IR 05000382/2010004
| ML103120697 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/08/2010 |
| From: | Clark J NRC/RGN-IV/DRP |
| To: | Kowalewski J Entergy Operations |
| References | |
| IR-10-004 | |
| Download: ML103120697 (37) | |
Text
UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION IV612 EAST LAMAR BLVD, SUITE 400ARLINGTON, TEXAS 76011-4125November 8, 2010
Joseph Kowalewski, 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 INTEGRATED INSPECTION REPORT 05000382/2010004
Dear Mr. Kowalewski:
On September 30, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford Steam Electric Station, Unit 3. The enclosed integrated inspection report documents the inspection results, which were discussed on October 1, 2010 with you and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Based on the results of this inspection, no findings of significance were identified. However, a licensee-identified violation which was determined to be of very low safety significance is listed in this report. The NRC is treating this violation as a noncited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy because of the very low safety significance of the violation and because it is entered into your corrective action program. If you contest the noncited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C. 20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 612 E Lamar Blvd., Suite 400, Arlington, Texas, 76011-4125; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspectors at the Waterford Steam Electric Station, Unit 3 facility.
Entergy Operations, Inc.
- 2 - In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, and its enclosure, will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRC's document 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/ Jeffrey A. Clark, P.E.
Chief, Project Branch E
Division of Reactor Projects Docket No.: 50-382 License No.: NPF-38
Enclosure:
Inspection Report 05000382/2010004 w/Attachment: Supplemental Information
REGION IV Docket No.:
50-382 License No.: NPF-38 Report: 05000382/2010004 Licensee: Entergy Operations, Inc. Facility: Waterford Steam Electric Station, Unit 3 Location: Killona, LA Dates: July 1 through September 30, 2010 Inspectors: M. Davis, Senior Resident Inspector D. Overland, Resident Inspector R. Azua, Senior Project Engineer P. Elkmann, Senior Emergency Preparedness Inspector K. Clayton, Senior Operations Engineer W. Schaup, Project Engineer
Approved By: Jeff Clark, P.E., Chief, Project Branch E Division of Reactor Projects
- 2 - Enclosure
SUMMARY OF FINDINGS
IR 05000382/2010004; 07/01/2010 - 09/30/2010; Waterford Steam Electric Station, Unit 3: Integrated Resident and Regional Report.
The report covered a 3-month period of inspection by resident inspectors and announced baseline inspections by region-based inspectors. 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.
A. NRC-Identified Findings and Self-Revealing Findings
None
B. Licensee - Identified Violations
Violations of very low safety significance, which were identified by the licensee, have been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. These violations and corrective action tracking numbers (condition report numbers) are listed in
Section 4OA7.
REPORT DETAILS
Summary of Plant Status The Waterford Steam Electric Station, Unit 3, began the inspection period at 100 percent power and remained at approximately 100 percent power for the rest of the inspection period.
REACTOR SAFETY
===Cornerstone: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness
1R01 Adverse Weather Protection
=
Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
Since topical storms Bonnie and Danielle were forecasted in the vicinity of the facility on July 24, 2010 and August 12, 2010, respectively, the inspectors reviewed the licensee's overall preparations and protection for the expected weather conditions. On July 24, 2010 and August 12 , 2010, the inspectors walked down the emergency diesel generators and portions of the dry cooling towers because their safety-related functions could be affected, or required, as a result of high winds or tornado-generated missiles or the loss of offsite power. The inspectors evaluated the plant staff's preparations against the site's procedures to determine if the staff's actions were adequate. During the inspection, the inspectors focused on plant-specific design features and the licensee's procedures used to respond to specified adverse weather conditions. The inspectors also toured the plant grounds to look for any loose debris that could become missiles during a tornado. The inspectors verified operator staffing and accessibility of controls and indications for those systems required to control the plant. Additionally, the inspectors reviewed the updated final safety analysis report and performance requirements for the systems selected for inspection, and verified that operator actions were appropriate as specified by plant-specific procedures. The inspectors also reviewed a sample of corrective action program items to verify that the licensee-identified adverse weather issues at an appropriate threshold and dispositioned them through the corrective action program in accordance with station corrective action procedures. Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of two
- (2) readiness for impending adverse weather condition samples as defined in Inspection Procedure 71111.01-05.
b. Findings
No findings were identified.
