ML062300336

IR 05000382-06-003; 04/08/2006-07/07/2006; Waterford Steam Electric Station, Unit 3; Identification and Resolution of Problems

ML062300336
Person / Time
Site:	Waterford
Issue date:	08/18/2006
From:	Graves D NRC/RGN-IV/DRP/RPB-E
To:	Venable J Entergy Operations
References
EA-06-192 IR-06-003
Download: ML062300336 (38)

See also: IR 05000382/2006003

Text

August 18, 2006

EA-06-192

Joseph E. Venable

Vice President Operations

Waterford 3

Entergy Operations, Inc.

17265 River Road

Killona, LA 70066-0751

SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED

INSPECTION 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 and

compliance with the Commissions 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 evaluated

under 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. The

violation was evaluated in accordance with the NRC Enforcement Policy. The current

Enforcement Policy is included on the NRCs 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 the

enclosed Notice when preparing your response. The NRC will use your response, in part, to

determine 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, its

enclosures, and your response will be made available electronically for public inspection in the

NRC Public Document Room or from the Publicly Available Records (PARS) component of

NRCs 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 them

with you.

Sincerely,

/RA/

David N. Graves, Chief

Project Branch E

Division of Reactor Projects

Docket: 50-382

License: 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 39286-1995

Vice President, Operations Support

Entergy Operations, Inc.

P.O. Box 31995

Jackson, MS 39286-1995

Wise, Carter, Child & Caraway

P.O. Box 651

Jackson, MS 39205

General Manager, Plant Operations

Waterford 3 SES

Entergy Operations, Inc.

17265 River Road

Killona, LA 70066-0751

Manager - Licensing Manager

Waterford 3 SES

Entergy Operations, Inc.

17265 River Road

Killona, LA 70066-0751

Chairman

Louisiana Public Service Commission

P.O. Box 91154

Baton Rouge, LA 70821-9154

Director, Nuclear Safety &

Regulatory Affairs

Waterford 3 SES

Entergy Operations, Inc.

17265 River Road

Killona, LA 70066-0751

Richard 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 70057

Winston & Strawn LLP

1700 K Street, N.W.

Washington, DC 20006-3817

Chairperson

Denton 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-Sensitive

R:\_REACTORS\_WAT\2006\WT2006-03RP-GFL.wpd

SRI:DRP/E DRS/EB1 C:DRS/PSB C:DRS/EB2 C:DRS/OB

GFLarkin JAClark MPShannon LJSmith ATGody

E-DNGraves /RA/ /RA/ /RA/ VGGaddy for

8/18/06 8/14/06 8/15/06 8/15/06 8/15/06

C:ACES D:DRP C:DRP/E

KSFuller ATHowell DNGraves

GMVasquez for /RA/ /RA/

8/18/06 8/18/06 8/18/06

OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

NOTICE OF VIOLATION

Entergy Operations, Inc. Docket No. 50-382

Waterford Steam Electric Station, Unit 3 License No. NPF-38

EA-06-192

During an NRC inspection completed on July 7, 2006, a violation of NRC requirements was

identified. 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 applicable

regulatory requirements and the design basis for systems to which Appendix B applies

are correctly translated 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 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. This

resulted 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 to

submit 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 the

subject 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 basis

for 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 include

previous 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, with

the 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 NRC

Public Document Room or from the NRCs document system (ADAMS), accessible from the

NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should

not 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

-1- Enclosure 1

necessary to provide an acceptable response, then please provide a bracketed copy of your

response that identifies the information that should be protected and a redacted copy of your

response that deletes such information. If you request withholding of such material, you must

specifically 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 will

create 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 working

days.

