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Category:Letter type:W
MONTHYEARW3F1-2023-0056, Owner'S Activity Report Form for Inservice Inspection Performed During Operating Cycle 24 / Refuel 242023-12-19019 December 2023 Owner'S Activity Report Form for Inservice Inspection Performed During Operating Cycle 24 / Refuel 24 W3F1-2023-0055, Reply to a Notice of Violation2023-12-14014 December 2023 Reply to a Notice of Violation W3F1-2023-0052, Core Operating Limits Report (COLR) - Cycle 26, Revision O2023-11-0707 November 2023 Core Operating Limits Report (COLR) - Cycle 26, Revision O W3F1-2023-0049, Revise Technical Specification 3/4.3.2 to Remove Exemption from Testing Certain Relays at Power to Support Elimination of Potential Single Point Vulnerability - Withdrawal2023-09-28028 September 2023 Revise Technical Specification 3/4.3.2 to Remove Exemption from Testing Certain Relays at Power to Support Elimination of Potential Single Point Vulnerability - Withdrawal W3F1-2023-0048, Special Report SR 2023-004-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days2023-09-25025 September 2023 Special Report SR 2023-004-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days W3F1-2023-0035, Application for Technical Specification Change to Revise Surveillance Requirements Included in the Surveillance Frequency Control Program2023-07-26026 July 2023 Application for Technical Specification Change to Revise Surveillance Requirements Included in the Surveillance Frequency Control Program W3F1-2023-0036, Special Report SR-2023-003-01 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days2023-05-0404 May 2023 Special Report SR-2023-003-01 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days W3F1-2023-0032, Annual Radioactive Effluent Release Report (ARERR) 20222023-04-27027 April 2023 Annual Radioactive Effluent Release Report (ARERR) 2022 W3F1-2023-0033, Submittal of Annual Radiological Environmental Operating Report - 20222023-04-27027 April 2023 Submittal of Annual Radiological Environmental Operating Report - 2022 W3F1-2023-0025, Annual Report of Individual Monitoring of Radiation Exposure for 2022 Per 10 CFR 20.22062023-04-11011 April 2023 Annual Report of Individual Monitoring of Radiation Exposure for 2022 Per 10 CFR 20.2206 W3F1-2023-0018, Updated Final Supplemental Response to NRC Generic Letter 2004-022023-03-30030 March 2023 Updated Final Supplemental Response to NRC Generic Letter 2004-02 W3F1-2023-0022, Registration of Dry Fuel Storage Cask Use2023-03-22022 March 2023 Registration of Dry Fuel Storage Cask Use W3F1-2023-0021, Submittal of Special Report SR 2023-003-00 Radiation Monitor Inoperable Greater than 7 Days2023-03-17017 March 2023 Submittal of Special Report SR 2023-003-00 Radiation Monitor Inoperable Greater than 7 Days W3F1-2023-0016, Registration of Dry Fuel Storage Cask Use2023-03-0303 March 2023 Registration of Dry Fuel Storage Cask Use W3F1-2023-0014, Reply to a Notice of Violation; EA-22-1192023-02-20020 February 2023 Reply to a Notice of Violation; EA-22-119 W3F1-2023-0013, Notification of Readiness for Supplemental Inspection2023-02-15015 February 2023 Notification of Readiness for Supplemental Inspection W3F1-2023-0007, Registration of Dry Fuel Storage Cask Use2023-02-0606 February 2023 Registration of Dry Fuel Storage Cask Use W3F1-2023-0010, Special Report SR 2023-002-00, Radiation Monitor Inoperable Greater than 7 Days2023-01-25025 January 2023 Special Report SR 2023-002-00, Radiation Monitor Inoperable Greater than 7 Days W3F1-2023-0002, SR 2023-001-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 30 Days2023-01-0505 January 2023 SR 2023-001-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 30 Days W3F1-2022-0067, Commitment Change Notification for Generic Safety Issue 191 and Generic Letter 2004-022022-12-20020 December 2022 Commitment Change Notification for Generic Safety Issue 191 and Generic Letter 2004-02 W3F1-2022-0054, Revise Technical Specification 3/4.3.2 to Remove Exemption from Testing Certain Relays at Power to Support Elimination of Potential Single Point Vulnerability2022-11-0101 November 2022 Revise Technical Specification 3/4.3.2 to Remove Exemption from Testing Certain Relays at Power to Support Elimination of Potential Single Point Vulnerability W3F1-2022-0063, Submittal of Emergency Preparedness