ML12310A497
| ML12310A497 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/05/2012 |
| From: | Ray Kellar Division of Reactor Safety IV |
| To: | Jacobs D Entergy Operations |
| References | |
| EA-12-198 IR-12-008 | |
| Download: ML12310A497 (50) | |
See also: IR 05000382/2012008
Text
November 5, 2012
Donna Jacobs, Site Vice President, Operations
Entergy Operations, Inc.
Waterford Steam Electric Station, Unit 3
17265 River Road
Killona, LA 70057-0751
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 -
NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION
REPORT 05000382/2012008 AND NOTICE OF VIOLATION
Dear Ms. Jacobs:
On August 2, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem
Identification and Resolution biennial inspection at your Waterford Steam Electric Station,
Unit 3. The enclosed inspection report documents the inspection results that were discussed on
August 2, 2012, with Keith Nichols, Director of Engineering, and other members of your staff.
After additional in-office inspection, a final telephonic exit meeting was conducted on September
24, 2012 with Keith Nichols, Director of Engineering, and other members of your staff.
This inspection was an examination of activities conducted under your license as they relate to
problem identification and resolution and compliance with the Commissions rules and
regulations and the conditions of your license. Within these areas, the inspection involved
examination of selected procedures and representative records, observations of activities, and
interviews with personnel.
Based on the inspection sample, the inspection team concluded that the implementation of the
corrective action program and overall performance related to identifying, evaluating, and
resolving problems at Waterford Steam Electric Station, Unit 3, were adequate. Licensee
identified problems were entered into the corrective action program at a low threshold.
Problems were generally prioritized and evaluated commensurate with the safety significance of
the problems. Corrective actions were generally implemented in a timely manner
commensurate with their importance to safety and addressed the identified causes of problems.
Lessons learned from industry operating experience were generally reviewed and applied when
appropriate. Audits and self-assessments were effectively used to identify problems and
appropriate actions. Finally, the team determined that the station maintains a safety-conscious
work environment where employees feel free to raise nuclear safety concerns without fear of
retaliation.
Five NRC identified findings of very low safety significance (Green) were identified during this
inspection and are documented in the enclosed report. All five of these findings were
determined to involve a violation of NRC requirements. The NRC is treating four of the five
UNITED STATES
NUCLEAR REGULATORY COMMISSION
RE GION I V
1600 EAST LAMAR BLVD
ARLINGTON, TEXAS 76011-4511
D. Jacobs
- 2 -
violations as non-cited violations (NCVs), consistent with Section 2.3.2 of the Enforcement
Policy. Additionally, a licensee-identified violation, which was determined to be of very low
safety significance, is listed in this report.
One of the findings that the NRC evaluated under the risk significance determination process as
having very low safety significance (Green) did not meet the criteria to be treated as a non-cited
violation. The violation associated with this issue was evaluated in accordance with the NRC
Enforcement Policy. The current version of this Policy is available on the NRC website at
(http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html). This violation is cited in
the enclosed Notice of Violation (Notice), and the circumstances surrounding it are described in
detail in the subject inspection report. The violation is being cited in the Notice in accordance
with Section 2.3.2 of the Enforcement Policy because you failed to restore compliance in a
reasonable period of time after the violation was previously identified as a non-cited violation.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. This reply should be clearly marked as a
"Reply to a Notice of Violation; EA-12-198" and should specifically include a firm commitment as
to when you will establish a design basis to determine the river level at which flood control
measures were to be initiated for closing the water tight doors as required in
Procedure OP-901-521, Severe Weather and Flooding. If you have additional information that
you believe the NRC should consider, you may provide it in your response to the Notice. The
NRC review of your response to the Notice will also determine whether further enforcement
action is necessary to ensure compliance with regulatory requirements.
If you contest these non-cited violations, you should provide a response within 30 days of the
date of this inspection report, with the basis for your denial, to the Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to:
(1) the Regional Administrator, Region IV; (2) the Director, Office of Enforcement, United States
Nuclear Regulatory Commission, Washington, DC 20555-0001; and (3) NRC Resident
Inspector Office at Waterford Steam Electric Station, Unit 3.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a
response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the Regional Administrator, Region IV; and the NRC Resident Inspector at
Waterford Steam Electric Station, Unit 3.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response will be available electronically for public inspection in the NRC
Public Document Room or from the Publicly Available Records (PARS) component of NRC's
Agency wide Document Access and Management System (ADAMS). ADAMS is accessible
from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic
Reading Room).
Sincerely,
/RA/
Ray Kellar, P.E., Chief
Technical Support Branch
Division of Reactor Safety
D. Jacobs
- 3 -
Docket No.: 50-382
License No: NPF-38
Enclosures:
1. Notice of Violation EA-12-198
2. Inspection Report 05000382/2012008
w/Attachments:
1. Supplemental Information
2. Information Request
cc w/enclosures: Electronic Distribution for Waterford 3
SUNSI Rev Compl.
Yes No
Yes No
Reviewer Initials
RLS
Publicly Avail.
Yes No
Sensitive
Yes No
Sens. Type Initials
TL/SRI:DRP/C RI:DRP/E
PE:DRP/C
RI:DRS/EB1
ACES
BC:DRP/E
RSmith
DOverland
RKumana
MYoung
HGepford
DAllen
-e-
-e-
/RA/
/RA/
/RA/
/RA/
10/23/2012
10/23/2012
10/13/2012
10/23/2012
10/26/2012
10/30/12
BC:DRS/TSB
RKellar
/RA/
11/5/2012
- 1 -
Enclosure 1
Entergy Operations, Inc.
Docket No. 50-382
Waterford Steam Electric Station, Unit 2
License No. NPF-38
During an NRC inspection conducted on July 16 through September 24, 2012, a violation of
NRC requirements was identified. In accordance with the NRC Enforcement Policy, the
violation is listed below:
Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion III, Design
Control, states, in part, that measures shall be established to assure that applicable
regulatory requirements and the design basis, as defined in 10 CFR 50.2, are correctly
translated into specifications, procedures, and instructions.
Contrary to the above, from March 10, 2011, to August 2, 2012, the licensee failed to
establish measures to assure that applicable regulatory requirements and the design
basis, as defined in 10 CFR 50.2, were correctly translated into specifications,
procedures and instructions. Specifically, the licensee had not established a design
basis to determine the river level at which flood control measures were to be initiated for
closing the water tight doors as required in Procedure OP-901-521, Severe Weather
and Flooding.
This violation is associated with a Green Significance Determination Process finding.
Pursuant to the provisions of 10 CFR 2.201, Entergy Operations is hereby required to submit a
written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document
Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator,
Region IV, and a copy to the NRC Resident Inspector at the facility that is the subject of this
Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This
reply should be clearly marked as a "Reply to a Notice of Violation; EA-12-198" and should
include for each violation: (1) the reason for the violation or, if contested, the basis for disputing
the violation or severity level, (2) the corrective steps that have been taken and the results
achieved, (3) the corrective steps that will be taken, and (4) the date when full compliance will
be achieved. Your response may reference or include previous docketed correspondence if the
correspondence adequately addresses the required response. If an adequate reply is not
received within the time specified in this Notice, an Order or a Demand for Information may be
issued as to why the license should not be modified, suspended, or revoked, or why such other
action as may be proper should not be taken. Where good cause is shown, consideration will
be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001.
- 2 -
Enclosure 1
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the NRCs document system (ADAMS), accessible from the
NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not
include any personal privacy, proprietary, or safeguards information so that it can be made
available to the public without redaction. If personal privacy or proprietary information is
necessary to provide an acceptable response, then please provide a bracketed copy of your
response that identifies the information that should be protected and a redacted copy of your
response that deletes such information. If you request withholding of such material, you must
specifically identify the portions of your response that you seek to have withheld and provide in
detail the bases for your claim of withholding (e.g., explain why the disclosure of information will
create an unwarranted invasion of personal privacy or provide the information required by
10 CFR 2.390(b) to support a request for withholding confidential commercial or financial
information). If safeguards information is necessary to provide an acceptable response, please
provide the level of protection described in 10 CFR 73.21.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working
days of receipt.
Dated this 5th day of November, 2012
- 1 -
Enclosure 2
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket:
50-382
License:
Report:
Licensee:
Entergy Operations, Inc.
Facility:
Waterford Steam Electric Station, Unit 3
Location:
17265 River Road
Killona, LA 70057-0751
Dates:
July 16 through September 24, 2012
Team Leader:
R. Smith, Senior Resident Inspector, Grand Gulf
Inspectors:
D. Overland, Resident Inspector, Waterford 3
R. Kumana, Project Engineer
M. Young, Reactor Inspector
Approved By:
Ray Kellar, P.E., Chief
Technical Support Branch
Division of Reactor Safety
- 2 -
Enclosure 2
SUMMARY OF FINDINGS
IR 05000382/2012008; July 16, 2012 -September 24, 2012; Waterford 3 "Biennial Baseline
Inspection of the Identification and Resolution of Problems."
The team inspection was performed by one senior resident inspector, one resident inspector,
one reactor inspector, and one project engineer. One cited violation and four non-cited
violations of very low safety significance (Green) were identified during this inspection. The
significance of most findings is indicated by their color (Green, White, Yellow, Red) using
Inspection Manual Chapter 0609, "Significance Determination Process". Findings for which the
significance determination process does not apply may be Green or be assigned a severity level
after NRC management review. The NRC's program for overseeing the safe operation of
commercial nuclear power reactors is described in NUREG 1649, "Reactor Oversight Process,"
Revision 4, dated December 2006.
Identification and Resolution of Problems
The team reviewed approximately 350 condition reports, work orders, engineering evaluations,
root and apparent cause evaluations, and other supporting documentation to determine if
problems were being properly identified, characterized, and entered into the corrective action
program for evaluation and resolution. The team reviewed a sample of system health reports,
self-assessments, audits, trending reports and metrics, and various other documents related to
the corrective action program.
Based on these reviews, the team concluded that the licensees corrective action program and
its other processes to identify and correct nuclear safety problems were adequate to support
nuclear safety. However, the team noted at times the licensee staff did not always use the
corrective action program for problems that were perceived as minor. The team also noted
several challenges in correcting adverse conditions in a timely manner. Further, the licensee
had several long-standing issues, which had been in the corrective action process for over a
year without resolution.
