form1999-08-31031 August 1999 Forwards LER 99-011-00,providing Details of Reactor Shutdown Due to Loss of Controlled bleed-off Flow.All Commitments Contained in Submittal Identified on Attached Commitment Identification/Voluntary Enhancement Form ML20211M3641999-08-30030 August 1999 Forwards Written Examination,Operating Tests & Supporting Ref Matl Identified in Attachment 2 of ES-210,in Response to NRC .Encl Withheld ML20211E3281999-08-26026 August 1999 Forwards fitness-for-duty Performance Data for Period of 990101-0630,IAW 10CFR26.71(d).Ltr Does Not Contain Commitments 05000382/LER-1999-010, Forwards LER 99-010-00,providing Details of Inadequate Pumping Capacity in Dry Cooling Tower Area.All Commitments Contained in Submittal Are Identified on Attached Commitment Identification Voluntary Enhancement Form1999-08-26026 August 1999 Forwards LER 99-010-00,providing Details of Inadequate Pumping Capacity in Dry Cooling Tower Area.All Commitments Contained in Submittal Are Identified on Attached Commitment Identification Voluntary Enhancement Form 05000382/LER-1999-009, Forwards LER 99-009-00 Re Discovery of Condition of Noncompliance with App R Involving Inadequate Separation of Essential Cables Routed in Fire Area RAB-30 in Rab. Compensatory Measures Were Established Immediately1999-08-26026 August 1999 Forwards LER 99-009-00 Re Discovery of Condition of Noncompliance with App R Involving Inadequate Separation of Essential Cables Routed in Fire Area RAB-30 in Rab. Compensatory Measures Were Established Immediately ML20211F3561999-08-24024 August 1999 Forwards CTS Pages & TS Proposed marked-up Pages for Insertion Into TS Change Request NPF-38-207 Re Efas, Originally Submitted on 980702.Original NSHC Determination Continues to Be Applicable ML20211F5421999-08-24024 August 1999 Forwards Proposed marked-up TS Page Xviii, Index Administrative Controls, Correcting Page Number Re TS Change Request NPF-38-220.Editorial Changes for TS Change NPF-38-221 Discussed ML20211C5101999-08-19019 August 1999 Forwards Certified Copies of Liability Insurance Policy Endorsements Issued in First Half of 1999 for Each Entergy Operations,Inc Nuclear Unit,Per 10CFR140.15 ML20210Q6161999-08-12012 August 1999 Forwards Corrected Copy of Monthly Operating Rept for July 1999 for Waterford 3.Original Rept,Submitted with ,Contained Typos ML20210S0561999-08-12012 August 1999 Submits Voluntary Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for NRC Fys 2000 & 2001 for Waterford 3 ML20217F2661999-08-12012 August 1999 Forwards Copy of 1999 Waterford 3 Biennial Exercise Package to Be Performed Using Waterford 3 CR Simulator 05000382/LER-1999-008, Forwards LER 99-008-00,re Failure to Perform Testing of ESF Filtration Units Per TS Srs.Commitments Made by Util Also Encl1999-07-29029 July 1999 Forwards LER 99-008-00,re Failure to Perform Testing of ESF Filtration Units Per TS Srs.Commitments Made by Util Also Encl ML20210H4291999-07-29029 July 1999 Forwards Response to NRC Rai,Associated with TS Change Request NPF-38-208,proposing to Replace Ref to Supplement 1 with Ref to Supplement 2 of Calculative Methods for CE Small Break LOCA Evaluation Model, in ACs Section of TSs ML20210F9451999-07-27027 July 1999 Forwards Proprietary & non-proprietary Version of Rev 29 to EPIP EP-002-100, Technical Support Ctr Activation,Operation & Deactivation. Proprietary Info Withheld,Per 10CFR2.790 ML20210D3171999-07-23023 July 1999 Submits Proposal for Final Resolution of Reracking Spent Fuel Pool at Plant,Per License Amend 144,issued by NRC in .No New Commitments Are Contained in Ltr 05000382/LER-1999-007, Forwards LER 99-007-00,providing Details of Operation Outside Tornado Missile Protection Licensing Basis for turbine-driven Emergency Feedwater Pump Exhaust Stack & Steam Supply Piping.All Commitments Identified on Attached1999-07-23023 July 1999 Forwards LER 99-007-00,providing Details of Operation Outside Tornado Missile Protection Licensing Basis for turbine-driven Emergency Feedwater Pump Exhaust Stack & Steam Supply Piping.All Commitments Identified on Attached ML20209G9771999-07-13013 July 1999 Forwards Objectives & Guidelines for Waterford 3 Emergency Preparedness Exercise Scheduled for 991013.List of Objectives cross-referenced Where Applicable to Relevant Sections of NUREG-0654 ML20209D4051999-07-0707 July 1999 Forwards Revised TS Pages