Dated this 18 day of August 2006

-2- Enclosure 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 Inspector

P. 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 Engineer

Approved By: David N. Graves, Chief, Project Branch E

ATTACHMENTS: Supplemental Information

-1- Enclosure 2

CONTENTS

SUMMARY OF FINDINGS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

REACTOR SAFETY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

1R01 Adverse Weather Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

1R04 Equipment Alignment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

1R05 Fire Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

1R06 Flood Protection Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

1R07 Heat Sink Performance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

1R11 Licensed Operator Requalification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

1R12 Maintenance Rule Implementation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

1R13 Maintenance Risk Assessments and Emergent Work Evaluation . . . . . . . . . . 9

1R14 Non-Routine Evolutions and Events . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

1R15 Operability Evaluations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

1R17 Permanent Plant Modifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

1R19 Post Maintenance Testing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

1R22 Surveillance Testing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

1EP1 Exercise Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

1EP4 Emergency Action Level and Emergency Plan Changes . . . . . . . . . . . . . . . . 14

1EP6 Drill Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

RADIATION SAFETY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

2OS1 Access Control to Radiological Significant Areas . . . . . . . . . . . . . . . . . . . . . . 16

2OS2 ALARA Planning and Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

OTHER ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

4OA1 Performance Indicator Verification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

4OA2 Identification and Resolution of Problems . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

4OA5 Other Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

4OA6 Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

4OA7 Licensee Identified Violations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

ATTACHMENT: SUPPLEMENTAL INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1

KEY POINTS OF CONTACT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1

ITEMS OPENED, CLOSED, AND DISCUSSED . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-2

LIST OF DOCUMENTS REVIEWED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-3

LIST OF ACRONYMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-9

-2- Enclosure 2

SUMMARY OF FINDINGS

IR05000382/2006-003; 04/08/2006-07/07/2006; Waterford Steam Electric Station, Unit 3;

Identification and Resolution of Problems

The 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 NRCs program for overseeing

the 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 NRC

identified that the emergency diesel generator starting air system was incapable

of 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 system

cornerstone objective due to the degradation of the design-basis capability of the

starting 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 Generic

Letter 91-18 guidance. Additionally, surveillance testing has demonstrated the

capability 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 have

been reviewed by the inspectors. Corrective actions taken or planned by the licensee

have been entered into the licensees corrective action program. These violations and

corrective actions are listed in Section 4OA7 of this report.

-3- Enclosure 2

REPORT DETAILS

Summary of Plant Status: The plant was operated at approximately 100 percent power from

April 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 SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R01 Adverse Weather Protection (71111.01)

.1 Readiness For Seasonal Susceptibilities

a. Inspection Scope

The inspectors completed a review of the licensee's readiness of seasonal

susceptibilities to hurricane force winds and rainfall. The inspectors: (1) reviewed plant

procedures, 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 listed

below 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 the

corrective 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 Safeties

Documents 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 Requirements

Compliance

• License Amendment 168 and Safety Evaluation Report to License

Amendment 168, September 7, 2000

• EC-C99-008, Revision 1, Tornado Missile Analysis

• CR-WF3-2005-3431

-4- Enclosure 2

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 listed

below and reviewed plant procedures and documents to verify that critical portions of the

selected systems were correctly aligned; and (2) compared deficiencies identified during

the 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 A

Documents reviewed by the inspectors are listed in the attachment. The inspectors

completed 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 material

condition 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 manual

actuators was unobstructed; (4) verified that fire extinguishers and hose stations were

provided 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 a

satisfactory material condition; (6) verified that adequate compensatory measures were

established for degraded or inoperable fire protection features and that the

-5- Enclosure 2

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 inspectors

completed 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 readiness

of 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 drill scenario, (17) performance

of the postdrill critique, and (18) restoration from the fire drill. The licensee simulated a

fire in the reactor auxiliary building laundry room.

Documents reviewed by the inspectors are listed in the attachment. The inspectors

completed one sample.

b. Findings

No findings of significance were identified.

-6- Enclosure 2

1R06 Flood Protection Measures (71111.06)

.1 Semi-Annual Internal Flooding

a. Inspection Scope

The inspectors: (1) reviewed the Updated Final Safety Analysis Report, the flooding

analysis, and plant procedures to assess seasonal susceptibilities involving internal

flooding; (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 inspectors

completed 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 industry

standards, and reviewed critical operating parameters and maintenance records for the

essential chiller Train A evaporator. The inspectors verified that: (1) performance tests

were satisfactorily conducted for heat exchangers/heat sinks and reviewed for problems

or errors; (2) the licensee utilized the periodic maintenance method outlined in Electrical

Power Research Institute NP-7552, "Heat Exchanger Performance Monitoring

Guidelines;" (3) the licensee properly utilized biofouling controls; (4) the licensees heat

exchanger 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 inspectors

completed one sample.

b. Findings

No findings of significance were identified.