The licensee appropriately evaluated industry operating experience for relevance to the facility
and entered applicable items in the corrective action program. However, there was one
example where the licensee failed to enter an information notice into their corrective action
program for evaluation of a condition adverse to quality. The licensee used industry operating
experience when performing root cause and apparent cause evaluations. The licensee
performed effective quality assurance audits and self-assessments, as demonstrated by self-
identification of poor corrective action program performance and identification of ineffective
corrective actions.
Finally, the team determined that the station continued to maintain a safety-conscious work
environment. Employees felt free to raise nuclear safety concerns to the attention of
management without fear of retaliation.
- 3 -
Enclosure 2
A.
NRC-Identified and Self-Revealing Findings
Cornerstone: Initiating Events
Green. The team identified a non-cited violation of 10 CFR Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings, for a failure to follow
Procedure EN-OP-115, Conduct of Operations. Specifically, the licensee failed
to ensure that control room operators knew the status of equipment at all times.
While interviewing the person responsible for tracking plant deficiencies, the
inspectors discovered that the licensee had two separate governing procedures.
These two instructions had different definitions for categories of plant deficiencies
and different databases for tracking them. The inspectors then interviewed the
on-shift operators in the control room and reviewed both databases. The
inspectors identified several issues, including lack of knowledge by the control
room operators about which procedure to use, failure to track deficiencies in both
databases, and inadequate classification of deficiencies. The inspectors
determined that in March 2010, the licensee changed their process for tracking
deficiencies to be consistent with their fleet reporting process. However, the
licensee did not revise the procedure and did not train all affected personnel on
the new process. As a result, control room operators did not have a complete
and accurate knowledge of all plant deficiencies. This finding was entered into
the licensees corrective action program as Condition Report CR-WF3-2012-
03732.
The failure to ensure that operators were aware of the status of all plant
equipment was a performance deficiency. The performance deficiency was more
than minor because it was associated with the procedure quality attribute of the
Initiating Events Cornerstone and affected the cornerstone objective to limit the
likelihood of those events that upset plant stability and challenge critical safety
functions during shutdown as well as power operations. Specifically, the licensee
failed to implement a procedure designed to ensure operators were aware of
deficiencies in the instrumentation, controls, and operation of nuclear plant
systems. In accordance with NRC Inspection Manual Chapter 0609,
Attachment 4, "Initial Characterization of Findings," the issue was determined to
affect the Initiating Events Cornerstone. In accordance with NRC Inspection
Manual Chapter 0609, Appendix A, The Significance Determination Process
(SDP) for Findings at Power, the issue was determined to have very low safety
significance (Green) because it did not cause a reactor trip and did not cause the
loss of mitigation equipment relied upon to transition the plant from the onset of
the trip to a stable shutdown condition. This finding had a cross-cutting aspect in
the human performance area, work practices component, in that the licensee
failed to define and effectively communicate expectations regarding procedural
compliance, and personnel did not follow procedures H.4.b] (Section 4OA2.5.d).
Green. The inspectors identified a non-cited violation of 10 CFR Part 50,
Appendix B, Criterion XVI, Corrective Actions, because the licensee failed to
determine the cause of a significant condition adverse to quality and take
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Enclosure 2
corrective actions to preclude repetition. Specifically, the licensee failed to
assure that the cause of the condition was determined and corrective action
taken to preclude repetition related to a contractors non-compliance with site
procedural requirements. The corrective actions include developing additional
training and provisions to provide additional contractor oversight. This finding
was entered into the licensees corrective action program as Condition Reports
CR-WF3-2012-03769 and CR-WF3-2012-03772.
The failure to determine the cause of a significant condition adverse to quality
and take corrective action to preclude repetition was a performance deficiency.
The performance deficiency was more than minor because if left uncorrected, it
could lead to more significant consequences; therefore, it is a finding.
Specifically, failure to determine the cause of a significant condition adverse to
quality and take corrective action to prevent recurrence can result in recurrence
of the condition. In accordance with NRC Inspection Manual Chapter 0609,
Attachment 4, "Initial Characterization of Findings," the issue was determined to
affect the Initiating Events Cornerstone. In accordance with NRC Inspection
Manual Chapter 0609, Appendix A, The Significance Determination Process
(SDP) for Findings at Power, the issue was determined to have very low safety
significance (Green) because the finding did not cause a reactor trip and the loss
of mitigation equipment relied upon to transition the plant from the onset of the
trip to a stable shutdown condition. This finding had a cross-cutting aspect in the
human performance, work practice component, in that the licensee failed to
follow guidance in the root cause evaluation procedure when developing
appropriate corrective actions to prevent repetition H.4(b) (Section 4OA2.5.e).
Cornerstone: Mitigating Systems
Green. The team identified a Green non-cited violation of 10 CFR Part 50,
Appendix B, Criterion V, Instructions, Procedures, and Drawings, for a failure to
follow the Operability Determination Process. Specifically, the licensee failed to
determine the operability of the emergency diesel generators immediately upon
discovery without delay and in a controlled manner using the best information
available in response to NRC Information Notice 2010-04. The licensee
completed an evaluation of the information notice that indicated that Waterford 3
was vulnerable and susceptible to the issue, but the licensee failed to issue a
condition report as required by their procedure. The failure to initiate a condition
report resulted in the licensees failure to perform an operability determination of
the emergency diesel generators as required by, EN-OP-104, Operability
Determination Process, Revision 6. In the evaluation, the licensee considered
the fact that they had an Action Request in their system to add routine
thermography inspections within the voltage regulator cabinets to their
preventative maintenance program as being adequate. The action request was
not completed when the inspection team reviewed the issue. The inspectors
questioned whether there was an operability concern for the emergency diesel
generators. The licensee recognized their failure to perform an operability
determination. They performed a prompt operability determination based on no
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Enclosure 2
observed degradation in performance and declared the emergency diesel
generators operable. In addition, they plan to conduct the thermography
inspections during the next scheduled emergency diesel generator surveillance.
This finding was entered into the licensees corrective action program as
Condition Report CR-WF3-2012-03761.
The failure to promptly perform an operability determination of the emergency
diesel generators in response to NRC Information Notice 2010-04 was a
performance deficiency. The performance deficiency was more than minor
because it was associated with the equipment performance attribute of the
Mitigating Systems Cornerstone and affected the cornerstone objective to ensure
the availability, reliability, and capability of systems that respond to initiating
events to prevent undesirable consequences. Specifically, the licensee failed to
promptly determine the operability of the diesel generators after obtaining
information of a potential condition adverse to quality. In accordance with NRC
Inspection Manual Chapter 0609, Attachment 4, "Initial Characterization of
Findings," the issue was determined to affect the Mitigating Systems
Cornerstone. In accordance with NRC Inspection Manual Chapter 0609,
Appendix A, The Significance Determination Process (SDP) for Findings at
Power, the issue was determined to have very low safety significance (Green)
because it was not a deficiency affecting the design or qualification of the
system, it did not represent a loss of system or function, and it was a Technical
Specification system, but did not represent an actual loss of function of a single
train for greater than it allowed outage time. Specifically, the licensee performed
an operability determination in response to the inspectors questions and
determined the emergency diesel generators were operable based on a review of
surveillance data and maintenance records. This finding had a cross-cutting
aspect in the problem identification and resolution area, operating experience
component, in that the licensee failed to systematically collect, evaluate, and
communicate to affected internal stakeholders in a timely manner relevant
internal and external operating experience P.2.a] (Section 4OA2.5.a).
Green. The team identified a non-cited violation of 10 CFR Part 50, Appendix B,
Criterion XVI, Corrective Action, for the failure to take timely corrective action
for a condition adverse to quality. Specifically, from May 2011, through
August 2012, the licensee failed to restore a degraded condition, which included
a corrective action to perform a new design analysis for the emergency
feedwater pump AB after the removal of heat trace circuit 1-8C, despite having a
reasonable amount of time to complete it. Currently, plant operators are required
once per shift to perform temperature verifications of the heat trace to ensure
condensation does not form in the steam supply pipe to the turbine driven pump
and to maintain emergency feedwater pump AB in an operable but degraded
status until the design analysis is complete. This finding was entered into the
licensees corrective action program as Condition Report CR-WF3-2012-03754.
The team determined that the failure to complete the corrective action of
performing a new design analysis to determine if emergency feedwater pump AB
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Enclosure 2
required a design modification based on the analysis in a timely manner was a
performance deficiency. The performance deficiency was more than minor
because it affected the equipment performance attribute of the Mitigating
Systems Cornerstone objective to ensure the availability, reliability, and capability
of systems that respond to initiating events to prevent undesirable
consequences. Specifically, failure to implement this corrective action could
result in reduced reliability of the emergency feedwater pump AB. In accordance
with NRC Inspection Manual Chapter 0609, Attachment 4, "Initial
Characterization of Findings," the issue was determined to affect the Mitigating
Systems Cornerstone. In accordance with NRC Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings
at Power, the issue was determined to have very low safety significance (Green)
because it affected the design or qualification of mitigating systems, structures,
and components; however, the systems, structures, and components maintained
operability. This finding had a cross-cutting aspect in the human performance
area, resources component, in that the licensee failed to minimize a long-
standing equipment issue adequately to assure nuclear safety H.2(a) (Section
4OA2.5.b).
Green. The team identified a cited violation of 10 CFR Part 50, Appendix B,
Criterion III, Design Control, for the failure to establish measures to assure that
applicable regulatory requirements and the design basis as defined in
10 CFR 50.2 are correctly translated into procedures. Specifically, the licensee
has not determined a basis for the level at which flood control measures are
initiated, two years after receiving a non-cited violation for the same deficiency.
As an interim compensatory measure for a previous violation of inadequate
technical specifications, the licensee modified their flooding procedure to include
an action to start shutting flood control doors at a river level of 24 feet instead of
27 feet. The licensee recognized the need to establish a basis for initiating these
actions at 24 feet, and issued a corrective action to track completion. The
licensee extended the due date several times and had not completed it by the
arrival of the inspection team. The inspection team questioned why the licensee
had not completed the calculation to justify their basis for their compensatory
measures, noting that it had been over two years since the original violation was
identified. The inspectors verified through walk-downs, procedure reviews, and
historical data that the licensees use of 24 feet did not represent an immediate
operability concern, and that the current river level was sufficiently low to allow
time for the licensee to correct the deficiency. This finding was entered into the
licensees corrective action program as condition report CR-WF3-2012-03752.