to Replace Attachment C,Entirely in Original TS Change Request NPF-38-207,per 990519 Discussion with C Patel of Nrc.Changes to Action 20 Delete Word Requirement & Revise Word Modes to Mode ML20209B6081999-06-30030 June 1999 Submits Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. Disclosure Encl 05000382/LER-1999-005, Forwards LER 99-005-00,providing Details of Discovery of Untested Electrical Contacts in safety-related Logic Circuits1999-06-24024 June 1999 Forwards LER 99-005-00,providing Details of Discovery of Untested Electrical Contacts in safety-related Logic Circuits ML20196G5731999-06-24024 June 1999 Forwards Operator Licensing Exam Outlines Associated with Exam Scheduled for Wk of 991004.Exam Development Is Being Performed in Accordance with NUREG-1021,Rev 8 ML20212J4121999-06-23023 June 1999 Responds to NRC Re Reconsideration of EA 98-022. Details Provided on Actions Util Has Taken or Plans to Take to Address NRC Concerns with Ability to Demonstrate Adequate Flow Availability to Meet Design Requirements ML20196E9371999-06-22022 June 1999 Forwards Revs Made to EP Training Procedures.Procedures NTC-217 & NTC-217 Have Been Deleted.Procedure NTP-203 Was Revised to Combine Requirement Previously Included in Procedures NRC-216 & NTC-217 ML20196A1021999-06-17017 June 1999 Provides Supplemental Response to GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves, Per 990513 Request of NRC Project Manager ML20195F3671999-06-0909 June 1999 Forwards Rev 21,Change 0 to EP-001-010, Unusual Event. Rev Reviewed in Accordance with 10CFR50.54(q) Requirements & Determined Not to Decrease Effectiveness of Emergency Plan ML20195C7801999-06-0303 June 1999 Submits Response to Violations Noted in Insp Rept 50-382/99-08.Corrective Actions:All Licensee Access Authorization Personnel Were Retrained Prior to Completion of Insp ML20195C2951999-05-28028 May 1999 Forwards Annual Evaluation of Changes & Errors Identified in Abb CE ECCS Performance Evaluation Models Used for LOCA Analyses.Results of Annual Evaluation for CY98 Detailed in Attached Rept,Based Upon Suppl 10 to Abb CE Rept ML20195C0241999-05-28028 May 1999 Notifies NRC of Operator Medical Condition for Waterford 3 Opertaor Sp Wolfe,License SOP-43723.Attached NRC Form & Memo Contain Info Concerning Condition.Without Encls ML20196L3281999-05-24024 May 1999 Informs That Entergy Is Withdrawing TS Change Request NPF-38-205 Re TS 3.3.3.7.1, Chlorine Detection Sys & TS 3.3.3.7.3, Broad Range Gas Detection Submitted on 980629 ML20206S4691999-05-17017 May 1999 Requests Waiver of Exam for SRO Licenses for an Vest & Hj Lewis,Iaw 10CFR55.47.Both Individuals Have Held Licenses at Plant within Past Two Year Period,But Licenses Expired Upon Leaving Util Employment.Encl Withheld 05000382/LER-1999-004, Forwards LER 99-004-00 Re Discovery That Response Time Testing Had Not Been Performed for ESFAS Containment Cooling Function,As Required by TS SR 4.3.2.31999-05-14014 May 1999 Forwards LER 99-004-00 Re Discovery That Response Time Testing Had Not Been Performed for ESFAS Containment Cooling Function,As Required by TS SR 4.3.2.3 ML20206N1921999-05-10010 May 1999 Provides Revised Attachment 2 for Alternative Request IWE-02,originally Submitted 990429 Re Bolt Torque or Tension Testing of Class Mc pressure-retaining Bolting as Specified in Item 8.20 of Article IWE-2500,Table IWE-2500-1 ML20206J1471999-05-0606 May 1999 Requests That Implementation Date for TS Change Request NPF-38-211 Be within 90 Days of Approval to Allow for Installation of New Monitoring Sys for Broad Range Gas Detection Sys ML20206J1721999-05-0606 May 1999 Notifies That Proposed Schedule for Plant 1999 Annual Exercise Is Wk of 991013.Exercise Objective Meeting Scheduled for 990513 at St John Baptist Parish Emergency Operations Ctr ML20206G8021999-05-0404 May 1999 Provides Revised Response to NRC Re Violations Noted in Insp Rept 50-382/99-01.Licensee Denies Violation as Stated.Change Made Is Denoted by Rev Bar & Does Not Materially Impact Original Ltr ML20206E7811999-04-29029 April 1999 Proposes Alternatives to Requirements of ASME B&PV Code Section XI,1992 Edition,1992 Addenda,As Listed.Approval of Alternative Request on or Before 990915,requested ML20205T2531999-04-22022 April 1999 Forwards LER 99-S02-00,describing Occurrence of Contract Employee Inappropriately Being Granted Unescorted Access to Plant Protected Area ML20205R2611999-04-20020 April 1999 Forwards Rev 19 to Physical Security Plan,Submitted in Accordance with 10CFR50.54(p).Plan Rev Was Approved & Implemented on 990407.Rev Withheld,Per 10CFR73.21 ML20205Q3241999-04-16016 April 1999 Submits Addl Info Re TS Change Request NPF-38-215 for Administrative Controls TS Changes.Appropriate Pages from New Entergy Common QA Program Manual Provided as Attachment to Ltr 1999-09-07
