IR 05000382/2025301
| ML25077A038 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/19/2025 |
| From: | Heather Gepford NRC/RGN-IV/DORS/OB |
| To: | Sullivan J Entergy Operations |
| References | |
| 50-382/25-301 50-382/OL-25 | |
| Download: ML25077A038 (1) | |
Text
March 19, 2025
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC EXAMINATION REPORT 05000382/2025301
Dear Joseph Sullivan:
On March 10, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an initial operator license examination at Waterford Steam Electric Station, Unit 3. The enclosed report documents the examination results and licensing decisions. The preliminary examination results were discussed on February 14, 2025, with Mr. W. Wesley, Superintendent - Operations Training, and other members of your staff. A telephonic exit meeting was conducted on March 10, 2025, with Mr. J. Robertson, Lead Exam Writer, who was provided the NRC licensing decisions.
The examination included the evaluation of four applicants for reactor operator licenses, six applicants for instant senior reactor operator licenses, and two applicants for upgrade senior reactor operator licenses. The license examiners determined that thirteen of the fourteen applicants satisfied the requirements of 10 CFR Part 55, and the appropriate licenses have been issued. There was one post-examination comment submitted by your staff. Enclosure 1 contains details of this report and Enclosure 2 summarizes post-examination comment resolution.
No findings were identified during this examination. 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Heather J. Gepford, Ph.D., Chief Operations Branch Division of Operating Reactor Safety Docket No. 05000382 License No. NPF-38 Enclosures:
1.
Examination Report 05000382/2025301 2.
NRC Post-Examination Comment Resolution Electronic Distribution via LISTSERV Signed by Gepford, Heather J.
on 03/19/25
ML25077A038 SUNSI Review:
ADAMS:
Non-Publicly Available Non-Sensitive Keyword:
By: JCK Yes No Publicly Available Sensitive NRR-079 OFFICE SOE:DORS:OB SOE:DORS:OB R1:SOE:OB OE:DORS:OB SOE:DORS:OB C:DORS:OB NAME JKirkland KClayton JDeMarshall KMurphy DYou HGepford SIGNATURE
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DATE 03/18/25 03/19/25 03/18/25 03/18/25 03/18/25 03/19/25
Enclosure 1 U.S. NUCLEAR REGULATORY COMMISSION Examination Report Docket Number:
05000382 License Number:
NPF-38 Report Number:
05000382/2025301 Enterprise Identifier:
L-2025-OLL-0017 Licensee:
Entergy Operations, Inc.
Facility:
Waterford Steam Electric Station, Unit 3 Location:
Killona, Louisiana Inspection Dates:
February 10, 2025, to March 10, 2025 Inspectors:
J. Kirkland, Senior Operations Engineer, Chief Examiner K. Clayton, Senior Operations Engineer J. DeMarshall, Senior Operations Engineer, Region 1 K. Murphy, Operations Engineer D. You, Operations Engineer Approved By:
Heather J. Gepford, Ph.D., Chief Operations Branch Division of Operating Reactor Safety
1-2 SUMMARY Examination Report 05000382/2025301; February 10 - March 10, 2025; Waterford Steam Electric Station, Unit 3; Initial Operator Licensing Examination Report The NRC examiners evaluated the competency of four applicants for reactor operator licenses, six applicants for instant senior reactor operator licenses and two applicants for upgrade senior reactor operator licenses at Waterford Steam Electric Station, Unit 3.
The licensee developed the examinations using NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 12. The written examination was administered by the licensee on February 19, 2025. The NRC examiners administered the operating tests on February 10 - 14, 2025.
The NRC examiners determined that thirteen of the fourteen applicants satisfied the requirements of 10 CFR Part 55, and the appropriate licenses have been issued.
A.
NRC-Identified and Self-Revealing Findings None.
B.
Licensee-Identified Violations None.
1-3 REPORT DETAILS OTHER ACTIVITIES - INITIAL LICENSE EXAM
.1 License Applications a.
Scope The NRC examiners reviewed all license applications submitted to ensure each applicant satisfied relevant license eligibility requirements. The NRC examiners also audited three of the license applications in detail to confirm that they accurately reflected the subject applicants qualifications. This audit focused on the applicants experience and on-the-job training, including control manipulations that provided significant reactivity changes.
b.
Findings No findings were identified.
.2 Examination Development a.
Scope The NRC examiners reviewed integrated examination outlines and draft examinations submitted by the licensee against the requirements of NUREG-1021. The NRC examiners conducted an onsite validation of the operating tests.
b.
Findings The NRC examiners provided outline, draft examination and post-validation comments to the licensee. The licensee satisfactorily completed comment resolution prior to examination administration.
The NRC examiners determined the written examinations and operating tests initially submitted by the licensee were within the range of acceptability expected for a proposed examination.
.3 Operator Knowledge and Performance a.