The failure to complete the corrective action to establish a basis for flood control
measures in a timely manner was a performance deficiency. The performance
deficiency was more than minor because it was associated with the protection
from external events attribute of the Mitigating Systems Cornerstone and affected
the cornerstone objective to ensure the availability, reliability, and capability of
systems that respond to initiating events to prevent undesirable consequences.
Specifically, the licensee failed to verify through calculations or analysis that the
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Enclosure 2
actions taken to secure flood doors could be completed in time to protect safety-
related equipment from flooding due to a levee failure. In accordance with
NRC Inspection Manual Chapter 0609, Attachment 4, "Initial Characterization
of Findings," the issue was determined to affect the Mitigating Systems
Cornerstone. In accordance with NRC Inspection Manual Chapter 0609,
Appendix A, The Significance Determination Process (SDP) for Findings at
Power, the issue was determined to have very low safety significance (Green)
because it did not involve the loss or degradation of equipment or function
specifically designed to mitigate a seismic, flooding, or severe weather initiating
event. Specifically, the inspectors confirmed that the licensee could reasonably
ensure the flood control doors could perform their safety function. This finding
had a cross-cutting aspect in the human performance area, resources
component in that the licensee failed to maintain long term plant safety by
maintenance of design margins and ensuring engineering backlogs low enough
to support safety. H.2.a] (Section 4OA2.5.c).
B.
Licensee-Identified Violations
A violation of very low safety significance, which was identified by the licensee, has been
reviewed by the inspectors. Corrective actions taken by the licensee have been entered
into the licensees corrective action program. This violation and associated corrective
action tracking numbers are listed in Section 4OA7 of this report.
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Enclosure 2
REPORT DETAILS
4.
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution (71152)
The team based the following conclusions on the sample of corrective action documents
that were initiated in the assessment period, which ranged from May 1, 2010, to the end
of the on-site portion of this inspection on August 2, 2012.
.1
Assessment of the Corrective Action Program Effectiveness
a.
Inspection Scope
The team reviewed approximately 350 corrective action documents, including
associated root cause, apparent cause, and direct cause evaluations, out of
approximately 17,000 corrective action documents that were issued between
May 1, 2010, and August 2, 2012, to determine if problems were being properly
identified, characterized, and entered into the corrective action program for
evaluation and resolution. The team reviewed a sample of system health
reports, operability determinations, self-assessments, trending reports and
metrics, and various other documents related to the corrective action program.
The team evaluated the licensees efforts in establishing the scope of problems
by reviewing selected logs, work requests, self-assessments results, audits,
system health reports, action plans, and results from surveillance tests and
preventive maintenance tasks. The team reviewed work requests and attended
the licensees daily Condition Review Group, (which is the management review
committee meeting to assess the reporting threshold, prioritization efforts, and
significance determination process), as well as observing the interfaces with the
operability assessment and work control processes when applicable. The teams
review included verifying the licensee considered the full extent of cause and
extent of condition for problems, as well as how the licensee assessed generic
implications and previous occurrences. The team assessed the timeliness and
effectiveness of corrective actions, completed or planned, and looked for
additional examples of similar problems. The team conducted interviews with
plant personnel to identify other processes that may exist where problems may
be identified and addressed outside the corrective action program.
The team also reviewed corrective action documents that addressed past
NRC-identified violations to ensure that the corrective action addressed the
issues as described in the inspection reports. The inspectors reviewed a sample
of corrective actions closed to other corrective action documents to ensure that
corrective actions were still appropriate and timely.
The team considered risk insights from both the NRCs and Waterford Steam
Electric Station, Unit 3s risk assessments to focus the sample selection and
plant tours on risk significant systems and components. The team selected the
- 9 -
Enclosure 2
component cooling water and auxiliary component cooling water systems as risk
significant systems to review. The samples reviewed by the team focused on,
but were not limited to, these systems. The team also expanded their review to
include five years of evaluations involving the emergency feedwater system to
determine whether problems were being effectively addressed. The team
conducted a walk-down of these systems to assess whether problems were
identified and entered into the corrective action program.
b. Assessments
1. Assessment - Effectiveness of Problem Identification
The team concluded in most cases that the licensee identified issues and
adverse conditions and entered them into the corrective action program in
accordance with the licensees corrective action program guidance and NRC
requirements. The team determined that the licensee generally was identifying
problems at a low threshold and entering them into the corrective action program.
The team identified one condition adverse to quality that was not placed in the
corrective action program. The licensee wrote approximately 17,000 condition
reports during the two-year period of review. The team noted that this high rate
of condition report generation is generally a sign of a healthy corrective action
program. The following issues were noted by the team:
Through the review of NRC information notices over the assessment
period, the team identified that the licensee failed to enter one information
notice applicable to Waterford Steam Electric Station, Unit 3s emergency
diesel generator voltage regulators into their corrective action program.
The team documented this as a Green non-cited violation in
Section 4OA2.5.a of this report.
The team identified that some main control room deficiencies, although
identified by white identification tags, had not been entered into the
licensees corrective action program. The team documented this as a
Green non-cited violation in Section 4OA2.5.d of this report.
The licensee self-identified a failure to initiate condition reports that
resulted in missed operability assessments on two occasions when the
emergency feedwater pump AB heat trace fell below the required
temperature per the operating instruction. The team documented this as
a licensee identified violation in Section 4OA7 of this report.
2. Assessment - Effectiveness of Prioritization and Evaluation of Issues
The team concluded that generally the licensee effectively prioritized and
evaluated conditions adverse to quality. The team found that even with the high
number of condition reports initiated on a daily basis, the licensees daily action
review committee pre-screening and the management review committees
- 10 -
Enclosure 2
effectively assessed each condition adverse to quality. The following are issues
the team identified or reviewed during the inspection:
The licensees extent of condition review for an incorrect preventive
maintenance classification of a limit switch identified additional incorrect
classifications. However, the team identified that the licensee failed to
initiate a separate condition report to document these additional errors
and, therefore, failed to ensure the testing requirements for each of the
newly identified components were met until challenged by the team. This
was documented in Condition Report CR-WF3-2012-03557.
The team identified that the licensee performed an inadequate apparent
cause evaluation of a failure of the security diesel generator. The
evaluation identified one cause as being an incorrect maintenance
classification. When the licensee found the component was properly
classified in its preventative maintenance optimization program, the
licensee did not revise their apparent cause. Instead, they determined
other corrective actions to address security equipment issues.
The team identified that the apparent cause evaluation for inservice
testing failures of the main feed isolation valves was determined to be
incorrect. The licensee first determined that the failure was the result of
moisture intrusion in the hydraulic fluid. However, additional failures and
a subsequent root cause analysis showed that the failure mechanism
was actually interior varnishing. This was identified by review of external
operating experience that was available, but missed during the initial
apparent cause evaluation.
The team identified a minor violation of 10 CFR Part 50, Appendix B,
Criterion V, that is not subject to enforcement action in accordance with
the NRCs Enforcement Policy. The licensee downgraded a Category A
condition report to Category B without obtaining approval of the condition
review group as required by Procedure EN-L1-102, Corrective Action
Program. This was documented in Condition Report CR-WF3-2012-
03325.
The team reviewed roll up Condition Report CR-WF3-2011-07610, which
identified that the quality of six previous causal analyses was inadequate.
The team identified that the licensee categorized many conditions
adverse to quality on the diesel fire pump as Category D. Although their
process allowed this, they could have identified and corrected non-
conforming trends in the diesel fire pumps more effectively with a higher
prioritization. This was documented in Condition Report CR-WF3-2012-
03747.
- 11 -
Enclosure 2
The team determined that the licensee categorized a problem with the
steam generator feedwater pump B requiring manual operation as an
Operator Burden when it could have met the definition of an Operator
Workaround, which carried a higher level of prioritization in the licensee
work planning process.
The team reviewed a licensee failure to frequently and regularly review a
degraded and nonconforming condition associated with the reactor
coolant pump N-9000 stage seals as required by Procedure EN-OP-104,
Operability Determination Process. This is an example of the licensee
not thoroughly evaluating problems, such that the resolutions address
causes and extent of conditions, as necessary. This was documented in
NRC Inspection Report 05000382/2011002 as a Green non-cited
violation.
The team reviewed a number of condition reports that involved operability
reviews to assess the quality, timeliness, and prioritization of operability
assessments. In general, both immediate and prompt operability assessments
reviewed were adequately completed in a timely manner.
3. Assessment - Effectiveness of Corrective Actions
Overall, the team concluded that the licensee generally developed appropriate
corrective actions to address problems. However, the team identified a number
of corrective actions associated with conditions adverse to quality that were not
completed in a timely manner:
The team identified that the licensee failed to take timely corrective
actions to correct a design basis analysis for the emergency feedwater
pump AB after the removal of required heat trace on the steam supply
piping. The team documented this as a Green non-cited violation in
Section 4OA2.5.b of this report.
The team identified that the licensee failed to take timely corrective
actions to establish a basis through analysis for the initiation of flood
control measures at a river level of 24 feet. The team documented this as
a Green cited violation in Section 4OA2.5.c of this report.
The team identified that the licensee failed to have a GMPO/Director
approve a due date extension on a long-term corrective action from
CR-WF3-2011-00887 (Corrective Action 13), which is not permitted by
Procedure EN-LI-102, Corrective Action Program. This resulted in a
minor violation of 10 CFR Part 50, Appendix B, Criterion V, that is not
subject to enforcement action in accordance with NRCs Enforcement
Policy. The corrective action was to complete an engineering analysis to
determine the scope of modifications needed for the steam driven
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Enclosure 2
emergency feedwater turbine steam supply piping. This was documented
in Condition Report CR-WF3-2012-03461.
The team identified a failure to complete a corrective action to validate
data for work hours for security personnel. This resulted in a minor
violation of 10 CFR 26.205.e that is not subject to enforcement action in
accordance with the NRCs Enforcement Policy. This was documented in
Condition Report CR-WF3-2012-03729.
The team reviewed a licensee failure to take or perform effective
corrective actions for boric acid leaks for the past seven years. This is an
example of the licensees failure to effectively correct identified boric acid
leaks in a timely manner. This was documented in NRC Inspection
Report 05000382/2010006 as a Green non-cited violation.
