IR 05000382/2006003
| ML062300336 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/18/2006 |
| From: | Graves D N NRC/RGN-IV/DRP/RPB-E |
| To: | Venable J E Entergy Operations |
| References | |
| EA-06-192 IR-06-003 | |
| Preceding documents: |
|
| Download: ML062300336 (38) | |
Text
August 18, 2006
EA-06-192Joseph E. VenableVice President Operations Waterford 3 Entergy Operations, Inc.
17265 River Road Killona, LA 70066-0751
SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATEDINSPECTION REPORT 05000382/2006003 AND NOTICE OF VIOLATION
Dear Mr. Venable:
On July 7, 2006, the NRC completed an inspection at your Waterford Steam Electric Station,Unit 3. The enclosed report documents the inspection findings, which were discussed on July 11, 2006, with Mr. B. Williams, Director, Engineering, and other members of your staff.This inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your license.
Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel.Based on the results of this inspection, the NRC has identified one issue that was evaluatedunder the risk significance determination process as having very low safety significance (Green). The NRC has also determined that a violation is associated with this issue. Theviolation was evaluated in accordance with the NRC Enforcement Policy. The currentEnforcement Policy is included on the NRC's Web site at www.nrc.gov; select What We Do,Enforcement, then Enforcement Policy. The 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 because your staff failed to restore compliance within a reasonable time after the deficient condition was identified. You are required to respond to this letter and should follow the instructions specified in theenclosed Notice when preparing your response. The NRC will use your response, in part, todetermine whether further enforcement action is necessary to ensure compliance with regulatory requirements.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosures, and your response will be made available electronically for public inspection in theNRC Public Document Room or from the Publicly Available Records (PARS) com ponent ofNRC'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).
Entergy Operations, Inc.-2-Should you have any questions concerning this inspection, we will be pleased to discuss themwith you.
Sincerely,/RA/
David N. Graves, ChiefProject Branch E Division of Reactor ProjectsDocket: 50-382License: NPF-38
Enclosure:
1. Notice of Violation 2. NRC Inspection Report 050000382/2006003
Entergy Operations, Inc.-3-cc w/enclosure:Senior Vice President and Chief Operating Officer Entergy Operations, Inc.
P.O. Box 31995 Jackson, MS 39286-1995Vice President, Operations SupportEntergy Operations, Inc.
P.O. Box 31995 Jackson, MS 39286-1995Wise, Carter, Child & Caraway P.O. Box 651 Jackson, MS 39205General Manager, Plant OperationsWaterford 3 SES Entergy Operations, Inc.
17265 River Road Killona, LA 70066-0751Manager - Licensing ManagerWaterford 3 SES Entergy Operations, Inc.
17265 River Road Killona, LA 70066-0751ChairmanLouisiana Public Service Commission P.O. Box 91154 Baton Rouge, LA 70821-9154Director, Nuclear Safety & Regulatory Affairs Waterford 3 SES Entergy Operations, Inc.
17265 River Road Killona, LA 70066-0751Richard Penrod, Senior Environmental Scientist Office of Environmental Services Northwestern State University Russsell Hall, Room 201 Natchitoches, LA 71497 Entergy Operations, Inc.-4-Parish President St. Charles Parish
P.O. Box 302 Hahnville, LA 70057Winston & Strawn LLP1700 K Street, N.W.
Washington, DC 20006-3817ChairpersonDenton Field Office Chemical and Nuclear Preparedness and Protection Division Office of Infrastructure Protection Preparedness Directorate Dept. of Homeland Security 800 North Loop 288 Federal Regional Center Denton, TX 76201-3698 Entergy Operations, Inc.-5-Electronic distribution by RIV:Regional Administrator (BSM1)DRP Director (ATH)DRS Director (DDC)DRS Deputy Director (RJC1)Senior Resident Inspector (GFL1)Branch Chief, DRP/E (DNG)Senior Project Engineer, DRP/E (VGG)Team Leader, DRP/TSS (RLN1)RITS Coordinator (KEG)Only inspection reports to the following:DRS STA (DAP)J. Lamb, OEDO RIV Coordinator (JGL1)ROPreports WAT Site Secretary (AHY)SUNSI Review Completed: __DNG__ ADAMS: Yes G No Initials: _DNG___ Publicly Available G Non-Publicly Available G Sensitive Non-SensitiveR:\_REACTORS\_WAT\2006\WT2006-03RP-GFL.wpd SRI:DRP/EDRS/EB1C:DRS/PSBC:DRS/EB2C:DRS/OBGFLarkinJAClarkMPShannonLJSmithATGodyE-DNGraves/RA//RA//RA/VGGaddy for 8/18/068/14/06 8/15/06 8/15/068/15/06C:ACESD:DRPC:DRP/EKSFullerATHowellDNGravesGMVasquez for/RA//RA/ 8/18/068/18/06 8/18/06OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax Enclosure 1-1-NOTICE OF VIOLATIONEntergy Operations, Inc.Docket No. 50-382 Waterford Steam Electric Station, Unit 3License No. NPF-38 EA-06-192During an NRC inspection completed on July 7, 2006, a violation of NRC requirements wasidentified. In accordance with the NRC Enforcement Policy, the violation is listed below: 10 CFR 50, Appendix B, Criterion III, "Design Control," requires, in part, that applicableregulatory requirements and the design basis for systems to which Appendix B appliesare correctly translated into specifications, procedures, and instructions. The Final Safety Analysis Report requires that the diesel generator air start system be capable ofproviding sufficient air capacity to start each diesel generator a minimum of five times. Contrary to the above, the licensee failed to translate into specifications, procedures,and instructions the design criteria for the diesel generator air start system. Thisresulted in the failure to maintain each diesel generator air receiver capable of starting the diesel engine five times as required since being identified in September 2003.
This violation is associated with a Green SDP finding.Pursuant to the provisions of 10 CFR 2.201, Entergy Operations, Inc. is hereby required tosubmit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Region IV, and a copy to the NRC Resident Inspector at the facility that is thesubject 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-06-192" and should include for the violation: (1) the reason for the violation, or, if contested, the basisfor 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 to avoid further violations, and (4)the date when full compliance will be achieved. Your response may reference or includeprevious 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, withthe basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001. Because your response will be made available electronically for public inspection in the NRCPublic Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it shouldnot 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 Enclosure 1-2-necessary to provide an acceptable response, then please provide a bracketed copy of yourresponse that identifies the information that should be protected and a redacted copy of yourresponse that deletes such information. If you request withholding of such material, you mustspecifically 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 willcreate 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 workingdays. Dated this 18 day of August 2006 Enclosure 2-1-U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket No.:50-382 License No.:NPF-38 Report No.:05000382/2006003 Licensee:Entergy Operations, Inc.