Documents. Includes EP-001-001, Revision 372022-10-27027 October 2022 Submittal of Emergency Preparedness Documents. Includes EP-001-001, Revision 37 W3F1-2022-0059, Response to Clarification Questions Concerning Supplement to License Amendment Request to Adopt TSTF-5052022-10-13013 October 2022 Response to Clarification Questions Concerning Supplement to License Amendment Request to Adopt TSTF-505 W3F1-2022-0058, Reply to a Notice of Violation; EA-22-0332022-10-12012 October 2022 Reply to a Notice of Violation; EA-22-033 W3F1-2022-0049, Response to Request for Additional Information Regarding License Amendment Requests to Adopt 10 CFR 50.69 and TSTF-5052022-08-19019 August 2022 Response to Request for Additional Information Regarding License Amendment Requests to Adopt 10 CFR 50.69 and TSTF-505 W3F1-2022-0037, Submittal of Owner'S Activity Report Form for Inservice Inspection Performed During Operating Cycle 24 / Refuel 242022-08-0808 August 2022 Submittal of Owner'S Activity Report Form for Inservice Inspection Performed During Operating Cycle 24 / Refuel 24 W3F1-2022-0044, SR-2022-004-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days2022-07-0606 July 2022 SR-2022-004-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days W3F1-2022-0042, SR-22-003-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days2022-06-27027 June 2022 SR-22-003-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days W3F1-2022-0015, Response to Request for Additional Information to License Amendment Request to Revise Technical Specifications to Adopt TSTF-505, Revision 2, Provide Risk Informed Extended Completion Times - Ritstf.2022-05-16016 May 2022 Response to Request for Additional Information to License Amendment Request to Revise Technical Specifications to Adopt TSTF-505, Revision 2, Provide Risk Informed Extended Completion Times - Ritstf. W3F1-2022-0026, Report of Facility Changes, Tests, and Experiments and Commitment Changes for Two Year Period Ending April 28, 20222022-04-28028 April 2022 Report of Facility Changes, Tests, and Experiments and Commitment Changes for Two Year Period Ending April 28, 2022 W3F1-2022-0028, Annual Radiological Environmental Operating Report - 20212022-04-26026 April 2022 Annual Radiological Environmental Operating Report - 2021 W3F1-2022-0029, Annual Report of Individual Monitoring of Radiation Exposure for 2021 Per 10 CFR 20.22062022-04-26026 April 2022 Annual Report of Individual Monitoring of Radiation Exposure for 2021 Per 10 CFR 20.2206 W3F1-2022-0009, Supplement to Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components (Sscs) for Nuclear Power Reactors2022-04-25025 April 2022 Supplement to Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components (Sscs) for Nuclear Power Reactors W3F1-2022-0031, Proposed Revision to Reactor Vessel Surveillance Capsule Withdrawal Schedule to Reflect Location of Standby Capsules 3/W-104 and 6/W-2842022-04-25025 April 2022 Proposed Revision to Reactor Vessel Surveillance Capsule Withdrawal Schedule to Reflect Location of Standby Capsules 3/W-104 and 6/W-284 W3F1-2022-0020, Review of Preliminary Accident Sequence Precursor Report2022-04-11011 April 2022 Review of Preliminary Accident Sequence Precursor Report W3F1-2022-0017, Annual Report on Westinghouse Electric Company LLC Combustion Engineering Emergency Core Cooling System Performance Evaluation Models for Calendar Year 20212022-04-0707 April 2022 Annual Report on Westinghouse Electric Company LLC Combustion Engineering Emergency Core Cooling System Performance Evaluation Models for Calendar Year 2021 W3F1-2022-0019, WAT-2022-02 Post Exam Analysis2022-03-0909 March 2022 WAT-2022-02 Post Exam Analysis W3F1-2022-0011, Special Report SR-22-002-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days2022-02-0808 February 2022 Special Report SR-22-002-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days W3F1-2022-0008, SR-22-001-00, Waterford Steam Electric Station, Unit 3, Radiation Monitors Inoperable Greater than 7 Days2022-02-0101 February 2022 SR-22-001-00, Waterford Steam Electric Station, Unit 3, Radiation Monitors Inoperable Greater than 7 Days W3F1-2021-0074, Commitment Change Notification for Generic Safety Issue - 191 and Generic Letter 2004-022021-12-16016 December 2021 Commitment Change Notification for Generic Safety Issue - 191 