.2
Assessment of the Use of Operating Experience
a.
Inspection Scope
The team examined the licensee's program for reviewing industry operating
experience, including reviewing the governing procedure and self-assessments.
The team reviewed a sample of 10 condition reports examining operating
experience documents that had been issued during the assessment period to
determine whether the licensee had appropriately evaluated the notification for
relevance to the facility. The team then examined whether the licensee had
entered those items into their corrective action program and assigned actions to
address the issues. The team reviewed a sample of root cause evaluations and
corrective action documents to verify whether the licensee had appropriately
included industry-operating experience.
b.
Assessment
Overall, the team determined that the licensee was adequately evaluating
industry operating experience for relevance to the facility, based on reviewing a
sample of 10 condition reports examining industry operating experience. The
licensee entered all but one applicable item in the corrective action program in
accordance with station procedures. The team concluded that the licensee was
evaluating industry operating experience when performing root cause and
apparent cause evaluations. Both internal and external operating experiences
were being incorporated into lessons learned for training and pre-job briefs. The
following are issues the team identified or reviewed during the inspection:
The team identified through the review of NRC information notices over
the assessment period that the licensee had failed to enter one
information notice applicable to Waterford 3 emergency diesel generator
voltage regulators into their corrective action program. In response, the
licensee did a complete audit of all NRC information notices issued during
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Enclosure 2
the assessment period and found no other discrepancies. The team
documented this as a Green non-cited violation in Section 4OA2.5.a
of this report.
The team reviewed three examples from this assessment period of the
licensees failure in the use of operating experience, resulting in the
licensee not implementing and institutionalizing operating experience
through changes to station processes, procedures, equipment, and
training programs.
o The team reviewed a licensee failure to implement a preventative
maintenance activity to replace dry cooling tower process analog
control cards based on internal and industry-wide operating
experience that documented previous failures of process analog
control cards due to age-related degradation after 15 years. This
was documented in NRC Inspection Report 05000382/2011004 as
a Green non-cited violation.
o The team reviewed a licensee failure to identify that varnish
deposits were causing the main feedwater isolation valve to fail its
inservice testing. This resulted from the licensees failure to use
relevant external operating experience to identify that other sites
experienced similar failures of feedwater isolation valves due to
varnish deposits on the interior surfaces. This was documented in
NRC Inspection Report 05000382/2011005 as a Green non-cited
violation.
o The team reviewed a licensee failure to evaluate the internal
condition of the condensate and refueling water storage pool
structures through performance of appropriate preventative
maintenance after previous documented industry-wide operating
experience of concrete degradation due to boric acid. This was
documented in Inspection Report 05000382/2011003 as a Green
non-cited violation.
.3
Assessment of Self-Assessments and Audits
a.
Inspection Scope
The team reviewed a sample size of 22 licensee self-assessments, surveillances,
and audits to assess whether the licensee was regularly identifying performance
trends and effectively addressing them. The team reviewed audit reports to
assess the effectiveness of assessments in specific areas. The team evaluated
the use of self- and third party assessments, the role of the quality assurance
department, and the role of the performance improvement group related to
licensee performance. The specific self-assessment documents reviewed are
listed in the Attachment.
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Enclosure 2
b.
Assessment
The team concluded that the licensee had an effective self-assessment process.
Licensee management was involved with developing tactical self-assessments.
The team determined that self-assessments were self-critical and thorough
enough to identify deficiencies. The following are issues the team reviewed
during the inspection:
The team reviewed a licensee self-assessment of plant status and
configuration control performed in March 2012. This self-assessment
was an opportunity for the site to identify and address the issues
associated with control room deficiencies documented in
Section 4OA2.5.d of this report, but the assessment did not discuss them.
The team reviewed the licensees failure to perform an adequate risk
assessment associated with the maintenance window for the turbine
driven emergency feedwater pump. This is an example of the licensees
failure to use independent and self-assessments because the licensee
performed a probabilistic risk assessment model update in April 2009, but
failed to identify an assumption crediting operator actions that were not in
procedures. This was documented in NRC Inspection
Report 05000382/2011007 as a Green non-cited violation.
.4
Assessment of Safety-Conscious Work Environment
a.
Inspection Scope
The inspection team conducted individual interviews with over 30 individuals from
a cross-section of functional organizations: engineering, operations,
maintenance, quality assurance, radiation protection, chemistry, security officers,
and contract personnel. Both supervisory and non-supervisory personnel were
included in these interviews. The team conducted these interviews to assess
whether conditions existed that would challenge the establishment of a safety-
conscious work environment (SCWE) at Waterford 3. The team also interviewed
the Waterford 3 employee concerns program manager and reviewed the last two
safety culture self-assessment documents.
b.
Assessment
Overall, the team concluded that a safety-conscious work environment exists at
Waterford Steam Electric Station, Unit 3. Employees demonstrated familiarity
with the various avenues available to raise safety concerns. They appeared
comfortable with submitting all nuclear safety issues.
The team noted a potential vulnerability in the licensees safety-conscious work
environment from discussions with plant personnel. There was a perception
among some members of the plant staff that management may use the condition
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Enclosure 2
report process to discipline workers when personnel errors were documented in
the condition reports. Additionally, some personnel stated that they did not write
condition reports, but rather they passed the comments along to supervisors who
would enter them into the corrective action program.
Overall, most individuals were familiar with the employee concerns program and
its location on site. There was visibility of the program throughout the site. Many
of the individuals interviewed had knowledge of the employee concerns
manager; however, no one interviewed indicated having direct interactions with
the employee concerns manger during the inspection period. Personnel
understood and were confident in the confidentiality of the program.
Site personnel have received initial and annual refresher training, which provided
instruction on safety-conscious work environment policies. Many of the
individuals interviewed were familiar with this training and with the overall
message in the training. However, not everyone was familiar with the details of
the policy. None of the individuals interviewed cited any examples of
harassment, intimidation, retaliation or discrimination, or any negative reactions
from management when individuals raised nuclear safety concerns. Finally,
individuals indicated that if they were to believe unsafe conditions existed, they
would feel comfortable stopping work without fear of retaliation, even if such
actions would prolong an outage or extend a planned schedule.
.5
Specific Issues Identified During This Inspection
a. Failure to Promptly Determine the Operability of the Emergency Diesel Generators
Introduction. The team identified a Green non-cited violation of 10 CFR Part 50,
Appendix B, Criterion V, Instructions, Procedures, and Drawings, for a failure to follow
Procedure EN-OP-104, Operability Determination Process. Specifically, the licensee
failed to determine the operability of the emergency diesel generators immediately upon
discovery without delay and in a controlled manner using the best information available
in response to NRC Information Notice 2010-04.
Description. The team reviewed the licensees corrective actions taken in response to
an NRC Information Notice. On February 26, 2010, the NRC issued Information
Notice 2010-04, Diesel Generator Voltage Regulation System Component [Failure] Due
to Latent Manufacturing Defect. This information notice describes the failure of a linear
power reactor in an emergency diesel generator voltage regulation system at a plant
where the licensees preventive maintenance program did not address the emergency
diesel generator excitation system magnetic components.
The licensee completed an evaluation of the information notice per Procedure EN-
OE-100, Operating Experience Program, on July 1, 2010. This evaluation indicated
that Waterford 3 was vulnerable and susceptible to the issue, but the licensee failed to
issue a condition report as required by their procedure. The failure to initiate a condition
report resulted in the licensees failure to perform an operability determination of the
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Enclosure 2
emergency diesel generators as required by Procedure EN-OP-104, Operability
Determination Process, Revision 6.
In the evaluation, the licensee considered the fact that they had an Action Request in
their system that addressed a similar concern to be an acceptable response to this
information notice. Action Request 079684 was initiated on December 10, 2009, to
address recommendations from an INPO assistance visit in 2007 and it included an
action to add routine thermography inspections within the voltage regulator cabinets to
their preventative maintenance program. The Entergy Nuclear Corporate Operating
Experience group also reviewed this information notice on March 4, 2010. In response,
they issued a specific action through their operating experience database to evaluate the
information notice to each Entergy site. However, they failed to issue one to
Waterford 3.
The licensee started routing Action Request 079684 for approval, but they stopped on
March 15, 2010. The licensee attributed this to an incomplete turnover by departing
personnel. No other approval actions were taken until April 16, 2012, when the request
was routed to the next person in the approval process. Again, no further action was
taken, and the action request was not completed when the inspection team reviewed the
issue.
The inspectors questioned why there was no condition report generated and why the
action request had not been completed more than two years after issuance. In
particular, the inspectors questioned whether there was an operability concern for the
emergency diesel generators. The licensee recognized their failure to issue a condition
report and perform an operability determination. They performed a prompt operability
determination based on operating data, work history, and no observed degradation in
performance, and declared the emergency diesel generators operable. In addition, they
plan to conduct the thermography during the next scheduled emergency diesel
generator surveillance.
The licensee initiated CR-WF3-2012-00596 and CR-WF3-2012-03761 to address the
issue. They also initiated CR-HQN-2012-00857 to address the failure of the corporate
organization to include Waterford 3 in their site-specific requests.
Analysis. The failure to promptly perform an operability determination of the emergency
diesel generators in response to NRC Information Notice 2010-04 was a performance
deficiency. The performance deficiency was more than minor because it was associated
with the equipment performance attribute of the Mitigating Systems Cornerstone and
affected the cornerstone objective to ensure the availability, reliability, and capability of
systems that respond to initiating events to prevent undesirable consequences.
Specifically, the licensee failed to promptly determine the operability of the diesel
generators after obtaining information of a potential condition adverse to quality. In
accordance with NRC Inspection Manual Chapter 0609, Attachment 4, "Initial
Characterization of Findings," the issue was determined to affect the Mitigating Systems
Cornerstone. In accordance with NRC Inspection Manual Chapter 0609, Appendix A,
The Significance Determination Process (SDP) for Findings at Power, the issue was
- 17 -
Enclosure 2
determined to have very low safety significance (Green) because it was not a deficiency
affecting the design or qualification of the system, it did not represent a loss of system or
function, and it was a Technical Specification system but did not represent an actual loss
of function of a single train for greater than it allowed outage time. Specifically, the
licensee performed an operability determination in response to the inspectors questions
and determined the emergency diesel generators were operable based on a review of
surveillance data and maintenance records. This finding had a cross-cutting aspect in
the problem identification and resolution area, operating experience component, in that
the licensee failed to systematically collect, evaluate, and communicate to affected
internal stakeholders in a timely manner relevant internal and external operating
experience P.2.a].
