IR 05000382/2022010
| ML22234A147 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/24/2022 |
| From: | Ami Agrawal NRC/RGN-IV/DORS |
| To: | Ferrick J Entergy Operations |
| References | |
| IR 2022010 | |
| Download: ML22234A147 (12) | |
Text
August 24, 2022
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000382/2022010
Dear Mr. Ferrick:
On July 28, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Waterford Steam Electric Station, Unit 3 and discussed the results of this inspection with Mr. Matt Lewis and other members of your staff.
The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Overall, the team concluded that all work groups at the Waterford Steam Electric Station, Unit 3, maintained a healthy safety-conscious work environment. Having said this, the team found some work environment challenges in the security department. Through interviews with the staff members, the team identified that an environment exists where morale among officers is low due to continued staffing issues and high levels of overtime. This has led to fatigue and work/life balance issues. If left uncorrected, the team posited that continued degradation of staff morale due to fatigue, could negatively impact staff performance and potentially plant safety. No findings or violations of more than minor significance were identified during this inspection.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Ami N. Agrawal, Team Lead Inspection Program & Assessment Team Division of Operating Reactor Safety Docket No. 05000382 License No. NPF-38
Enclosure:
As stated
Inspection Report
Docket Number:
05000382
License Number:
Report Number:
Enterprise Identifier:
I-2022-010-0005
Licensee:
Entergy Operations, Inc.
Facility:
Waterford Steam Electric Station, Unit 3
Location:
Killona, LA
Inspection Dates:
July 03, 2022, to July 28, 2022
Inspectors:
R. Azua, Senior Reactor Inspector
D. Childs, Resident Inspector
B. Correll, Reactor Inspector
N. Makris, Senior Emergency Response Coordinator
Approved By:
Ami N. Agrawal, Team Lead
Inspection Program & Assessment Team
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Waterford Steam Electric Station, Unit 3, in accordance with the Reactor Oversight Process.
The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)
- (1) The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety conscious work environment.
Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the Auxiliary Component Cooling Water (ACCW)system.
Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience,
Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.
Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Effectiveness of Problem Identification: Based on the samples reviewed, the team determined that the licensee's performance in this area adequately supported nuclear safety. Overall, the team found that the licensee was identifying and documenting problems at an appropriately low threshold that supported nuclear safety.
Effectiveness of Prioritization and Evaluation of Issues: Overall, the team found that the licensee was appropriately prioritizing and evaluating issues to support nuclear safety. Of the samples reviewed, the team found that the licensee, in general, correctly characterized condition reports as to whether they represented conditions adverse to quality, and then prioritized the evaluation and corrective actions in accordance with program guidance.
Effectiveness of Corrective Actions: Overall, the team concluded that the licensee's corrective actions supported nuclear safety. Specifically, the staff at the Waterford Steam Electric Station, Unit 3 developed effective corrective actions for the problems evaluated in the corrective action program and generally implemented these corrective actions in a timely manner commensurate with their safety significance. Having said this, two examples were identified where this was not the case. The team informed the licensee of these errors, and they addressed them through the corrective action program. The team determined these were isolated instances and did not represent a programmatic issue.
As part of this inspection, the team selected the Auxiliary Component Cooling Water (ACCW) system for a focused review within the corrective action program. For this system, the team performed sample selections of condition reports, looking at the adequacy of the licensee's evaluation process for determining which items are placed in the corrective actions process, and the corrective actions taken. The team also reviewed the licensee's use of operational experience and the 10 CFR Part 21 process with respect to this system. No problems were noted.
Corrective Action Program Assessment: Based on the samples reviewed, the team determined the licensee's corrective action program complied with regulatory requirements and self-imposed standards, and the licensee's implementation of the corrective action program adequately supported nuclear safety. The team found that management's oversight of the corrective action program process was effective.
Assessment 71152B Operating Experience: The team reviewed a variety of sources of Operating Experience including 10 CFR Part 21 notifications and other vendor correspondence, NRC generic communications, and publications from various industry groups including INPO and EPRI. The team determined that the Waterford Steam Electric Station, Unit 3 is adequately screening and addressing issues identified through Operational Experience that apply to the station and that this information is evaluated in a timely manner once it is received. Having said this, a couple of minor examples of process errors regarding 10 CFR Part 21s were identified and entered into the licensee's corrective action program.
Self-Assessments and Audit Assessment: The team reviewed a sample of the licensee's departmental self-assessments and audits to assess whether they regularly identified performance trends and effectively addressed them. The team also reviewed audit reports to assess the effectiveness of assessments in specific areas. Overall, the team concluded that the licensee had an effective departmental self-assessment and audit process. The audits that the team reviewed were very detailed, thorough, and identified issues.