[Table view] Category:UTILITY TO NRC
MONTHYEARW3P90-1505, Forwards Proposed Operator Licensing Exam Schedule & Proposed Requalification Exam Schedule,Per Generic Ltr 90-071990-09-17017 September 1990 Forwards Proposed Operator Licensing Exam Schedule & Proposed Requalification Exam Schedule,Per Generic Ltr 90-07 W3P90-1163, Forwards Relief Requests Associated w/10-yr Inservice Insp Program Per Section 50.55a(g)(6)(i) of 10CFR501990-09-0606 September 1990 Forwards Relief Requests Associated w/10-yr Inservice Insp Program Per Section 50.55a(g)(6)(i) of 10CFR50 W3P90-1191, Responds to Violations Noted in Insp Rept 50-382/90-15. Corrective Actions:Tech Spec Surveillance Procedure PE-005-004 Will Be Revised to Ensure That Normally Closed Valves Opened & Verified to Close for Toxic Gas Signal1990-08-31031 August 1990 Responds to Violations Noted in Insp Rept 50-382/90-15. Corrective Actions:Tech Spec Surveillance Procedure PE-005-004 Will Be Revised to Ensure That Normally Closed Valves Opened & Verified to Close for Toxic Gas Signal W3P90-1194, Submits Fitness for Duty Performance Data for 6-month Period from Jan-June 19901990-08-29029 August 1990 Submits Fitness for Duty Performance Data for 6-month Period from Jan-June 1990 W3P90-1184, Responds to Violations Noted in Insp Rept 50-382/90-14. Corrective Actions:Local Leak Rate Test Activities Shall Be Administratively Controlled to Require Use of Test Method Other than Pressure Decay1990-08-20020 August 1990 Responds to Violations Noted in Insp Rept 50-382/90-14. Corrective Actions:Local Leak Rate Test Activities Shall Be Administratively Controlled to Require Use of Test Method Other than Pressure Decay W3P90-1187, Forwards Booklet Entitled, Safety Info - Plans to Help You During Emergencies, Recently Distributed to General Public1990-08-17017 August 1990 Forwards Booklet Entitled, Safety Info - Plans to Help You During Emergencies, Recently Distributed to General Public W3P90-1189, Forwards Waterford 3 Steam Electric Station Emergency Preparedness Exercise for 901024. Annual Exercise Will Be Performed Using Control Room Simulator1990-08-17017 August 1990 Forwards Waterford 3 Steam Electric Station Emergency Preparedness Exercise for 901024. Annual Exercise Will Be Performed Using Control Room Simulator W3P90-1162, Forwards Rev 4 to 10-Yr Inservice Insp Program First Interval 1985-19951990-08-16016 August 1990 Forwards Rev 4 to 10-Yr Inservice Insp Program First Interval 1985-1995 W3P90-1174, Forwards Rev to Emergency Plan & QA Program,Consisting of Chart Indicating Changes to Util Organization1990-08-0707 August 1990 Forwards Rev to Emergency Plan & QA Program,Consisting of Chart Indicating Changes to Util Organization W3P90-1177, Forwards Revised Objectives for Emergency Preparedness Exercise Scheduled for 9010241990-08-0303 August 1990 Forwards Revised Objectives for Emergency Preparedness Exercise Scheduled for 901024 W3P90-1164, Forwards Waterford Steam Electric Station Unit 3 Basemat Monitoring Program Special Rept 3. Rept Documents Continued Integrity of Basemat as Verified by Program from Time of Inception of Monitoring in 1985 Through Mar 19901990-08-0303 August 1990 Forwards Waterford Steam Electric Station Unit 3 Basemat Monitoring Program Special Rept 3. Rept Documents Continued Integrity of Basemat as Verified by Program from Time of Inception of Monitoring in 1985 Through Mar 1990 W3P90-1167, Forwards Rev 12 to Emergency Plan Implementing Instruction EP-001-001, Recognition & Classification of Emergency Conditions, Reflecting Name Change of State Agency to Louisiana Radiation Protection Div1990-07-19019 July 1990 Forwards Rev 12 to Emergency Plan Implementing Instruction EP-001-001, Recognition & Classification of Emergency Conditions, Reflecting Name Change of State Agency to Louisiana Radiation Protection Div W3P90-1148, Responds to NRC 900503 Submittal Concerning Review of Util Rev 6,Change 1 