ML20211M440

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/97-15 Issued on 970828

ML20211M440
Person / Time
Site:	Waterford
Issue date:	10/09/1997
From:	Harrell P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dugger C ENTERGY OPERATIONS, INC.
References
50-382-97-15, NUDOCS 9710140205
Download: ML20211M440 (5)

See also: IR 05000382/1997015

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9 997

Charles M. Dugger, Vice President

Operations Waterford 3

Entergy Operations, Inc.

P.O. Box B

Killona, Louisiana 70066

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SUBJECT:

NRC INSPECTION REPORT 50 382/9715

Dear Mr. Dugger:

.

Thank you for your letter of September 29,1997, in response to our letter and

Notice of Violation dated August 28,1997. We have reviewed your reply and, as

discussed with you during a telephone conference on October 2,1997, the information

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you provided for the corrective steps that have been taken and the results achieved for

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Violation 9715 03 did not fully address what was reque:sted, it is our understanding that

you will provide this information in a supplement to your previous response. Your

response to the concerno raised in Violation 9715-06 was adequate. We will review the

implementation of your corrective actions during a future inspection to det' ermine that full

compliance has been achieved and will be maintained.

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Sincorely,

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Pr) Ject Section D

Docket No.: 50 382

License No.: NPF 38

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Executive Vice President and

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Chief Operating Officer

Entergy Operations, Inc.

P.O. Box 31995

Jackson, Mississippi 39286-1995

9710140205 971009

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Entergy Operations, Inc.

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Vice President, Operations bupport

Entergy Operations, Inc.

P.O. Box 31995

Jackson, Mississippl 3928610^7

Wise, Carter, Child & Caraway

P.O. Box 651

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Jackson, Mississippl 39205

General Manager, Plant Operations

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Waterford 3 SES~ ~

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Entergy Operations, Inc.

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P.O. Box B

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Killona, Loulslana 70066

Manager Licensing Manager

Waterford 3 SES

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Entergy Operations, Inc,

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P.O. Box B

Killona, Loulslana 70066

Chairman

Loulslana Public Service Commission

- One American Place, Suite 1630

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Baton Rouge, Louisiana 70825 1697

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Director, Nuclear Safety &

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Regulatory Affairs

Waterford 3 SES

~ Entergy Operations, Inc.

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. P.O. Box B

Killona, Louisiana - 70066

William H. Spell, Administrator

. Loulslana Radiation Protection Division

P.O. Box 82135 -

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Baton Rouge, Loulslana 70884 2135-

._ Parish President

St. Charles Parish

P.O. Box 302:

Hahnville, Loulslana 70057

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Entergy Operations, Inc.

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Mr. Williern A. Cross

Bethesda Licensing Office

3 Metro Center

Suite 610

Bethesda, Maryland 20814

Winston & Strawn

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1400 L Streeti N.W.-

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Washington, D.C.- 20005 3502-

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DOCUMENT NAME: R:\\_WAT\\WT715AK.LAK

To receive copy of document, indicate in box: "C" = Copy without enclosures

"E" = Copy with enclosures "N" = No copy

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OFFICIAL RECORD COPY

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W3F1-97-0229

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September 29,.1997;

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.U.S. Nuclear Regulatory Commission -

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ATTN: Document Control Desk"

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Waterford 3 SES

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Docket No. 50-382 -

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License No. NPF-38'

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NRC Inspection Report 50-382/97-15-

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Reply to Notice of Violation

Gentlemen:

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. In accordance with 10CFR2.201, Entergy Operation 3, Inc. hereby submits in .

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Attachment.1 the msoonse to the violations identified in Enclosure 1 of the subject

C Inspection Report

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If you have any questions concoming thle r6sponse, please contact me at (504) 739 -

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6242 or Tim Gaudet at (504) 739-6666.

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Very truly yours,-

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E.C. Ewing

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>: Nuclear Safety & Regulatory Affairs-

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- Reply to Notice if Violation

W3F1-97-0229.

_ Page 2

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September 29,1997 <

/E W Merschoff(NRC Region IV)

cc:

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C.P. Patel (NRC-NRR) -

. J. Smith

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N.S. Reynolds

NRC Resident inspectors Office

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W3F1-97-0229

PAGE 1 OF 5

ATTACHMENT 1

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ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATIONS IDENTIFIED IN

ENCLOSURE 1 OF INSPECTION REPORT 97-15

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VIOLATION NO. 9715-03

L10 CFR 50.65(a)(1) states, in part, that each holder of an operating license shall

monitor the performance or condition of structures, systems, or components, against

licensee-established goais and such goals shall be established commensurate with

safety.

10 CFR 50.65(a)(2) states, in part, that monitoring under paragraph (a)(1) is not

required where it has been demonstrated that the performance or condition of a

structure, system, or component is being effectively controlled through the

performance of appropriate preventive maintenance such that the structure, system,

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or component remains capable of performing its intended safety function. Paragraph

(c) states, "[t]he requirements of this section shall be implemented by each licensee

no later than July 10,1996. "

- Contrary to the above, as of January 1997, for the emergency lighting system, the

licensee: (1) failed to establish goals commensurate with safety as described in 10

_ CFR 50.65(a)(1); or (2) as an alternative, failed to demonstrate that the performance

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of the above specified system was effectively controlled through the performance of -

appropriati preventive maintenance and that the system remained capable of

pcrforming its intended function in that neither the unavailability of the function

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performed by the system was monitored nor an acceptable alternative method for

compliance proposed.

This is a Severity Level IV violation (Supplement 1) (50-382/9715-03).