Assessment 71152B Safety-Conscious Work Environment: The team interviewed approximately 30 individuals in group sessions of varying sizes, plus some one-on-one interviews. The interviews were conducted in person. The purpose of these interviews was
- (1) to evaluate the willingness of your staff to raise nuclear safety issues, either by initiating a condition report or by another method,
- (2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems, and
- (3) to evaluate the Waterford Steam Electric Station, Unit 3's safety-conscious work environment (SCWE). The focus group participants included personnel from Security, Engineering, and Production. Overall, the Waterford Steam Electric Station, Unit 3, was found to have an adequate SCWE.
Willingness to Raise Nuclear Safety Issues: In all the interviews, the team found no evidence of challenges to SCWE. Individuals in these groups expressed a willingness to raise nuclear safety concerns and other issues through at least one of the several means available.
However, the team found some work environment challenges in the security department. Through interviews with the staff members, it was identified that an environment exists where morale among officers is low due to continued staffing issues and high levels of overtime, leading to fatigue and work/life balance issues. The team posited that continued degradation of staff morale due to fatigue, could negatively impact staff performance.
Specifically, tired, and distracted people make mistakes. Plus, low morale may ultimately have a negative impact on SCWE.
Overall, the team concluded that all work groups at the Waterford Steam Electric Station, Unit 3, maintained a healthy safety-conscious work environment. However, morale issues may have a deleterious effect on staff performance and potentially on plant safety.
Employee Concerns Program: The team looked at the Waterford Steam Electric Station, Unit 3's Employee Concerns Program (ECP). The team interviewed the ECP manager and reviewed a number of investigations. Overall, the team determined that the investigation packages were of excellent quality, clearly demonstrating steps taken and basis for conclusions. In addition, the ECP manager demonstrated detailed knowledge of all the cases that were reviewed.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On July 28, 2022, the inspectors presented the biennial problem identification and resolution inspection results to Mr. Matt Lewis and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
ECF14-046
WF3 Fire Safety Analysis - Fire Area RCB
Calculations
Combustible Loading Calculation for Fire Area RCB
005
Corrective Action
Documents
CR-WF3-
2013-00445, 2015-05234, 2016-07183, 2018-04804, 2019-
01751, 2019-02349, 2019-03153, 2019-04695, 2019-06297,
2019-07175, 2020-00191, 2020-01109, 2020-02178, 2020-
2188, 2020-02316, 2020-02649, 2020-02945, 2020-05569,
20-05600, 2020-05607, 2020-05692, 2020-05855, 2020-
05982, 2020-06067, 2020-06110, 2020-06312, 2020-06336,
20-06462, 2020-06650, 2020-06722, 2020-06814, 2020-
06904, 2020-06924, 2020-06930, 2020-06939, 2020-06980,
20-07058, 2020-07178, 2020-07211, 2020-07215, 2020-
254, 2020-07255, 2020-07294, 2020-07328, 2020-07394,
21-00040, 2021-00062, 2021-00195, 2021-00198, 2021-
00199, 2021-00220, 2021-00226, 2021-00299, 2021-00300,
21-00326, 2021-00404, 2021-00469, 2021-00496, 2021-
00608, 2021-00836, 2021-00853, 2021-00895, 2021-00903,
21-00908, 2021-00912, 2021-00918, 2021-00922, 2021-
00924, 2021-00948, 2021-01116, 2021-01254, 2021-01268,
21-01299, 2021-01386, 2021-01492, 2021-01630, 2021-
01662, 2021-01784, 2021-01797, 2021-01835, 2021-01837,
21-02059, 2021-02251, 2021-02262, 2021-02290, 2021-
2312, 2021-02391, 2021-02466, 2021-02901, 2021-02993,
21-03036, 2021-03065, 2021-03671, 2021-03677, 2021-
03683, 2021-03832, 2021-03864, 2021-03868, 2021-03873,
21-04001, 2021-04165, 2021-04184, 2021-04236, 2021-
279, 2021-04614, 2021-04905, 2021-04911, 2021-04912,
21-04950, 2021-04974, 2021-04976, 2021-05004, 2021-
284, 2021-05322, 2021-05945, 2021-05242, 2021-05244,
21-06020, 2021-06180, 2021-06244, 2021-06466, 2021-