Facility:Waterford Steam Electric Station, Unit 3 Location:Hwy. 18 Killona, Louisiana Dates:April 8 through July 7, 2006 Inspectors:G. F. Larkin, Senior Resident InspectorP. J. Elkmann, Emergency Preparedness Inspector, Operations Branch M. C. Hay, Senior Project Engineer J. C. Kirkland, Project Engineer, Project Branch E D. L. Stearns, Health Physics Inspector, Plant Support Branch T. F. Stetka, Senior Operations EngineerApproved By:David N. Graves, Chief, Project Branch E ATTACHMENTS:Supplemental Information Enclosure 2-2-
SUMMARY OF FINDINGS
IR05000382/2006-003; 04/08/2006-07/07/2006; Waterford Steam Electric Station, Unit 3;Identification and Resolution of ProblemsThe report covered a 3-month period of inspection by resident inspectors, a project engineer,and emergency preparedness, senior operations, and health physics inspectors. The inspectors identified one Green finding. 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 SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeingthe safe operation of commercial nuclear power reactors is described in NUREG-1649,"Reactor Oversight Process," Revision 3, dated July 2000. A.
NRC-Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a Green violation of 10 CFR Part 50,Appendix B, Criterion III, "Design Control." In September 2003, the NRCidentified that the emergency diesel generator starting air system was incapableof supplying sufficient air to start its respective emergency diesel generator a minimum of five times without being recharged. To date, the licensee has failed to take appropriate corrective actions in a timely manner to correct this deficiency and restore compliance. This finding is greater than minor because it affected the mitigating systemcornerstone objective due to the degradation of the design-basis capability of thestarting air system. This finding has a crosscutting aspect in the corrective action component of the problem identification and resolution area because the licensee failed to take actions to address safety issues in a timely manner, commensurate with its safety significance and complexity. The finding was determined to be of very low safety significance because the deficiency did not represent an actual loss of the starting air system safety function per GenericLetter 91-18 guidance. Additionally, surveillance testing has demonstrated thecapability of each diesel generator to start within the required 10 seconds(Section 4OA2).
B.Licensee-Identified Violations
Violations of very low safety significance, which were identified by the licensee havebeen 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 actions are listed in Section 4OA7 of this report.
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REPORT DETAILS
Summary of Plant Status: The plant was operated at approximately 100 percent power fromApril 7 through July 7, 2006, except when reactor power was reduced to approximately 89 percent on May 19, 2006, to conduct high-pressure turbine valve testing.1.REACTOR SAFETYCornerstones: Initiating Events, Mitigating Systems, Barrier Integrity1R01Adverse Weather Protection (71111.01)
.1 Readiness For Seasonal Susceptibilities
a. Inspection Scope
The inspectors completed a review of the licensee's readiness of seasonalsusceptibilities to hurricane force winds and rainfall. The inspectors:
- (1) reviewed plantprocedures, the Updated Final Safety Analysis Report, and Technical Specifications to ensure that operator actions defined in adverse weather procedures maintained the readiness of essential systems;
- (2) walked down portions of the three systems listedbelow to ensure that adverse weather protection features (missile barriers) were sufficient to support operability, including the ability to perform safe shutdown functions;(3) evaluated operator staffing levels to ensure the licensee could maintain the readiness of essential systems required by plant procedures; and
- (4) reviewed thecorrective action program to determine if the licensee identified and corrected problems related to adverse weather conditions. *June 21, 2006: Dry Cooling Towers Sump Pumps*June 22, 2006: Atmospheric Dump Valves
- June 22, 2006: Steam Generator Code SafetiesDocuments reviewed by the inspectors included:
- OP-901-521, Revision 4, Severe Weather and Flooding
- UFSAR, Revision 14
- OP-100-014, Revision 15, Technical Specification and Technical RequirementsCompliance*License Amendment 168 and Safety Evaluation Report to LicenseAmendment 168, September 7, 2000*EC-C99-008, Revision 1, Tornado Missile Analysis
- CR-WF3-2005-3431 2-5-The inspectors completed one sample.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment (71111.04)
.1 Partial Walkdown
a. Inspection Scope
The inspectors:
- (1) walked down portions of the three risk important systems listedbelow and reviewed plant procedures and documents to verify that critical portions of the selected systems were correctly aligned; and
- (2) compared deficiencies identified duringthe walk down to the licensee's Updated Final Safety Analysis Report and corrective action program to ensure problems were being identified and corrected. *April 26, 2006: High Pressure Safety Injection System Train B*May 10, 2006: Emergency Diesel Generating System Train A
- May 16, 2006: Component Cooling Water System Train ADocuments reviewed by the inspectors are listed in the attachment. The inspectorscompleted three samples.
b. Findings
No Findings of significance were identified.
1R05 Fire Protection (71111.05)
.1 Quarterly Inspection
a. Inspection Scope
The inspectors walked down the seven plant areas listed below to assess the materialcondition of active and passive fire protection features and their operational lineup and readiness. The inspectors:
- (1) verified that transient combustibles and hot work activities were controlled in accordance with plant procedures;
- (2) observed the condition of fire detection devices to verify they remained functional;
- (3) observed fire suppression systems to verify they remained functional and that access to manualactuators was unobstructed;
- (4) verified that fire extinguishers and hose stations wereprovided at their designated locations and that they were in a satisfactory condition;
- (5) verified that passive fire protection features (electrical raceway barriers, fire doors, fire dampers, steel fire proofing, penetration seals, and oil collection systems) were in asatisfactory material condition;
- (6) verified that adequate compensatory measures were established for degraded or inoperable fire protection features and that the 2-6-compensatory measures were commensurate with the significance of the deficiency;and
- (7) reviewed the Updated Final Safety Analysis Report to determine if the licensee identified and corrected fire protection problems. *April 17, 2006: Fire Zone RAB 1A, 15, 31, and 32 *April 24, 2006: Fire Zone RAB 1B, 3, 8B, and RAB Roof East
- May 10, 2006: Fire Zone RAB 6, 7A, 7B, 7C, 7D, 8
- May 16, 2006: Fire Zone RAB 31, 32, 36
- June 2, 2006: Fire Zone RAB 2, 15, 36, 37, and 39
- June 13, 2006: Fire Zone RAB 2 and 32
- June 15, 2006: Fire Zone RAB 1E, 6, 8B, and Roof West Documents reviewed by the inspectors are listed in the attachment. The inspectorscompleted seven samples.
b. Findings
No findings of significance were identified.
.2 Annual Inspection
a. Inspection Scope
On June 23, 2006, the inspectors observed a fire brigade drill to evaluate the readinessof licensee personnel to prevent and fight fires, including the following aspects:
- (1) the number of personnel assigned to the fire brigade,
- (2) use of protective clothing,
- (3) use of breathing apparatuses,
- (4) use of fire procedures and declarations of emergency action levels,
- (5) command of the fire brigade,
- (6) implementation of prefire strategies and briefs,
- (7) access routes to the fire and the timeliness of the fire brigade response,
- (8) establishment of communications,
- (9) effectiveness of radio communications,
- (10) placement and use of fire hoses,
- (11) entry into the fire area,
- (12) use of fire fighting equipment,
- (13) searches for fire victims and fire propagation,
- (14) smoke removal,
- (15) use of prefire plans,
- (16) adherence to the dr ill scenario,
- (17) performanceof the postdrill critique, and
- (18) restoration from the fire drill. The licensee simulated afire in the reactor auxiliary building laundry room. Documents reviewed by the inspectors are listed in the attachment. The inspectorscompleted one sample.
b. Findings
No findings of significance were identified.
