IR 05000382/1996099

Revised Plant Support Section of SALP Rept 50-382/96-99

ML20137C214
Person / Time
Site:	Waterford
Issue date:	03/17/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20137B600	List: IR 05000382/1996099 ML20137B594
References
50-382-96-99, NUDOCS 9703240183
Download: ML20137C214 (1)

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l PLANT SUPPORT Overall safety performance in the plant support area during this assessment period was determined to be good. While the licensee maintained an appropriate focus on safety-related issues, performance declined in the radiological controls and security areas, and inconsistencies were identified with the implementation of otherwise strong programs for emergency preparedness and fire protection. A number of corrective actions have been initiated to re-establish the performance standards of the past, but their effectiveness had yet to be determine l i

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Generally, good performance was noted in the radiological controls area. An appropriately trained and qualified staff was maintained. The radiation protection program remained sound, but declined from the previous performance level. Problems were noted with material and contamination controls and worker adherence to radiological control 1 requirements. The goals for skin and clothing contamination events were not met during the 1995 refueling outage. Nevertheless, the 3-year average exposure at the site was better than the national average for pressurized water reactors. The effectiveness of the l ALARA program was good but inconsistent and did not meet management expectations in j several cases. Conversely, quality assurance audits were performance-based, included l specialists from outside the site, and were part of the licensee's self-improvement effort The emergency preparedness program continued to be an overall strength. Actual events were correctly classified and offsite agency notifications were timely. Quality assurance audits, management controls, and self-critiques were effective. However, there were several exceptions to the superior indicators typical of past performance. Although good performance was observed in all response facilities during the biennial exercise, an exercise weakness associated with communications problems was identified and two poor emergency planning practices at the emergency operations facility were noted. Finally, during the annual program review, declaration of a General Emergency was delayed because two operating crews had difficulty diagnosing fuel integrity statu Performance in the security area was good but inconsistent. As a result of the preparations for the Operational Safeguards Response Evaluation, coordination between the security and operations organizations improved. Significant changes were made within the management structure of the security organization, partly in response to daily operational and morale issues, such as those associated with the conduct of fire watches and the differentiation of duties between armed and unarmed officers. Deficiencies were also noted in the implementation of the access authorization program, the identification of degraded lighting conditions, and the establishment of compensatory measures. White, overall, there was a decline in security during this assessment period, there was evidence of improvement in the latter part of this assessment perio The fire protection program was found to be effective. The transition to the updated fire protection system went well; however, examples of inconsistent and questionable conduct ]

of fire watch rounds detracted from the overall performance. Housekeeping remained at an acceptable level. While several problems were noted early in the assessment period and ;

during outage conditions, performance improved and was considered very good during .

normal plant operating condition )

i The performance rating in the plant support area is Category l

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l 9703240183 970317 I PDR ADOCK 05000382 G PDR

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p i n auc m a=.iam Operations

Q W3F1-97-0012 A4.05 PR February 21,1997 .. m:

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U.S. Nuclear Regulatory Commission pg 2 4997 ATTN: Document Control Desk Washington, D.C. 20555 b -

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M Offl Subject: Waterford 3 SES Docket No. 50-382 License No. NPF-38 Reply to Systematic Assessment Licensee Performarice (SALP)

Report 50-382/96-99 Gentlemen:

By letter dated January 6,1997, the Nuclear Regulatory Commission (NRC)

requested that Entergy Operations, Inc. provide written comments to address weaknesses in the Engineering functional area. The weaknesses are documented in the NRC's SALP report that covers Waterford 3 performance for the period April 30, 1995, through November 30,1996. Enclosed (see Attachment 1) is Waterford 3's response to that reques Your assessment of Waterford 3 reflects both a decline in our performance and a rebaselining of performance criteria. Although the issues identified by Waterford 3 and the NRC during the SALP period are well understood and addressed, we recognize that the plant's overall performance was unacceptable. That performance

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did not reflect the expectations of Entergy or the NRC.

Waterford 3 is committed to continuous improvement. To that end, we will continue to identify, correct and preclude the recurrence of adverse conditions. We will vigorously pursue improvements in all functiona! area For example, in the Operations area, we have taken aggessive steps to address identified weaknesses such as procedural adherence. Operations is committed to enhancing their role as leaders and owners of the plant. Training continues to be ha b r 7 - O'T ~7 l

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i Reply to SALP Report 96-99 l

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W3F1-97-0012 Page 2 February 21,1997 l

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a strong point for Operations. Organizational changes are being implemented to l improve functionality and responsiveness. Furthermore, Operations will better utilize I self assessments to assist in the discovery of plant problems and in the bounding of plant issue l l

In the Maintenance area, we have developed a well-trained and competent staf That staff is aggressively taking action to address weaknesses in human i performance and procedural compliance on a broad scale. Maintenance will utilize !