06554, 2021-06728, 2021-06774, 2022-00284, 2022-00342,
22-00546, 2022-00814, 2022-00854, 2022-01167, 2022-
01302, 2022-01503, 2022-01695, 2022-01837, 2022-01953,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
22-02217, 2022-02336, 2022-02475, 2022-02484, 2022-
2647, 2022-02746, 2022-02885, 2022-03125, 2022-03362,
22-03430, 2022-03513, 2022-03529, 2022-03552, 2022-
03575, 2022-03598, 2022-03704, 2022-03735, 2022-03963,
22-03999, 2022-04052, 2022-04112, 2022-04164, 2022-
283, 2022-04351, 2022-04699, 2022-05424, 2022-05531
Operability Input to CR-WF3-2020-02316 - Failure to Test
CCW Surge Tank LOLO Level Relays
000
Operability Input for Cut Rebar Documented in CR-WF3-
2016-07183
Operability Input for CR-WF3-2020-2178 CC
MPMP0001A(B)(AB)
EC-C94-015
Structural Design of ACCW Equipment Platforms
A
Engineering
Changes
ENGCHG-WF3-
Operability Input to CR-WF3-2020-02316 - Failure to Test
CCW Surge Tank LOLO Level Relays
000
Engineering
Evaluations
WF3-PE-
217881
Procurement Engineering Evaluation 00217881
05/19/2022
AR-21003222
Molded Case Circuit Breaker PM Classification Update
03/29/2021
LO-WLO-2020-
00058
Effectiveness review for CR-WF3-2020-6336
N/A
OBS-2020-
117987, 118055
N/A
OBS-2021-
0184, 3066, 3069, 3073, 3202, 3204, 7405, 7410, 8035,
8131, 8134, 9604, 9975, 9977, 14920, 17040, 21221, 21292
N/A
Performance
Review Meeting
(DPRM/APRM)
Radiation Protection - 4/22/2021, 7/27/2021, 10/28/2021,
2/31/2021
Performance
Review Meeting
(DPRM/APRM)
Maintenance (Electrical and I&C) - 4/28/2021, 7/14/2021,
10/27/2021, 1/25/2022
Miscellaneous
WLP-ESPC-
TRBLREFESH
Trouble Shooting Refresher
Document Control and Records Management Programs
Design Inputs
Procedures
Control of Combustibles
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Maintenance Rule (a)(1) Process
Employee Concerns Program
EN-EC-100-01
Employee Concerns Program Coordinator Training
Differing Professional Opinion Resolution Process
Equipment Important to Emergency Response
Equipment Important to Emergency Response
EN-FAP-DC-014
Engineering Change Stakeholder Engagement
Industrial Safety Planning & Job Safety Hazard Analysis
Corrective Action Program
Causal Analysis Process
Planning
Operating Experience Program
EN-OE-100-01
IER Level 1 and Level 2 Evaluations and Effectiveness
Reviews
Nuclear Excellence Model
Safety Conscious Work Environment (SCWE) Policy
Maintaining a Strong Safety Culture
Nuclear Safety Culture Monitoring
JA-PI-03
OE Screening
MI-004-300
Guidelines for Rework of Electronic Equipment
303
MI-004-300
Guidelines for Rework of Electronic Equipment
305
OP-006-010
TEDG Operations
OP-006-010
TEDG Operations
OP-010-003
Plant Startup
356
OP-010-003
Plant Startup
357
OP-010-003
Plant Startup
358
OP-010-003
Plant Startup
359
OP-010-003
Plant Startup
360
OP-010-003
Plant Startup
361
OP-100-014
Technical Specification and Technical Requirements
Compliance
355
Self-Assessments LO-WLO-2020-
00058
Effectiveness Review for CR-WF3-2020-06336
N/A
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
QA-04-2022-W3-
Engineering (Design Control) Audit
4/18/2022
QA-12/18-2021-
W3-1
Combined Operations and Technical Specifications Audit
7/12/2021
QA-14/15-2021-
W3-01
Quality Assurance Audit Report - Combined Radiation
Protection and Radwaste Audit
10/25/2021
QA-3-2021-W3-1
Quality Assurance Audit Report - Corrective Action Program
(CAP)
06/29/2021
QS-2022-WF3-
2
22 Corrective Action Program (CAP) Surveillance
05/05/2022
216288
(OD) BMSR-416 - Type I Snubber Functional Test
N/A
518880
QSPDS #2 NODE BOX DOES NOT PRESENT DATA TO
REGULAR
DISPLAY
N/A
2776774
NG IPIS0945-B, NG IPS0935-B, NG MVAAA812, Calibrate
2796992
SI IF0390-B, Calibrate Flow Loop IAW MI Procedures
2824939
SM IYR6040-V, Calibrate Spectrum Recorder IAW MI-003-
345
545054
CC EREL701-Relay Perform Functional Test of LSX (CR 20-
2316)
550262
CC EREL702-Relay Perform Functional Test of LSX (CR 20-
2316)
554762
RC IHTE0221-B, REPLACE QSPDS 2 HJTC ASSEMBLY
N/A
554774
TROUBLESHOOT RC IUTE0221 B 20-6814
N/A
494, 533, 599, 616, 3618
Work Orders
Replace Mechanical Seal on ACCMPMP0001 B Pump CR-
19-4695