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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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. e. o. Box so34o l OUISI POWE A&ANALIGHT / aireAnoNNeSinceT NEW ORLEANS. LOUISlANA 70160 * (504) 595 3100
$$b hs4k0 April 3, 1989 W3P89-0070 A4.05 QA 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 h1C Inspection Report 89-02 Gentlemen:
In accordance with 10 CFR Part 2.201, Louisiana Power & Light hereby submits in Attachment 1 the responses to the Violations identified in Appendix A of the subject Inspection Report.
If you have any questions concerning these responses, please contact T.J. Gaudet at (504) 464-3325.
Very truly yours,
/
R.F.'Burski Manager Nuclear Safety & Regulatory Affairs RFB:TJG:ssf Attachment cc: R.D. Martin, NRC Region IV J.A. Calvo, NRC-NRR D.L. Wigginton, NRC-NRR NRC Resident Inspectors Office E.L. Blake W.M. Stevenson NS41567C s904100390 890403 2 l DR ADOCK 0500 "AN EQUAL OPPORTUNITY EMPLOYER" /
Attschment to W3P89-0070 Page 1 of 9
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ATTACEdENT 1 LP&L Responses to the Violations Identified in Appendix A of Inspection Report 89-02 VIOLATION NO. 8902-01 Failure to Adhere to Documented Drawings Criterion V of Appendix B to 10 CFR Part 50 and the licensee's approved quality assurance program description require that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings, of a type appropriate to the circumstances.
Design Drawing 1564-1539, R26 for pressurizer surge line Sample Isolation Valve 2SL-V2505 specifies that the material for Item 11 (valve gland studs) shall be ASME SA-193 Grade B6 or B7.
Contrary to the above, a valve gland stud for valve 2SL-V2505 had been incorrectly replaced with ASKE SA-193 Grade B8 material.
This is a Severity Level IV violation.
RESPONSE
(1) Reason For The Violation The root cause of this violation is personnel error. In accordar;e with UNT-5-015, " Work Authorization Preparation and Implementation,"
a work authorization (WA 01018888) was prepared to install packing gland fastener material on the pressurizer surge line sample isolation valve. The existing material was badly corroded and needed replacement. Section 5.7.5 of UNT-5-015 states that all replacement parts and materials installed in plant systems shall be "like-for-like" replacements or engineering approved equivalents. It also states that the parts shall be obtained from the warehouse and be traceable to a Requisition on Stores (ROS) number. In an attempt to comply with Section 5.7.5 of UNT-5-015 Design Drawing 1564-1539, the field control drawing for this valve, was obtained. When viewing this drawing, which was a poor quality reproduced copy made from an aperture card (micro-film), the' responsible individual misinterpreted the material designation to be SA 193 B8 as opposed to the specified q SA 193 B6. Consequently, the incorrect material (SA 193 B8 material) {
was entered on WA 01018888 and the ROS ticket as a "like-for-like" replacement. On 4/13/88, the incorrect material was then installed.
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Attechm:nt to W3P89-0070 Page 2 of 9 (2) Corrective Steps That Have Been Taken And The Results Achieved on 2/9/89, Maintenance generated a quality notice (QN QA-89-037) to formally address and resolve the concern. On 1/12/89, a non-conformance Condition Identification (CI 260888) was issued to disposition the incorrectly installed material. Calculations performed under C1 260888 and the application of the SA 193 B8 material as a gland fastener supported the operability of the pressure boundary. Accordingly, the shift supervisor accepted the use of the material.
Since Engineering has recommended that the replacement material conform to the design drawing, the material will be replaced during the next refueling cutage with the correct SA 193 B6 material under CI 260888 and the associated work authorization (WA 01033177). Note:
this action is separate from the violation response and, therefore, does not need to be completed to be in full compliance.
The individuals responsible for the violation were counselled on the importance of obtaining clear and legible drawings prior to continuing work when the field control drawing is of poor quality.
(3) Corrective Steps Which Will Be Taken To Avoid Further Violations To prevent recurrence, Maintenance Procedure HD-1-014, " Conduct of Maintenance," will be revised to address the use of unclear drawings.
(4) Date When Full Compliance Will Be Achieved Procedure MD-01-014 will be revised by June 1, 1989, at which time LP&L will be in full compliance.
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., , Attachment to W3P89-0070 Page 3 of 9 VIOLATION NO. 8902-02 Failure to Impose ~10 CFR Part 21 Section 21.31 of 10 CFR Part 21 requires the licensee to specify on each procurement document for a basic component that the provisions of 10 CFR Part 21 apply.
Contrary to the above, since 1985, the licensee has not specified on procurement documents for basic components placed with the Okonite i Company, that the provisions of 10 CFR Part 21 were applicable.
