ML14344A212

Audit of the Licensee'S Management of Regulatory Commitments - Audit Performed August 13-14, 2014

ML14344A212
Person / Time
Site:	Waterford
Issue date:	02/12/2015
From:	Michael Orenak Plant Licensing Branch IV
To:	Entergy Operations
Wang A
References
TAC MF4430
Download: ML14344A212 (21)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 12, 2015 Vice President, Operations Entergy Operations, Inc.

Waterford Steam Electric Station, Unit 3 -

17265 River Road Killona, LA 70057-3093 SUBJECT WATERFORD STEAM ELECTRIC STATION, UNIT 3 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO MF4430)

Dear Sir or Madam:

The U.S. Nuclear Regulatory Commission (NRC) informed licensees in Regulatory Issue Summary (RIS) 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments. RIS 2000-17 encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC.

The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that regulatory commitments are being effectively implemented. The previous audit of Entergy Operations, lnc.'s (the licensee's) commitment management program for Waterford Steam Electric Station, Unit 3 (WF3), was documented in an NRC letter dated August 29, 2011.

An onsite audit of the commitment management program for WF3 was performed on August 13-14, 2014. The NRC staff concludes, based on the audit, that (1) the licensee has implemented NRC commitments on a timely basis, and (2) the licensee has implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.

If you have any questions, please contact me at (301) 415-3229 or by e-mail at Michael.Orenak@nrc.gov.

Sincerely, Michael D. Orenak, Project Manager Plant Licensing IV-2 and Decommissioning Transition Branch Division of Operating R~actor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382

Enclosure:

Audit Report cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION' WA~ljit;IGTON, D.C. 2~555~0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS ENTERGY OPERATIONS. INC.

WATERFORD STEAM ELECTRIC STATION. UNIT 3 DOCKET NO. 50-382

1.0 INTRODUCTION AND BACKGROUND

The U.S. Nuclear Regulatory Commission (NRC) informed licensees in Regulatory Issue Summary (RIS) 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML003741774), that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments. RIS 2000-17 encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC. NEI 99-04 describes a "regulatory commitment" as an explicit statement tq take a specific action agreed to, or volunteered by, a licensee by a certain date and submitted in writing on the docket to the NRC .

. The NRC Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that regulatory commitments are being effectively implemented. An audit of Entergy Operations, lnc.'s (Entergy's, the licensee's) commitment management pr9gram for Waterford Steam Electric Station, Unit 3 (WF3) was performed at the plant site during August 13-14, 2014. The audit.

reviewed commitments made from June 30, 2011, to June 30, 2014. The previous audit of the licensee's regulatory commitment management program for WF3 was documented in an NRC letter dated August 29, 2011 (ADAMS Accessi<?n No. ML111580073).

NRR guidelines direct the NRR Project Manager to audit the licensee's commitment management program by assessing the adequacy of the licensee's implementation of a sample of commitments made to the NRC in past licensing actions (amendments, reliefs, exemptions, etc.) and activities (bulletins, generic letters, etc.).

Enclosure

2.0 AUDIT PROCEDURE AND RESULTS The audit consisted of three major parts: (1) verification of the licensee's implementation of NRC commitments that have been completed, (2) verification of the licensee's program for managing changes to NRC commitments, and (3) verification that all regulatory commitments reviewed were correctly applied in NRC staff licensing action reviews.

2.1 Verification of Licensee's Implementation of NRC Regulatory Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented commitments made to the NRC as part of past licensing actions/activities. For commitments not

• yet implemented, the NRC staff determines whether they have been captured in an effective program for future implementation. The audit also verifies that the licensee's commitment management system includes a mechanism to ensure traceability of commitments following initial implementation. This ensures that licensee personnel are able to recognize that future proposed changes to the affected design features or operating practices require evaluation in accordance with the commitment change control process.

2.1.1 Audit Scope The audit addressed a sample of commitments made during the review period. The audit focused on regulatory commitments (as defined above) made in writing to the NRC as a result of past licensing actions (amendments, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.). Commitments made in Licensee Event Reports or in response to Notices of Violation may be included in the sample, but the review will be limited to verification of restoration of compliance, not the specific methods used. Before the audit, the NRC staff searched ADAMS for the licensee's submittals during the last 3 years and selected a representative sample for verification.

The audit excluded the following types of commitments that are internal to licensee processes:

(1) Commitments made on the licensee's own initiative among internal organizational components.

