ML20148F156

Requests Expeditious NRC Review & Approval of Supplemental Reg Guide 1.97 Response Submitted on 970523

ML20148F156
Person / Time
Site:	Waterford
Issue date:	05/30/1997
From:	Ewing E ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-REGGD-01.097, RTR-REGGD-1.097 W3F1-97-0139, W3F1-97-139, NUDOCS 9706040119
Download: ML20148F156 (2)

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W O Entirgy Operations,Inc.

Killona, LA 70066 Tel 504 739 6242 l

Early C. Ewing, til u afety & ReguMtory Affaas W3F1-97-0139 A4.05 PR

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May 30,1997 l

U.S. Nuclear Regulatory Commission i ATTN: Document Control Desk l Washington, D.C. 20555

Subject:

Waterford 3 SES Docket No. 50-382 License No. NPF-36 '

Mode Restraint for RG 1.97 Supplemental Response Gentlemen:

On May 23,1997, Waterford 3 submitted a supplemental response to our 1991 RG 1.97 submittal. This supplemental response added position indicators for a number /

of remotely-operated, non-automatic containment isolation valves (CIVs) to the D scope of RG 1.97 instrumentation. These indicators were not previously considered to fall under the scope of RG 1.97 as explained in the supplemental response. As described in the supplemental response, three of the CIVs (MS-116A, MS-116B, and hp1 CVC-209) do not possess RG 1.97 qualified position indication in the control room.

Waterford 3 has requested the NRC's approval for deviation from RG 1.97 based on the non-qualified indication for these valves, alternate means of indication, and compensatory measures. Waterford 3 is currently in MODE 5, starting up from Refueling Outage 8, and believes that entry into MODE 4 is contingent upon the NRC's approval of these deviations from RG 1.97. This is based on the fact that TS 3.3.3.6, " Accident Monitoring Instrumentation," requires position indication for RG 1.97 Category 1 CIVs. The addition of the position indicators listed in the supplemental response to the scope of RG 1.97 results in the requirements of TS 3.3.3.6 being applicable to these indicators. Without RG 1.97 qualified position indication for the three valves mentioned above, or NRC approval for deviation from the RG, entry into MODE 4 would result in violating TS 3.3.3.6, although there is no shutdown requirement for this TS (Action 29 provides an Allowed Outago Time of 30 days and requires a subsequent 14-day Special Report). Due to the above, Waterford 3 is requesting an expeditious NRC review and approval of the nannnn i p 000 M PDR ,

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' Mode Restraint for RG 1.97 Supplemental Response ,

W3F1-97-0139 l Page 2 l May 30,1997 supplemental RG 1.97 response submitted on May 23,1997. The current projected date for MODE 4 entry is June 7,1997.

Should you have any questions concerning the above please contact me at (504) 739-6242.

Very truly yours, j 1,'

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/ E.C. Nwing Director Nuclear Safety & Regulatory Affairs ECE/DFL/ssf cc: E.W. Merschoff, NRC Region IV C.P. Patel, NRC-NRR J. Smith N.S. Reynolds NRC Resident inspectors Office