Enforcement. Title 10 of the Code of Federal Regulations Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings, states, in part, that activities
affecting quality shall be prescribed by documented instructions, procedures, or
drawings of a type appropriate to the circumstances and shall be accomplished in
accordance with these instructions, procedures, or drawings. Licensee Procedure
EN-OP-104, Operability Determination Process, Revision 6, Section 5.1 step 13
required that an operability should be determined immediately upon discovery without
delay and in a controlled manner using the best information available. Contrary to this
requirement, from July 1, 2010, to July 25, 2012, the licensee failed to accomplish an
activity affecting quality prescribed by documented instructions. Specifically, the
licensee failed to determine the operability of the emergency diesel generators as
required by Licensee Procedure EN-OP-104 in response to NRC Information
Notice 2010-04. The licensee immediately determined the operability of the emergency
diesel generators based on operating data and work history, and they established a
reasonable basis for operability. This violation is being treated as an NCV, consistent
with Section 2.3.2 of the Enforcement Policy, because it was of very low safety
significance (Green) with no actual or potential safety consequences and was entered
into the licensees corrective action program as Condition Report CR-WF3-2012-03761
to address recurrence. (NCV 05000382/2012008-01, Failure to Promptly Determine the
Operability of the Emergency Diesel Generators)
b. Failure to Take Corrective Action Associated with the Emergency Feedwater Pump AB
Introduction. The team identified a Green non-cited violation of 10 CFR Part 50,
Appendix B, Criterion XVI, Corrective Action, for the failure to take timely corrective
action for a condition adverse to quality. Specifically, the licensee failed to restore a
degraded condition, which included a corrective action to perform a new design analysis
for the emergency feedwater pump AB after the removal of heat trace circuit 1-8C
despite having a reasonable amount of time to complete it.
Description. The team performed an in-depth review of corrective actions associated
with the emergency feedwater system. The turbine driven emergency feedwater pump
AB has steam piping that is maintained at a high temperature with a heat trace to
prevent excessive condensation from developing, which could reduce the reliability of
the pump to perform its design function. The licensee removed heat trace circuit 1-8C
- 18 -
Enclosure 2
from a horizontal section of steam piping because the heat trace was not maintaining the
piping above the required setpoint. In May 2011, the licensee determined that
emergency feedwater pump AB was operable but degraded. A corrective action was
initiated to perform a design analysis using RELAP to determine what modifications
needed to be performed on the system to return the system to a fully operable status.
The team identified that the licensee extended the due date twice for the corrective
action, first from February 23 to June 15, 2012, and then from June 15 until
October 12, 2012. The last extension was approved due to lack of engineering
resources resulting from other activities placed at a higher priority by Waterford 3
management. The team determined that from May 2011 to August 2012, a corrective
action to perform a design analysis for the long-standing equipment issue of determining
whether or not a plant modification is needed to maintain the system operable had not
been performed in a timely manner. Currently, plant operators are required once per
shift to perform temperature verifications of the heat trace to ensure condensation does
not form in the steam supply pipe to the turbine driven pump and maintain emergency
feedwater pump AB in an operable, but degraded, status until the design analysis is
complete. The licensee has entered the concern into their corrective action program as
Condition Report CR-WF3-2012-03754.
Analysis. The team determined that the failure to complete the corrective action of
performing a new design analysis to determine if emergency feedwater pump AB
required a design modification based on the analysis in a timely manner was a
performance deficiency. The performance deficiency was more than minor because it
affected the equipment performance attribute of the Mitigating Systems Cornerstone
objective to ensure the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. Specifically, failure to implement
this corrective action could result in reduced reliability of the emergency feedwater pump
AB. In accordance with NRC Inspection Manual Chapter 0609, Attachment 4, "Initial
Characterization of Findings," the issue was determined to affect the Mitigating Systems
Cornerstone. In accordance with NRC Inspection Manual Chapter 0609, Appendix A,
The Significance Determination Process (SDP) for Findings at Power, the issue was
determined to have very low safety significance (Green) because it affected the design
or qualification of mitigating systems, structures, and components; however, the
systems, structures, and components maintained operability. This finding had a cross-
cutting aspect in the human performance area, resources component, in that the
licensee failed to minimize a long-standing equipment issue adequately to assure
nuclear safety H.2(a).
Enforcement. Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action,
states, in part, that measures be established to assure that conditions adverse to quality,
such as failures, malfunction, deficiencies, deviations and non-conformances are
promptly identified and corrected. Contrary to this requirement, from May 2011 through
August 2012, the licensee failed to assure that measures were established to assure
that a condition adverse to quality was promptly corrected. Specifically, the licensee
failed to take prompt corrective action to restore a degraded condition by not performing
- 19 -
Enclosure 2
a design analysis for emergency feedwater pump AB after heat trace circuit 1-8C was
removed. Consequently, plant operators are required once per shift to perform
temperature verifications of the heat trace to ensure condensation does not form in the
steam supply pipe to the turbine driven pump and maintain emergency feedwater pump
AB in an operable, but degraded, status until the design analysis is complete. This
violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement
Policy because it was of very low safety significance (Green) with no actual or potential
safety consequence and was entered into the licensees corrective action program as
CR-WF3-2012-03754 to address recurrence. (NCV 05000382/2012008-02, Failure to
Take Corrective Action Associated with Emergency Feedwater Pump AB)
c. Failure to Take Timely Corrective Action to Establish a Basis for Flood Control Measures
Introduction. The team identified a Green cited violation of 10 CFR Part 50, Appendix B,
Criterion III, Design Control, for the failure to establish measures to assure that
applicable regulatory requirements and the design basis as defined in 10 CFR 50.2 are
correctly translated into procedures. Specifically, the licensee has not determined a
basis for the level at which flood control measures are initiated, two years after receiving
a non-cited violation for the same deficiency.
Description. The team reviewed the licensees corrective actions taken in response to a
non-cited violation from 2010 documented as NCV 2010006-02, Non-conservative
Technical Specification 3.7.5 Action Statement. The licensee entered this violation into
their corrective action program under CR-WF3-2010-03232 on May 24, 2010. The
licensee determined that Technical Specification 3.7.5 Flood Protection was not
required to be included in their technical specifications and submitted an amendment to
move it to the Technical Requirements Manual. As an interim compensatory measure,
the licensee modified their Procedure OP-901-521, Severe Weather and Flooding to
include an action to start shutting flood control doors at a river level of 24 feet instead of
27 feet.
The required actions included verifying that all flood control penetrations below a level of
30 feet were shut within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> before the river was projected to reach 27 feet. There
are seven flood control doors of varying sizes that are required to be shut and two valves
that are required to be locked shut. Five of these doors and both valves are normally
shut during power operations, but may be open during outages. Most of them require
entry into the Radiologically Controlled Area and one requires entry into a locked room
for access.
The licensee recognized the need to establish a basis for initiating these actions at
24 feet, and issued Corrective Action 18 (CA-18) in CR-WF3-2010-03232 on
March 10, 2011, to formally evaluate and document whether 24 feet was an acceptable
river level elevation at which to initiate flood control measures. The CA-18 due date was
extended twice and on February 24, 2012, they determined that the methodology they
intended to use was not acceptable. CA-18 was closed to Corrective Action 23 (CA-23)
which directed the licensee to issue an engineering change using the methodology used
- 20 -
Enclosure 2
in Waterford 3 UFSAR Section 2.4.3.7. The due date for CA-23 was itself extended to
September 30, 2012.
The inspection team questioned why the licensee had not completed the calculation
to justify their basis for their compensatory measures, noting that it had been over
two years since the original violation was identified. The licensee initiated
CR-WF3-2012-03752 to address this concern. The inspectors verified through
walk-downs, procedure reviews, and historical data that the licensees use of 24 feet
did not represent an immediate operability concern and that the current river level was
sufficiently low to allow time for the licensee to correct the deficiency.
Analysis. The failure to complete the corrective action to establish a basis for flood
control measures in a timely manner was a performance deficiency. The performance
deficiency was more than minor because it was associated with the protection from
external events attribute of the Mitigating Systems Cornerstone and affected the
cornerstone objective to ensure the availability, reliability, and capability of systems that
respond to initiating events to prevent undesirable consequences. Specifically, the
licensee failed to verify through calculations or analysis that the actions taken to secure
flood doors could be completed in time to protect safety-related equipment from flooding
due to a levee failure. In accordance with NRC Inspection Manual Chapter 0609,
Attachment 4, "Initial Characterization of Findings," the issue was determined to affect
the Mitigating Systems Cornerstone. In accordance with NRC Inspection Manual
Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings
at Power, the issue was determined to have very low safety significance (Green)
because it did not involve the loss or degradation of equipment or function specifically
designed to mitigate a seismic, flooding, or severe weather initiating event. Specifically,
the inspectors confirmed that the licensee could reasonably ensure the flood control
doors could perform their safety function. This finding had a cross-cutting aspect in the
human performance area, resources component in that the licensee failed to maintain
long term plant safety by maintenance of design margins and ensuring engineering
backlogs low enough to support safety H.2.a].
Enforcement. Title 10 of the Code of Federal Regulations Part 50, Appendix B,
Criterion III, Design Control, states, in part, that measures shall be established to
assure that applicable regulatory requirements and the design basis, as defined in
10 CFR 50.2, are correctly translated into specifications, procedures and instructions.
Contrary to the above, from March 10, 2011, to August 2, 2012, the licensee failed to
establish measures to assure that applicable regulatory requirements and the design
basis, as defined in 10 CFR 50.2, were correctly translated into specifications,
procedures and instructions. Specifically, the licensee had not established a design
basis to determine the river level at which flood control measures were to be initiated for
closing the water tight doors, as required in Procedure OP-901-521, Severe Weather
and Flooding. The licensee demonstrated sufficient safety margin based on historical
data and current river levels to provide assurance that this is not an immediate safety
concern. Due to the licensees failure to restore compliance within a reasonable time
- 21 -
Enclosure 2
following previous NCV 05000382/2010006-02, this violation is being cited as a Notice of
Violation consistent with Section 2.3.2 of the NRC Enforcement Policy. This is a
violation of 10 CFR 50, Appendix B, Criterion III. A Notice of Violation is attached.