2-7-1R06Flood Protection Measures (71111.06)
.1 Semi-Annual Internal Flooding
a. Inspection Scope
The inspectors:
- (1) reviewed the Updated Final Safety Analysis Report, the floodinganalysis, and plant procedures to assess seasonal susceptibilities involving internalflooding;
- (2) reviewed the Updated Final Safety Analysis Report and corrective action program to determine if the licensee identified and corrected flooding problems;
- (3) inspected underground bunkers/manholes to verify the adequacy of
- (a) sump pumps,
- (b) level alarm circuits,
- (c) cable splices subject to submergence, and
- (d) drainage for bunkers/manholes;
- (4) verified that operator actions for coping with flooding can reasonably achieve the desired outcomes; and
- (5) walked down the area listed below to verify the adequacy of:
- (a) equipment seals located below the floodline,
- (b) floor and wall penetration seals,
- (c) watertight door seals,
- (d) common drain lines and sumps,
- (e) sump pumps, level alarms, and control circuits, and
- (f) temporary or removable flood barriers. *May 8, 2006: Unit 1, Safeguards Pump Room Train A Documents reviewed by the inspectors are listed in the attachment. The inspectorscompleted one sample.
b. Findings
No findings of significance were identified.
1R07 Heat Sink Performance (71111.07)
a. Inspection Scope
The inspectors reviewed licensee programs, verified performance against industrystandards, and reviewed critical operating parameters and maintenance records for the essential chiller Train A evaporator. The inspectors verified that:
- (1) performance testswere satisfactorily conducted for heat exchangers/heat sinks and reviewed for problems or errors;
- (2) the licensee utilized the periodic maintenance method outlined in ElectricalPower Research Institute NP-7552, "Heat Exchanger Performance Monitoring Guidelines;"
- (3) the licensee properly utilized biofouling controls;
- (4) the licensee's heatexchanger inspections adequately assessed the state of tube cleanliness, and
- (5) the heat exchanger was correctly categorized under the Maintenance Rule. Documents reviewed by the inspectors are listed in the attachment. The inspectorscompleted one sample.
b. Findings
No findings of significance were identified.
2-8-1R11Licensed Operator Requalification Program(71111.11)
a. Inspection Scope
On June 27, 2006, the inspectors observed testing and training of senior reactoroperators and reactor operators to identify deficiencies and discrepancies in the training, to assess operator performance, and to assess the evaluator's critique. The training scenario involved multiple instrumentation failures, loss of Train B charging pump, inadvertent closure of Train A main feed isolation valve, loss of offsite power, and a main steam line break.
Documents reviewed by the inspectors included:
- Simulator Scenario Number E-99 list of events and event objectives
- Operations Procedure OP-902-000, "Standard Post Trip Actions," Revision 10
- Operations Procedure OP-902-003, "Loss of Offsite Power/Loss of ForcedCirculation Recovery," Revision 5*Operations Procedure OP-902-004, "Excess Steam Demand Recover,"Revision 10*Emergency Planning Procedure EP-001-001, "Recognition and Classification ofEmergency Conditions," Revision 20The inspectors completed one sample.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness (71111.12)
a. Inspection Scope
The inspectors reviewed the two maintenance activities listed below to:
- (1) verify theappropriate handling of structure, system, and component performance or conditionproblems;
- (2) verify the appropriate handling of degraded structure, system , andcomponent functional performance;
- (3) evaluate the role of work practices and common cause problems; and
- (4) evaluate the handling of structure, system, and componentissues reviewed under the requirements of the Maintenance Rule, 10 CFR Part 50 Appendix B, and the Technical Specifications. *June 14, 2006: Emergency Diesel Generator A*June 15, 2006: Emergency Diesel Generator Air SystemDocuments reviewed by the inspectors are listed in the attachment. The inspectorscompleted two samples.
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b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
.1 Risk Assessment and Management of Risk
a. Inspection Scope
The inspectors reviewed the assessment activity listed below to verify:
- (1) performanceof risk assessments when required by 10 CFR 50.65 (a)(4) and licensee procedures prior to changes in plant configuration for maintenance activities and plant operations;
- (2) the accuracy, adequacy, and completeness of the information considered in the risk assessment;
- (3) that the licensee recognizes, and/or enters as applicable, the appropriate licensee-established risk category according to the risk assessment results and licensee procedures; and
- (4) the licensee identified and corrected problems related to maintenance risk assessments.*May 10-11, 2006: Planned maintenance activities on emergency dieselgenerator Train ADocuments reviewed by the inspectors are listed in the attachment. The inspectorscompleted one sample.
b. Findings
No findings of significance were identified.
.2 Emergent Work Control
a. Inspection Scope
The inspectors:
- (1) verified that the licensee performed actions to minimize theprobability of initiating events and maintained the functional capability of mitigatingsystems and barrier integrity systems;
- (2) verified that emergent work-related activitiessuch as troubleshooting, work planning/scheduling, establishing plant conditions, aligning equipment, tagging, temporary modifications, and equipment restoration did not place the plant in an unacceptable configuration; and
- (3) reviewed the Updated FinalSafety Analysis Report to determine if the licensee identified and corrected risk assessment and emergent work control problems. *May 17, 2006: During emergent work activities on instrument air Train B Documents reviewed by the inspectors are listed in the attachment. The inspectorscompleted one sample.
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b. Findings
No findings of significance were identified.
1R14 Operator Performance During Nonroutine Evolutions and Events (71111.14)
a. Inspection Scope
The inspectors:
- (1) reviewed operator logs, plant computer data, and/or strip charts forthe evolutions listed below to evaluate operator performance in coping with nonroutineevents and transients;
- (2) verified that operator actions were in accordance with the response required by plant procedures and training; and
- (3) verified that the licensee has identified and implemented appropriate corrective actions associated with personnel performance problems that occurred during the nonroutine evolutions sampled. *April 8, 2006: A hot spot was discovered on Breaker LVDEBKR312A-5BR,B phase lug, due to a poor electrical connection. Breaker LVDEBKR312A-5BR powered portions of Train A emergency core cooling system, containment spray, component cooling water system, main steam system, control room ventilationsystem, and additional safety and nonsafety-related systems. Plant shutdowncontingency plans were developed if maintenance failed to correct the condition within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> because the required valve line-up during maintenance that would divert the reactor coolant pump control bleed off flow to the quench tank, which has a limited capacity, instead of back to the volume control tank to be injected into the reactor coolant system. Maintenance successfully corrected theloose lug condition. See Section
4OA7 for additional details.Documents reviewed by the inspectors are listed in the attachment.
The inspectorscompleted one sample.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations
a. Inspection Scope
The inspectors:
- (1) reviewed plants status documents such as operator shift logs,emergent work documentation, deferred modifications, and standing orders to determine if an operability evaluation was warranted for degraded components;(2) referred to the Updated Final Safety Analysis Report and design-basis documents to review the technical adequacy of licensee operability evaluations;
- (3) evaluatedcompensatory measures associated with operability evaluations;
- (4) determineddegraded component impact on any Technical Specifications;
- (5) used the Significance Determination Process to evaluate the risk significance of degraded or inoperable equipment; and
- (6) verified that the licensee has identified and implemented appropriate corrective actions associated with degraded components.