(2) Commitments that pertain to milestones of licensing actions/activities (e.g., respond to an NRC request for additional information by a certain date). Fulfillment of these commitments was indicated by the fact that the subject licensing action/activity was completed. -

(3) Commitments made as an internal reminder to take actions to. comply with existing regulatory requirements such as regulations and technical specifications (TSs).

Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.

2.1.2 Audit Results Table 1 (provided as Attachment 1 of this report), "Verification of the Licensee's Implementation of NRC Commitments," provides the specific details and results of the audit for verification of the licensee's implementation of regulatory commitments. The NRC staff sampled nine open, nine

closed, and four "passive" commitments (descriptions provided in Section 2.2.1 ). The review of the audit sample information yielded two minor deficiencies. One sample did not contain the appropriate closeout documentation, but was correctly completed. Another sample had an incorrect source document date. All of the sample regulatory commitments were correctly added into WF3's tracking database (LRS). All regulatory commitments were completed within their due dates (whether they were active, passive, or closed). The licensee tracked, completed, and closed the sample regulatory commitments successfully.

2.2 Verification of the Licensee's Program for Managing Changes to NRC Commitments The primary focus of this part of the audit is to verify that the licensee has established administrative controls for modifying or deleting commitments made to the NRC. The NRC staff compared the licensee's process for controlling regulatory commitments to the guidelines in NEI 99-04, which the NRC has found to be an acceptable guide for licensees to follow for managing and changing commitments. The process used at WF3 is contained in the licensee's procedure EN-Ll-11 O, Revision 6, "Commitment Management Program." The audit reviewed a sample of commitment changes that included changes that were or will be reported to the NRC, and changes that were not or will not be reported to the NRC.

2.2.1 Audit Results 2.2.1.1 Procedure EN-Ll-110 The NRC staff reviewed the licensee's Procedure EN-Ll-110, Revision 6, against NEI 99-04.

Sections 1.0 and 2.0 of Procedure EN-Ll-11 O reference NEI 99-04 as a basis for this procedure.

The NRC staff found that the process described in Procedure EN-Ll-11 O generally follows the guidance of NEI 99-04 and provides detailed instructions for: (1) making and identifying regulatory commitments; (2) tracking regulatory commitments; (3) annotating implementing documents to provide traceability of regulatory commitments; (4) changing regulatory commitments; and (5) periodic reporting of commitment changes.

The licensee's Procedure EN-Ll-110, Section 3.0 [10] uses an unusual categorization for the types of open regulatory commitments. Other reactor licensees use open and continuing compliance as categories for their open regulatory commitments. Procedure EN-Ll-11 O uses active and passive for regulatory commitment categories.

• Active means that an action needs to be directly performed. This is used for both open and continuing compliance regulatory commitments.

• Passive means that the action is completed through some other means (procedure, administrate controls, etc.), but the action might still need t6 be continually performed. Many of these regulatory commitments could be considered closed or continuing compliance by other licensees, but LRS continues to track them as regulatory commitments.

Despite the unusual categorization, the licensee correctly implemented the procedure's categorical definitions, unlike other recently audited Entergy sites using Procedure EN-Ll-110.

The NRC staff concludes that the procedure used by the licensee to manage regulatory commitments provides the necessary attributes for an effective regulatory commitment management program in accordance with NEI 99-04.

2.2.1.2 Comments on Procedure EN-Ll-110 Procedure EN-Ll-11 O demonstrated that it provides the necessary attributes for an effective regulatory commitment management program in accordance with NEI 99-04. However, the audit uncovered room for improvement in the following areas:

• The licensee's Procedyre EN-Ll-110 does not contain a process or procedure to obtain and process regulatory commitments made by Entergy Corporate or other industry partners, such as NEI. The licensee's stated, not written, procedure for these types of regulatory commitments was to receive the regulatory commitment (through any channel) and determine if it will accept the regulatory commitment. The*

licensee stated that no outside entity, including Entergy Corporate, can make a regulatory commitment for WF3.

• For an active continual compliance regulatory commitment, no proceduralized step(s) exists in Procedure EN-Ll-110 for the completion documentation and reset of due dates in LRS. From the audit sample, the licensee correctly performed this step in each case by putting notes in the status section of the. commitment's LRS record; however, a procedure step would be useful.

• Multiple regulatory commitments can be derived from a single source document.

The LRS records that shared a single source document did not distinguish the commitment number in the source document. For enhanced traceability, each LRS entry could incorporate the commitment number from the source document.