This is a Severity Level IV violation.
RESPONSE
(1) Reason For The Violation The root cause of this violation is programmatic in that the plant procedure that was used for processing procurement documents lacked adequate instructions for ensuring nuclear requirements were not invoked when 10CFR part 21 requirements were not imposed.
Plant Administrative Procedure UNT-8-001, " Processing of Procurement Documents," described the methods used by plant personnel from 1979-1987 to initiate procurement documents for plant station modifications, spare and replacement components, subcomponents, parts, material, tools and services required to support plant operations. Through the use of this procedure, plant personnel, from 1982-1987, requested purchase orders to be placed with The Okonite Company for tape and cement which were to be used as basic components at Waterford 3. (NOTE: A basic component, as defined in 10CFR21.3 means a plant structure, system, component or part thereof necessary to assure (i) the integrity of the reactor coolant pressure boundary, (ii) the capability to shut down the reactor and maintain it in a safe shutdown condition, or (iii) the capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to those referred to in 10CFR part 100). Since the procedure lacked adequate instructions for ensuring nuclear requirements were not invoked when 10CFR part 21 requirements were not imposed, six Okonite orders (Purchase Order Numbers 10450, 12403, 14107, 65603, 85303 and 97037) were placed imposing certification to Qualification Test Reports without imposing 10CFR part 21.
(2) Steps That Have Been Taken And The Results Achieved In November 1987, this procedural problem was corrected. On November 9, !
1987, UNT-8-001 was replaced with Nuclear Operations Engineering Procedure NOEP-004, "The Engineering Procurement Process". Step 5.1.3.2 !
of NOEP-004 requires the procurement engineer to draft procurement ;
documents in accordance with Nuclear Operations Engineering Instruction l N0EI-152, " Safety-Related Procurement Methods & Standard Technical &
QA Statements." N0EI-152 (Revision 1 dated 9/8/87) provides guidelines and methods for Nuclear Operations Engineering personnel to use when I I
specifying technical and quality requirements on safety-related procurement documents.
Attacharnt to W3P89-0070 Page 4 of 9 Section 5.2 of NOEI-152 describes the method used to obtain safety-related structures, systems, components, parts or services that l are subject to unique design or specification requirements or that cannot be procured to the manufacturer's catalog or industry standards i
alone. This method applies to components ordered from The Okonite Company. Step 5.2.3 specifically states that procurement specifications shall invoke 10CFR part 21 on the supplier. To date, however, The Okonite Company still refuses to accept 10CFR part 21. Consequently, when such action from a supplier occurs, the basic component (s) being purchased will be identified in the order as commercial grade in accordance with Step 5.5.11 of NOEI-152. Items ordered from the Okonite Company have been since November, 1987 and will continue to be purchased as commercial grade.
(3) Corrective Steps Which Will Be Taken To Avoid Further Violations N0EI-152, as described above, provides adequate instruction to prevent recurrence of a similar type of violation in the future.
(4) Date When Full Compliance Will Be Achieved LP&L is currently in full compliance.
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Attachment to l W3P89-0070 Page 5 of 9 VIOLATION NO. 8902-03 Failure to Follow Procedures Criterion V of Appendix B to 10 CFR Part 50 and the licensee's approved quality assurance program description require that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings, of a type appropriate to the circumstances.
Contrary to the above, the licensee failed to implement procedures as shown in the following examples:
o Contrary to Section 5.7.7 in Procedure N0EI-152, Revision 1, the licensee failed to identify shelf life requirements in Purchase Order WP016013 for Buna-N parts.
o Contrary to Section 5.4.3.2 in Procedure UNT-7-021, Revision 1, the licensee failed to update at least five vendor technical manuals to incorporate data to support replacement AGASTAT relays installed during Mod.ification SM 1701.
o Contrary to Section 5.2.1.4 in Procedure UNT-8-001, the licenset . oiled to properly dedicate commercial grade replacement electrical resistors which had been procured on Purchase Order W117408.
This is a Severity Level IV violation.
RESPONSE
(1) Reason For The Violation The root cause for examples one and three cited in the violation is personnel error. (Note: LP&L denies that example two is a violation of failing to follow procedures. A discussion of the basis for denial is provided on pages 8 and 9.)
Example 1 Nuclear Operations Engineering Instruction N0EI-152, " Safety-Related Procurement Methods & Standard Technical & QA Statements," provides guidelines and methods for specific technical and quality requirements on safety-related procurement d'cuments o and for dedicating commercial ,
grade items for safety-related use during the procurement process. Step '
5.7.7 of N0EI-152 states that "Other requirements may be noted as part of the Procurement Documents to identify the need for. . . shelf life. . ." i Using this guidance provided in N0EI-152, a procurement engineer generated a purchase order (P.O. WP016013) to order seal kits for ASCO solenoid valves on the diesel generator. The Kits contained Buna-N (Butadine/ Acrylonitrile) items which have a limited shelf life.