2-11-*April 20, 2006: Operability evaluation addressing a steam leak of feedwaterValve FW-1841B as described in Condition Report 2006-1177*March 15, 2006: Operability evaluation addressing an identified discrepancyaffecting the pipe stress analysis for component cooling water supply to the safety injection and containment spray pumps as described in Condition Report 2006-756*June 5, 2006: Operability evaluation addressing emergency diesel generatorTrain A million volt-amps-reactive, Mwatt and Phase C current spikes during amonthly surveillance run as described in Condition Report 2006-1660*March 14, 2006: Operability evaluation addressing the feasibility of postfireoperator hot shutdown manual actions in the event of a relay room fire as described in Condition Report 2006-735Documents reviewed by the inspectors are listed in the attachment. The inspectorscompleted four samples.
b. Findings
No findings of significance were identified.
1R17 Permanent Plant Modifications (71111.17)Annual Review
a. Inspection Scope
The inspectors reviewed key affected parameters associated with energy needs,materials/replacement components, timing, heat removal, control signals, equipment protection from hazards, operations, flow paths, pressure boundary, ventilation boundary, structural, process medium properties, licensing basis, and failure modes for the one modification listed below. The inspectors verified that:
- (1) modification preparation, staging, and implementation did not impair emergency/abnormal operatingprocedure actions, key safety functions, or operator response to loss of key safety functions;
- (2) postmodification testing maintained the plant in a safe configuration during testing by verifying that unintended system interactions will not occur, structure, system,and component performance characteristics still meet the design basis, theappropriateness of modification design assumptions, and the modification test acceptance criteria has been met; and
- (3) the licensee has identified and implemented appropriate corrective actions associated with permanent plant modifications. *June 22, 2006: Reroute of essential chiller Train B control power from staticuninterruptible power Supply B to power distribution Panel PDP-391-SB to limit reliability concerns associated with a cable vault or control room fire 2-12-Documents reviewed by the inspectors are listed in the attachment. The inspectorscompleted one sample.
b. Findings
No findings of significance were identified.
1R19 Postmaintenance Testing (71111.19)
a. Inspection Scope
The inspectors selected the four postmaintenance test activities of risk significantsystems or components listed below. For each item, the inspectors:
- (1) reviewed theapplicable licensing basis and/or design-basis documents to determine the safety functions;
- (2) evaluated the safety functions that may have been affected by the maintenance activity; and
- (3) reviewed the test procedure to ensure it adequately tested the safety function that may have been affected. The inspectors either witnessed or reviewed test data to verify that acceptance criteria were met, plant impacts were evaluated, test equipment was calibrated, procedures were followed, jumpers were properly controlled, the test data results were complete and accurate, the test equipment was removed, the system was properly realigned, and deficiencies duringtesting were documented. The inspectors also reviewed the Updated Final Safety Analysis Report to determine if the licensee identified and corrected problems related to postmaintenance testing. *May 11, 2006: Planned maintenance for emergency diesel generator Train A
- May 20, 2006: Emergent maintenance for shield building ventilation fan breakerTrain A *June 15, 2006: Planned maintenance for controlled area ventilati on syst emValve HVR-313B *June 22, 2006: Planned maintenance for control room air handling unit isolationRelay HVCEREL1168ADocuments reviewed by the inspectors are listed in the attachment. The inspectorscompleted four samples.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing (71111.22)
a. Inspection Scope
The inspectors reviewed the Updated Final Safety Analysis Report, procedurerequirements, and Technical Specifications to ensure that the four surveillance activities 2-13-listed below demonstrated that the structures, systems, and components tested werecapable of performing their intended safety functions. The inspectors either witnessed or reviewed test data to verify that the following significant surveillance test attributes were adequate:
- (1) preconditioning;
- (2) evaluation of testing impact on the plant;
- (3) acceptance criteria;
- (4) test equipment;
- (5) procedures;
- (6) jumper/lifted lead controls;
- (7) test data;
- (8) testing frequency and method demonstrated Technical Specification operability;
- (9) test equipment removal;
- (10) restoration of plant systems;(11) fulfillment of ASME Code requirements;
- (12) updating of performance indicatordata;
- (13) engineering evaluations, root causes, and bases for returning tested structures, systems, and components not meeting the test acceptance criteria werecorrect;
- (14) reference setting data; and
- (15) annunciators and alarms setpoints. The inspectors also verified that the licensee identified and implemented any needed corrective actions associated with the surveillance testing. *April 24, 2006: Surveillance Procedure STA-001-001, "Containment Air LockDoor Seal Leakage Test," Revision 4. This surveillance verified that thecontainment air lock door seal leakage is less than an acceptable value.*May 2, 2006: Maintenance Procedure MM-007-033, "IST Safety and ReliefValve Bench Testing and Maintenance," Revision 0. This surveillance verifiedthat the chemical and volume control relief Valve CVC-192A set pressure was correctly set.*May 3, 2006: Surveillance Procedure ME-003-110 "Fire Pump Diesel StartingBattery (Quarterly)," Revision 7. This procedure provided instructions to ensure operability of starting batteries and associated chargers for diesel fire Pump 1.*June 23, 2006: Surveillance Procedure OP-903-046, "Emergency Feed PumpOperability Check," Revision 15. This surveillance verified operability of emergency feedwater Pump A/B.Documents reviewed by the inspectors are listed in the attachment. The inspectorscompleted four samples.
b. Findings
No findings of significance were identified.
Cornerstone:
Emergency Preparedness (EP)1EP1Exercise Evaluation (71114.01)
a. Inspection Scope
The Waterford Unit 3 2005 Biennial Emergency Preparedness Exercise, originallyscheduled for December 7, 2005, was deferred until June 28, 2006, as a result of the impact of Hurricane Katrina (see letter from M. Fields, Project Manager, to J. Venable, Vice President Operations, dated December 13, 2005, ML0534705240). The inspectors reviewed the objectives and scenario for the biennial emergency plan exercise to 2-14-determine if the exercise would acceptably test major elements of the emergency plan. The scenario simulated a tornado in Owner Controlled Area, a ground on an electrical switchgear causing a fire, a failure of both the automatic and manual reactor protection system following damage to a reactor coolant pump, loss of condenser vacuum, failureof two charging pumps, loose parts in a steam generator followed by steam generator tube rupture, fission product barrier failures, core damage, and a radiological release to the environment via an open main steam safety valve, to demonstrate the licensee's capabilities to implement the emergency plan.The inspectors evaluated exercise performance by focusing on the risk-significantactivities of event classification, offsite notification, recognition of offsite dose consequences, and development of protective action recommendations, in the Simulator Control Room and the following dedicated emergency response facilities:*Technical Support Center*Operations Support Center
- Emergency Operations FacilityThe inspectors also assessed recognition of and response to abnormal and emergencyplant conditions, the transfer of decision making authority and emergency function responsibilities between facilities, onsite and offsite communications, protection ofemergency workers, emergency repair evaluation and capability, and the overallimplementation of the emergency plan to protect public health and safety and the environment. The inspectors reviewed the current revision of the facility EmergencyPlan and emergency plan implementing procedures associated with operation of the above facilities and performance of the associated emergency functions. Theseprocedures are listed in the attachment to this report.The inspectors compared the observed exercise performance with the requirements inthe facility Emergency Plan, 10 CFR 50.47(b), 10 CFR 50 Appendix E, and with theguidance in the emergency plan implementing procedures and other federal guidance.The inspectors attended the postexercise critiques in each of the above facilities toevaluate the initial licensee self-assessment of exercise performance. The inspectors also attended a subsequent formal presentation of critique items to plant management. The inspectors completed one sample during the inspection.