(VIO 05000382/2012008-03, Failure to Take Timely Corrective Action to Establish a
Basis for Flood Control Measures)
d. Failure to Ensure Operator Knowledge of Equipment Status
Introduction. The team identified a Green non-cited violation of 10 CFR Part 50,
Appendix B, Criterion V, Instructions, Procedures, and Drawings, for a failure to follow
Procedure EN-OP-115, Conduct of Operations. Specifically, the licensee failed to
ensure that control room operators knew the status of equipment at all times.
Description. The team reviewed how the licensee was addressing deficiencies in plant
instrumentation, controls, and equipment that impacted the ability of operators to
properly operate the plant. This included a review of the licensees program to identify,
compensate for, and correct these plant deficiencies and a walk-down of the control
room.
While interviewing the person responsible for tracking plant deficiencies, the inspectors
discovered that the licensee had two separate governing procedures. The licensee used
the Entergy Fleet Administrative Procedure EN-FAP-OP-006, Operator Aggregate
Impact Index Performance Indicator, to track several categories of plant deficiencies in
a standardized spreadsheet. The licensee also had the local departmental Operating
Instruction OI-002-000, Annunciator, Control Room Instrumentation and Workarounds
Status Control. This instruction had different definitions for categories of plant
deficiencies and directed the use of a different database.
The inspectors then interviewed the on shift operators in the control room and reviewed
both databases. The inspectors identified several issues:
The person responsible for tracking plant deficiencies was only using the fleet
administrative procedure and was unaware of the operating instruction.
On one shift, the shift technical advisor believed the fleet administrative
procedure was being used and was not aware of the operating instruction,
while the control room supervisor believed the operating instruction was
being used and was not aware of the fleet administrative procedure.
The database required by the operating instruction had not been maintained
for two years.
The operating instruction did not have a category for Operator Burdens;
however, the shift crew differentiated between Operator Workarounds and
Operator Burdens. In most cases, they chose the less conservative
designation of Operator Burden.
- 22 -
Enclosure 2
The fleet administrative procedure was intended for fleet performance
reporting, not plant deficiency control. It does not direct any actions to
address and correct plant deficiencies.
The operating instruction subcategorizes Workarounds by scheduling of
resources rather than by risk significance or impact to operators. The fleet
administrative procedure does not subcategorize Operator Workarounds or
Operator Burdens, but the licensee carried over this practice to the fleet
administrative procedure spreadsheet. This could lead to improper
prioritization of corrective actions.
The operating instruction directs identification of plant deficiencies through a
review of work requests, but it does not require a review of condition reports.
Some plant deficiencies were not entered into either database.
Operators were using the same tags for Control Room Deficiencies and
informal operator notes. These notes are not controlled by either procedure.
A list of plant deficiencies was not immediately available to control room
operators.
The inspectors determined that when the fleet administrative procedure was issued in
March 2010, the licensee changed their process for tracking deficiencies. The licensee
Procedure W2.109, Procedure Development, Review & Approval, is safety-related and
requires implementation and maintenance of procedures and departmental instructions.
This procedure prescribes a process for approving and revising procedures and
instructions and conducting necessary training. When the licensee began tracking plant
deficiencies per the fleet administrative procedure, the licensee did not revise the
operating instruction to conform to the new process, and the licensee did not train all
affected personnel on the new process. As a result, the operators did not maintain a
consistent accurate list and were not aware of all plant deficiencies, and therefore were
not aware of the status of all plant equipment. This was not in accordance with
Procedure EN-OP-115, Conduct of Operations, Revision 9, Section 5.13 step 1, which
states that the status of plant equipment is known at all times by plant operators.
The licensee initiated CR-WF3-2012-03732 to address the issue. The licensee will
revise the operating instruction to address the process issues and make the intended
changes.
Analysis. The failure to ensure that operators were aware of the status of all plant
equipment was a performance deficiency. The performance deficiency was more than
minor because it was associated with the procedure quality attribute of the Initiating
Events Cornerstone and affected the cornerstone objective to limit the likelihood of those
events that upset plant stability and challenge critical safety functions during shutdown
as well as power operations. Specifically, the licensee failed to implement a procedure
designed to ensure operators were aware of deficiencies in the instrumentation, controls,
- 23 -
Enclosure 2
and operation of nuclear plant systems. In accordance with NRC Inspection Manual
Chapter 0609, Attachment 4, "Initial Characterization of Findings," the issue was
determined to affect the Initiating Events Cornerstone. In accordance with NRC
Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process
(SDP) for Findings at Power, the issue was determined to have very low safety
significance (Green) because it did not cause a reactor trip and the loss of mitigation
equipment relied upon to transition the plant from the onset of the trip to a stable
shutdown condition. This finding had a cross-cutting aspect in the human performance
area, work practices component, in that the licensee failed to define and effectively
communicate expectations regarding procedural compliance, and personnel did not
follow procedures H.4.b].
Enforcement. Title 10 of the Code of Federal Regulations Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings, states, in part, that activities
affecting quality shall be prescribed by documented instructions, procedures, or
drawings of a type appropriate to the circumstance and shall be accomplished in
accordance with these instructions, procedures, or drawings. Procedure EN-OP-115,
Conduct of Operations, Revision 9, Section 5.13, step 1, states that the status of plant
equipment is known at all times by plant operators. Contrary to this requirement, from
March 2, 2010, to August 1, 2012, the licensee failed to accomplish an activity affecting
quality in accordance with the documented instructions appropriate to the circumstance.
Specifically, the licensee failed to ensure operators knew the status of plant equipment
at all times in accordance with Licensee Procedure EN-OP-115, Conduct of
Operations. The licensee has a corrective action to revise their operating instruction for
tracking plant deficiencies, and none of the current plant deficiencies represents an
immediate safety concern. This violation is being treated as an NCV, consistent with
Section 2.3.2 of the Enforcement Policy, because it was of very low safety significance
(Green) with no actual or potential safety consequences and was entered into the
licensees corrective action program as CR-WF3-2012-03732 to address recurrence.
(NCV 05000382/2012008-04, Failure to Ensure Operator Knowledge of Equipment
Status)
e. Failure to Develop Effective Corrective Actions to Preclude Repetition
Introduction. The inspectors identified a non-cited violation of 10 CFR Part 50,
Appendix B, Criterion XVI, Corrective Actions, because the licensee failed to determine
the cause of a significant condition adverse to quality and take corrective actions to
prevent recurrence. Specifically, the licensee failed to assure that the cause of the
condition was determined and corrective action taken to preclude repetition associated
with a contractors non-compliance with site procedural requirements.
Description. During refuel outage 16 in 2009, contract instrumentation and control
technicians performed a functional test on a feedwater heater level switch according to
work order instructions. Following restoration, a plant transient occurred because a
valve was out of position (CR-WF3-2009-7420). The licensee determined that the event
constituted a significant condition adverse to quality in accordance with guidance from
Procedure EN-LI-102, Corrective Action Process. During the valve manipulation, the
- 24 -
Enclosure 2
work instructions called for concurrent verification. However the licensees root cause
analysis determined that the contract workers failed to perform concurrent verification as
required by the procedure (NCV 2011003-04). The contract workers knew the
procedural requirement, but they behaved inappropriately when they chose not to follow
the instructions. The licensees root cause analysis did not determine why the contract
workers chose not to follow the procedure. The licensees corrective action to preclude
repetition (CAPR) of this significant condition adverse to quality (SCAQ) was to release
the contract workers for not following the procedure and prohibit them from future work
at Entergy sites. No actions to preclude repetition that addressed the underlying cause
of the failure to perform concurrent verification were taken. The team identified that
despite guidance provided in Procedure EN-LI-118, Attachment 9.9, Root Cause
Evaluation Process, which states that discipline of individuals is not an appropriate
CAPR, disciplinary action was the only CAPR identified in the root cause for
CR-WF3-2009-07420 performed on January 7, 2010.
The failure to determine the cause of a significant condition adverse to quality and take
corrective action to preclude repetition had no actual consequences on nuclear plant
safety. However, the failure to determine the cause of the condition adverse to quality
and take corrective action to preclude repetition from an ineffective CAPR has the ability
to lead to more significant safety consequences. The licensee documented this violation
in Condition Reports CR-WF3-2012-03769 and CR-WF3-2012-03772. The corrective
actions include developing additional training and provisions to provide additional
contractor oversight.
Analysis. The failure to determine the cause of a significant condition adverse to quality
and take corrective action to preclude repetition was a performance deficiency. The
performance deficiency was more than minor because if left uncorrected, it could lead to
more significant consequences, therefore it is a finding. Specifically, failure to determine
the cause of a significant condition adverse to qualify and take corrective action to
prevent recurrence can result in recurrence of the condition. In accordance with NRC
Inspection Manual Chapter 0609, Attachment 4, "Initial Characterization of Findings," the
issue was determined to affect the Initiating Events Cornerstone. In accordance with
NRC Inspection Manual Chapter 0609, Appendix A, The Significance Determination
Process (SDP) for Findings at Power, the issue was determined to have very low safety
significance (Green) because the finding did not cause a reactor trip and the loss of
mitigation equipment relied upon to transition the plant from the onset of the trip to a
stable shutdown condition. This finding had a cross-cutting aspect in the human
performance, work practice component, in that the licensee failed to follow guidance in
the root cause evaluation procedure when developing appropriate corrective actions to
prevent repetition H.4(b).
Enforcement. Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action,
states, in part, in the case of significant conditions adverse to quality, the measures shall
assure that the cause of the condition is determined and corrective action taken to
preclude repetition. Contrary to this requirement, on January 7, 2010, for a significant
condition adverse to quality, the licensee failed to take measures to assure that the
cause of the condition was determined and corrective actions taken to preclude
- 25 -
Enclosure 2
repetition. Specifically, the licensee did not determine the underlying cause of the failure
of the site contract workers to comply with licensees procedural requirements nor were
corrective actions taken to preclude repetition of the condition. The licensees corrective
actions to address this problem include developing additional training and provisions to
provide additional contractor oversight. This violation is being treated as an NCV,
consistent with Section 2.3.2 of the Enforcement Policy because it was of very low safety
significance (Green) with no actual or potential safety consequence and was entered
into the licensees corrective action program as CR-WF3-2012-03769 and
CR-WF3-2012-03772 to address recurrence. (NCV 05000382/2012008-05, Failure to
Develop Effective Corrective Actions to Preclude Repetition)
4OA6 Meetings
Exit Meeting Summary
On August 2, 2012, the team presented the inspection results to Keith Nichols, Director of
Engineering, and other members of the licensee staff. The licensee acknowledged the issues
presented. The inspector asked the licensee whether any materials examined during the
inspection should be considered proprietary. No proprietary information was identified.