to Inservice Testing Program for Pumps & Valves1990-07-17017 July 1990 Responds to NRC 900503 Submittal Concerning Review of Util Rev 6,Change 1 to Inservice Testing Program for Pumps & Valves W3P90-1143, Advises That 900404 Request for Addl Info Re Tech Spec Change Request NPF-38-103 Will Be Provided by 900803.Change Will Extend Test Frequency of Channel Functional Tests for ESF Actuation Sys & Reactor Protection Sys Instrumentation1990-07-0606 July 1990 Advises That 900404 Request for Addl Info Re Tech Spec Change Request NPF-38-103 Will Be Provided by 900803.Change Will Extend Test Frequency of Channel Functional Tests for ESF Actuation Sys & Reactor Protection Sys Instrumentation W3P90-1379, Provides Notification That Util Has Consolidated Operation of All Nuclear Facilities,Effective 9006061990-07-0202 July 1990 Provides Notification That Util Has Consolidated Operation of All Nuclear Facilities,Effective 900606 ML20044A5541990-06-26026 June 1990 Forwards Response to Generic Ltr 90-04 Requesting Info on Status of Licensee Implementation of Generic Safety Issues Resolved W/Imposition of Requirements or Corrective Actions ML20044A5551990-06-22022 June 1990 Describes Changes Required to Emergency Plan as Result of Transfer of Operations to Entergy Operations,Inc. Administrative Changes to Plan Necessary to Distinguish Support Functions to Be Retained by Louisiana Power & Light W3P90-1365, Provides Notification of Change in Operator Status Per 10CFR50.74 Due to Entergy Corp Consolidating Operation of All Nuclear Generating Facilities,Including Plant Under Util1990-06-19019 June 1990 Provides Notification of Change in Operator Status Per 10CFR50.74 Due to Entergy Corp Consolidating Operation of All Nuclear Generating Facilities,Including Plant Under Util ML20043G3431990-06-14014 June 1990 Requests That All NRC Correspondence Re Plant Be Addressed to RP Barkhurst at Address Indicated in 900523 Ltr ML20043F5121990-06-0808 June 1990 Forwards List of Directors & Officers of Entergy Operations, Inc.Operation of All Plants Transferred to Entergy on 900606 ML20043F2621990-06-0606 June 1990 Requests Withdrawal of 900504 Request to Extend Implementation Date of Amend 60 Re Transfer of Operations to Entergy,Inc.All Necessary Regulatory Approvals Obtained & License Conditions Implemented ML20043C1861990-05-29029 May 1990 Submits Response to 900426 Comments Re Investigation Case 4-88-020.Util Issued P.O. Rev Downgrading Order of Circuit Breakers & Eliminating Nuclear Requirements ML20043E5441990-05-24024 May 1990 Forwards Public Version of Change 1 to Rev 2 to EPIP EP-002-015, Emergency Responder Activation. Release Memo Encl ML20043B3501990-05-23023 May 1990 Forwards Response to Concerns Noted in Insp Rept 50-382/90-02.Response Withheld ML20043B3781990-05-23023 May 1990 Requests Change in NRC Correspondence Distribution List, Deleting Rt Lally & Adding DC Hintz,Gw Muench & RB Mcgehee. All Ref to Util Changed to Entergy Operations,Inc.Proposed NRC Correspondence Distribution List Encl W3P90-1314, Requests NRC Concurrence That Design/Controls/Testing to Minimize Potential for Common Header Blockage Acceptable Per 900510 Meeting.Tap Alternatives for Shutdown Cooling Level Indication Sys Discussed1990-05-21021 May 1990 Requests NRC Concurrence That Design/Controls/Testing to Minimize Potential for Common Header Blockage Acceptable Per 900510 Meeting.Tap Alternatives for Shutdown Cooling Level Indication Sys Discussed ML20043B3271990-05-21021 May 1990 Forwards Justification for Continued Operation Re Taped Splice for Use in Instrument Circuits,Per 900517 Request ML20042F5251990-05-0404 May 1990 Requests Extension of 90 Days to Implement Amend 60 to License NPF-38 in Order to Provide Securities & Exchange Commission Time to Review Transfer of Licensed Activities to Entergy Operations,Inc ML20042E5501990-04-17017 April 1990 Responds to Request for Addl Info Re Feedwater Isolation Valve Bases Change Request Dtd 891006 ML20012F4551990-04-10010 April 1990 Forwards Rev 10,Change 4 to Physical Security Plan.Encl Withheld ML20012F5491990-04-0606 April 1990 Advises That Util Installed Two Addl Benchmarks for Use as Part of Basemat Surveillance Program to Increase Efficiency of Survey Readings.New Benchmarks Will Be Shown on FSAR Figure 1.2.1 as Part of Next FSAR Rev ML20012F3181990-04-0606 April 1990 Forwards Util,New