b. Findings
No findings of significance were identified.1EP4Emergency Action Level and Emergency Plan Changes (71114.04)
a. Inspection Scope
The inspector performed an in-office review of Revision 20-4 of Emergency PlanImplementing Procedure EP-01-001, "Recognition and Classification of Emergency Conditions," received April 16, 2006. This revision deleted two emergency action levels 2-15-related to site protection, which were redundant to those the licensee implemented inaccordance with NRC Bulletin 2005-002, "Emergency Preparedness and ResponseActions for Security-Based Events."The revision was compared to its previous revision, 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, to NRC Bulletin 2005-002, and to the requirements of 10 CFR 50.47(b) and 50.54(q) to determine if the licensee adequately implemented 10 CFR 50.54(q). This review was not documented in a Safety Evaluation Report and did not constitute approval of licensee changes, therefore these changes are subject to future inspection. The inspector completed one sample during this inspection.
b. Findings
No findings of significance were identified.1EP6Drill Evaluation (71114.06)
a. Inspection Scope
For the one dr ill and simulator-based training evolutions contributing to Drill/ExercisePerformance and Emergency Response Organization Performance Indicators listed below, the inspectors:
- (1) observed the training evolution to identify any weaknesses and deficiencies in classification, notification, and Protective Action Requirements development activities;
- (2) compared the identified weaknesses and deficiencies against licensee-identified findings to determine whether the licensee is properly identifying failures; and
- (3) determined whether licensee performance is in accordance with the guidance of the NEI 99-02, "Voluntary Submission of Performance Indicator Data,"
acceptance criteria. *May 11, 2006: The simulator based drill involving an anticipated transientwithout scram resulting in a site area emergency due to reactor coolant systemleakage greater than available charging pump capacity.Documents reviewed by the inspectors included:
- Simulator Scenario Number E-47 list of events and event objectives
- Operations Procedure OP-902-000, "Standard Post Trip Actions," Revision 10
- Operations Procedure OP-902-002, "Loss of Coolant Accident RecoveryProcedure," Revision 11*Emergency Planning Procedure EP-001-001, "Recognition and Classification ofEmergency Conditions," Revision 20The inspectors completed one sample.
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b. Findings
No findings of significance were identified.2.RADIATION SAFETYCornerstone: Occupational Radiation Safety2OS1Access Control to Radiologically Significant Areas (71121.01)
a. Inspection Scope
This area was inspected to assess the licensee's performance in implementing physicaland administrative controls for airborne radioactivity areas, radiation areas, high radiation areas, and worker adherence to these controls. The inspector used the requirements in 10 CFR Part 20, the Technical Specifications, and the licensee's procedures required by Technical Specifications as criteria for determining compliance.
During the inspection, the inspector interviewed the radiation protection manager,radiation protection supervisors, and radiation workers. The inspector performed independent radiation dose rate measurements and reviewed the following items:*Performance indicator events and associated documentation packages reportedby the licensee in the Occupational Radiation Safety Cornerstone *Controls (surveys, posting, and barricades) of three high radiation areas
- Self-assessments, audits, licensee event reports, and special reports related tothe access control program since the last inspection*Corrective action documents related to access controls
- Radiation work permit (or Radiation exposure permit) briefings and workerinstructions *Posting and locking of entrances to all accessible high dose rate - high radiationareas and very high radiation areas*Radiation worker and radiation protection technician performance with respect toradiation protection work requirements The inspector completed 11 of the required 21 samples.
b. Findings
No findings of significance were identified.
2-17-2OS2ALARA Planning and Controls (71121.02)
a. Inspection Scope
The inspector assessed licensee performance with respect to maintaining individual andcollective radiation exposures as low as reasonably achievable (ALARA). The inspector used the requirements in 10 CFR Part 20 and the licensee's procedures required by Technical Specifications as criteria for determining compliance. The inspector interviewed licensee personnel and reviewed:*Current 3-year rolling average collective exposure
- Site specific trends in collective exposures, plant historical data, and source-termmeasurements*Site specific ALARA procedures
- Interfaces between operations, radiation protection, maintenance, maintenanceplanning, scheduling, and engineering groups *Integration of ALARA requirements into work procedure and radiation workpermit (or radiation exposure permit) documents*Person-hour estimates provided by maintenance planning and other groups tothe radiation protection group with the actual work activity time requirements *Dose rate reduction activities in work planning
- Assumptions and basis for the current annual collective exposure estimate, themethodology for estimating work activity exposures, the intended dose outcome, and the accuracy of dose rate and man-hour estimates *Workers use of the low dose waiting areas
- Records detailing the historical trends and current status of tracked plant sourceterms and contingency plans for expected changes in the source term due to changes in plant fuel performance issues or changes in plant primary chemistry *Source-term control strategy or justifications for not pursuing such exposurereduction initiatives *Specific sources identified by the licensee for exposure reduction actions andpriorities established for these actions, and results achieved against since the last refueling cycle *Radiation worker and radiation protection technician performance during workactivities in radiation areas, airborne radioactivity areas, or high radiation areas *Declared pregnant workers during the current assessment period, monitoringcontrols, and the exposure results 2-18-*Self-assessments, audits, and special reports related to the ALARA programsince the last inspection*Corrective action documents related to the ALARA program and follow-upactivities such as initial problem identification, characterization, and tracking *Effectiveness of self-assessment activities with respect to identifying andaddressing repetitive deficiencies or significant individual deficiencies The inspector completed 9 of the required 15 samples and 8 of the optional samples.
b. Findings
No findings of significance were identified.4.OTHER ACTIVITIES (OA)
4OA1 Performance Indicator Verification
a. Inspection Scope
The inspector sampled licensee submittals for the performance indicators listed belowfor the period from October 2005 through March 2006. To verify the accuracy of the performance indicator data reported during that period, performance indicator definitions and guidance contained in NEI 99-02, "Regulatory Assessment Indicator Guideline,"
Revision 2, were used to verify the basis in reporting for each data element.Occupational Radiation Safety CornerstoneOccupational Exposure Control Effectiveness Performance Indicators Licensee records reviewed included corrective action documentation that identifiedoccurrences in high radiation areas with dose rates greater than 1,000 millirem per hourat 30 centimeters (as defined in Technical Specifications), very high radiation areas (as defined in 10 CFR 20.1003), and unplanned personnel exposures (as defined in NEI 99-02). Additional records reviewed included as low as reasonably achievable records and whole-body counts of selected individual exposures. The inspector interviewed licensee personnel that were accountable for collecting and evaluating the performance indicator data. In addition, the inspector toured plant areas to verify thathigh radiation and very high radiation areas were properly controlled.The inspector completed the required sample
- (1) in this cornerstone.
Public Radiation Safety CornerstoneRadiological Effluent Technical Specification/Offsite Dose Calculation Manual Radiological Effluent Occurrences Licensee records reviewed included corrective action documentation that identifiedoccurrences for liquid or gaseous effluent releases that exceeded performance indicator 2-19-thresholds and those reported to the NRC. The inspector interviewed licenseepersonnel that were accountable for collecting and evaluating the performance indicator
data. The inspector completed the required sample
- (1) in this cornerstone.
b. Findings
No findings of significance were identified.4OA2Identification and Resolution of Problems (71152)
.1 Routine Review of Identification and Resolution of ProblemsThe inspectors performed a daily screening of items entered into the licensee'scorrective action program.