R04 Equipment Alignments
.1 Partial Walkdown
a. Inspection Scope
The inspectors performed partial system walkdowns of the following risk-significant systems:
On July 23, 2010, Train B of the low pressure safety injection system after testing the B LPSI pump On August 31, 2010, Train A of the chemical volume control system following in-service valve testing of one the control valves in the system On September 14, 2010, Train A of the low pressure safety injection system following an extended system outage On September 28, 2010, Train AB of the emergency feedwater system following an extended system outage The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could affect the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, Updated Final Safety Analysis Report, technical specification requirements, administrative technical specifications, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also inspected accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of four
- (4) partial system walkdown samples as defined in Inspection Procedure 71111.04-05.
b. Findings
No findings were identified.
.2 Complete Walkdown
a. Inspection Scope
On August 26, 2010, the inspectors performed a complete system alignment inspection of Train B of the control room ventilation system while Train A was inoperable for preventative maintenance activities to verify the functional capability of the system. The inspectors selected this system because it was considered both safety significant and risk significant in the licensee's probabilistic risk assessment. The inspectors inspected the system to review mechanical and electrical equipment line ups, electrical power availability, system pressure and temperature indications, as appropriate, component labeling, component lubrication, component and equipment cooling, hangers and supports, operability of support systems, and to ensure that ancillary equipment or debris did not interfere with equipment operation. The inspectors reviewed a sample of past and outstanding work orders to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the corrective action program database to ensure that system equipment-alignment problems were being identified and appropriately resolved. Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of one
- (1) complete system walkdown sample as defined in Inspection Procedure 71111.04-05.
b. Findings
No findings were identified.
1R05 Fire Protection
Quarterly Fire Inspection Tours
a. Inspection Scope
The inspectors conducted fire protection walkdowns that were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:
On July 21, 2010, Reactor auxiliary building relay room, fire area RAB 7 On July 22, 2010, Reactor auxiliary building switchgear room, fire area RAB 8 On August 5, 2010, Reactor auxiliary building ventilation and controlled ventilation area system fan room, fire area RAB 2 On August 19, 2010, Reactor auxiliary building battery rooms, fire areas RAB 11, 12, and 13 The inspectors reviewed areas to assess if licensee personnel had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant; effectively maintained fire detection and suppression capability; maintained passive fire protection features in good material condition; and had implemented adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features, in accordance with the licensee's fire plan.
The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plant's Individual Plant Examination of External Events with later additional insights, their potential to affect equipment that could initiate or mitigate a plant transient, or their impact on the plant's ability to respond to a security event. Using the documents listed in the attachment, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensee's corrective action program. Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of four
- (4) quarterly fire-protection inspection samples as defined in Inspection Procedure 71111.05-05.
b. Findings
No findings were identified.
1R06 Flood Protection Measures
a. Inspection Scope
The inspectors reviewed the Updated Final Safety Analysis Report, the flooding analysis, and plant procedures to assess susceptibilities involving internal flooding; reviewed the corrective action program to determine if licensee personnel identified and corrected flooding problems; and verified that operator actions for coping with flooding can reasonably achieve the desired outcomes. The inspectors also inspected the areas listed below to verify the adequacy of equipment seals located below the flood line, floor and wall penetration seals, watertight door seals, and control circuits, and temporary or removable flood barriers. Specific documents reviewed during this inspection are listed in the attachment.
On July 24, 2010, the inspectors walkdown the following risk significant areas: emergency diesel generator rooms and switchgear rooms These activities constitute completion of one
- (1) flood protection measures inspection sample as defined in Inspection Procedure 71111.06-05.
b. Findings
No findings were identified.
R11 Licensed Operator Requalification Program (71111.11/B)
The licensed operator requalification program involves two training cycles that are conducted over a 2-year period. In the first cycle, the annual cycle, the operators are administered an operating test consisting of job performance measures and simulator scenarios. In the second part of the training cycle, the biennial cycle, operators are administered an operating test and a comp rehensive written examination.
.1 Bennial Inspection
a. Inspection Scope
Only the annual was required during this cycle.
b. Findings
No findings were identified.