On August 23, 2012, the team exited with the revised characterization of the inspection results
to William McKinney, Acting Director Nuclear Safety and Assurance, and other members of the
licensee staff. The licensee acknowledged the issues presented.
On September 24, 2012, the team exited with the revised characterization of the inspection
results to Keith Nichols, Director of Engineering, and other members of the licensee staff. The
licensee acknowledged the issues presented.
4OA7 Licensee-Identified Violations
The following violation of very low safety significance (Green) was identified by the licensee
and is a violation of NRC requirements, which meets the criteria of Section VI of the
NRC Enforcement Policy, NUREG-1600, for being dispositioned as an NCV.
Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion V,
Instructions, Procedures, and Drawings, states, in part, that activities affecting quality
shall be prescribed by documented instructions, procedures, or drawings and shall be
accomplished in accordance with these instructions, procedures, or drawings. Contrary
to this requirement, on May 10 and May 12, 2011, the licensee failed to accomplish an
activity affecting quality as prescribed by the documented procedure. Specifically, the
licensee failed to perform operability reviews when heat trace circuit 1-8C fell below the
operating instruction temperature on the steam supply piping to the emergency
feedwater pump in accordance with Procedure EN-OP-104, Operability Determination
Process. The team determined that this finding was of very low safety significance
(Green) because it affected the design or qualification of a mitigating system structure
component; however, the system structure component maintained its operability.
- 26 -
Enclosure 2
The emergency feed water pump AB was declared inoperable on May 14, 2011;
however, subsequent evaluation declared the pump operable but degraded.
This was documented in the licensees corrective action program as Condition
Reports CR-WF3-2011-03599 and CR-WF3-2011-03600.
ATTACHMENTS:
SUPPLEMENTAL INFORMATION
INFORMATION REQUEST
A1-1
Attachment 1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
S. Adams, Planning Scheduling and Outage Manger
J. Bourgeois, Acting Chemistry Manager
E. Brauner, Supervision of System Engineering
K. Cook, General Manager, Plant Operations
G. Fey, Emergency Planning Manager
S. Fontenot, Acting Corrective Actions and Assessment Manager
R. Gilmore, Engineering and Components Manager
J. Gumnick, Radiation Protection Manager
D. Jacobs, Site Vice President, Operations
J. Jarrell, Assistant Operations Shift Manager
B. Lanka, Manager, System Engineering Manager
B. Lindsey, Maintenance Manager
M. Mason, Acting Licensing Manager
W. McKinney, Acting Director Nuclear Safety and Assurance
K. Nichols, Director of Engineering
R. Porter, Design Engineering Manager
D. Rieder, Quality Assurance Supervisor
K. Rockwood, Acting Technical Training Supervisor
T. Sanders, Security Superintendant
P. Stanton, Design Engineering Supervisor
NRC Personnel
R. Kumana, Project Engineer
R. Smith, Team Leader/Senior Resident Inspector
D. Overland, Resident Inspector
M. Young, Reactor Inspector
A1-2
Attachment 1
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened 05000382/2012008-03 VIO
Failure to Take Timely Corrective Action to Establish a Basis for
Flood Control Measures (Section 4OA2.5.c)
Opened and Closed 05000382/2012008-01 NCV Failure to Promptly Determine the Operability of the Emergency
Diesel Generators (Section 4OA2.5.a)05000382/2012008-02 NCV Failure to Take Corrective Action Associated with Emergency
Feedwater Pump AB (Section 4OA2.5.b)05000382/2012008-04 NCV Failure to Ensure Operator Knowledge of Equipment Status
(Section 4OA2.5.d)05000382/2012008-05 NCV Failure to Develop Effective Corrective Actions to Preclude
Repetition (Section 4OA2.5.e)
A1-3
Attachment 1
LIST OF DOCUMENTS REVIEWED
PROCEDURES
NUMBER
TITLE
REVISION
Self-Assessment and Benchmark Process
8
Corrective Action Process
19
Root Cause Evaluation Process
17
Apparent Cause Evaluation (ACE) Process
15
Operability Determination Process
6
Conduct of Nuclear Oversight
7
Quality Control Inspection Program
1
QA Surveillance Process
9
Fundamentals of Maintenance
10
OP-901-310
Loss of Train A Safety Bus
308
OP-903-115
Train A Integrated Emergency Diesel Generator /
Engineering Safety Features Test
21
ME-007-005
Time Delay Relay Setting Check, Adjustment and
Functional Test
16
Systematic Approach to Training Process
12
Systematic Approach to Training Process
13
TM-OP-100
Operations Training Manual
16
Licensed Operator Requalification Training Program
Description
3
Inprocessing Training Program
6
A1-4
Attachment 1
NUMBER
TITLE
REVISION
Inprocessing Training Program
8
General Employee Training
7
Guidelines For Implementation Of The Employee
Concerns Program
6
Control of Scaffolding
8
OP-002-007
Freeze Protection and Temperature Maintenance
18
Confined Space Program
8
OP-903-046
Emergency Feed Pump Operability Check
309
EN-NE-G-013
Human Reliability Analysis for PSA Models
1
OP-009-003
Emergency Feedwater
304
EN-FAP-OP-006
Operator Aggregate Impact Index Performance Indicator
0
OI-002-000
Operator Instruction Annunciator, Control Room
Instrumentation and Workarounds Status Control
304
Licensed Operator Candidate Selection Process
2
NRC Cross-Cutting Analysis and Trending
1
Operating Experience Program
14
EN-LI-118-06
Common Cause Analysis (CCA)
3
OP-002-007
Freeze Protection and Temperature Maintenance
18
OP-903-053
Fire Protection System Pump Operability Test
17
UNT-005-013
12
EN-FAP-LI-001
Condition Review Group (CRG)
3
A1-5
Attachment 1
NUMBER
TITLE
REVISION
EN-FAP-LI-003
Corrective Action Review Board (CARB) Process
8
Human Performance Error Reviews
7
Procedure and Work Instruction Use and Adherence
0
Personnel Expectations Related to Fatigue Management
0
Initial Licensed Operator Training Program Description
7
OP-100-014
Technical Specification and Technical Requirements
Compliance
317
OP-901-521
Severe Weather and Flooding
305
Operating Experience Program
14
EN-FAP-AD-001
Fleet Administrative Procedure (FAP) Process
0
EN-AD-101-01
NMM Procedure Writer Manual
9
Procedure Process
14
Entergy Nuclear Change Management
4
W2.109
Procedure Development, Review & Approval
13
Fitness For Duty Program
9
Fitness For Duty Processes
6
EN-OM-123-02
Working Hour Limits eSOMS Users Guide
1
Fatigue Management Program
4
Personnel Expectations Related to Fatigue Management
0
Conduct of Operations
9
A1-6
Attachment 1
CALCULATIONS
NUMBER
TITLE
REVISION
EC-C97-003
Probabilistic Evaluation of Tornado Missile Strike for
Waterford 3 Nuclear Station
0, Change 1
EC-M00-004
Thermal-Hydraulic Calculation for the EFW Steam Supply
Valves (MS-401A(B)) and Lines
0
Calculation No.
MNQ3-5
Flooding Analysis Outside Containment
4
EC-M99-010
Minimum Flow for DCT Sump Pump
0-2
134669-G-07
Scour Analysis and Scour Protection Design from a
Hypothetical Levee Break
1
DRAWINGS
NUMBER
TITLE
REVISION
G-153
Feedwater, Condensate & Air Evacuation Systems
G-151
Flow Diagram Main & Extraction Steam System
43
G-924
HVAC - Water Treatment Bldg. & Fire Pump House
6
G1370
Fire Protection Turbine Bldg.