This assessment was accomplished by reviewing condition reports and attending corrective action review and work control meetings. The inspectors:
- (1) verified that equipment, human performance, and program issues were being identified by the licensee at an appropriate threshold and that the issues wereentered into the corrective action program;
- (2) verified that corrective actions were commensurate with the significance of the issue; and
- (3) identified conditions that mightwarrant additional follow-up through other baseline inspection procedures.
.2 Selected Issue Follow-up InspectionIn addition to the routine review, the inspectors selected the one
system listed below fora more in-depth review. The inspectors considered the following during the review ofthe 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. June 17, 2006: Emergency Diesel Generator Starting Air
b. Findings
Introduction.
The inspectors identified a Green violation of 10 CFR Part 50 Appendix B,Criterion III, "Design Control." In September 2003, the NRC identified that theemergency diesel generator starting air system was incapable of supplying sufficient airto start its respective emergency diesel generator a minimum of five times without being recharged. To date, the licensee has failed to take corrective actions in a timely manner to address this deficiency and restore compliance. Discussion. On October 7, 2003, NRC Inspection Report 05000382/2003006documented a violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control,"for failing to maintain each emergency diesel generator starting air receiver pressure capable of starting the diesel engine five times as required by the Updated Final Safety Analysis Report. The inspectors noted that each air receiver was maintained at a 2-20-nominal operating pressure less than the lowest pressure that qualified each receiver tostart the diesel five times. Entergy documented the inadequate diesel generator starting air system capacity as a Generic Letter 91-18 issue, established administrative controlsto manage the nonconformance, and initially decided to resolve the issue by submitting a Technical Specification Change Request to the NRC for approval. The starting airsystem nonconformance was not resolved as scheduled due to licensing departmentpersonnel changes and technical and regulatory issues associated with finalizing the Technical Specification Change Request. To date, Entergy has not submitted a Technical Specification Change Request to the NRC for approval. Procedure EN-LI-108, "Operating License Amendments," states that administrativecontrols do not alleviate the need to revise the Technical Specification and that aTechnical Specification Change Request should be requested in a timely manner, commensurate with its safety significance. Entergy also considered modifying the starting air system to increase the receiveroperating pressure, installing larger air receivers, and providing a calculation to justify afour start capability as a technical justification for an exemption to the Standard ReviewPlan, "9.5.6 Emergency Diesel Engine Starting System," five start requirement. Entergy rejected increasing the receiver operating pressure and installing larger air receivers fortechnical reasons. On January 18, 2006, Entergy performed a starting air system testthat demonstrated the capability of the A2 air receiver to start emergency dieselgenerator Train A four times.
Calculation ECM98-017, "Diesel Generator Starting Air Receiver Pressure Process Limit," analyzed the January 2006 test results and the May 1983 preoperational test results and concluded that the starting air system had afive start capability based on the air mass consumption per start excluding starting airsystem pressure decay between successive starts due to system leakage. Theinspectors reviewed Calculation ECM98-017 and determined, in part, that the systemdid not demonstrate a five start capacity per the Standard Review Plan because
- (1) system air leakage is an integral part of any air start test and its effectsmust be accounted for in the test program;
- (2) Entergy's analysis did not account for changes to the emergency diesel generator rolling resistance to starting during 23 yearsof operation; and
- (3) the starting air system was te sted at 85F, butCalculation ECM98-017 did not account for the reduced air mass in the air receiver at the emergency diesel generator design room temperature of 120F. NRC Inspection Manual, Part 9900, "Operability Determinations and FunctionalityAssessments for Resolution of Degraded and Nonconforming Conditions Adverse to Quality or Safety," provides a standard to disposition degraded and nonconforming conditions. Part 9900 states that a degraded or nonconforming condition should be resolved at the first available opportunity unless an appropriate evaluation justifies a longer completion schedule. Since September 2003 Entergy has failed to either:
- (1) demonstrate a successful five starts capability of the emergency dieselgenerator starting air system;
- (2) change their licensing or design basis to a four startcapability; or
- (3) make effective plant modifications to obtain a five start capacity such asincreasing the starting air receiver set point pressure or increasing the size of the system's air receivers. Entergy has exceeded its established completion dates toresolve this issue several times. These failures constitute a performance deficiency.Analysis. The failure to take prompt corrective measures to reestablish full qualificationof the emergency diesel generator starting air system by some means is a performancedeficiency. This finding is greater than minor because it affected the mitigating system 2-21-cornerstone objective due to the degradation of the design-basis capability of thestarting air system. This finding has a crosscutting aspect in the corrective action component of the problem identification and resolution area because the licensee failed to take actions to address safety issues in a timely manner. The finding was determined to be of very low safety significance because the deficiency did not represent an actual loss of the starting air system safety function. Additionally, surveillance testing hasdemonstrated the capability of each diesel generator to start within the required10 seconds.Enforcement. 10 CFR Part 50, Appendix B, Criterion III, "Design Control," requires, inpart, that The Code of Federal Regulations, Part 50, Appendix B, Criterion III, "DesignControl," requires, in part, that applicable regulatory requirements and the design basisfor systems to which Appendix B applies are correctly translated into into specifications,procedures, and instructions. The Final Safety Analysis Report requires that the diesel generator air start system be capable of providing sufficient air capacity to start eachdiesel generator a minimum of five times. Contrary to the above, the licensee failed to translate into specifications, procedures, and instructions the design criteria for the diesel generator air start system. This resulted in the failure to maintain each dieselgenerator air receiver capable of starting the diesel engine five times as required since September 2003, when the NRC identified that the emergency diesel generator startingair system capacity was inadequate to meet the design basis. The licensee has failed totake corrective actions to resolve the problem and restore compliance with the design basis. As a result, this violation is being cited in accordance with VIA.1.a of the NRC Enforcement Policy. This issue was documented in the licensee's corrective action program as Condition Report CR-WF3-2003-2502 (VIO 50-382/2006003-01, Untimely Actions to Restore Design Basis Compliance of the Emergency Diesel Generator Starting Air System).Documents reviewed by the inspectors are listed in the attachment.
.3 Semiannual Trend Review
a. Inspection Scope
As required by Inspection Procedure 71152, Identification and Resolution of Problems, the inspectors performed a review of the licensee's corrective action program and associated documents to identify trends that could indicate the existence of a moresignificant safety issue. The inspectors' review focused on repetitive equipment issues, but also considered the results of screening the corrective action program, self-assessment reports, control room logs, quality assurance audits, Maintenance Rule assessments, and department self-assessments to determine if additional adverse trends existed. The inspectors compared and contrasted their results with the results contained in Entergy's latest quarterly trend reports. For those areas where trends were documented in the corrective action program, the inspectors verified that Entergy had corrective actions planned or in place to address the trend. The inspectors also evaluated the corrective actions against Entergy's procedural requirements of Procedure LI-102, "Corrective Action Program." The inspectors' review nominally considered the 6-month period of July through December 2005.