.2 Annual Inspection
a. Inspection Scope
The inspectors conducted an in-office review of the annual requalification training program to determine the results of this program. The licensee examined 50 operators (12 reactor operators and 38 senior reactor operators) during this requalification cycle.
In addition, 10 operating crews were examined on the facility's simulator. All of the operating crews passed the simulator scenarios and all operators passed the operating tests.
The inspectors completed one
- (1) inspection sample of the annual licensed operator requalification program.
b. Findings
No findings were identified.
.3 Quarterly Review
a. Inspection Scope
On September 22
, 2010, the inspectors observed a crew of licensed operators in the plant's simulator to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:
Licensed operator performance Crew's clarity and formality of communications
Crew's ability to take timely actions in the conservative direction
Crew's prioritization, interpretation, and verification of annunciator alarms Crew's correct use and implementation of abnormal and emergency procedures Control board manipulations
Oversight and direction from supervisors Crew's ability to identify and implement appropriate technical specification actions and emergency plan actions and notifications The inspectors compared the crew's performance in these areas to pre-established operator action expectations and successful critical task completion requirements. Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of one
- (1) quarterly licensed-operator requalification program sample as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors evaluated degraded performance issues involving the following risk significant systems:
On July 12, 2010, Static uninterruptible power supply inverters On August 11, 2010, Chemical volume control system The inspectors reviewed events such as where ineffective equipment maintenance has resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:
Implementing appropriate work practices Identifying and addressing common cause failures
Scoping of structures, systems, and components in accordance with 10 CFR 50.65(b)
Characterizing system reliability issues for performance Charging unavailability for performance Balancing reliability and unavailability for performance
Trending key parameters for condition monitoring
Ensuring proper classification and reclassification in accordance with 10 CFR 50.65(a)(1) or (a)(2)
Verifying appropriate performance criteria for structures, systems, and components classified as having an adequate demonstration of performance through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as requiring the establishment of appropriate and adequate goals and corrective actions for systems classified as not having adequate performance, as described in 10 CFR 50.65(a)(1)
The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of two
- (2) quarterly maintenance effectiveness sample(s) as defined in Inspection Procedure 71111.12-05.
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed licensee personnel's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:
On July 5, 2010, emergent maintenance activities on the letdown heat exchanger temperature control valve (CC-636) with Train A of the shielding building ventilation system being out of service On August 24, 2010, planned maintenance activities on Train B of the component cooling water pump and Train B of the emergency diesel generator air receiver On September 3, 2010, planned maintenance activity to test Train A of the startup transformer deluge system On September 7, 2010, planned maintenance on switchgear ventilation air handling Unit AH-30 The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)and that the assessments were accurate and complete. When licensee personnel performed emergent work, the inspectors verified that the licensee personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of four
- (4) maintenance risk assessments and emergent work control inspection samples as defined in Inspection
Procedure 71111.13-05.
b. Findings
No findings were identified.
1R15 Operability Evaluations
a. Inspection Scope
The inspectors reviewed the following issues:
On July 26, 2010, operability evaluation related to the jacket water circuit pump pressure indicators EGCI IPI and 30021B and 3002B On August 9, 2010, operability evaluation related the number 1 dry cooling tower sump discharge check valve back leakage On August 25, 2010, operability evaluation related to the over-pressurization of the chemical volume control pump Train B suction line The inspectors selected these potential operability issues based on the risk-significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and Updated Final Safety Analysis Report to the licensee personnel's evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors also reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of three
- (3) operability evaluations inspection samples as defined in Inspection Procedure 71111.15-04
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the following post-maintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional
capability: On July 28, 2010, repacked, inspected and lubricated couplings on the Train B charging pump on July 27, 2010 and performed breaker work and pressure switch calibrations for the B charging pump On August 23, 2010, calibrated emergency feedwater flow control valve (EFW-224A)
On July 7, 2010, replaced positioner for the letdown heat exchanger temperature control valve (CC-636)
On July 15, 2010, replaced relay card on the number 2 steam generator low pressure plant protection system channel D On September 15, 2010, replaced the reactor trip breaker number 7 following a failed pre-installation test On September 28, 2010, performed motor operated valve maintenance activities on the emergency feedwater steam supply valve (MS-401A) for the train AB emergency feedwater steam driven pump The inspectors selected these activities based upon the structure, system, or component's ability to affect risk. The inspectors evaluated these activities for the following (as applicable):
The effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed Acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate
The inspectors evaluated the activities against the technical specifications, the Updated Final Safety Analysis, 10 CFR Part 50 requirements, the licensee's procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them in the corrective action program and that the problems were being corrected commensurate with their importance to safety. Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of six
- (6) post-maintenance testing inspection samples as defined in Inspection Procedure 71111.19-05.