2
OTHER DOCUMENTS
NUMBER
TITLE
REVISION/
DATE
QS-2012-W3-008
QA Follow-up Surveillance of Category A Condition
Reports initiated during April 2012
1
QS-2012-W3-007
QA Follow-up review of EN-QV-126 required issues
initiated January, February, and March 2012
1
QS-2011-W3-015
QA Follow-up Surveillance of Category A Condition
Reports initiated during September, 2011
July 26, 2011
QS-2011-W3-012
QA Follow-up Surveillance of the 2011 Corrective
Action Program (CAP) Audit
September 12,
2011
A1-7
Attachment 1
NUMBER
TITLE
REVISION/
DATE
QS-2011-W3-009
QA Follow-up Surveillance of Quality Assurance
Finding CR-WF3-2011-3084
1
QS-2011-W3-008
QA Follow-up Surveillance of Category A Condition
Reports Initiated During May 2011
June 13, 2011
QS-2011-W3-007
QA Follow-up Surveillance of Category A Condition
Reports Initiated During April 2011
1
QS-2011-W3-006
QA Follow-up to Category A Condition Reports for
January and February 2011
1
LO-WLO-2011-
0007
Quality of Causal Analysis Focused Assessment
October 13, 2011
LO-WLO-2011-
0053
Maintenance Training Focused Self-Assessment
(I&C, Mechanical, Electrical)
July 29, 2011
LO-WLO-2011-
0124
Quality Assurance Self-Assessment Report
December 9, 2011
LO-WLO-2012-
0015
Snapshot Assessment / Benchmark On: PME
Performance
May 23, 2012
LO-WLO-2012-
0030
Snapshot Assessment / Benchmark On:
Maintenance - Advanced Qualifications
February 6, 2012
OE34343-
20111008
Seismic Monitoring Systems Failed to Actuate
During a Seismic Event
September 1, 2011
OE35212-
20120211
Extraction Steam System Carbon Steel Reducer
found Below Design Minimum Wall due to
Unpredicted Flow-Accelerated Corrosion
November 3, 2011
OE34934-
20120107
Nuclear Regulatory Commission Red Finding Root
Cause Analysis Results
December 9, 2011
LO-WLO-2010-
00143
Licensed Operator Requal 71111.11 Pre-Inspection
Assessment
March 3, 2011
Evaluate the Effectiveness of Waterford 3 Shift
Manager/STA Training Program
November 3, 2011
LOR/STAR
Biennial Written
Exam Worksheet
Examination # WWEX-LOR-11046R/S
Examination # WEX-LOR-11043R/S
2011
A1-8
Attachment 1
NUMBER
TITLE
REVISION/
DATE
Site Broadcast
RCA Drain Limitations
February 16, 2012
Waterford 3 - 2010 Employee Concerns Data
Analysis
Waterford 3 - 2011 Employee Concerns Data
Analysis
FCBT-GET-
PATSS
Entergy Fleet Specific Plant Access Training
17
Training Review Group Meeting Minutes
June 9, 2010
WLP-TRNC-SATR
Focused SAT Review
2
2nd QTR 2010 Instructor Continuing Training Kickoff
LO-WLO-2010-
0059
Waterford 3 Equipment Reliability and Core
Business Focused Self Assessment
May 27-29, 2010
LO-WLO-2010-
0091
WF3 IST Program Focused Self Assessment
August 20-24, 2010
LO-WLO-2011-
0041
Snapshot Assessment/Benchmark on: Relief Valve
Program
October 26, 2011
WH-TB-11-5-A2
Evaluation Summary: Evaluation of Downstream
Sump Debris Effects in Support of GSI-191
June 14, 2011
TB-11-5
Assessment of WCAP-16406-P-A Abrasive Wear
Model and Recommendations
March 1, 2011
WH-TB-10-4-A2
Evaluation Summary: CEDM Upper Pressure
Housing Venting
August 17, 2010
TB-10-4
Potential for Stress Corrosion Cracking in Control
Element Drive Mechanism Upper Pressure Housing
April 12, 2010
SD-EFW
Emergency Feedwater
11
DCP-3506
Auxiliary Steam Test Connection for EFW Pump
A/B
March 12, 1997
A1-9
Attachment 1
NUMBER
TITLE
REVISION/
DATE
DCP-3506
Auxiliary Steam Test Connection for EFW Pump
A/B
July 24, 1998
DCP-3506
Auxiliary Steam Test Connection for EFW Pump
A/B
February 25, 1999
DCP-3506
Auxiliary Steam Test Connection for EFW Pump
A/B
May 26, 1999
DC-3526
EFW Heat Trace Reliability Improvements
September 3, 1999
Replacement of MCC DCT Cubicle Compartments
0
Operability Assistance Tool
STI-WO-275977
CS117A, Shutdown Cooling Heat Exchanger
Discharge Stop Check Valve Leakage Test
0
Clarify Safety Function and Leakage Criteria for CS-
111A(B) and CS-117A(B)
Draft
W3-DBD-003
301
CRG Report for Tuesday
July 31, 2012
CRG Report for Thursday
August 2, 2012
Operational Focus
July 31, 2012
Operational Focus
August 2, 2012
LO-WLO-2010-
00061
Status of the Safety Conscious Work Environment
in Security
July 6, 2010
LO-WLO-2012-
006
Operations Assessment of Plant Status and
Configuration Control
March 1, 2012
A1-10
Attachment 1
NUMBER
TITLE
REVISION/
DATE
LPL-EQA-4.2B
Environmental Qualification Assessment on Allis-
Chalmers Form Wound Motors Used in the
Waterford SES Unit No. 3
2
NRC IN 2010-04
Diesel Generator Voltage Regulation System
Component Due to Latent Manufacturing Defect
February 26, 2010
NRC-IN-2010-04-
A2-WF3-0002-001
Entergy OE A2 Evaluation Summary
July 1, 2010
OP-903-053 V134
Fire Protection System Pump Operability Test
January 9, 2008
OP-903-053 V135
Fire Protection System Pump Operability Test
June 18, 2009
ER-W3-2002-
0429-000
Diesel Fire Pump Louvers
0
WSES-FSAR-
UNIT-3
Updated Final Safety Analysis Report
OP-903-053 V136
Fire Protection System Pump Operability Test
August 25, 2011
W3-DBD-018
Fire Protection
0
Waterford Operating License
W3-DBD-037
Nuclear Island and Building Design - RCB
1
Ltr from A H Wern
Waterford SES Unit No. 3 Levee Stability Analysis
December 7, 1972
Flood Protection
NA
License Amendment Request to Relocate Technical
Specifications to the Technical Requirements
Manual Waterford Steam Electric Station Unit 3
November 21, 2011
AR079684079684
Scope Revision to PMID 6718 incorporate EPRI
Recommend Pdm
December 12, 2009
A1-11
Attachment 1
NUMBER
TITLE
REVISION/
DATE
Annual Work Hour Review & Fatigue Assessment
Summary
2010
Annual Work Hour Review & Fatigue Assessment
Summary
2011
SI MTRP0001 Auto Vent
0
14
Entergy System
Policies &
Procedures
Workplace Violence and Weapons
1
General Industrial Safety Requirements
11
PS-011-102
Personnel Access Control
308
PS-011-103
Vehicle Access Control
303
PS-011-110
Security Owner Controlled Area Vehicle and
Personnel Access Control
010
Waterford 3 Accreditation Board Report
September 2010
CONDITION REPORTS
A1-12
Attachment 1
CONDITION REPORTS
A1-13
Attachment 1
CONDITION REPORTS
CR-ANO-C-2011-00441
A1-14
Attachment 1
WORK ORDERS
248856
52230980
289449
275977
196828
262164
283919
256250
64753
205779
296253
303342
296271
305641
52340992
52356683
52371026
52376231
52389001
254348
257755
246482
254493
263585
286950
261413
279127
298743
28810
287883
245561
52382399
52351187
254203
A2-1
Attachment 2
Information Request
June 11, 2012
Biennial Problem Identification and Resolution Inspection - Waterford 3 Nuclear
Generating Station
Inspection Report 2012008
This inspection will cover the period from May 1, 2010, to June 1, 2012. All requested
information should be limited to this period unless otherwise specified. To the extent possible,
the requested information should be provided electronically in Adobe PDF or Microsoft Office
format. Lists of documents should be provided in Microsoft Excel or a similar sortable format.
A supplemental information request will likely be sent during the week of July 9, 2012.
Please provide the following no later than June 30, 2012:
1.
Document Lists
Note: for these summary lists, please include the document/reference number, the
document title or a description of the issue, initiation date, and current status. Please
include long text descriptions of the issues.
a.
Summary list of all corrective action documents related to significant conditions
adverse to quality that were opened, closed, or evaluated during the period
b.
Summary list of all corrective action documents related to conditions adverse to
quality that were opened or closed during the period
c.
Summary lists of all corrective action documents which were upgraded or
downgraded in priority/significance during the period
d.
Summary list of all corrective action documents that subsume or roll up one or
more smaller issues for the period
e.
Summary lists of operator workarounds, engineering review requests and/or
operability evaluations, temporary modifications, and control room and safety
system deficiencies opened, closed, or evaluated during the period
f.
Summary list of plant safety issues raised or addressed by the Employee
Concerns Program (or equivalent)
g.
Summary list of all Apparent Cause Evaluations completed during the period
h.
Summary list of all Root Cause Evaluations planned or in progress, but not
complete at the end of the period
2.
Full Documents, with Attachments
a.
Root Cause Evaluations completed during the period
A2-2
Attachment 2
b.
Quality assurance audits performed during the period
c.
All audits/surveillances performed during the period of the Corrective Action
Program, of individual corrective actions, and of cause evaluations
d.
Corrective action activity reports, functional area self-assessments, and non-
NRC third party assessments completed during the period (do not include INPO
assessments)
e.
Corrective action documents generated during the period for the following:
i.
NCVs and Violations issued to Waterford 3
ii.
LERs issued by Waterford 3
f.
Corrective action documents generated for the following, if they were determined
to be applicable to Waterford 3 (for those that were evaluated, but determined
not to be applicable, provide a summary list):
i.
NRC Information Notices, Bulletins, and Generic Letters issued or
evaluated during the period
ii.
Part 21 reports issued or evaluated during the period
iii.
Vendor safet
iv.
y information letters (or equivalent) issued or evaluated during the period
v.
Other external events and/or Operating Experience evaluated for
applicability during the period
g.
Corrective action documents generated for the following:
i.
Emergency planning drills and tabletop exercises performed during the
period
ii.
Maintenance preventable functional failures which occurred or were
evaluated during the period
iii.
Adverse trends in equipment, processes, procedures, or programs which
were evaluated during the period
iv.
Action items generated or addressed by plant safety review committees
during the period
A2-3
Attachment 2
3.
Logs and Reports
a.
Corrective action performance trending/tracking information generated during the
period and broken down by functional organization
b.
Corrective action effectiveness review reports generated during the period
c.
Current system health reports or similar information
d.
Radiation protection event logs during the period
e.
Security event logs and security incidents during the period (sensitive information
can be provided by hard copy during first week on site)
f.
Employee Concern Program (or equivalent) logs (sensitive information can be
provided by hard copy during first week on site)
g.
List of training deficiencies, requests for training improvements, and simulator
deficiencies for the period
4.
Procedures
a.
Corrective action program procedures, to include initiation and evaluation
procedures, operability determination procedures, apparent and root cause
evaluation/determination procedures, and any other procedures which implement
the corrective action program at Waterford 3
b.
Quality Assurance program procedures
c.
Employee Concerns Program (or equivalent) procedures
d.
Procedures which implement/maintain a Safety-Conscious Work Environment
5.
Other
a.
List of risk significant components and systems
b.
Organization charts for plant staff and long-term/permanent contractors
A2-4
Attachment 2
Note: Corrective action documents refers to condition reports, notifications, action requests,
cause evaluations, and/or other similar documents, as applicable to Waterford 3.
As it becomes available, but no later than June 30, 2012, this information should be uploaded
on the Certrec IMS website. When these documents have been compiled (and by June 30,
2012), please download these documents onto a CD or DVD and sent it via overnight carrier to:
Richard L. Smith
U.S. NRC Resident Inspector Office
7003 Bald Hill Road
Port Gibson, MS 39150
Please note that the NRC is not able to accept electronic documents on thumb drives or other
similar digital media. However, CDs and DVDs are acceptable.