and Generic Letter 2004-02 W3F1-2021-0064, Proposed Revision to Reactor Vessel Surveillance Capsule Withdrawal Schedule to Support Relocation of Capsules 104 and 2842021-11-30030 November 2021 Proposed Revision to Reactor Vessel Surveillance Capsule Withdrawal Schedule to Support Relocation of Capsules 104 and 284 W3F1-2021-0061, Supplement to License Amendment Request to Relocate Chemical Detection Systems Technical Specifications to Technical Requirements Manual2021-10-14014 October 2021 Supplement to License Amendment Request to Relocate Chemical Detection Systems Technical Specifications to Technical Requirements Manual W3F1-2021-0063, Request for One-Time Exemption from 10 CFR 50, Appendix E Biennial Emergency Preparedness Evaluated Exercise Requirements Due to Severe Storm Recovery2021-10-12012 October 2021 Request for One-Time Exemption from 10 CFR 50, Appendix E Biennial Emergency Preparedness Evaluated Exercise Requirements Due to Severe Storm Recovery W3F1-2021-0050, Response to U. S. Nuclear Regulatory Commission Request for Additional Information Regarding License Amendment Request to Adopt2021-10-0101 October 2021 Response to U. S. Nuclear Regulatory Commission Request for Additional Information Regarding License Amendment Request to Adopt W3F1-2021-0060, Response to Request for Additional Information Regarding License Amendment Request to Relocate Chemical Detection Systems Technical Specifications to Technical Requirements Manual2021-09-30030 September 2021 Response to Request for Additional Information Regarding License Amendment Request to Relocate Chemical Detection Systems Technical Specifications to Technical Requirements Manual W3F1-2021-0039, Application for Technical Specification Change to Revise Pressure/Temperature and Low Temperature Overpressure Protection for 55 Effective Full Power Years2021-08-25025 August 2021 Application for Technical Specification Change to Revise Pressure/Temperature and Low Temperature Overpressure Protection for 55 Effective Full Power Years W3F1-2021-0055, Supplement to License Amendment Request to Relocate Boration Systems Technical Specifications to the Technical Requirements Manual2021-08-20020 August 2021 Supplement to License Amendment Request to Relocate Boration Systems Technical Specifications to the Technical Requirements Manual W3F1-2021-0057, (Waterford 3) - Emergency Plan Revision 0522021-08-18018 August 2021 (Waterford 3) - Emergency Plan Revision 052 W3F1-2021-0054, License Amendment Request to Implement a Digital Upgrade to the Core Protection Calculator (CPC) System and Control Element Assembly Calculator (Ceac) System, Dated July 23, 20202021-07-29029 July 2021 License Amendment Request to Implement a Digital Upgrade to the Core Protection Calculator (CPC) System and Control Element Assembly Calculator (Ceac) System, Dated July 23, 2020 W3F1-2021-0051, Revised Licensing Technical Report for the Common Q Core Protection Calculator System - License Amendment Request to Implement a Digital Upgrade to the Core Protection Calculator System and Control Element Assembly Calculator2021-07-19019 July 2021 Revised Licensing Technical Report for the Common Q Core Protection Calculator System - License Amendment Request to Implement a Digital Upgrade to the Core Protection Calculator System and Control Element Assembly Calculator 2023-09-28
[Table view] Category:Licensee Response to Notice of Violation
MONTHYEARW3F1-2023-0055, Reply to a Notice of Violation2023-12-14014 December 2023 Reply to a Notice of Violation W3F1-2023-0014, Reply to a Notice of Violation; EA-22-1192023-02-20020 February 2023 Reply to a Notice of Violation; EA-22-119 W3F1-2022-0058, Reply to a Notice of Violation; EA-22-0332022-10-12012 October 2022 Reply to a Notice of Violation; EA-22-033 W3F1-2021-0028, Response to an Apparent Violation in NRC Inspection Report 05000382/2021013; EA-20-1142021-04-0202 April 2021 Response to an Apparent Violation in NRC Inspection Report 05000382/2021013; EA-20-114 W3F1-2019-0045, Updated Reply to a Notice of Violation; NRC Inspection Report 05000382/20180082019-06-20020 June 2019 Updated Reply to a Notice of Violation; NRC Inspection Report 05000382/2018008 W3F1-2019-0033, (Waterford 3) - Reply to Notice of Violation EA-18-020 Supplement2019-05-17017 May 2019 (Waterford 3) - Reply to Notice of Violation