-7- Enclosure 2

1R11 Licensed Operator Requalification Program(71111.11)

a. Inspection Scope

On June 27, 2006, the inspectors observed testing and training of senior reactor

operators 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 Forced

Circulation Recovery, Revision 5

• Operations Procedure OP-902-004, Excess Steam Demand Recover,

Revision 10

• Emergency Planning Procedure EP-001-001, Recognition and Classification of

Emergency Conditions, Revision 20

The 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 the

appropriate handling of structure, system, and component performance or condition

problems; (2) verify the appropriate handling of degraded structure, system, and

component functional performance; (3) evaluate the role of work practices and common

cause problems; and (4) evaluate the handling of structure, system, and component

issues 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 System

Documents reviewed by the inspectors are listed in the attachment. The inspectors

completed two samples.

-8- Enclosure 2

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) performance

of 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 diesel

generator Train A

Documents reviewed by the inspectors are listed in the attachment. The inspectors

completed 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 the

probability of initiating events and maintained the functional capability of mitigating

systems and barrier integrity systems; (2) verified that emergent work-related activities

such 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 Final

Safety 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 inspectors

completed one sample.

-9- Enclosure 2

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 for

the evolutions listed below to evaluate operator performance in coping with nonroutine

events 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 ventilation

system, and additional safety and nonsafety-related systems. Plant shutdown

contingency 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 the

loose lug condition. See Section 4OA7 for additional details.

Documents reviewed by the inspectors are listed in the attachment. The inspectors

completed one sample.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations (71111.15)

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) evaluated

compensatory measures associated with operability evaluations; (4) determined

degraded 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.

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• April 20, 2006: Operability evaluation addressing a steam leak of feedwater

Valve FW-1841B as described in Condition Report 2006-1177

• March 15, 2006: Operability evaluation addressing an identified discrepancy

affecting 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 generator

Train A million volt-amps-reactive, Mwatt and Phase C current spikes during a

monthly surveillance run as described in Condition Report 2006-1660

• March 14, 2006: Operability evaluation addressing the feasibility of postfire

operator hot shutdown manual actions in the event of a relay room fire as

described in Condition Report 2006-735

Documents reviewed by the inspectors are listed in the attachment. The inspectors

completed 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 operating

procedure 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, the

appropriateness 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 static

uninterruptible power Supply B to power distribution Panel PDP-391-SB to limit

reliability concerns associated with a cable vault or control room fire

-11- Enclosure 2

Documents reviewed by the inspectors are listed in the attachment. The inspectors

completed 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 significant

systems or components listed below. For each item, the inspectors: (1) reviewed the

applicable 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 during

testing 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 breaker

Train A

• June 15, 2006: Planned maintenance for controlled area ventilation system

Valve HVR-313B

• June 22, 2006: Planned maintenance for control room air handling unit isolation

Relay HVCEREL1168A

Documents reviewed by the inspectors are listed in the attachment. The inspectors

completed 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, procedure

requirements, and Technical Specifications to ensure that the four surveillance activities

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listed below demonstrated that the structures, systems, and components tested were

capable 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 indicator

data; (13) engineering evaluations, root causes, and bases for returning tested

structures, systems, and components not meeting the test acceptance criteria were

correct; (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 Lock

Door Seal Leakage Test, Revision 4. This surveillance verified that the

containment air lock door seal leakage is less than an acceptable value.

• May 2, 2006: Maintenance Procedure MM-007-033, IST Safety and Relief

Valve Bench Testing and Maintenance, Revision 0. This surveillance verified

that 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 Starting

Battery (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 Pump

Operability Check, Revision 15. This surveillance verified operability of

emergency feedwater Pump A/B.

Documents reviewed by the inspectors are listed in the attachment. The inspectors

completed four samples.

b. Findings

No findings of significance were identified.