Scope On February 19, 2025, the licensee proctored the administration of the written examinations to all applicants. The licensee staff graded the written examinations, analyzed the results, and presented their analysis and post-examination comments to the NRC on February 27, 2025.
The NRC examination team administered the various portions of the operating tests to all applicants from February 10 - 14, 2025.
1-4 b.
Findings No findings were identified.
All applicants passed the written examination and all parts of the operating test. The final examinations and post-examination analysis and comments may be accessed in the ADAMS system under the accession numbers noted in the attachment.
Post-examination analysis revealed four generic weaknesses associated with applicant performance on the written examination: identifying the color of CEA position light at the lower electrical limit; how a positive pressure in the control room is established with Outside Air Intake (OAI) flow < 200 CFM; tracking operability; and actions associated with inadequate boron concentration. These weaknesses were captured in the licensees corrective action program as Condition Report WT-WF3-2024-00175-0076.
Copies of all individual examination reports were sent to the facility Training Manager for evaluation and determination of appropriate remedial training.
.4 Simulation Facility Performance a.
Scope The NRC examiners observed simulator performance with regard to plant fidelity during examination validation and administration.
b.
Findings No findings were identified.
.5 Examination Security a.
Scope The NRC examiners reviewed examination security for examination development during both the onsite preparation week and examination administration week for compliance with 10 CFR 55.49 and NUREG-1021. Plans for simulator security and applicant control were reviewed and discussed with licensee personnel.
Findings No findings were identified.
EXIT MEETINGS AND DEBRIEFS Exit Meeting Summary The chief examiner presented the preliminary examination results to Mr. W. Wesley, Superintendent - Operations Training, and other members of the staff on February 14, 2025. A telephonic exit was conducted on March 10, 2025, between Mr. J. Kirkland Chief Examiner, and Mr. J. Robertson, Lead Exam Writer. The licensee did not identify any information or materials used during the examination as proprietary.
1-5 ADAMS DOCUMENTS REFERENCED Accession No. ML25077A031 - FINAL WRITTEN EXAMS Accession No. ML25077A029 - FINAL OPERATING TEST Accession No. ML25077A013 - POST-EXAMINATION ANALYSIS-COMMENTS
Enclosure 2 NRC Resolution to the Waterford Post-Examination Comment A complete text of the licensee's post-examination analysis and comments can be found in ADAMS under Accession Number ML25077A013.
SRO QUESTION # 8 COMMENT: The use of the word "only" after isolating the PMU ignores the requirement of T.S. 4.0.1 which states "Failure to meet a Surveillance... shall be failure to meet the LCO."
To clearly document the minimum actions needed to meet the LCO, answer A should have discussed the requirement to be in compliance and periodicity of the appropriate surveillances.
Action 3.1.2.9.b has 2 required surveillances, 4.1.2.9.3 and 4.1.2.9.4. Surveillance 4.1.2.9.3 defines that isolating the primary makeup flow path means "verified to be isolated by either locked closed manual valve, deactivated automatic valves secured in the isolation position, or by power being removed from all charging pumps, at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."
The bases for TS 4.0.1 states, in part, Systems and components are assumed to OPERABLE when the associated Surveillance Requirements have been met. Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when either: b. The requirements of the Surveillance(s) are known to be not met between required Surveillance performances. Based on this statement, knowing the surveillance requirement is not met because the valve is not locked, we could not say we are meeting the LCO until the valve is locked.
Due to the use of "only" and the lack of wording to be in compliance with the required Surveillances, there is no correct answer for this question.
NRC RESOLUTION: The NRC disagrees with the licensee position that there is no correct answer. Answer choice A is the correct answer.
The question asks what minimum action(s) is(are) required to meet the LCO. In order to satisfy Tech Spec 3.1.2.9, either part a OR part b must be met. Part a is not met because one source range instrument has failed high. Part b states, 1. The primary makeup water flow path to the reactor coolant system shall be isolated and 2. Do not operate the plant in the configurations prohibited by the COLR for the current MODE.
The licensee argues that after isolating the primary makeup water flow path, they must then verify the valve is locked (the valve is PMU-136), because when it is known to be unlocked, the requirements of the surveillance are known to not be met. (Note, verifying PMU-136 is locked is one of three methods of complying with the surveillance and is used as an example. One could interchange deactivating automatic valves secured in the isolation position, or by removing power from all charging pumps in place of locking closed the manual valve.)
However, isolating the primary makeup water flow path and locking PMU-136 are not mutually exclusive. As the licensee states, surveillance 4.1.2.9.3 defines that isolating the primary makeup flow path means verified to be isolated by either locked closed manual valve Therefore, one cannot state that primary water flow has been isolated until the valve is locked.
2-2 Because locking PMU-136 (or deactivating automatic valves secured in the isolation position or removing power from all charging pumps in place of locking closed the manual valve) is inherent in declaring primary makeup water flow isolated, one can say isolating the primary makeup water flow path to the RCS only is the minimum action required to meet the LCO.