EA-18-020 Supplement W3F1-2018-0073, (Waterford 3) - Reply to a Notice of Violation; NRC Inspection Report 05000382/20180082018-12-14014 December 2018 (Waterford 3) - Reply to a Notice of Violation; NRC Inspection Report 05000382/2018008 W3F1-2018-0056, Reply to Notice of Violation EA-18-0202018-09-12012 September 2018 Reply to Notice of Violation EA-18-020 W3F1-2013-0072, Reply to a Notice of Violation: EA-12-2572013-12-18018 December 2013 Reply to a Notice of Violation: EA-12-257 W3F1-2012-0097, Reply to a Notice of Violation: EA-12-1982012-12-0303 December 2012 Reply to a Notice of Violation: EA-12-198 W3F1-2009-0043, Reply to Non-Cited Violation2009-09-16016 September 2009 Reply to Non-Cited Violation ML0629303022006-10-18018 October 2006 Response to NRC Inspection Report 05000382/2006009 Notice of Violation W3F1-2006-0053, Reply to Notice of Violation: EA-06-1362006-09-29029 September 2006 Reply to Notice of Violation: EA-06-136 W3F1-2006-0048, Reply to Notice of Violation: EA-06-1922006-09-18018 September 2006 Reply to Notice of Violation: EA-06-192 W3F1-2004-0040, Reply to Notice of Violation, EA-03-230, NRC Inspection Report No. 50-382/03-0072004-05-12012 May 2004 Reply to Notice of Violation, EA-03-230, NRC Inspection Report No. 50-382/03-007 2023-02-20
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Text
Entergy Operations, Inc.
17265 River Road Killona, LA 70057-3093 SEntergy Tel 504 739 6673 Fax 504 739 6698 mmason~entergy.com Michael E. Mason Licensing Manager, Acting Waterford 3 W3F1-2012-0097 10 CFR 2.201 December 3, 2012 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
Subject:
Reply to a Notice of Violation: EA-1 2-198 Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38
Reference:
NRC letter to Entergy Operations, Inc. "Waterford Steam Electric Station, Unit 3 - NRC Problem Identification and Resolution Inspection Report 05000382/2012008 and Notice of Violation," dated November 5, 2012 (ADAMS Accession No. ML12310A497)
Dear Sir or Madam:
In reference 1, the U.S. Nuclear Regulatory Commission (NRC) issued Notice of Violation EA-12-198 to Entergy Operations' Waterford Steam Electric Station, Unit 3 (Waterford 3).
Pursuant to the provisions of 10 CFR 2.201, Attachment 1 provides Waterford 3's reply to Notice of Violation EA-1 2-198.
This letter contains one new commitment, which is listed in Attachment 2.
If you have any questions or require additional information, please contact the acting Licensing Manager, Michael E. Mason, at (504) 739-6673.
Sincerely, MEM/RJP Attachments: 1) Reply to Notice of Violation: EA-1 2-198
- 2) List of Regulatory Commitments
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W3F1 -2012-0097 Page 2 cc: Mr. Elmo E. Collins, Jr. RidsRgn4MailCenter@nrc.gov Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 E. Lamar Blvd.
Arlington, TX 76011-4511 NRC Senior Resident Inspector Marlone. Davis@nrc.gov Waterford Steam Electric Station Unit 3 Dean.Overland@nrc.gov P.O. Box 822 Killona, LA 70066-0751 U. S. Nuclear Regulatory Commission Kaly.Kalyanam@nrc.gov Attn: Mr. N. Kalyanam Mail Stop O-07D1 Washington, DC 20555-0001
Attachment I to W3FI-2012-0097 Reply to Notice of Violation: EA-12-198 to W3F1 -2012-0097 Page 1 of 3 Reply to Notice of Violation EA-12-198 In U.S. Nuclear Regulatory Commission (NRC) letter to Entergy Operations, Inc. "Waterford Steam Electric Station, Unit 3 - NRC Problem Identification and Resolution Inspection Report 05000382/2012008 and Notice of Violation," dated November 5, 2012 (ADAMS Accession No. ML12310A497), the NRC issued Notice of Violation EA-12-198 to Entergy Operations' Waterford Steam Electric Station, Unit 3 (Waterford 3).
Pursuant to the provisions of 10 CFR 2.201, this enclosure provides Waterford 3's reply to Notice of Violation EA-1 2-198.
Description of Violation Violation Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion III, "Design Control,"
states, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in 10 CFR 50.2, are correctly translated into specifications, procedures, and instructions.
Contrary to the above, from March 10, 2011, to August 2, 2012, the licensee failed to establish measures to assure that applicable regulatory requirements and the design basis, as defined in 10 CFR 50.2, were correctly translated into specifications, procedures and instructions.