INPO training in Human Performance and implement a task force to determine the )

root cause(s) of procedural compliance issues. We agree that our Maintenance !

backlogs are high but well controlled. However, we intend to use additional resources and overtime to reduce those backlogs. Design Engineering now has the responsibility for the IST plan. A comprehensive review of ASME class 1,2, and 3 '

pumps and valves has been performed to ensure appropriate valves are in the pla l In addition, procedural controls have been implemented to ensure consistency between the IST and basis document In the Plant Support Area, Waterford concurs with the assessment of its performance with the exception of your characterization that the 3-year average radiation i exposure was at the national average. Waterford's three year average radiation exposure is better than approximately 70% of other operating domestic PWR plant l

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Your staff acknowledged that fact during the SALP public meeting. Waterford 3 has taken aggressive steps to address weaknesses identified in the SALP report and to continuously improve performance in this area. Enhancements in training, organization and processes have been made to strengthen personnel and department performance Currently, Waterford 3 has an aggressive self assessment schedule. These assessments will be more critical and intrusive and will better assist all functional areas in reaching higher performance levels. Finally, we believe that although our performance has improved, we hold people to higher standards of performance. The.-

Timeless Principles and "True North" goals that have been set at Waterford 3 are the foundr. tion upon which continuous improvement will be mad .

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Reply to SALP Report 96-99 W3F1-97-0012 Page 3

. February 21,1997 If you have any questions concerning this letter or the attached response, please j contact Tim Gaudet at (504) 739-6666.

! Very truly yours, t

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T.J. Gaudet Acting - Director i Nuclear Safety & Regulatory Affairs TJG/GCS/WDM/tjs Attachment

cc: zLJ Callan (NRC Region IV)

C.P. Patel (NRC-NRR)

R.B. McGehee

> N.S. Reynolds NRC Resident inspectors Office i

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Attachment 1 to >

W3F1-97-0012 b' Pcge 1 of 2 b

j Waterford 3 accepts the finding of the NRC in the Engineering section of the SALP

! report and acknowledges that significant work is ahead of us. Action plans, l j organizational changes, resource additions, and budgets are being developed to 1

ensure that the implementation is appropriately integrated to achieve the expected results. Our immediate challenge is to further develop and sustain the high level of

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questioning attitude, work down the backlogs (focusing on the highest priority items ,

first), and simultaneously embark on some major engineering program i improvements.

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Waterford 3 Engineering recognizes the need to aggressively identify problems, to l thoroughly bound them, and to solve them the first time. As a result of initiatives implemented in early 1996, Engineering directly initiated, or indirectly participated in, 11 major assessments. Engineering is actively striving to minimize operator workarounds, long standing or repetitive temporary alterations, and compensatory actions. A prioritized modification list has resulted in approximately 40 planned modifications for RF0 Waterford 3 is committed to licensing and design basis fidelity. It should be emphasized that Waterford's basic design is sound and provides opportunities to increase our confidence in its overall safety and reliability. Major programs are planned for the FSAR and design basis documents that will focus on retrieval, confirming assumptions, eliminating inconsistencies, preserving margin, and recapturing original design margin where required. Improved Technical Specification and IST programs are in progress. The challenge is to integrate these various actions, including FSAR review, improved Tech Specs, and 50.54(f) commitments, to get prompt result Another result of recent initiatives is changes that have been implemented to improve the quality of information provided to the control room. Engineering interface with the control room is more rigorous and formal. Engineering inputs are independently reviewed and treated within the design control progra Rigor in the control and use of assumptions and inputs has been tightened so that engineering outputs have appropriate documented bases. The technical review process has been improved and supervisors have been charged with the responsibility to maintain standards for quality, rigor, and bases of engineering ,

evaluations. Refresher training has been given to all engineering staff qualified to '

perform 10CFR50.59 evaluations. The Design Review Committee has been implemented to provide ongoing oversight and assessment to ensure standards for performance are being met and to identify areas of additional improvement in a multi-discipline settin .

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