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors reviewed the Updated Final Safety Analysis Report, procedure requirements, and technical specifications to ensure that the six surveillance test activities listed below demonstrated that the systems, structures and/or components being tested were capable of performing their intended safety functions. The inspectors either observed or reviewed test data to verify that the significant surveillance test attributes were adequate to address the following: Preconditioning Evaluation of testing impact on the plant Acceptance criteria Test equipment Procedures Jumper/lifted lead controls Test data Testing frequency and method demonstrated technical specification operability Test equipment removal Restoration of plant systems Fulfillment of ASME Code requirements Updating of performance indicator data Engineering evaluations, root causes, and bases for returning tested systems, structures, and components not meeting the test acceptance criteria were correct Reference setting data Annunciators and alarms setpoints The inspectors also verified that licensee personnel identified and implemented any needed corrective actions associated with the surveillance testing activity. On July 20, 2010, scheduled surveillance of the operability for the containment cooling fans (OP-903-037)
On July 23, 2010, scheduled surveillance of the operability for the Train B of the low pressure safety inspection pump (OP-903-030)
On July 26, 2010, scheduled surveillance of the operability for the Train B emergency diesel generator (OP-903-068)
On July 28, 2010, scheduled surveillance of the operability for the Train B emergency feedwater pump (OP-903-046) - inservice test On July 7, 2010, surveillance testing of the operability for the letdown heat exchanger temperature control Valve CC-636 (OP-903-118)
On Sept 9, 2010, scheduled surveillance of the operability for the Train A emergency diesel generator (OP-903-115)
These activities constitute completion of six
- (6) surveillance testing inspection samples as defined in Inspection Procedure 71111.22-05. Specific documents reviewed during this inspection are listed in the attachment.
b. Findings
No findings were identified. Cornerstone: Emergency Preparedness
1EP2 Alert Notification System Testing
a. Inspection Scope
The inspectors discussed with licensee staff the operability of offsite siren emergency warning systems and backup alerting methods to determine the adequacy of licensee methods for testing the alert and notification system in accordance with 10 CFR Part 50, Appendix E. The licensee
=s alert and notification system testing program was compared with criteria in NUREG-0654, ACriteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,@ Revision 1; FEMA Report REP-10, A Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants
@; and the licensee
=s current FEMA-approved alert and notification system design report, "Updated Final Report, Alert Notification System, Waterford-3 Steam Electric Station," November 2009, Revision 6. The specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of one
- (1) sample as defined in Inspection
Procedure 71114.02-05.
b. Findings
No findings were identified.
1EP3 Emergency Response Organization Augmentation Testing
a. Inspection Scope
The inspectors discussed with licensee staff the operability of primary and backup systems for augmenting the on-shift emergency response staff to determine the adequacy of licensee methods for staffing emergency response facilities in accordance with their emergency plan. The inspectors reviewed the results of seven pager response tests and two tests of the backup emergency response organization paging system. The inspectors evaluated the licensee
=s ability to staff the emergency response facilities in accordance with the licensee's emergency plan and the requirements of 10 CFR Part 50, Appendix E. The specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of one
- (1) sample as defined in Inspection Procedure 71114.03-05.
b. Findings
No findings were identified.
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
The inspectors reviewed five evaluations of changes to the licensee's emergency plan and emergency plan implementing procedures. The evaluations were compared to the criteria of NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, and to the standards in 10 CFR 50.47(b) to determine if the evaluations adequately implemented the requirements of 10 CFR 50.54(q). These reviews were not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, these document revisions are subject to future inspection. The specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of one
- (1) sample as defined in Inspection Procedure 71114.04-05.
b. Findings
No findings were identified.