Orleans Public Svc,Inc & Entergy Corp 1989 Annual Repts ML20012E8971990-03-30030 March 1990 Submits Results of Evaluation of Util 900414 Response to Station Blackout Rule (10CFR50.63).Station Mod May Be Required to Change Starting Air Sys to Accomodate Compressed Bottled Air ML20012E2551990-03-27027 March 1990 Responds to Violation Noted in Insp Rept 50-382/90-01. Corrective Actions:Qa Review of Licensed Operator Medical Exam Records Conducted & Sys Implemented to Track Types & Due Dates of Medical Exams Required for Operators ML20012E0511990-03-27027 March 1990 Forwards Rev 10,Change 3 to Physical Security Plan.Rev Withheld ML20012D5461990-03-22022 March 1990 Forwards Documentation from Nuclear Mutual Ltd,Nelia & Nuclear Electric Insurance Ltd Certifying Present Onsite Property Damage Insurance ML20012D4911990-03-21021 March 1990 Responds to NRC 900208 Ltr Re Violations Noted in Investigation Rept 4-89-002.Corrective Action:Proper Sequence of Insp Hold Point Placed in Procedure Under Change Implemented on 880425 ML20012C0691990-03-14014 March 1990 Advises That Util Intends to Address Steam Generator Overfill Concerns (USI A-47) Utilizing Individual Plant Exam Process,Per Generic Ltr 89-14 ML20012C0421990-03-12012 March 1990 Forwards Questionnaire in Response to Generic Ltr 90-01, Request for Voluntary Participation in NRC Regulatory Impact Survey. Results Not Reflective of Particular Calendar Yr ML20012B6731990-03-0707 March 1990 Responds to NRC Bulletin 88-011,Action 1.a Re Insp of Surge Line to Determine Discernible Distress or Structural Damage & Advises That Neither Surge Line Nor Affiliated Hardware Suffered Any Discernible Distress or Structural Damage ML20006F5321990-02-22022 February 1990 Forwards Payment for Order Imposing Civil Monetary Penalty in Response to Enforcement Action EA-89-069 ML20011F1401990-02-21021 February 1990 Responds to Violations Noted in Insp Rept 50-382/89-41. Corrective Action:Review of Independent Verification Requirements Re Maint Activities Performed ML20006F1731990-02-19019 February 1990 Forwards Corrected Pages 9.2-21 & 9.2-22 of Rev 3 to FSAR, Per 891214 Ltr ML20006E5781990-02-13013 February 1990 Forwards Third Refueling Inservice Insp Summary Rept for Waterford Steam Electric Station Unit 3. ML20006D0571990-02-0202 February 1990 Responds to SALP Rept for Aug 1988 - Oct 1989.Contrary to Info Contained in SALP Rept,Civil Penalty Not Assessed by State of Nv for Radioactive Matl Transport Violations.Issue Resolved W/State of Nv W/O Issuance of Civil Penalty ML20006C1631990-01-30030 January 1990 Requests Extension of Commitment Dates in Response to Violations Noted in Insp Repts 50-382/89-17 & 50-382/89-22 to 900222 & 19,respectively.Violations Covered Use of Duplex Strainers & Missing Seismic Support for Cabinet ML20006C1581990-01-29029 January 1990 Forwards Response to Generic Ltr 89-13 Re safety-related Open Svc Water Sys.Instruments in Place on Component Cooling Water Sys/Auxiliary Component Cooling Water Sys HXs Which Connect to Plant Monitor Computer ML20006C1611990-01-29029 January 1990 Responds to NRC Bulletin 89-003 Re Potential Loss of Required Shutdown Margin During Refueling Operations. Instructions for Determining Acceptable Refueling Boron Concentration Provided in Procedure RF-005-001 ML20006B4121990-01-26026 January 1990 Informs That Photographic Surveys Discontinued,Per Basemat Monitoring Program.Monitoring Program Implementing Procedure Will Be Revised to Reflect Change ML20006A7091990-01-22022 January 1990 Forwards List of Individuals That No Longer Require Reactor Operator Licenses at Plant 1990-09-06
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Lounsinma / 3,7eAnoNNsS1neer . e.O.Boxe0340 NEW ORLEANS, LOUISIANA 70160 + (504) 595-3100 POWER & L1GHT ,
$uyksSysE l May 16, 1986 W3P86-0077 A4.05 QA Mr. James M. Taylor Director, Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Enforcement Action EA 86-50
References:
- 1. NRC Region IV letter 4/16/86 (EA 86-50), subject: Notice of Violation and Proposed Imposition of Civil Penalty (NRC Inspection Report 50-382/86-02).
- 2. NRC Inspection Report No. 86-02 via transmittal letter dated 2/27/86.
Dear Mr. Taylor:
Pursuant to 10CFR2.201, Louisiana Power & Light Company submits in Attachment A the responses to the violations identified as I and II in the ,
reference 1 notice of violation.