Cornerstone: Emergency Preparedness (EP)

1EP1 Exercise Evaluation (71114.01)

a. Inspection Scope

The Waterford Unit 3 2005 Biennial Emergency Preparedness Exercise, originally

scheduled 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

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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, failure

of 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-significant

activities 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 Facility

The inspectors also assessed recognition of and response to abnormal and emergency

plant conditions, the transfer of decision making authority and emergency function

responsibilities between facilities, onsite and offsite communications, protection of

emergency workers, emergency repair evaluation and capability, and the overall

implementation of the emergency plan to protect public health and safety and the

environment. The inspectors reviewed the current revision of the facility Emergency

Plan and emergency plan implementing procedures associated with operation of the

above facilities and performance of the associated emergency functions. These

procedures are listed in the attachment to this report.

The inspectors compared the observed exercise performance with the requirements in

the facility Emergency Plan, 10 CFR 50.47(b), 10 CFR 50 Appendix E, and with the

guidance in the emergency plan implementing procedures and other federal guidance.

The inspectors attended the postexercise critiques in each of the above facilities to

evaluate 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.

1EP4 Emergency Action Level and Emergency Plan Changes (71114.04)

a. Inspection Scope

The inspector performed an in-office review of Revision 20-4 of Emergency Plan

Implementing Procedure EP-01-001, Recognition and Classification of Emergency

Conditions, received April 16, 2006. This revision deleted two emergency action levels

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related to site protection, which were redundant to those the licensee implemented in

accordance with NRC Bulletin 2005-002, Emergency Preparedness and Response

Actions 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.

1EP6 Drill Evaluation (71114.06)

a. Inspection Scope

For the one drill and simulator-based training evolutions contributing to Drill/Exercise

Performance 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 transient

without scram resulting in a site area emergency due to reactor coolant system

leakage 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 Recovery

Procedure, Revision 11

• Emergency Planning Procedure EP-001-001, Recognition and Classification of

Emergency Conditions, Revision 20

The inspectors completed one sample.

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b. Findings

No findings of significance were identified.

2. RADIATION SAFETY

Cornerstone: Occupational Radiation Safety

2OS1 Access Control to Radiologically Significant Areas (71121.01)

a. Inspection Scope

This area was inspected to assess the licensees performance in implementing physical

and 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 licensees

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 reported

by 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 to

the access control program since the last inspection

• Corrective action documents related to access controls

• Radiation work permit (or Radiation exposure permit) briefings and worker

instructions

• Posting and locking of entrances to all accessible high dose rate - high radiation

areas and very high radiation areas

• Radiation worker and radiation protection technician performance with respect to

radiation protection work requirements

The inspector completed 11 of the required 21 samples.

b. Findings

No findings of significance were identified.

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2OS2 ALARA Planning and Controls (71121.02)

a. Inspection Scope

The inspector assessed licensee performance with respect to maintaining individual and

collective radiation exposures as low as reasonably achievable (ALARA). The inspector

used the requirements in 10 CFR Part 20 and the licensees 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-term

measurements

• Site specific ALARA procedures

• Interfaces between operations, radiation protection, maintenance, maintenance

planning, scheduling, and engineering groups

• Integration of ALARA requirements into work procedure and radiation work

permit (or radiation exposure permit) documents

• Person-hour estimates provided by maintenance planning and other groups to

the 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, the

methodology 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 source

terms 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 exposure

reduction initiatives

• Specific sources identified by the licensee for exposure reduction actions and

priorities established for these actions, and results achieved against since the

last refueling cycle

• Radiation worker and radiation protection technician performance during work

activities in radiation areas, airborne radioactivity areas, or high radiation areas

• Declared pregnant workers during the current assessment period, monitoring

controls, and the exposure results

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• Self-assessments, audits, and special reports related to the ALARA program

since the last inspection

• Corrective action documents related to the ALARA program and follow-up

activities such as initial problem identification, characterization, and tracking

• Effectiveness of self-assessment activities with respect to identifying and

addressing 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 (71151)

a. Inspection Scope

The inspector sampled licensee submittals for the performance indicators listed below

for 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 Cornerstone

Occupational Exposure Control Effectiveness Performance Indicators

Licensee records reviewed included corrective action documentation that identified

occurrences in high radiation areas with dose rates greater than 1,000 millirem per hour

at 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 that

high radiation and very high radiation areas were properly controlled.