1EP5 Correction of Emergency Preparedness Weaknesses and Deficiencies
a. Inspection Scope
The inspectors reviewed the licensee
=s corrective action program requirements in Procedure NMM-EN-LI, "Corrective Actions," Revision 15. The inspectors reviewed summaries of 100 corrective action program documents assigned to the emergency
preparedness department and emergency response organization between November 2008, and June 2010, and selected nine for detailed review against the program requirements. The inspectors evaluated the response to the corrective action requests to determine the licensee
=s ability to identify, evaluate, and correct problems in accordance with the licensee program requirements, planning standard 10 CFR 50.47(b)(14), and 10 CFR Part 50, Appendix E. The inspectors also reviewed licensee self-assessments, drill reports, audits, and after-action reports to determine whether the licensee was identifying weaknesses and deficiencies in the emergency preparedness program. The specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of one
- (1) sample as defined in Inspection Procedure 71114.05-05.
b. Findings
No findings were identified.
1EP6 Drill Evaluation
a. Inspection Scope
The inspectors evaluated the conduct of an emergency drill on August 10, 2010, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the Simulator Control Room to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended a licensee's drill critique to compare any inspector-observed weakness with those identified by the licensee's staff in order to evaluate the critique and to verify whether the staff was properly identifying weaknesses and entering them into the corrective action program. As part of the inspection, the inspectors reviewed the drill package and other documents listed in the
attachment.
These activities constitute completion of one
- (1) simulator drill evaluation inspection sample as defined in Inspection Procedure 71114.06-05.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Data Submission Issue
a. Inspection Scope
The inspectors performed a review of the data submitted by the licensee for the third quarter 2010 performance indicators for any obvious inconsistencies prior to its public release in accordance with Inspection Manual Chapter 0608, "Performance Indicator
Program."
This review was performed as part of the inspectors normal plant status activities and, as such, did not constitute a separate inspection sample.
b. Findings
No findings were identified.
.2 Drill/Exercise Performance (EP01)
a. Inspection Scope
The inspectors sampled licensee submittals for the Drill and Exercise Performance, performance indicator for the period April 2009 through April 2010. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, was used. The inspectors reviewed the licensee's records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the Nuclear Energy Institute guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the performance indicator; assessments of performance indicator opportunities during pre-designated control room simulator training sessions, performance during the 2009 biennial exercise, and performance during other drills.
These activities constitute completion of the drill/exercise performance sample as defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
.3 Emergency Response Organization Drill Participation (EP02)
a. Inspection Scope
The inspectors sampled licensee submittals for the Emergency Response Organization Drill Participation performance indicator for the period April 2009 through April 2010. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in Nuclear Energy Institute
Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, was used. The inspectors reviewed the licensee's records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the Nuclear Energy Institute guidance.
Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the performance indicator, rosters of personnel assigned to key emergency response organization positions, and exercise participation records.
These activities constitute completion of the emergency response organization drill participation sample as defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
.4 Alert and Notification System (EP03)
a. Inspection Scope
The inspectors sampled licensee submittals for the Alert and Notification System performance indicator for the period April 2009 through April 2010. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, was used.
The inspectors reviewed the licensee's records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the Nuclear Energy Institute guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the performance indicator and the results of periodic alert notification system operability tests.
These activities constitute completion of the alert and notification system sample as defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
.5 Mitigating Systems Performance Index - High Pressure Injection Systems (MS07)
a. Inspection Scope
The inspectors sampled licensee submittals for the mitigating systems performance index - high pressure injection systems performance indicator for the period from the
second quarter 2009 through the second quarter 2010 to determine the accuracy of the performance indicator data reported during those periods. The inspectors used definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6. The inspectors reviewed the licensee's operator narrative logs, issue reports, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports for the period of March 2009 through June 2010.to validate the accuracy of the submittals. The inspectors reviewed the mitigating systems performance index component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance.
The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.
These activities constitute completion of one
- (1) mitigating systems performance index high pressure injection system sample as defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
.6 Mitigating Systems Performance Index - Heat Removal System (MS08)
a. Inspection Scope
The inspectors sampled licensee submittals for the mitigating systems performance index - heat removal system performance indicator for the period from the second quarter 2009 through the second quarter 2010 to determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6. The inspectors reviewed the licensee's operator narrative logs, issue reports, event reports, mitigating systems performance index
derivation reports, and NRC integrated inspection reports from the second quarter 2009 through the second quarter 2010 to validate the accuracy of the submittals. The inspectors reviewed the mitigating systems performance index component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.