2-22-
b. Findings and Observations
No findings of significance were identified. The inspectors concluded that, in general,Entergy had adequately identified trends associated with steam leaks in the steam generator secondary systems.
.4 Radiation Safety
a. Inspection Scope
The inspector evaluated the effectiveness of the licensee's problem identification andresolution process with respect to the following inspection areas:*Access Control to Radiologically Significant Areas (Section 2OS1)*ALARA Planning and Controls (Section 2OS2)
b. Findings
No findings of significance were identified.4OA5Other Activities 1.Implementation of Temporary Instruction TI 2515/165 - Operational Readiness of OffsitePower and Impact on Plant Risk
a. Inspection Scope
The objective of TI 2515/165, "Operational Readiness of Offsite Power and Impact onPlant Risk," was to gather information to support the assessment of nuclear power plant operational readiness of offsite power systems and impact on plant risk. During thisinspection, the inspectors interviewed licensee personnel, reviewed licensee procedures, and gathered information for further evaluation by the Office of Nuclear Reactor Regulation.
b. Findings
No findings of significance were identified.4OA6Meetings, Including Exit
Exit Meeting Summary
.1 On May 19, 2006, the inspector conducted a telephonic exit meeting to present theemergency action level and emergency plan changes inspection results to Mr. J. Lewis,
Manager, Emergency Preparedness, who acknowledged the findings. The inspector confirmed that proprietary information was not provided or examined during the inspection.
2-23-
.2 On June 22, 2006, the inspector presented the ALARA inspection results toMr. J. Venable, Vice President, Nuclear, and other members of the staff who
acknowledged the findings. The inspector confirmed that proprietary information was not provided or examined during the inspection.
.3 On June 30, 2006, the inspectors presented the results of the emergency preparednessexercise inspection to Mr. K. Walsh, General Manager, Plant Operations, and other
members of his staff who acknowledged the findings. The lead inspector confirmed that proprietary information was not provided or examined during the inspection.
.4 On July 11, 2006, the resident inspectors presented the inspection results toMr. B. Williams, Director, Engineering, and other members of management.
Thelicensee 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. 4OA7Licensee Identified ViolationsThe following violation of very low safety significance (Green) was identified by thelicensee and is a violation of NRC requirements which meets the criteria of Section VI ofthe NRC Enforcement Policy, NUREG-1600, for being dispositioned as a noncitedviolation.*10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures andDrawings," requires that work on safety-related structures, systems, andcomponents be completed in accordance with appropriate instructions to ensure the structures, systems, and components will perform satisfactorily when placedin service. Contrary to this requirement, work to land the B phase lead on a 480 VAC molded case circuit breaker was not properly performed and verified in accordance with Testing Procedure ME-007-002, "Molded Case Circuit Breakers." To correct the improperly terminated B phase lead, the licensee entered Technical Specification shutdown action statements that affectedseveral trains of Alpha safety-related equipment. The finding was greater than minor because the finding is associated with a degraded condition that could concurrently influence mitigation equipment and an initiating event. The finding was of very low safety significance because it did not represent an actual event that upset plant stability or challenge critical safety functions, and the affectedstructures, systems, and components were inoperable for less time than theallowed Technical Specification outage time. This deficiency was identified in Entergy's corrective action program as Condition Report CR-WF3-2006-0746.
See Section 1R14 for additional details.ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- S. Anders, Superintendent, Plant Security
- J. Brawley, ALARA Coordinator, Radiation Protection
- L. Dauzat, Operations, Supervisor Radiation Protection
- C. Fugate, Assistant Manager, Operations (Shift)
- B. Goldman, ALARA Refuel Planner, Radiation Protection
- J. Laque, Manager, Maintenance
- J. Lewis, Manager, Emergency Preparedness
- M. Mason, Licensing Representative
- R. Murillo, Manager, Licensing
- O. Pipkins, Senior Staff Engineer, Licensing
- R. Putnam, Manager, Programs and Components
- J. Ridgel, Acting Director, Nuclear Safety Assurance
- R. Peters, Director, Planning and Scheduling
- B. Pilutti, Manager, Radiation Protection
- G. Scott, Licensing Engineer
- J. Venable, Vice President, Operations
- K. Walsh, General Manager, Plant Operations
- B. Williams, Director, Engineering NRC
- D. Graves, Chief, Project Branch E
- J. Keeton, Consultant
- M. Mendoza, Engineering Associate
AttachmentA-2
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened 50-382/2006003-01VIOUntimely Actions to Restore Design Basis Compliance ofthe Emergency Diesel Generator Starting Air System
(Section 4OA2)
LIST OF DOCUMENTS REVIEWED
Section 1RO4: Equipment Alignment (71111.04)ProceduresNUMBERTITLEREVISIONOP-002-003Component Cooling Water System14ME-004-1154.16
- KV G.E. Magna-Blast Breaker12ME-003-3274.16/6.9 KV Magna-Blast Operating MechanismOverhaul 1OP-009-002Emergency Diesel Generator19Miscellaneous DocumentsNUMBERTITLE/SUBJECTREVISIONMNQ6-27NPSH Calculation for the HPSI and CS Pumps4OP-009-008Safety Injection System18 Information Notice91-13Inadequate Testing of Emergency Diesel GeneratorsW3-DBD-001Safety Injection System3Condition Reports
- 2006-437, 687, 756, 982, 1051, 1429, 1434, 1439, 1444
- AttachmentA-3
Section 1R05: Fire Protection (71111.05)ProcedureNUMBERTITLEREVISIONAdministrative ProcedureUNT-005-013Fire Protection Program9Operating Procedure 009-004Fire Protection11-8Maintenance Procedure
- MM-007-010Fire Extinguisher Inspectionand Extinguisher Replacement
- 13Administrative Procedure UNT-005-
- 013Fire Protection Program9Fire Protection Procedure FP-001-
- 015Fire Protection SystemImpairments
- 17Training Manual ProcedureNTP-202Fire Protection Training11-4
Section 1R07: Heat Sink Performance (71111.07)Miscellaneous DocumentsNUMBERTITLE/SUBJECTREVISIONEPRI
- TR-107397Service Water Heat Exchanger Testing GuidelinesMarch
- 1998Work Order
- 13173Section 1R12: Maintenance Effectiveness (71111.12)ProceduresNUMBERTITLEREVISIONDC-121Maintenance Rule1NUMARC 93-01Industry Guideline for Monitoring theEffectiveness of Maintenance at Nuclear Power Plants 3
- AttachmentA-4Condition ReportsCR-WF3-2004-1945CR-WF3-2004-2051
- CR-WF3-2005-1315CR-WF3-2005-3162CR-WF3-2006-1755
- CR-WF3-2005-1075CR-WF3-2005-4943CR-WF3-2006-0185
Section 1R14: Operator Response to NonRoutine Events (71111.14)Miscellaneous DocumentsNUMBERTITLE/SUBJECTREVISIONEN-OP-111Operational Decision Making Instruction (ODMI)Process 1
- EN-IS-123Electrical Safety1Condition ReportsCR-WF3-2006-0746Work Order
- 00012273
Section 1R15:
- Operability Evaluations (71111.15)Procedures:NUMBERTITLEREVISIONSTI-W3-2005-0005Emergency Diesel Generator A2 Starting AirReceiver Capacity Test
- 0OP-009-002Emergency Diesel Generator19OP-901-524Fire in Areas Affecting Safe Shutdown0
- Draft Regulatory Guide DG-
- 1136Demonstrating the Feasibility and Reliability ofOperator Manual Actions in Response to FireFebruary 2005Regulatory Issue Summary2005-30Clarification of Post-Fire Safe-Shutdown CircuitRegulatory RequirementsDecember 2005
- AttachmentA-5Condition ReportsCR-WF3-2006-1495CR-WF3-2006-1660CR-WF3-2005-4943CR-WF3-2001-1284CR-WF3-2001-0782CR-WF3-2006-1735
Section 1R17: Permanent Plant Modifications (71111.17)Miscellaneous DocumentsNUMBERTITLE/SUBJECTREVISION1564-331119FA Electronic Controls14Condition ReportsCR-WF3-1997-1985CR-WF3-1997-2509CR-WF3-2006-0421CR-WF3-1998-1032CR-WF3-2006-0952Work OrdersWA 01162451Section 1R19: Postmaintenance Testing (71111.19)Procedures:NUMBERTITLEREVISIONOP-903-052Controlled Ventilation Area System OperabilityCheck 9OP-903-118Primary Auxiliaries
- IST Valve Tests6ME-007-050Electroswitch Control/Latching Relay5ENS-MA-114Post Maintenance Testing5
- EN-MA-101Conduct of Maintenance1
- ME-004-142480 Volt G.E.