Additionally, pursuant to 10CFR2.205, LP&L in Attachment B responds to the civil penalty associated with Violation I. Due to extenuating circumstances and the prompt identification, correction and reporting of the violation LP&L requests mitigation of the civil penalty. LP&L has also reviewed the severity level classification of the violation and consequently requests that the violation be re-classified as Severity Level IV, i
Very truly yours, I 8605200006 860516 . b, /
PDR ADOCK 05000382 PDR h,
G K.W. Cook Nuclear Support & Licensing Manager KWC:GEW:ssf Attachment cc: R.D. Martin, NRC Region IV G.W. Knighton, NRC-NRR J.H. Wilson, NRC-NRR NRC Resident Inspectors Office i
y B.W. Churchill W.M. Stevenson "AN EQUAL OPPORTUNITY EMPLOYER"
~
5/16/86 ATTACHMENT A to W3P86-0077 Sheet 1 of 3
~LP&L RESPONSES TO THE VIOLATIONS IN ENFORCEMENT ACTION EA 86-50 VIOLATION I. Violation Assessed a Civil Penalty (was apparent Violation 8602-03)
Technical Specification (TS) 3.6.2.1 requires that two independent containment spray systems be OPERABLE with each spray system capable of taking suction from the RWSP on a containment spray actuation signal and automatically transferring suction to the safety injection system sump on a circulation actuation signal. This applies to MODES 1, 2, 3, and 4.
TS 3.0.4 requires that entry into an OPERATIONAL MODE or other specified condition shall not be made unless the conditions of the limiting condition for operation are met without reliance on provisions contained in the ACTION requirements.
Contrary to the above, on December 16, 1985, the plant entered Mode 3 while relying on the ACTION requirements of TS 3.6.2.1 in that Train B of the Containment Spray system was inoperable due to a closed discharge header valve (CS-111B).
This is a Severity Level III violation.
RESPONSE TO VIOLATION (1) Alleged Violation LP&L admits to the Technical Specification violation and it was reported to NRC as LER-85-055 on January 15, 1986.
(2) Reason for the Violation The error has been attributed to a disconnected reach-rod operator.
When operations personnel attempted to open the valve, they used the reach-rod and mistakenly thought the valve had been opened. Also, a typographical error in the Operations Annunciators Response procedure may have confused the operators.
(3) Corrective Actions That Have Been Taken and Results Achieved The Operations Superintendent added an instruction in the Operation Night Orders cautioning operations personnel on the shortcomings associated with reach-rods and their use for independent verification of valve lineups. In addition, operations personnel have compiled a list of manual valves which are operated by reach rods and have hung warning tags on all accessible valves to instruct plant operators to verify actual valve positions when operating the subject valves. The necessity of treating inoperable reach-rods as plant equipment requiring maintenance and initiating a CIWA to document the work is being stressed to all operations personnel.
5/16/86 ^ ATTACHMENT A to W3P86-0077 .
Sheet 2 of 3 -
(4) Corrective Actions That Will Be Taken The list of manual valves that are operated with reach-rods will be included in.the appropriate operations procedure along with a statement of caution in procedure 0I-10-000, "Waterford 3 Operations
' Department Good Operating Practices". The annunciator title has been changed to identify the valves being monitored. A review will be conducted to determine if there are any other ambiguously titled annunciators and if any are found, they will be appropriately ,
re-named.
.(5) Date When Full Compliance Will Be Achieved Full compliance with Technical Specification 3.6.2.1 was achieved on December 17, 1985.
- - - - - . - - l
5/16/86 ATTACHMENT A to W3P86-0077 Sheet 3 of 3 ,
VIOLATION II - Violation Not Assessed a Civil Penalty (was apparent Violation 8602-04).
. TS 6.8.1 requires, in part, that written procedures be established for the procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33 Revision 2, Appendix A, requires procedures for performance of maintenance on safety-related equipment. Regulatory Guide 1.33, endorses ANSI N18.7-1976 which requires (paragraph 5.3.5) that provisions be provided for conducting and recording results of required tests.
Contrary to the above, adequate written procedures were not established for the work required by Condition Identification Work Authorization 024584 in that no written requirements were specified or results recorded for the required operability test on Chiller Unit A of the Essential Chilled Water System following corrective maintenance.
This is a Severity Level IV violation.
RESPONSE TO VIOLATION (1) Alleged Violation LP&L admits to the violation.
(2) Reason for the Violation Condition Identification Work Authorization (CIWA) 024584 did not contain written requirements for recording operability testing for Chiller Unit A for the Essential Chilled Water System. However, Chiller Unit A was properly retested by observation of chilled water temperature being less than 42*F and flow being greater than 500 gpm.
This information is documented in the Control Room Log.
(3) Corrective Action That Has Been Taken Late entries to CIWA 024584 have been made to document that the proper retest of Chiller Unit A was performed.
(4) Corrective Action That Will Be Taken Plant procedure OP-100-010 Equipment Out of Service, will be revised to incorporate the provision for identifying and documenting retest requirements for safety-related equipment.
(5) Date When Full Compliance Will Be Achieved The procedure is expected to be revised and approved by June 13, 1986.
I
5/16/86 ATTACHMENT B to W3P86-0077 Sheet 1 of 5 LP&L FILING PURSUANT TO 10CFR2.205 FOR VIOLATION I OF EA 86-50 Summary Enforcement Action 86-50 proposed imposition of a civil penalty on LP&L.for violation of Technical Specification 3.0.4 which requires that entry into an operational mode shall not be made unless the limiting conditions for operation are met without reliance on provisions contained in the action statements.- Specifically, on December 16, 1985 Waterford 3 entered Mode 3 while relying on the action statement of Technical Specification 3.6.2.1 in that Train B of the Containment Spray System was inoperable due to a closed discharge header valve (CS-111B).