The inspector completed the required sample (1) in this cornerstone.

Public Radiation Safety Cornerstone

Radiological Effluent Technical Specification/Offsite Dose Calculation Manual

Radiological Effluent Occurrences

Licensee records reviewed included corrective action documentation that identified

occurrences for liquid or gaseous effluent releases that exceeded performance indicator

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thresholds and those reported to the NRC. The inspector interviewed licensee

personnel 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.

4OA2 Identification and Resolution of Problems (71152)

.1 Routine Review of Identification and Resolution of Problems

The inspectors performed a daily screening of items entered into the licensee's

corrective 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 were

entered into the corrective action program; (2) verified that corrective actions were

commensurate with the significance of the issue; and (3) identified conditions that might

warrant additional follow-up through other baseline inspection procedures.

.2 Selected Issue Follow-up Inspection

In addition to the routine review, the inspectors selected the one system listed below for

a more in-depth review. The inspectors considered the following during the review of

the licensee's actions: (1) complete and accurate identification of problems in a timely

manner; (2) evaluation and disposition of operability/reportability issues;

(3) consideration of extent of condition, generic implications, common cause, and

previous occurrences; (4) classification and prioritization of the resolution of the

problem; (5) identification of root and contributing causes of the problem;

(6) identification of corrective actions; and (7) completion of corrective actions in a timely

manner.

C 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 the

emergency diesel generator starting air system was incapable of 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 corrective actions in a timely manner

to address this deficiency and restore compliance.

Discussion. On October 7, 2003, NRC Inspection Report 05000382/2003006

documented 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

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nominal operating pressure less than the lowest pressure that qualified each receiver to

start the diesel five times. Entergy documented the inadequate diesel generator starting

air system capacity as a Generic Letter 91-18 issue, established administrative controls

to manage the nonconformance, and initially decided to resolve the issue by submitting

a Technical Specification Change Request to the NRC for approval. The starting air

system nonconformance was not resolved as scheduled due to licensing department

personnel 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 administrative

controls do not alleviate the need to revise the Technical Specification and that a

Technical 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 receiver

operating pressure, installing larger air receivers, and providing a calculation to justify a

four start capability as a technical justification for an exemption to the Standard Review

Plan, "9.5.6 Emergency Diesel Engine Starting System," five start requirement. Entergy

rejected increasing the receiver operating pressure and installing larger air receivers for

technical reasons. On January 18, 2006, Entergy performed a starting air system test

that demonstrated the capability of the A2 air receiver to start emergency diesel

generator 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 a

five start capability based on the air mass consumption per start excluding starting air

system pressure decay between successive starts due to system leakage. The

inspectors reviewed Calculation ECM98-017 and determined, in part, that the system

did 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 effects

must be accounted for in the test program; (2) Entergys analysis did not account for

changes to the emergency diesel generator rolling resistance to starting during 23 years

of operation; and (3) the starting air system was tested at 85EF, but

Calculation ECM98-017 did not account for the reduced air mass in the air receiver at

the emergency diesel generator design room temperature of 120EF.

NRC Inspection Manual, Part 9900, "Operability Determinations and Functionality

Assessments 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 diesel

generator starting air system; (2) change their licensing or design basis to a four start

capability; or (3) make effective plant modifications to obtain a five start capacity such as

increasing the starting air receiver set point pressure or increasing the size of the

systems air receivers. Entergy has exceeded its established completion dates to

resolve this issue several times. These failures constitute a performance deficiency.

Analysis. The failure to take prompt corrective measures to reestablish full qualification

of the emergency diesel generator starting air system by some means is a performance

deficiency. This finding is greater than minor because it affected the mitigating system

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cornerstone objective due to the degradation of the design-basis capability of the

starting 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 has

demonstrated the capability of each diesel generator to start within the required

10 seconds.