• The licensee's Procedure EN-Ll-110, Section 5.12, states that the licensee should perform a self-assessment of the regulatory commitment management program prior to the NRC audit. The NRC staff provided a list of commitments for the audit 2 weeks prior to arrival at WF3; however, no self-assessment was performed. The licensee did perform a self-assessment in 2013. Within the first hour of the onsite audit, the licensee staff acknowledged that the procedure requests a self-assessment be performed, but one was not completed. Other recently audited Entergy sites did not know that a pre-audit self-assessment should have been completed.

2.2.1.3 LRS The licensee uses a tracking database named LRS that is common between Entergy sites.

LRS is used not only for regulatory commitments, but for other non-regulatory commitment items, such as the items listed in Section 2.1.1 of this report. Because of this co-mingling, the ability to distinguish regulatory commitments from the rest of the database proved to be difficult and time consuming. To find regulatory commitments, the licensee performed a search of LRS with select keywords, then opens up the originating document to look specifically for regulatory commitments. No method was available to directly identify all regulatory commitments with one

action. The licensee stated that it recognized this challenge and is currently in the process of updating the LRS database to allow for improved searches and regulatory commitment identification.

2.2.1.4 Review of Commitment Changes On April 30, 2012 (ADAMS Accession No. ML121220247), and April 29, 2014 (ADAMS Accession No. ML14129A350), the licensee submitted reports on the regulatory commitment changes per Procedure EN-Ll-11 O and NEI 99-04. Table 2, "Verification of the Licensee's Program for Managing NRC Commitment Changes" (provided as Attachment 2 of this report),

• verifies the licensee's program for managing commitment changes, as assessed from three samples. The NRC staff review of these samples found that all listed commitment changes within the audit date range were appropriate and performed per the guidance documents and procedures.

2.3 Verification That All Regulatory Commitments Were Correctly Applied The commitments reviewed for this audit were also evaluated to determine if they had been misapplied. A commitment is considered to be misapplied if the action comprising the commitment was relied on by the NRC staff in making a regulatory decision, such as a finding of public health and safety in an NRC safety evaluation associated with a licensing action.

Reliance on an action to support a regulatory decision must be elevated from a regulatory commitment to a legal obligation (e.g., license condition, condition of a relief request, regulatory exemption limitation or condition). A commitment is also considered to have been misapplied if the commitment involves actions that were safety significant (i.e., commitments used to ensure safety).

2.3.1 Audit Scope As discussed in LIC-105, the scope of this portion of the audit includes reviewing each of the commitments selected to sample the licensee's management of commitments (samples in Tables 1 and 2 examine the licensee's management of commitments) to determine if any had been misapplied. In addition, the NRC staff is directed to identify all license amendments, relief requests and exemptions that have been issued for a facility in the previous 3 years. Table 3, "Review of Issued License Amendments, Relief Requests and Exemptions" (provided as Attachment 3 of this report), lists each of these licensing actions for WF3.

2.3.2 Audit Results 2.3.3 Review of NRC License Amendments. Relief Requests, and Exemptions Table 3 reviews issued license amendments, relief requests, and exemptions. Thirteen samples in the interval from June 30, 2011, to June 30, 2014, were reviewed. Eight of those samples contained a total of 13 commitments. In all eight cases, the commitments were used properly by NRC staff.

As shown in Table 3, Items 1, 4, 5, 6, 8, 9, 13, and 14 contain a total of 13 commitments. The NRC staff did not use any of the commitments as the basis for its safety evaluations. However, many of the licensee's regulatory commitments were covered within the regulatory process of

' the submittal and did not need to be regulatory commitments (see Section 2.1.1 above). For the amendments regarding Cyber Security, the four commitments are the same as the amendment's proposed license conditions, making the proposed regulatory commitment redundant. For each of the seven regulatory commitments contained within the request(s) for alternative(s), the submittals were also paralleled by the proposed commitments. In any request(s) for alternative(s), the proposed alternative becomes a part of the licensee's inservice inspection or inservice testing programs and are therefore obligations (i.e., changing from one alternative to another alternative would require NRG approval), resulting in the proposed regulatory commitments being redundant.

3.0 OBSERVATIONS RELEVANT TO FUTURE AUDITS

• The licensee stated that it is in the process of reorganizing and updating LRS to allow for easier identification and tracking of regulatory commitments. Future audits should check the progress of this update process.

• The licensee stated that the southern Entergy sites (WF3, Grand Gulf Nuclear Station, and River Bend Station) would be coordinating a revision to Procedure EN-Ll-11 O to separate regulatory commitments from other items in LRS. Future

. audits should examine this updated section.

• The licensee quickly acknowledged that a pre-audit self-assessment/inspection was not performed, but is a part of NEI 99-04. The licensee could be reminded gf this pre-audit inspection, so there is sufficent time to perform it before NRG staff arrival.