As noted in the violation response (see Attachment A to W3P86-0077), LP&L admits the violation. However, pursuant to 10CFR2.205 LP&L requests mitigation of the civil penalty and reduction in the severity level of the violation.
Exted4ating Circumstances to Support Mitigation Analyses of the occurrence against each of the five factors of Section V.B of 10CFR Part 2, Appendix C, supports substantial mitigation of the civil penalty, as discussed below.
- 1. Prompt Identification and Reporting The inoperability of Train B of the Containment Spray System (CSS) was promptly identified by Operations personnel and reported to the NRC under 10CFR50.73.
On December 16, 1985 Waterford 3 was commencing a plant Feat-up in preparation for power operation. At 1341, while in Mode 4, shutdown cooling was secured. At this point, the CSS is required to be operable in accordance with Technical Specification 3.6.2.1. However, because valve alignments and surveillance are required prior to declaring the CSS operable, reliance is placed upon the action statement of Technical Specification 3.6.2.1 which allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before the CSS must be operable (note: the CSS was finally confirmed operable at 0453 the following day - a period of some 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />).
In performing the CSS valve lineup two valves, among others, must be opened - CS-111B, the Train B pump discharge valve, and CS-1178, the shutdown heat exchanger stop check valve. The position of both valves is indicated in the control room only via a single white alarmed annunciator (E-14 on the N annunciator panel) with the legend ,
" Containment Spray Header B Discharge Valve Closed". Thus, from the control room indication available, it would not be clear which valve could be the source of an alarm condition.
On December 16, 1985, while performing the CSS valve lineup, CS-117B was found to have a disconnected reach rod. This valve was then opened. CS-111B also had a disconnected reach rod. In this case, however, the disconnection was not apparent to the operator, who felt
5/16/86 ATTACHMENT B to W3P86-0077 Sheet 2 of 5 resistance (unlike CS-Il7B) when " opening" the valve. Although CS-IllB remained closed due to the disconnected reach rod, the operator firmly believed that he had opened the valve. At 1600, based on operator completion of the CSS lineup the CSS was declared operable.
At this point, control room personnel were aware that annunciator window E-14 had not cleared. They looked for the annunciator response procedure for this window but were unable to locate it because the Column E annunciator on Panel N had been incorrectly labelled as "F" in the procedures. Had they been able to find the E-14 procedure it would have identified CS-IllB and CS-117B as the initiating devices for the alarm. In the procedure, the possible causes for alarm were stated to be:
- 1. Improper lineup
- 2. Valve not fully on its seat
- 3. Limit switch malfunction Regardless of availability of the E-14 response procedure, the operators' attention would have been directed to first evaluate CS-117B. The reach rod for CS-117B had earlier been found disconnected, while the same operator " opening" CS-111B had found sufficient reach rod turning resistance to indicate that CS-111B had been successfully opened. The known disconnected reach rod for CS-Il7B was enough to suggest that there may be additional problems with that valve. Therefore, although not having the annunciator response procedure in hand, operations personnel over a period of several hours investigated the possibility that either CS-117B was not open or that there may be a broken limit switch associated with the valve. In the course of the investigation, the stem position of CS-117B was checked three times to verify that the valve was open. Based on these ongoing actionc and the previous operator belief that CS-IllB had been properly opened, the shift supervisor had good reason to believe that an electrical problem was causing the alarm condition of annunciator window E-14. Therefore, at 2042, directions were given to enter Mode 3.
It should be noted that during this shift (1500-2300) on December 16, 1985, the control room was quite busy in heating-up the plant in preparation for criticality. Yet, the alarm at annunciator E-14 was given adequate attention (based on the information available) and the thought process followed in tracing potential causes of the alarm tracked that of the mis-labelled annunciator response procedure.
Shift turnover occurred at 2250. Having been briefed on the E-14 alarm by a control room operator who served on both shif ta, the oncoming Control Room Supervisor requested operations personnel to re-investigate the possible reasons for the alarm. At 0425 on December 17, 1985, after researching control wiring diagrams, it was discovered that CS-IllB position was also an input to E-14. Still suspecting an electrical problem, personnel were dispatched to locally '
verify CS-IllB limit switch integrity. Upon local inspection it was
5/16/86 ATTACHMENT B to W3P86-0077 Sheet 3 of 5 discovered that the reach rod to CS-111B was disconnected and that the valve was closed. CS-IllB was immediately opened at 0453, and the CSS re-declared as operable.