Enforcement. 10 CFR Part 50, Appendix B, Criterion III, "Design Control," requires, in

part, that The Code of Federal Regulations, Part 50, Appendix B, Criterion III, "Design

Control," requires, in part, that applicable regulatory requirements and the design basis

for 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 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. This resulted in the failure to maintain each diesel

generator air receiver capable of starting the diesel engine five times as required since

September 2003, when the NRC identified that the emergency diesel generator starting

air system capacity was inadequate to meet the design basis. The licensee has failed to

take 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 licensees 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 licensees corrective action program and

associated documents to identify trends that could indicate the existence of a more

significant 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 Entergys 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 Entergys procedural requirements of

Procedure LI-102, Corrective Action Program. The inspectors review nominally

considered the 6-month period of July through December 2005.

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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 licensees problem identification and

resolution 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.

4OA5 Other Activities

1. Implementation of Temporary Instruction TI 2515/165 - Operational Readiness of Offsite

Power and Impact on Plant Risk

a. Inspection Scope

The objective of TI 2515/165, "Operational Readiness of Offsite Power and Impact on

Plant 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 this

inspection, 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.

4OA6 Meetings, Including Exit

Exit Meeting Summary

.1 On May 19, 2006, the inspector conducted a telephonic exit meeting to present the

emergency 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.

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.2 On June 22, 2006, the inspector presented the ALARA inspection results to

Mr. 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 preparedness

exercise 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 to

Mr. B. Williams, Director, Engineering, and other members of management. The

licensee 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.

4OA7 Licensee Identified Violations

The following violation of very low safety significance (Green) was identified by the

licensee and is a violation of NRC requirements which meets the criteria of Section VI of

the NRC Enforcement Policy, NUREG-1600, for being dispositioned as a noncited

violation.

• 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and

Drawings, requires that work on safety-related structures, systems, and

components be completed in accordance with appropriate instructions to ensure

the structures, systems, and components will perform satisfactorily when placed

in 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 affected

several 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 affected

structures, systems, and components were inoperable for less time than the

allowed Technical Specification outage time. This deficiency was identified in

Entergys corrective action program as Condition Report CR-WF3-2006-0746.

See Section 1R14 for additional details.

ATTACHMENT: SUPPLEMENTAL INFORMATION

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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

A-1 Attachment

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

50-382/2006003-01 VIO Untimely Actions to Restore Design Basis Compliance of

the Emergency Diesel Generator Starting Air System

(Section 4OA2)

LIST OF DOCUMENTS REVIEWED

Section 1RO4: Equipment Alignment (71111.04)

Procedures

NUMBER TITLE REVISION

OP-002-003 Component Cooling Water System 14

ME-004-115 4.16 KV G.E. Magna-Blast Breaker 12

ME-003-327 4.16/6.9 KV Magna-Blast Operating Mechanism 1

Overhaul

OP-009-002 Emergency Diesel Generator 19

Miscellaneous Documents

NUMBER TITLE/SUBJECT REVISION

MNQ6-27 NPSH Calculation for the HPSI and CS Pumps 4

OP-009-008 Safety Injection System 18

Information Notice Inadequate Testing of Emergency Diesel Generators

91-13

W3-DBD-001 Safety Injection System 3

Condition Reports

2006-437, 687, 756, 982, 1051, 1429, 1434, 1439, 1444

A-2 Attachment

Section 1R05: Fire Protection (71111.05)

Procedure

NUMBER TITLE REVISION

Administrative Procedure Fire Protection Program 9

UNT-005-013

Operating Procedure 009-004 Fire Protection 11-8

Maintenance Procedure MM-007-010 Fire Extinguisher Inspection 13

and Extinguisher

Replacement

Administrative Procedure UNT-005- Fire Protection Program 9

013

Fire Protection Procedure FP-001- Fire Protection System 17

015 Impairments

Training Manual Procedure Fire Protection Training 11-4

NTP-202

Section 1R07: Heat Sink Performance (71111.07)

Miscellaneous Documents

NUMBER TITLE/SUBJECT REVISION

EPRI TR-107397 Service Water Heat Exchanger Testing Guidelines March

1998

Work Order 13173

Section 1R12: Maintenance Effectiveness (71111.12)