• The process to incorporate Corporate/NEl/Pressurized Water Reactors Owners Group/etc., commitments could be proceduralized further, possibly into Procedure EN-Ll-110. Currently, there is no procedure or method to discover external commitments and one could not be communicated and forgotten. Future audits should check for the existence of a process for obtaining external commitments.

• The licensee's Procedure EN-Ll-11 O does not have a procedure step to update and document in LAS each successive completion of a continuing compliance commitment. Future audits should check the procedure for an added step to ensure this action occurs.

• Because multiple regulatory commitments can be derived from a single source document, LRS regulatory commitment records that share a single source document could incorporate the commitment number from the source document. Future audits should check on future LRS regulatory commitment records to see if they incorporate a source document commitment number.

• Many of the recent commitments were redundant with the submittal from which they came. Future audits should check the submittals and associated commitments for redundancy.

4.0 CONCLUSION

The NRC staff concludes, based on the above audit, that (1) the licensee has implemented NRC commitments on a timely basis, and (2) the licensee* has implemented an effective program for managing NRC commitment changes. The licensee's procedure used to manage commitments provides the necessary attributes for an effective commitment management program. The combination of the procedure, software platform, and support staff appear to be effective in their management of regulatory commitments. The licensee's staff appears to properly apply commitments in its regulatory decision making.

5.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT

\ Lilian Brown Joe Williams Principal Contributors: M. Orenak A. Wang Date: February 12, 2015 Attachments:

1. Table 1 - Verification of the Licensee's Implementation of NRC Commitments

2. Table 2 - Verification of the Licensee's Program for Managing NRC Commitment Changes

3. Table 3 ~ Review of NRC License Amendments, Relief Requests, and Exemptions

TABLE 1 Verification of the Licensee's Implementation of NRC Commitments (See Note 1)

Commitment Status and Audit Sample Item Commitment Disposition Tracking Number Results in accordance with and Licensee Submittal NEI 99-04 and Licensee's Item Open/Closed/ (ADAMS Commitment as stated in Licensee Procedures? (Yes/No) in No. Passive Accession No.) Subject Submittal boldface 1 A-27530 Letter dated Response to NRC's Submit Flood Hazard Evaluation to the Item tracked properly.

6/7/2012 Request for Information NRC. Commitment completion Open Regarding the Flooding scheduled.

Agencywide Aspects of Documents Access Recommendations 2. 1 and Yes and Management 2.3 of the Near-Term Task System (ADAMS) Force (NTTF) Review of Accession No. Insights from the Fukushima ML12164A676 Daiichi Accident.

2 A-27531 Letter dated Response to NRC's An approach for developing an Integrated Item tracked properly.

6/7/2012 Request for Information Assessment for Waterford Steam Electric, Open Regarding the Flooding Unit 3 (WF3) will be submitted 60 days after Yes ADAMS Accession Aspects of NRC endorsement of the integrated No. ML12164A676 Recommendations 2.1 and assessment guidance.

2.3 of the (NTTF) Review of Insights from the Fukushima Daiichi Accident.

3 A-27588 Letter dated Request for Alternative W3- Perform N-770-1 Examination of the 30" Item tracked properiy.

9/26/2013 ISl-023, American Society and _12" reactor coolant system (RCS) Commitment completion Open of Mechanical Engineers nozzles within 54 months of the Spring scheduled.

ADAMS Accession (ASME) Code Case N-770- 2014 outage [letter stated fall 2018 outage].

No. ML13270A041 1 Successive Examinations. Yes 4 A-27554 Letter dated Closure Option for Generic If Waterford 3 removes or modifies Item tracked properly.

5/16/2013 Safety Issue - 191. insulation debris sources in containment, Open then Waterford 3 will revise its' current Yes ADAMS Accession license bases within six months after any No. ML13137A133 refueling outage where insulation change occurs.

Attachment 1

Commitment Status and Audit Sample Item Commitment Disposition Tracking Number Results in accordance with and Licensee Submittal NEI 99-04 and Licensee's Item Open/Closed/ (ADAMS Commitment as stated in Licensee Procedures? (Yes/No) in No. Passive Accession No.) Subject Submittal boldface

• 5 A-27487 Letter dated Entergy's 60-Day Response Conduct the onsite and augmented staffing Item tracked properly.

5/10/2012 to the March 12, 2012, assessment considering functions related to Commitment completion Open Information Request, Action NTTF Recommendation 4.2. scheduled. Source document ADAMS Accession Plan for Completing date in LRS (WF3 tracking No. ML12135A087 Emergency Communication database) is incorrect.

and Staffing Assessments.