From initial " completion" of the CSS lineup at 1600 on December 16, to discovery of the disconnected reach rod and opening of CS-111B at 0453 on December 17, the response of the operations personnel to the alarm at E-14 was professional, timely and appropriate. While availability of the E-14 annunciator response procedure may have led to a slightly earlier identification of CS-IllB as a potential problem (i.e.
operations personnel would not have had to confirm E-14 inputs through CWDs), CS-Il7B would still have been the prime suspect of the I annunciator alarm, and the same investigative process would have been followed. For these reasons, LP&L takes exception to the NRC statement that "... timely and appropriate response to the annunciator indication was not made."
By 0609 on December 17, 1985 the control room personnel had completed the Potentially Reportable Event form identifying that a mode change had occurred with an inoperable CSS train. The NRC Resident Inspector was briefed on the event at the earliest opportunity, and preparation of the LER required by 10CFR50.73 was initiated. The LER was submitted to the NRC via W3P86-00ll dated January 15, 1986 - within the period prescribed by 10CFR50.73.
The NRC has some question about the adequacy of the LER, noting that
"...your subsequent review of the event was deficient in that the Licensee Event Report 382/85-55 that you submitted did not precisely describe when and how this abnormal plant condition was recognized."
It is not clear from the NRC's comment precisely what information was not contained in the LER, which should have been. The LER attributed the identification of the annunciator alarm as leading to the discovery of the disconnected reach rod on CS-IllB. LP&L agrees with the NRC that the root cause of the violation was the failure to adequately control the condition and the status of remote valve operators. For that reason, the LER placed emphasis on the disconnected reach rod and, from that point of view, provided in the LER the essential elements required by 10CFR50.73(b)(2)(ii)(A-L).
LP&L does not, however, agree that failure to follow the appropriate annunciator procedure was a root cause of the violation. As previously noted, operations personnel er untially followed the procedural steps of the relevant annuncia r response procedure.
Having the procedure available would have caly had a minimal effect on the length of time the CSS train was inoperable.
While admitting the violation and its associated root cause, LP&L feels that the actions of its operation staff were highly commendable in quickly and professionally identifying the problem of the disconnected reach rod to CS-IllB and subsequently reporting the Technical Specification violation to the NRC. On this basis, LP&L requests mitigation of the civil penalty.
- xw
(
. 5/16/86 ATTACHMENT B to W3P86-0077 Sheet 4 of 5
- 2. Corrective Action to Prevent Recurrence In th violation response (see Attachment A to W3P86-0077) LP&L identified the detailed corrective action implemented as a result of discovering the violation.
Corrective action was implemented to prevent recurrence as well as longer-term in-depth actions to assure that remote operators would be considered as essential components of plant equipment. All corrective actions were implemented on LP&L's initiative, independent of the NRC's inspection activities. The actions taken were prompt and effective in preventing recurrence of a similar situation. On this basis LP&L requests mitigation of the civil penalty.
- 3. Past Performance Inappropriate mode changes due to faulty valve operation have not previously occurred at Waterford 3.
- 4. Prior Notice of Similar Event LP&L had no prior knowledge of a similar problem due to LP&L audits, or specific NRC or industry notification.
- 5. Multiple occurrences Multiple examples of the violation have not been identified during this inspection period.
Basis for Reduction in Violation Severity Level The violation has been assigned a Severity Level III (Supplement I) by the NRC. LP&L agrees that a technical violation has occurred but disagrees with the severity level assigned.
10CFR2, Appendix C, Supplement I, provides certain examples of Severity Level III violations for reactor operations. No example clearly fits the subject violation, and the inferred characteristics of a Severity Level III violation are more severe than those of the subject violation. Where one train of a significant safety system is inoperable, the exampics imply that the train must be inoperable for a period in excess of that allowed by the associated Technical Specification in order to qualify as a Severity Level III violation. The subject violation concerns non-compliance with Technical Specification 3.0.4 (mode change restrictions) so is not directly applicable. 'However, solely for the purpose of assessing the severity level of the violation, it should be noted that Technical Specification 3.6.2 allows a single CSS train to be inoperable for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The prompt action on the part of LP&L personnel restored operability of CSS Train B in approximately 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />.
The other similar Severity Level III example involves a safety system (i.e., all redundant trains) not being able to perform its safety functions. The subject violation included the loss of one train of the CSS for a period less than the allowabic outage time (had there been no mode
. 5/16/86 ATTACHMENT B to W3P86-0077 Sheet 5 of 5 change). The redundant CSS train was available to perform its intended safety function throughout the time in question.
To place the violation in perspective, with respect to Severity Level classification, one could postulate that the plant had been in Mode 3 pri.or to CS-111B closing. For such a hypothetical case, the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> action statement of Technical Specification 3.6.2 would apply. Restoring operability of CSS Train B within 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> would have resulted in compliance with the Technici.1 Specifications and no violation. What has been reported by LP&L is a technical violation of Technical Specification 3.0.4 which is not of appropriate safety significance to be classified as a Severity Level III violation.
The Severity Level IV examples in 10CFR2 Appendix C discuss less significant Technical Specification violations. LP&L feels that the subject violation is appropriately classified as a Severity Level IV.
Accordingly, LP&L requests that the Severity Level of the violation be reviewed and amended as appropriate.
L