These activities constitute completion of one
- (1) mitigating systems performance index heat removal system sample as defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
.7 Mitigating Systems Performance Index -
Residual Heat Removal System (MS09)
a. Inspection Scope
The inspectors sampled licensee submittals for the mitigating systems performance index - residual heat removal system performance indicator for the period from the
second quarter 2009 through the second quarter 2010 to determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6. The inspectors reviewed the licensee's operator narrative logs, issue reports, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports for the period from the second quarter 2009 through the second quarter 2010 to validate the accuracy of the submittals. The inspectors reviewed the mitigating systems performance index component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.
These activities constitute completion of one
- (1) mitigating systems performance index residual heat removal system sample as defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
4OA2 Identification and Resolution of Problems
.1 Routine Review of Identification and Resolution of Problems
a. Inspection Scope
As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensee's corrective action program at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. The inspectors reviewed attributes that included the complete and accurate identification of the problem; the timely correction, commensurate with the safety significance; the evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews; and the classification, prioritization, focus, and timeliness of corrective actions. Minor issues entered into the licensee's corrective action program because of the inspectors observations are included in the attached list of documents reviewed.
These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure, they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.
b. Findings
No findings were identified.
.2 In-depth Review of Operator Workarounds
a. Inspection Scope
During a review of items entered in the licensee's corrective action program, the inspectors reviewed operator workarounds and burdens. The inspectors considered the following during the review of the licensee's actions:
- (1) complete and accurate identification of problems in a timely manner;
- (2) evaluation and disposition of operability/reportability issues;
- (3) consideration of extent of condition, generic implications, common cause, and previous occurrences;
- (4) classification and prioritization of the resolution of the problem;
- (5) identification of root and contributing causes of the problem;
- (6) identification of corrective actions; and
- (7) completion of corrective actions in a timely manner.
These activities constitute completion of one
- (1) in-depth problem identification and resolution samples as defined in Inspection Procedure 71152-05.
b. Findings
No findings were identified.
4OA3 Event Follow-up
.1 (Closed) Licensee Event Report (LER) 05000382/2008002-00, Inoperable Steam Generator Narrow Range Level Channels
On May 23, 2008, the licensee identified that one transmitter for Steam Generator No. 1 and one transmitter for Steam Generator No. 2 were inoperable during a previous cycle of operation and the associated technical specification of limiting condition for operation had not been entered. The licensee determined that the condition occurred due to an inadequate procedure because the procedure did not provide sufficient detail to assure that proper manipulations of valves and venting of the sensing lines occurred after installation of the steam generator narrow range transmitters. These transmitters are used for trip input into the plant protective system for the steam generator narrow range level. Upon discovery of this condition, both steam generators' transmitters were calibrated during the following refueling cycle, thus restoring the steam generator narrow range channels back to an operable status. This licensee-identified finding involved a violation of technical specification Table 3.3-1. The enforcement aspects of the violation are discussed in Section 4OA7. This licensee event report is closed is closed.
.2 (Closed) Licensee Event Report (LER) 05000382/2008004-00, Loose Intercell Connecting Bolts on 125 Vdc Station Battery
On September 3, 2008, the licensee declared the B train 125 Vdc station battery inoperable due to a low voltage condition. Upon further investigation, the licensee identified a loose battery connection of two intercell connecting bolts for battery cells 57 and 58. Operators immediately tightened the bolts and verified the inter-cell resistance.
The licensee concluded that the most likely cause of the loose connection was that the bolts were left loose during the replacement of the battery cell 56, performed on May 24, 2008. The licensee determined that the cause of the condition was a failure to maintain plant equipment status control due to a lack of specific work instructions and a lack of work order documentation of the intercell connectors that were loosened or removed during the May 24, 2008 maintenance activity. This issue and its associated notice of violation were discussed in NRC Inspection Report 05000382/2009008 and Supplemental Inspection Report 05000382/2010007. The licensee documented this issue in Condition Report CR-WF3-2008-04179. This licensee event report is closed.