(Note: Limited shelf life items are those that have a shelf life of less than 40 years). Based on this information and in accordance with Step 5.7.7 of N0EI-152, shelf life data for the Buna-N items should have been but was not included on the purchase order.
. Attachm:nt to W3P89-0070 Page 6 of 9 Example 3 Plant Administrative Procedure UNT-7-021 (Revision 4), " Spare Parts Equivalency Evaluation Report (SPEER)/ Parts Quality Level Determination (PQD), " provided the methods used to process either a SPEER or a PQD. A SPEER would be used to determine whether a spare or replacement part, not of original design or having a technical difference, is acceptable for use in the original application. A PQD would be used to determine the quality requirements of a part when the quality level is unknown and to provide for the dedication of such commercial grade items in a safety-related application after the quality level has been determined. Plant Administrative Procedure UNT-8-001, " Processing of Procurement Documents," described the methods used by plant personnel-from 1979-1987 to initiate procurement documents for plant station modifications, spare and replacement components, subcomponents, parts, material, tools and services required to support plant operations.
Using the guidance p,rovided in UNT-7-021 and UNT-8-001, a purchase order (P.O. W-11794-K) was generated to order thirty replacement electrical resistors. Step 5.1.10 of UNT-7-021 stated that a PQD shall not be required for the use of like for like commodity type items for non-code application or where the code or standard does not specify code material.
Since the replacement resistors were like for like commodity type items, the parts were ordered as Commercial Grade (QC-3), and in accordance with step 5.1.10 of UNT-7-021, no PQD was performed. Although this action appeared to be appropriate, it was in direct conflict with step 5.2.1.4 of UNT-8-001 which stated:
"a SPEER/PER (project evaluation request) shall be initiated for all parts or components for use in a safety-related system determined to be ' Commercial Grade' (QC-3) except those items previously approved and included in Reference 2.16 (UNT-7-003, " Control of Expendable Material"), 2.26 (UNT-5-007, " Plant Lubrication Programs"), 2.27 (RAN 457001798, " Plant Erpendable Materials Manual") or other approved engineering design or design change documents."
Consequently, the ordered parts were designated as Commercial Grade without the proper dedication. Two of the thirty resistors (under Work Authorization 01017698 and Condition Identification 255518) were installed in a position indicator as a like for like replacement.(NOTE: Post installation tests had been performed to ensure that the indicator operated properly.) ,
(2) Corrective Steps That Have Been Taken And The Results Achieved Example 1 A Quality ' Notice (QN QA-89-009) was issued on 1/13/89 to formally 1 address and track the corrective actions for the procedural violation.
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Att:chmest to W3P89-0070 Page 7 of 9 Procurement Engineers, including the individual respnsible for the I procedural violation, were required to review the quality notice and were instructed to impose shelf life requirements on all orders for items that have a limited shelf life.
The Waterford 3 Materials Management Information System was updated to reflect a five year shelf life for the Buna-N items.
Example 3 A Quality Notice (QN QA-89-004) was issued on 1/13/89 to formally address and track the corrective actions for the procedural violation.
On November 9, 1987, UNT-8-001 was replaced with Nuclear Operations Engineering Procedure NOEP-004, "The Engineering Procurement Process."
N0EP-004 addresses commercial grade procurement in greater detail than did UNT-8-001. To ensure consistency with NOEP-004, UNT-7-021 has been revised. In particular, the exemption regarding commodity type items, Step 5.1.10 of UNT-7-021, has been deleted.
The twenty-eight resistors remaining in the warehouse were downgraded to non-safety (QC-2). This action will require that = PQD be performed before the resistors are used in a safety-related application. The two resistors that were installed in the plant were evaluated in accordance with N0EP-004, Section 4.4.3, and NOEI-152, Section 5.5 and found to be acceptable for their intended use.
(3) Corrective Steps Which Will Be Taken To Avoid Further Violations Example 1 NOEI-152 will be revised to insure that shelf life requirements are imposed on orders for items having a limited shelf life.
An overall program will be established to ensure that shelf life controls are consistently applied in the appropriate plant procedures. A review of items in stores will be done to identify and correct other shelf life data deficiencies. (This effort will be tracked under quality notice QN QA-89-071 dated 3/17/89).
Example 3 Based on the corrective actions that have been taken for this example, i further violations of this type'should be prevented. l l
(4) Date When Full Compliance Will Be Achieved I l
Example 1 Revision to Procedure N0EI-152 will be completed by July 1, 1989 The stores review is expected to be completed by December 31, 1989, at which time LP&L will be in full compliance.