Yes 6 A-27488 Letter dated Entergy's 60-Day Response Provide onsite and augmented staffing Item tracked properly.

5/10/2012 to the March 12, 2012, assessment considering functions related to Commitment completion Open Information Request, Action NTTF Recommendation 4.2.

• scheduled. Source document ADAMS Accession Plan for Completing date in LRS is incorrect.

No. ML12135A087 Emergency Communication and Staffing Assessments. Yes 7 A-27489 Letter dated Entergy's 60-Day Response Provide a schedule of the time needed to Item tracked properly.

5/10/2012 to the March 12, 2012, implement changes associated with the Commitment completion Open Information Request, Action Phase 2 staffing assessment. scheduled. Source document ADAMS Accession Plan for Completing date in LRS is incorrect.

No. ML12135A087 Emergency Communication and Staffing Assessments. Yes 8 A-27490 Letter dated Entergy's 60-Day Response Identify changes that have been made or Item tracked properly.

5/10/2012 to the March 12, 2012, will be made to the emergency plan Commitment completion Open Information Request, Action regarding the on-shift or augmented staffing scheduled. Source document ADAMS Accession Plan for Completing changes associated with the Phase 2 date in LRS is incorrect.

No. ML12135A087 Emergency Communication staffing assessment.

and Staffing Assessments. Yes 9 A-27576 Letter dated Implementation of Multi- Waterford 3 plans to transition to software Item tracked properly.

6/27/2013 source Dose Assessment such as Unified Rascal Interface (URI), Commitment completion Open Capability. Version 2, which provides for an improved scheduled. Source document ADAMS Accession capability for multi-source dose date in LRS is missing.

No. ML13179A038 consequence analysis.

Yes

Commitment Status and Audit Sample Item Commitment Disposition Tracking Number Results in accordance with and Licensee Submittal NEI 99-04 and Licensee's Item Open/Closed/ (ADAMS Commitment as stated in Licensee Procedures? (Yes/No) in No. Passive Accession No.) Subject* Submittal boldface 10 A-27587 Letter dated 9/26/13 Request for Alternative W3- The actual examination summary and Item closed properly with ISl-023, ASME Code Case coverage results will be provided to the adequate documentation.

Closed ADAMS Accession N-770-1 Successive NRC only if the actual examination No. ML13270A041 Examinations. coverage is less than the weld with the Yes bounding examination coverage provided in Table 1.

11 A-27485 Letter dated Response to the March 12, Provide an assessment of the current Item closed properly with 10/31/12 2012, Information Request communications systems and equipment adequate documentation.

Closed Pursuant To 10 CFR used during an emergency event to identify ADAMS Accession 50.54(f) Regarding any enhancements that may be needed to Yes No. ML12306A194 Recommendation 9.3 For ensure communications are maintained Completing Emergency during a large scale natural event.

Communication Assessments.

12 A-27483 Letter dated Entergy's 90-Day Response Identify any interim actions that have been Item closed properly with 6/7/2012 to the March 12, 2012, taken or are planned prior to the completion adequate documentation.

Closed Information Request, Action of the staffing assessment.

ADAMS Accession Plan for Completing Yes No. ML12164A683 Emergency Communication and Staffing Assessments.

13 A-27478 Letter dated Entergy's 90-Day Response Describe any interim actions that have been Item closed properly with 6/7/2012 to the March 12, 2012, taken or are planned to be taken to adequate documentation.

Closed Information Request, Action enhance existing communications systems ADAMS Accession Plan for Completing power supplies until the communications Yes No. ML12164A683 Emergency Communication assessment and the resulting actions are and Staffing Assessments. complete.

Submit to NRC.

Commitment Status and Audit Sample Item Commitment Disposition Tracking Number Results in accordance with and Licensee Submittal NEI 99-04 and Licensee's Item Open/Closed/ (ADAMS Commitment as stated in Licensee Procedures? (Yes/No) in No. Passive Accession No.) Subject Submittal boldface 14 A-27565 Letter dated Entergy's Response to NRC Entergy Operations Inc. (Entergy), intends Item closed properly with 4/29/2013 Request for Information to respond to Enclosure 1 of NRC letter to adequate documentation.

Closed Pursuant to 10 CFR 50.54(f) Entergy, Request for Information Pursuant ADAMS Accession Regarding the Seismic to Title 10 of the Code of Federal Yes No. ML13119A461 Aspects of Regulations [10 CFR] 50.54(f) Regarding Recommendation 2.1 of Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Near-Term Task Force Review of Insights Review of Insights from the from the Fukushima Daiichi Accident, dated Fukushima Dai-ichi March 12, 2012, by following the approach Accident. described in Nuclear Energy Institute (NEI) letter to NRC, Proposed Path Forward for NTIF Recommendation 2. 1: Seismic Reevaluations, dated April 9, 2013.