.3 (Closed) Licensee Event Report (LER) 05000382/2008004-01, Loose Intercell Connecting Bolts on 125 Vdc Station Battery
This licensee event report is the revised report for the above mention loose battery connection of two intercell connecting bolts for battery cells 57 and 58. This issue and its associated notice of violation were discussed in NRC Inspection Report 05000382/2009008 and Supplemental Inspection Report 05000382/2010007. The licensee documented this issue in Condition Report CR-WF3-2008-04179. This licensee event report is closed.
4OA6 Meetings
Exit Meeting Summary
On July 1, 2010, the inspectors presented the results of the onsite inspection of the licensee's emergency preparedness program to Mr. J. Kowalewski, Vice President, and other members of the licensee's staff. The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
On September 16, 2010, the inspectors briefed Mr. D. Vincent and other members of the licensee's staff of the results of the licensed operator requalification program inspection. The licensee representatives acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified. On October 1, 2010, the resident inspectors presented the inspection results to Mr. J. Kowalewski, Vice President, and other members of the licensee's staff. The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
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 meet the criteria of the NRC Enforcement Policy, for being dispositioned as a non-cited violation.
On May 23, 2008, the licensee identified that one transmitter for Steam Generator No. 1 and one transmitter for Steam Generator No. 2 were inoperable during a previous cycle of operation with the associated technical specification of limiting condition for operation had not been entered. Specifically, the licensee operable with one less than the total number of channels required for startup or power operations without placing the channel in bypass or a trip condition within one hour. This was a violation of Technical Specification Table 3.3-1. The licensee determined that the cause was an inadequate procedure that did not provide enough detail to assure proper valve manipulation and venting to properly calibrate the transmitters. The licensee documented this issue in Condition Report CR-WF3-2008-02107. The corrective actions included enhancing training for temporary outage workers on how to properly calibrate the equipment, revising calibration procedures to provide specifics on appropriate set-up of sensing lines and to identify other reference leg level transmitter calibration procedures which are inadequate. This finding is more than minor because it is associated with the procedure quality attribute of the Mitigating System Cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). This finding was considered to have very low safety significance (Green) after using NRC Manual Chapter 0609, Phase 1 screening worksheet under the Mitigation Systems Cornerstone.
This licensee-identified finding involved a violation of Technical Specification 3.3.1, Reactor Protective Instrumentation.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Entergy Personnel
- C. Arnone, General Manager, Plant Operations
- C. Alday, Manager, System Engineering
- E. Begley, Senior Engineer, Programs and Components
- D. Boan, Supervisor, Radiation Protection
- E. Brauner, Supervisor, System Engineering
- B. Briner, Technical Specialist IV, Programs and Components
- A. Buford, Engineer II, System Engineering
- K. Cook, Manager, Operations
- G. Fey, Manager, Emergency Preparedness
- C. Fugate, Assistant Manager, Operations
- M. Haydel, Supervisor, Programs and Components
- J. Hornsby, Manager, Chemistry
- J. Kowalewski, Site Vice President
- H. Landeche, Jr., Senior Technician, Instruments and Controls
- B. Lanka, Manager, Design Engineering
- B. Lindsey, Manager, Maintenance
- M. Mason, Senior Licensing Specialist, Licensing
- W. McKinney, Manager, Corrective Action and Assessments
- R. Murillo, Acting Director, Nuclear Safety Assurance
- K. Nichols, Director, Engineering
- A. Piluti, Manager, Radiation Protection
- J. Pollack, Engineer, Licensing
- T. Qualantone, Manager, Plant Security
- W. Renz, Director, Emergency Preparedness, Entergy Operations, Inc.
- W. Steeleman, Acting Manager, Licensing
- J. Williams, Senior Licensing Specialist, Licensing
Other Personnel
- J. Polk, Homeland Security Coordinator, St. Charles Parish Louisiana Department of Homeland Security and Emergency Preparedness
NRC Personnel
- M. Davis, Senior Resident Inspector
- D. Overland, Resident Inspector
Attachment
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Closed
LER Inoperable Steam Generator Narrow Range Level
Channels (4OA3)
LER Lose Intercell Connecting Bolts on 125 Vdc
Station Battery (4OA3)
LER Lose Intercell Connecting Bolts on 125 Vdc Station Battery Rev. 1 (4OA3)