Example 3 LP&L is currently in full compliance.
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. Att: chm:nt to W3P89-0070 Page 8 of 9 Basis for Denying Example Two of Violation 8902-03 LP&L denies that Section 5.4.3.2 of UNT-7-021 was violated since the applicable technical manuals were updated. Subsequent to the citing of this apparent violation during an NRC Exit Meeting, LP&L insnediately generated a quality notice (QN QA 89-005) to document the finding and address its root cause. Based on a review of Station Modification (SM) No. 1701 and its associated documentation, LP&L determined that the manuals had been adequately updated and no further action was necessary. Consequently, the QN was dispositioned as invalid. The following information substantiates this position.
Using the guidance provided in Plant Administrative Procedure UNT-7-021, Revision 1, " Spare Parts Equivalency Evaluation," Spare Parts Equivalency Evaluation Report (SPEER) No.85-231 was generated to support the replacement of Commercial Grade Agastat Relays with Class 1E Agastat Relays. Step 5.4.3.2 of UNT-7-021 (Revision 1) required that changes to documents affected by the SPEER are to be initiated in accordance with Procedure PE-2-006, " Plant Engineering Station Modification." Accordingly, SM 1701 was initir 4 to update the design documents associated with SPEER 85-231. During ne processing of SM 1701, evaluations were requested and performed to document the known differences between and applications of the Agastat 7000 Series Relays (commercial grade) and the E7000 Series Relays (IE grade). In general these evaluations (Reference Project Evaluation Requests 60312, 60536 and 70520) concluded that although the 7000 Series Relays were no different from the E7000 Series Relays, the E7000 Series should be used for future replacements of Agastat Timing Relays.
The evaluations became part of the SM 1701 package. Also included in the SM Package was LP&L's documented actions that were taken to use the E7000 Series ,
Relays to replace E7000 or 7000 Relays in safety-related applications. The !
following actions were taken: {
- 1. ME-7-005, " Time-Delay Relay Setting Check, Adjustment and Functional j Test," was revised to require that emergency diesel generator (EDG) l agastat relays in safety-related (SR) applications be replaced by SR (E Series) relays. This procedure also requires that E Series relays be replaced every 10 years from date of manufacture. The Waterford 3 Plant !
Preventive Maintenance Program was revised to include this replacement l frequency. ,
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- 2. Maintenance history was reviewed on both EDGs to verify that no i unqualified relays were installed as replacements. This review revealed j that only two agastat relays were replaced and both were replaced by j safety-related relays, i Based on the above information, the following notice (Reference LP&L Letter No. W3E86-0260 dated 11/3/86) was placed in each of the applicable manuals:
This notice serves to accommodate the recent policy of Amerace Corp. to provide Agastat relays for safety-related applications with the "E" prefix designation, l
-( . . . .
Attachm2nt to W3P89-0070 .
Page 9 of 9 Agastat 7000 series relays qualified by Amerece Corporation for Nuclear l application have model numbers with an "E" prefix.. 1 Part number design discrepancies may exist where agastat relays ate.shown in a particular design drawing that do not have the "E" prefix where in
' fact the corresponding field installed relay may nov have the "E" designation. Conversely, a field installed relay may be found to be an Agastat relay qualified by a subvendor (instead of Amerace) and found to not be from a subgrade batch of commercially produced relays, that.do not have the "E" prefix, in certain applications.
Further information may 1,e obtained from checking the responses.to PElR 70520, PEIR 60312,'and PEIR 60536.
The applicable manuals that were updated with this information were:
Technical Manuals 457000005, Volume 1 (R [ Revision) 0); 457000212-(R2);
457000225, Volume 4 (RI); 457000238 (RO); 457000281 (RS); 457000854 (RI) and-457001225, Volume 3 (R8). (Note: Technical Manual 457000106 was originally listed in SM 1701 as requiring'an update, but a revision to this manual was not actually required as indicated on an Engineering Review Comment Resolution Fo rm ..)
On January 13, 1989,-QN QA-89-005 was issued to address the apparent procedural violation of not updating the noted manuals. After a review of the information contained in SPEER 85-231, SM 1701 and the applicable Technical Manuals, the QN was dispositioned as invalid. (Note: In addition to the manuals stated above, Technical Manuals 457000291 (RO) and 4570002146 (RI) had been included in the QN as needing an update. Both manuals were determined to be not applicable to the issue.)-
Consequently, LP&L believes that the appropriate Technical Manuals were adequately updated in accordance with UNT-7-021. Therefore, in light of the information provided above, LP&L requests that this example be reevaluated.
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