Procedures

NUMBER TITLE REVISION

DC-121 Maintenance Rule 1

NUMARC 93-01 Industry Guideline for Monitoring the 3

Effectiveness of Maintenance at Nuclear Power

Plants

A-3 Attachment

Condition Reports

CR-WF3-2004-1945 CR-WF3-2005-3162 CR-WF3-2005-4943

CR-WF3-2004-2051 CR-WF3-2006-1755 CR-WF3-2006-0185

CR-WF3-2004-2517 CR-WF3-2006-0717 CR-WF3-2006-1035

CR-WF3-2004-2933 CR-WF3-2006-1756 CR-WF3-2005-4936

CR-WF3-2005-2598 CR-WF3-2006-1415 CR-WF3-2006-1562

CR-WF3-2005-1315 CR-WF3-2005-1075 CR-WF3-2005-3498

Section 1R14: Operator Response to NonRoutine Events (71111.14)

Miscellaneous Documents

NUMBER TITLE/SUBJECT REVISION

EN-OP-111 Operational Decision Making Instruction (ODMI)Process 1

EN-IS-123 Electrical Safety 1

Condition Reports

CR-WF3-2006-0746

Work Order 00012273

Section 1R15: Operability Evaluations (71111.15)

Procedures:

NUMBER TITLE REVISION

STI-W3-2005-0005 Emergency Diesel Generator A2 Starting Air 0

Receiver Capacity Test

OP-009-002 Emergency Diesel Generator 19

OP-901-524 Fire in Areas Affecting Safe Shutdown 0

Draft Regulatory Guide DG- Demonstrating the Feasibility and Reliability of February

1136 Operator Manual Actions in Response to Fire 2005

Regulatory Issue Summary Clarification of Post-Fire Safe-Shutdown Circuit December

2005-30 Regulatory Requirements 2005

A-4 Attachment

Condition Reports

CR-WF3-2006-1495 CR-WF3-2005-4943 CR-WF3-2001-0782

CR-WF3-2006-1660 CR-WF3-2001-1284 CR-WF3-2006-1735

Section 1R17: Permanent Plant Modifications (71111.17)

Miscellaneous Documents

NUMBER TITLE/SUBJECT REVISION

1564-3311 19FA Electronic Controls 14

Condition Reports

CR-WF3-1997-1985 CR-WF3-2006-0421 CR-WF3-2006-0952

CR-WF3-1997-2509 CR-WF3-1998-1032

Work Orders

WA 01162451

Section 1R19: Postmaintenance Testing (71111.19)

Procedures:

NUMBER TITLE REVISION

OP-903-052 Controlled Ventilation Area System Operability 9

Check

OP-903-118 Primary Auxiliaries IST Valve Tests 6

ME-007-050 Electroswitch Control/Latching Relay 5

ENS-MA-114 Post Maintenance Testing 5

EN-MA-101 Conduct of Maintenance 1

ME-004-142 480 Volt G.E. AKR-30/AKR-50 Breaker 3

Overhaul

CEP-IST-1 IST Bases Document 3

Condition Reports

CR-WF3-1999-0063 CR-WF3-2006-1308

A-5 Attachment

Work Orders

25187, 65416, 65353

Section 1R22: Surveillance Testing (71111.22)

Procedure

NUMBER TITLE REVISIONS

MM-007-033 IST Safety and Relief Valve Bench 0

Testing and Maintenance

STA-001-001 Containment Air Lock Door Seal Leakage 4

Test

ME-003-110 Fire Pump Diesel Starting Battery 7

(Quarterly)

OP-903-046 Emergency Feed Pump Operability Check Revision 15

ME-003-110 Fire Pump Diesel Starting Battery 7

(Quarterly)

MM-007-033 IST Safety and Relief Valve Bench 0

Testing and Maintenance

OP-903-011 High Pressure Safety Injection Pump 9

Preservice Operability Check

CEP-IST-1 IST Bases Document 3

Work Order 51040121, 51024833, 51020508, 51021167, 5101888, 51028329

Section 1EP1 (71114.01)