RESPONSE-

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(1)'

Reason for the Violation

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Entergy admits this violation and believes it to be the result of inadequate

- mansgement oversight. In September of 1996, the Maintenance Rule Expert

Panel discussed the need to scope the Emergency Lighting System (LTE) into

the Maintenance Rule. At the end of 1996, LTE was officially approved for

entry into the Maintenance Rule by the Expert Panel. Subsequent to this,

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W3F1-g7-0229

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performance criteria for LTE were prepared and presented to the Expert

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Panel. Differing interpretations of the industry's position on emorgency

lighting prevented the Expert Panel from reaching a consensus on the .

systems - performance criteria. As a result of personnel turncver and an --

extended refueling outage, no further Expert Panel meetings _were held .

Approval of LTE's Maintenance Rule function and criteria were therefore not

completed in a timely manner.-

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A review of systems scoped in the Maintenance Rule was performed to

identify any other systems whose historical review may not be complete or-

whose function and criteria were not approved, in addition to LTE, it was

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determined that the communication / paging (CMP) and communication / radio

(CMR) systems did'not yet have a Maintenance Rule function or criteria .

approved by the Expert Panel.- The maintenance history review of these

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systems is also not complete,

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'(2)

Corrective Steps That Have Been Taken and the Results Achieved

Condition Report g7-2038 was generated to place this event in the Waterford

3 corrective action program.

<(3)

LCorrective Steps Which Will Be Taken to Avoid Further Violations

in accordance with 10 CFR50.65 paragraph (a)(2), provisions will be made to

monitor the reliability performance of the emergency lighting and the

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communication systems; Reliability critoria has been established, reviewed

and approved by the Expert Panel. The maintenance history review of these

systems is in progress and once completed will be reviewed against their

respective (a)(2) reliability performance criteria. At that time, a system (a)(1)

or (a)(2) categorization will be made, if determined that (a)(1) status is

warranted, then (a)(1) goals will be. established.

.(4)

Date When Full Compliance Will Be Achieved

The above corrective actions are in progress and will be completed by

December 18, igg 7, when system categorizations will have been made. If

warranted, (a)(1) goals will then be established. Upon completion'of the

above, Waterford 3 will be in full compliance.

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W3F1-97-0229

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- ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOL.ATION IDENTIFIED IN

ENCLOSURE 1 OF INSPECTION REPORT 97-15

VIOLATION NO. 9715-06

'10 CFR Part 50, Appendix R, Section Ill(J), states that emergency lighting units with

at least an 8-hour battery power supply shall be provided in all areas needed for

operation of safe shutdown equipment and in access and egress routes thereto.

Safety Evaluation Report, Supolement 8, Section 9, and Updated Final Safety

Analysis Report, Table 9.5.1-4, both indicate that the chilled water system is required

for safe shutdown following a fire.

Contrary to the above, as of August 9,1997, emergency lighting units with at least

an 8-hour battery power supply were not provided for the reactor auxiliary building

stainuell leading to the +46-foot Chilled Water System room, an access and egress

route for an area needed for operation of safe shutdown equipment.'

This is a Severity Level IV violation (Supplement l} (50-382/9715-06).

RESPONSE

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-(1)-

Reason for the Violation

Waterford 3 admits to the violation of the Appendix R requirement to provide a

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lighted path to equipment required for safe shutdown. The violation resulted

from an apparent inadequate initial evaluation. In the case cited in the

' violation (Essential Chillers), an Appendix R path had been established to the

. equipment. However, access via the path could be blocked by smoke in the

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hallway of the Control Room envelope. - During subsequent walkdowns, it was

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determined that an Appendix R lighted path had not been established to

ACCW valves required for safe shutdown.

-(2)

Corrective Steps That Have Been Taken and the Results Achieved

- A plant walkdown was conducted in applicable areas to assess the adequacy

. of Appendix R emergency lighted pathways to equipment required for safe

shutdown. Based on results from the walkdown, a more appropriate pathway

(a stairwell leading from the +21 to the +46 elevation) was selected to

facilitate Operator access to the Essential Chillers during a Control Room fire.

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ATTACHMENT TO

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W3F1-97-0229

PAGE 4 OF 5

Also, it was determined that an Appendix R lighed path had not been

established to two ACCW valves.

(3)-

Corrective Steps Which Will Be Taken to Avold Further Violations

Based on results frorn the plant walkdown,8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Appendix R lighting units

are being installed in the following locations to establish required lighted

paths:

in the stairway from +21 to +46 to the Essential Chillers, and

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in the path to two ACCW Valves (ACC 138A&B).

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In addition to the above installations,8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Appendix R lighting units are

being installed in the following locations as enhancements to other paths:

in front of the Reactor Trip Breakers,

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near 4160 voit switchgear 3A-S, and

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near the Chilled Water isolation valves.

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While these corrective actions are being implemented, the Operators have

flash lights available for lighting their path to the applicable safe shutdown

equipment. The paths are partially illuminated via emergency diesel

generator backed lighting units. The majority of the path to the east side

ACCW valve is located outside of the building and is therefore illuminated

during daylight tours.

Operators will review this violation as pad of their required reading to increase

awareness of the potential need for use of flashlights in the identified areas

during the interim until the required lighting units are installed.

Established lighted Appendix R paths will be identified in the Operations safe

shutdown procedure.

Permanent, controlled documentation of established Appendix R emergency

lighted pathways will be prepared.

(4)

Date When Full Compliance Will Be Achieved

Installation of the Appendix R lighting in the areas listed above will be

completed by 1/30/98, with the exception of the ACCW valve path, which will

be complete by 6/30/98.

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W3F1-97-0229

PAGE 5 OF 5

- Operator required reading will be complete by 10/20/97.

Preparation of controlled documentation of established Appendix R paths will

be completed by 1/30/98.

The revision of the safe shutdown procedure (as described above) will be

completed by 3/31/98.'

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Upon completion of the above, Waterford 3 will be in full compliance.

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