Commitment Status and Audit Sample Item Commitment .. Disposition Tracking Number Results in accordance with and Licensee Submittal NEI 99-04 and Licensee's Item Open/Closed/ (ADAMS. Commitment as stated in Licensee Procedures? (Yes/No) in No. Passive Accession No.) Subject Submittal boldface 15 A-27511 Letter dated Request for Alternative W3- Waterford 3 will perform appropriate actions Item closed properly with 11/30/2012 1Sl-021, ASME Code Case to comply with ASME Section XI Code Case adequate documentation.

Closed N-770-1 Baseline N-770-1 baseline examinations for ADAMS Accession Examination Request for dissimilar metal weld 08-007 prior to startup Yes No. ML12339A070 Alternative. from the planned Spring 2014 refueling outage. Actions to accomplish compliance with ASME Section XI Code Case N-770-1 consist of the following:

1. Entergy will work with EPRI [Electric Power Research Institute] to design a mock up that incorporates the - configuration of the Waterford 3 08-007 OM [dissimilar metal] weld.

2. This mock-up will be used to demonstrate/qualify the UT [Ultrasonic Examination] technique utilized during the Fall refueling outage (RF18). This UT technique will be performed in accordance with the POI [Performance Demonstrative Initiative] Site Specific Configuration Mockup Requirements for OM Welds or through procedure expansion in accordance with the POI Program. If the demonstration should determine that additional scanning is required, Entergy will reexamine weld 08-007 during the scheduled Spring 2014 refueling outage using the newly qualified.

16 A-27510 Letter dated Reply to a Notice of Waterford 3 will establish a design basis for Item closed properly. Adequate 12/3/2012 Violation: EA-12-198. the Mississippi River level at which flood documentation was not Closed control measures are to be initiated for provided for the update of ADAMS Accession closing the water tight doors and Procedure procedure OP-901-521.

No. ML12340A011 OP-901-52.1, "Severe Weather and Flooding" will be updated as necessary. Yes

Commitment Status and Audit Sample Item Commitment Disposition Tracking Number Results in accordance with and Licensee Submittal NEI 99-04 and Licensee's Item Open/Closed/ (ADAMS Commitment as stated in Licensee . Procedures? (Yes/No) in No. Passive Accession No.) Subject Submittal boldface 17 A-27464 Letter dated License Amendment The proposed change will relocate the Item closed properly with 11/21/2011 Request to Relocate following Technical Specifications (TS) to adequate documentation.

Closed Technical Specifications to the Waterford 3 Technical Requirements ADAMS Accession the Technical Requirements Manual: Yes No. ML11326A283 Manual. TS 3.4.6 (Chemistry)

TS 3.7.5 (Flood Protection)

TS 3.7.9 (Sealed Source Contamination)

TS 3.9.5 (Communications).

18 A-27017 Letter dated Entergy Actions to Address Waterford 3 will continue to perform Item closed properly with 12/20/2006 . RF14 Batwing Failures. augmented inspections of the secondary adequate documentation.

Closed side of the steam generators in each ADAMS Accession subsequent refueling outage until the Yes No. ML063600109 current steam generators are replaced. The augmented inspections will include the upper batwing to wrapper bar welds, inspection of the stay cavity region, and foreign object search and retrieval (FOSAR) of the secondary side.

19 P-27535 Letter dated Entergy 120-Day Response Entergy confirms that it will use the seismic Item adequately documented.

7/9/2012 to NRC Request for walkdown procedure (EPRI Report Passive Information (RFI) Pursuant 1025286, "Seismic Walkdown Guidance: Yes ADAMS Accession to 10 CFR 50.54(f) For Resolution of Fukushima Near-Term No. ML12192A208 Regarding the Seismic Task Force Recommendation 2.3: Seismic")

Aspects of as endorsed by Reference 2 as the basis to Recommendation 2.3 of the conduct the walkdowns and develop the Near-Term Task Force needed information at Waterford 3.

Review of Insights from Fukushima Dai-ichi Accident Waterford Steam Electric Station, Unit 3.

Commitment Status and Audit Sample Item Commitment Disposition Tracking Number Results in accordance with and Licensee Submittal NEI 99-04 and Licensee's Item Open/Closed/ (ADAMS Commitment as stated in Licensee Procedures? (Yes/No) in No. Passive Accession No.) Subject Submittal boldface 20 P-27496 Letter dated Response Providing Entergy will conduct training on the Item adequately documented.