EP-001-001, "Recognition and Classification of Emergencies," Revision 19

EP-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

A-6 Attachment

EP-002-030, "Emergency Radiation Exposure Guidelines & Controls," Revision 9

EP-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 Documents

2005-04971, 2006-00126, 2006-00235

Radiation Work Permits

1915 RF-13, Remove and Replace LPRMs, Including Support Activities

1921 RF-13, Flow Control Valve Maintenance, Including Support Activities

1929 RF-13, Recirc Pump Work, Including Support Activities

Procedures

HP-001-107, High Radiation Area Access Control, Revision 18

HP-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 Documents

2005-04630, 2005-04820, 2005-04860, 2005-04898, 2005-05010, 2005-05066

2006-00008, 2006-00060, 2006-00293, 2006-00468, 2006-00674

Procedures

ENS-RP-105, Radiation Work Permits, Revision 7

UNT-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 2

Audits and Assessments

WLO-2006-00040, ALARA Pre-NRC Inspection Assessment

LO-WLO-2005-0005-01, ALARA Planning and Controls

WLO-2005-00053, Radiation Protection Organizational Effectiveness

Five Year ALARA Plan, 2006 - 2010

A-7 Attachment

Radiation Work Permits

RWP-2006-0011, Declared Pregnant Females

RWP-2006-0005, Tours and Inspections

RWP-2006-0064, Containment Entry at Power

Section 4OA1: Performance Indicator Verification (71151)

Procedures

EN-LI-114, Performance Indicator Process, Revision 1

Miscellaneous Documents

Batch Release Summary Information for 2005

Batch Release Summary Information for 2006

NRC Performance Indicator Technique Sheet for RETS/ODCM Radiological Effluent

Occurrences, dated 1/09/6 and 4/04/06

NRC Performance Indicator Technique Sheet for Occupational Exposure Control Effectiveness

dated 1/11/06 and 4/06/06

Section 4OA2: Identification and Resolution of Problems

Procedure

NUMBER TITLE REVISIONS

Standard Review Plan Emergency Diesel Engine Starting System 0

9.5.6

ECM98-017 Diesel Generator Starting Air Receiver 0

Pressure Process Limit

EN-LI-103 Operating License Amendment 0

STI-W3-2005-00 Emergency Diesel Generator A2 Starting 0

Air Receiver Capacity Test

EN-LI-113 Licensing Basis Document Change 1

Process

MM-007-033 IST Safety and Relief Valve Bench 0

Testing and Maintenance

Condition Reports

CR-WF3-2006-1537 CR-WF3-2006-1457 CR-WF3-2004-3891

CR-WF3-2006-1633 CR-WF3-2003-2502 CR-WF3-2005-4712

CR-WF3-2005-3983 CR-WF3-2006-1342 CR-WF3-2006-1459

CR-WF3-2006-1340 CR-WF3-2006-1459 CR-WF3-2004-1945

A-8 Attachment

CR-WF3-2004-2051 CR-WF3-2006-0717 CR-WF3-2005-4936

CR-WF3-2004-2517 CR-WF3-2006-1756 CR-WF3-2006-1562

CR-WF3-2004-2933 CR-WF3-2006-1415 CR-WF3-2005-3498

CR-WF3-2005-2598 CR-WF3-2005-1075 CR-WF3-2003-2502

CR-WF3-2005-1315 CR-WF3-2005-4943 CR-WF3-2005-4712

CR-WF3-2005-3162 CR-WF3-2006-0185

CR-WF3-2006-1755 CR-WF3-2006-1035

Miscellaneous Documents

NUMBER TITLE/SUBJECT REVISION

Waterford Quarterly Trend Report 1st Quarter 2006 0

Waterford Quarterly Trend Report 4th Quarter 2005 0

Work Order 51040121, 51024833, 51020508, 51021167, 5101888, 51028329

LIST OF ACRONYMS

NRC Nuclear Regulatory Commission

PDR Public Document Room

CFR Code of Federal Regulations

NRR Nuclear Reactor Regulation, Office of (NRC)

ASME Code American Society of Mechanical Engineers Boiler and Pressure Vessel

Code

ALARA As low as reasonably achievable

A-9 Attachment