- AKR-30/AKR-50 BreakerOverhaul 3CEP-IST-1IST Bases Document3Condition ReportsCR-WF3-1999-0063CR-WF3-2006-1308
- AttachmentA-6Work Orders
- 25187, 65416, 65353
Section 1R22: Surveillance Testing (71111.22)ProcedureNUMBERTITLEREVISIONSMM-007-033IST Safety and Relief Valve BenchTesting and Maintenance
- 0STA-001-001Containment Air Lock Door Seal LeakageTest 4ME-003-110Fire Pump Diesel Starting Battery(Quarterly)
- 7OP-903-046Emergency Feed Pump Operability Check Revision 15ME-003-110Fire Pump Diesel Starting Battery(Quarterly)
- 7MM-007-033IST Safety and Relief Valve BenchTesting and Maintenance
- 0OP-903-011High Pressure Safety Injection PumpPreservice Operability Check
- 9CEP-IST-1IST Bases Document3Work Order
- 51040121,
- 51024833,
- 51020508,
- 51021167,
- 5101888, 51028329Section 1EP1 (71114.01)EP-001-001, "Recognition and Classification of Emergencies," Revision 19EP-002-010, "Notifications and Communications," Revision 29
- EP-002-015, "Emergency Responder Activation," Revision 8
- EP-002-052, "Protective Action Guidelines," Revision 18
- EP-002-071, "Site Protective Measures," Revision 18
- EP-002-100, "Technical Support Center Activation and Deactivation," Revision 32
- EP-002-101, "Operational Support Center Activation, Operation, and Declaration," Revision 27
- AttachmentA-7EP-002-030, "Emergency Radiation Exposure Guidelines & Controls," Revision 9EP-002-033, "Administration of Iodine Blocking Agents," Revision 9
- EP-002-130, "Emergency Team Assignments," Revision 20
- OP-901-524, "Fire in Areas Affecting Safe Shutdown," Revision 0
- Waterford 3 Emergency Plan, Revision 32
Section 2OS1: Access Controls to Radiologically Significant Areas (71121.01)Corrective Action Documents2005-04971, 2006-00126, 2006-00235Radiation Work Permits 1915RF-13, Remove and Replace
- LPRMs, Including Support Activities1921RF-13, Flow Control Valve Maintenance, Including Support Activities
- 29RF-13, Recirc Pump Work, Including Support ActivitiesProceduresHP-001-107, High Radiation Area Access Control, Revision 18HP-001-123, Plant Conditions and Radiological Concerns, Revision 3
- ENN-RP-108, Radiation Protection Posting, Revision 4
Section 2OS2: ALARA Planning and Controls (71121.02)Corrective Action Documents2005-04630,
- 2005-04820,
- 2005-04860,
- 2005-04898,
- 2005-05010,
- 2005-050662006-00008,
- 2006-00060,
- 2006-00293,
- 2006-00468, 2006-00674ProceduresENS-RP-105, Radiation Work Permits, Revision 7UNT-001-016,Radiation Protection, Revision 1
- ENS-RP-110,ALARA Program, Revision 2
- ENS-RP-102,Radiological Control, Revision 0
- ENS-RP-109,Hot Spot Program, Revision 2
- HP-001-114, Control of Temporary Shielding, Revision 9
- RP-205, Prenatal Monitoring, Revision 2Audits and AssessmentsWLO-2006-00040, ALARA Pre-NRC Inspection AssessmentLO-WLO-2005-0005-01, ALARA Planning and Controls
- WLO-2005-00053, Radiation Protection Organizational Effectiveness Five Year ALARA Plan, 2006 - 2010
- AttachmentA-8Radiation Work PermitsRWP-2006-0011, Declared Pregnant FemalesRWP-2006-0005, Tours and Inspections
- RWP-2006-0064, Containment Entry at PowerSection 4OA1: Performance Indicator Verification (71151)ProceduresEN-LI-114, Performance Indicator Process, Revision 1Miscellaneous DocumentsBatch Release Summary Information for 2005
- Batch Release Summary Information for 2006
- NRC Performance Indicator Technique Sheet for RETS/ODCM Radiological EffluentOccurrences, dated 1/09/6 and 4/04/06NRC Performance Indicator Technique Sheet for Occupational Exposure Control Effectiveness dated 1/11/06 and 4/06/06Section 4OA2: Identification and Resolution of ProblemsProcedureNUMBERTITLEREVISIONSStandard Review Plan
- 9.5.6Emergency Diesel Engine Starting System0ECM98-017Diesel Generator Starting Air ReceiverPressure Process Limit
- 0EN-LI-103Operating License Amendment0STI-W3-2005-00Emergency Diesel Generator A2 StartingAir Receiver Capacity Test
- 0EN-LI-113Licensing Basis Document ChangeProcess 1MM-007-033IST Safety and Relief Valve BenchTesting and Maintenance
- 0Condition ReportsCR-WF3-2006-1537CR-WF3-2006-1633
- CR-WF3-2006-1340CR-WF3-2006-1457CR-WF3-2003-2502
- CR-WF3-2006-1459CR-WF3-2004-3891CR-WF3-2005-4712
- AttachmentA-9CR-WF3-2004-2051CR-WF3-2004-2517
- CR-WF3-2006-1755CR-WF3-2006-0717CR-WF3-2006-1756
- CR-WF3-2006-1035CR-WF3-2005-4936CR-WF3-2006-1562
- CR-WF3-2005-4712Miscellaneous DocumentsNUMBERTITLE/SUBJECTREVISIONWaterford Quarterly Trend Report 1
st Quarter 20060Waterford Quarterly Trend Report 4
th Quarter 20050Work Order
- 51040121,
- 51024833,
- 51020508,
- 51021167,
- 5101888, 51028329
LIST OF ACRONYMS
NRCNuclear Regulatory CommissionPDRPublic Document Room
CFRCode of Federal Regulations