1/11/2007 Information Regarding mitigation strategy procedures or Passive Implementation Details for guidelines. Yes Nonpublic- the Phase 2 and Phase 3 Security-Related Mitigation Strategies.

Information 21 P-27019 Letter dated Entergy Actions to Address Steam generator leakage transient Item adequately documented.

12/20/2006 RF14 Batwing Failures simulator scenarios will be used in the Passive operating training in alternating cycles. Yes ADAMS Accession No. ML063600109 22 P-27472 Letter dated License Amendment Entergy will modify the Waterford 3 Final Item adequately documented.

2/22/2010 Request for Approval of Safety Analysis Report to include additional Passive Leak-Before-Break of the details on RCS Leakage Detection System Yes ADAMS Accession Pressurizer Surge Line. capability.

No. ML100550606 Note 1: The scope of this portion of the audit includes verification of the licensee's implementation of commitments associated with NRC licensing actions (e.g., amendments, relief requests, exemptions, orders) or licensing activities (e.g., bulletins, generic letters) during the previous 3 years. For purposes of this audit, the scope included samples based on review of licensee submittals dated June 30, 2011, through June 30, 2014. See Audit Report Section 2.1 for further details.

TABLE 2 Verification of the Licensee's Program for Managing NRC Commitment Changes (See Note 1)

Item Licensee Audit Results - Verification of Licensee's Program No. Tracking No. Description of Commitment Change for Managing Commitment Changes 9 A-27589 lnservice inspection of the Dissimilar Metal Weld (DMW) weld Commitment was made more conservative and a overlays with cast stainless steel safe ends for Pressurizer revised commitment was appropriate.

Letter dated Safety/Relief Valves' weld overlays will be performed at a 10/31/2013 higher frequency, every 9 years instead of 10 years, than other DMW weld overlays.

ADAMS Accession No. ML13305A127 2 A-27017 Augmented inspections are to be performed of the secondary The steam generators were replaced, so the side of the steam generators in each subsequent refueling commitment was properly deleted.

Letter dated 4/29/2014 outage untilthe current steam generators are replaced.

ADAMS Accession No. ML14129A350 3 A-27466 The licensee changed the date as to when their aging The licensee appropriately changed the committed date management program in accordance with Materials Reliability as to when the aging management program would be Letter dated 12/19/11 Program (MRP)-227 would be submitted to the NRC. At the submitted.

time of the letter, the approved version of the topical report ADAMS Accession had yet to be published.

No. ML11356A083 Note 1: The scope of this portion of the audit includes verifying that the licensee has established appropriate administrative controls for modifying or deleting regulatory commitments made to the NRC. The scope includes commitment changes reported to the NRC and commitment changes not reported to the NRC for the previous 3 years. See Audit Report Section 2.2.2.4 for further details.

Attachment 2

TABLE 3 Review of Issued License Amendments, Relief Requests, and Exemptions (See Note 1)

Safety Evaluation Discusses Item NRC letter date Commitments?

No. (Accession No.) Description (Yes/No) Audit Results 1 7/20/11 Amendment No. 234, Revise License Yes The licensee provided two commitments. The safety Condition and Approval of Cyber evaluation stated the licensee committed to dates related to ADAMS Accession Security Plan and Associated the Cyber Security Plan, but these dates can't be unilaterally No. ML111800021 Implementation Schedule changed per 10 CFR 73.54, "Protection of digital computer and communication systems and networks."

The staff dispositioned the commitments properly.

2 4/25/12 Amendment No. 235, Revise Technical No . No use of commitments Specification Applicability and Action ADAMS Accession Language for Revised Fuel Handling No. ML120940171 Accident Analysis 3 7/31/12 Amendment No. 236, Revise Technical No No use of commitments Specifications Related to Steam ADAMS Accession Generator Tube Integrity to Support No. ML12152A341 Replacement of Steam Generators 4 10/31/12 Amendment No. 237, Revise Technical No The licensee provided two commitments. One provided an Specification 3/4.7.4 Table 3.7-3, implementation date and the other was to provide a docked ADAMS Accession "Ultimate Heat Sink Minimum Fan supplement, both of which were used properly.

No. ML12250A435 Requirements Per Train" The staff did not discuss or use the commitments.

5 12/20/12 Amendment No. 238, Relocate No The licensee provided one commitment, which was basically to Technical Specification (TS) 3.4.6, TS perform the action they requested in the amendment request.