Specifically, the licensee had not established a design basis to determine the river level at which flood control measures were to be initiated for closing the water tight doors as required in Procedure OP-901-521, "Severe Weather and Flooding."
End of Violation This violation is associated with a Green Significance Determination Process finding.
Inspection Report 05000382/2012008, that accompanies the Notice of Violation, provides additional insight indicating that the need to establish a basis for initiating flood control measures was being tracked to completion in a corrective action. The due date for the corrective action was extended several times and had not been completed by the arrival of the inspection team. The failure to complete the corrective action to establish a basis for flood control measures in a timely manner was a performance deficiency. This finding had a cross-cutting aspect in the human performance area, resources component in that the licensee failed to maintain long term plant safety by maintenance of design margins and ensuring engineering backlogs low enough to support safety. H.2.a]
Reason for the Violation When the condition was first identified in 2010, Waterford 3 Condition Report CR-WF3-2010-3232 was initiated to address the lack of an adequate design basis for the Mississippi River level at which flood control measures are to be initiated. The corrective actions associated with this issue have had several due date extensions. Both Licensing and Engineering personnel have extended the corrective actions, and tended to justify the extensions based upon the river level being at below flood level at the time and that satisfactory interim actions were in place.
to W3F1 -2012-0097 Page 2 of 3 While the extensions did consider actual risk, no consideration of these actions being associated with a regulatory issue was documented. The fact that the corrective actions were addressing a regulatory issue was not discussed in due date extension requests or in the corrective action assignments. As a result, the actions were inappropriately extended.
Corrective Steps That Have Been Taken and the Results Achieved Licensing implemented additional internal guidance to improve its oversight of the completion of corrective actions associated with resolution of regulatory concerns and issues. Specific direction was given to obtain Licensing's approval to extend the corrective action due date and to approve its closure for regulatory related corrective actions issued by Licensing. Since development of the guidance, Licensing has been more intrusive in monitoring the completion of corrective actions associated with the resolution of regulatory concerns and issues.
Lessons learned from the untimeliness of corrective action completion were developed and communicated to the Engineering and Licensing Departments. The lessons learned included information about the importance of owning corrective actions, the need for corrective actions to be timely, and the need to determine as soon as possible if the assigned action cannot be completed as assigned.
Engineering has completed an Engineering Reply under Engineering Change (EC) 39741 that determined the maximum rate of level rise of the Mississippi River that will be used to establish a basis for implementing flood control measures. The value was based on the daily recorded Mississippi River levels for flooding events from the nearest river gage (located at Reserve, LA),
as provided by the U.S. Army Corps of Engineers (USACE).
The USACE Mississippi River levee design elevation documentation has been incorporated into the appropriate design documents.
A License Amendment Request (LAR) has been submitted to the NRC to move TS 3.7.5 to the Waterford 3 Technical Requirements Manual (TRM). This action will improve timely implementation of the design requirements for flooding into Waterford 3's Licensing Basis. The LAR is undergoing NRC review.
Corrective Steps That Will Be Taken
- 1) The time required to close all of the exterior doors and hatches listed in Attachment 3 of OP-901-521 will be determined and a conservative response time to perform the required flood protection actions at the site will be developed. This information will be used to establish a design basis for the Mississippi River level at which flood control measures are to be initiated for closing the water tight doors in Procedure OP-901-521, "Severe Weather and Flooding" and will be reflected in procedures by March 7, 2013.
- 2) Upon NRC approval of the LAR, TS 3.7.5 will be moved to the Waterford 3 Technical Requirements Manual (TRM). Subsequent revision of the TRM will establish requirements for the initiation of flood control measures with consideration given to the basis developed in item 1 above.
to W3F1 -2012-0097 Page 3 of 3 Date When Full Compliance Will Be Achieved Full compliance will be achieved by March 7, 2013. This date precedes the Mississippi River level rise in the Spring of 2013.
to W3FI-2012-0097 List of Regulatory Commitments
. Attachment 2 to W3F1 -2012-0097 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
TYPE SCHEDULED (Check One) COMPLETION COMMITMENT ONE- DATE TIME CONTINUING (If Required)
ACTION COMPLIANCE Waterford 3 will establish a design basis X March 7, 2013 for the Mississippi River level at which flood control measures are to be initiated for closing the water tight doors and Procedure OP-901-521, "Severe Weather and Flooding" will be updated as necessary.