ADAMS Accession 3.7.5, TS 3.7.9, and TS 3.$.5 to the No. ML12278A331 Technical Requirements Manual The staff did not use or discuss the commitment.

6 12/20/12 Amendment No. 239, Revise Physical Yes The licensee provided one commitment. The safety evaluation Protection License Condition Related stated the licensee committed to dates related to the Cyber ADAMS Accession to Milestone 6 of the Cyber Security Security Plan, but these dates can't be unilaterally changed per No. ML12244A059 Plan Implementation Schedule 10 CFR 73.54.

The staff dispositioned the commitment properly.

Attachment 3

Safety Evaluation Discusses Item NRC letter date Commitments?

No. (Accession No.) Description (Yes/No) Audit Results 7 12/28/12 Amendment No. 240, Revise QA No No use of commitments Program Manual and Staff ADAMS Accession Qualification Technical Specifications No. ML12347A140 8 10/14/11 Request for Alternative W3-ISl-019 Yes The two commitments constitute the proposed alternative, from lnservice Inspection which results in them becoming a part of the ISi program and ADAMS Accession Requirements of Reactor Vessel Head elevating them to the obligation status. The staff No. ML112570168 In-Core Instrument Nozzles, Third acknowledged the commitments, but did not highlight this fact 10-Year lnservice Inspection Interval in the SE. The staff addres~ed the commitments properly.

The staff addressed the commitments in the proper manner.

9 10/14/11 Request for Alternative W3-ISl-018 Yes The one commitment constitutes the proposed alternative, from lnservice Inspection which results in it becoming a part of the ISi program and ADAMS Accession Requirements of Reactor Pressure elevating it to the obligation status. The staff acknowledged No. ML112570273 Vessel Head Control Element Drive the commitment, but did not highlight this fact in the SE. The Mechanism Nozzles, Third 10-Year staff addressed the commitment properly.

lnservice Inspection Interval The staff addressed the commitment in the proper manner.

10 1/4/12 Request for Alternative W3-CISl-002 to No No use of commitments ASME Code,Section XI, IWE-5221 for ADAMS Accession Post-repair Testing of Steel No. ML113330137 Containment Vessel Opening, Third 10-Year lnservice Inspection Interval 11 11/8/12 Relief Request VRR-WF3-2012-1 No No use of commitments Associated with Category A Leak Test ADAMS Accession of Component Cooling Water Check No. ML12293A362 Valve ACC-1088 for the Third 10-Year lnservice Inspection Interval 12 5/31/13 Request for Alternative W3-ISl-020, No No use of commitments ASME Code Case N-770-1 Baseline ADAMS Accession Examination Request for the Third No. ML13128A129 10-Year lnservice Inspection Interval

Safety Evaluation

/

Discusses Item NRC letter date Commitments?

No. (Accession No.) Description (Yes/No) Audit Results 13 8/2/13 Request for Alternative W3-ISl-021, Yes The two commitments constitute the proposed alternative, ASME Code Case N-770-1 Baseline which results in them becoming a part of the ISi program and ADAMS Accession Examination Request for the Third elevating them to the obligation status. The staff No. ML13192A222 10-Year lnservice Inspection Interval acknowledged the commitments, but did not highlight this fact in the SE. The staff addressed the commitments properly.

The staff addressed the commitments in the proper manner.

14 3/26/14 Request for Alternative W3-ISl-023, No The two commitments constitute the proposed alternative, ASME Code Case N-770-1 Successive which results in them becoming a part of the ISi program and ADAMS Accession Examinations, Third 10-Year lnservice elevating them to the obligation status. The staff did not No. ML14070A008 Inspection Interval acknowledge the commitments in the SE.

The staff did not utilize the licensee's commitment in the evaluation.

Note 1: The scope of this portion of the audit includes a review of all license amendments and relief requests issued during the previous 3 years for WF3. There were no exemptions issued for WF3 in the past 3 years. The intent of the review is to determine the extent to which commitments have been misapplied (e.g., commitment relied on by NRC staff rather than making the commitment an obligation or incorporating the commitment into a mandated licensing basis document). See Audit Report Section 2.3 for further details.

ML14344A212 *via email OFFICE NRR/DOR/LPL4-2/PM N RR/DORL/LPL4-2/LA NRR/DORL/LPL4-2/LA NAME MOrenak PBlechman JBurkhardt*

DATE 2/3/15 12/18/15 1/12/15 OFFICE NRR/DORL/LPL4-2/BC NRR/DORL/LPL4-2/PM NAME MKhanna MOrenak DATE 2/11/15 2/12/15