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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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Entergy Operations, Inc.
17265 River Road Killona, LA 70057-3093 En teiy Tel 504 739 6685 Fax 504 739 6698 jjarrelentergy.com John P. Jarrell III Manager, Regulatory Assurance Waterford 3 W3F1 -201 8-0056 September 12, 2018 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Reply to Notice of Violation EA-18-020 Waterford Steam Electric Station, Unit 3 (Waterlord 3)
License No. NPF-38 Docket No. 50-382
REFERENCES:
NRC Letter, WATERFORD STEAM ELECTRIC STATION, UNIT 3 INSPECTION OF THE IMPLEMENTATION OF MITIGATION STRATEGIES AND SPENT FUEL POOL INSTRUMENTATION ORDERS AND EMERGENCY PREPAREDNESS COMMUNICATION/STAFFING/MULTI-UNIT DOSE ASSESSMENT PLANS-INSPECTION REPORT 05000382/2017009, July 20, 2018, [Accession Number: ML18201A492J.
Dear Sir or Madam:
This letter provides the Entergy Operations, Inc. (EOI) reply to Notice of Violation EA-18-020 (Reference), issued by the NRC to the Waterford Steam Electric Station, Unit 3 on July 20, 2018. This information is provided pursuant to the provisions of Title 10 Code of Federal Regulations 2.201.
Should you have questions regarding this report, please contact John P. Jarrell, Regulatory Assurance Manager, at (504) 739-6685.
SI,
Attachment:
Reply to Notice of Violation EA-1 8-020
W3F1-2018-0056 Page 2 of 2 cc: Mr. Kriss Kennedy, Regional Administrator U.S. NRC, Region IV RidsRgn4MailCenter@nrc.gov Mr. Anton Vegel, Director of Reactor Projects U.S. NRC, Region IV Anton.Vegel@nrc.gov U.S. NRC Project Manager for Waterford 3 April.Pulvirenti@nrc.gov U.S. NRC Senior Resident Inspector for Waterford 3 Frances.Ramirez@nrc.gov Chris.Speer@nrc.gov
Attachment to W3F1-2018-0056 Reply to Notice of Violation EA-18-020 (4 pages)
Attachment to W3F1-2018-0056 Page 1 of 4 Reply to Notice of Violation EA-18-020 In U.S. Nuclear Regulatory Commission (NRC) letter to Entergy Operations, Inc. "Waterford Steam Electric Station, Unit 3 - Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communications/Staffing/Multi-Unit Dose Assessment Plans - NRC Integrated Inspection Report 05000382/2017009 and Notice of Violation," dated July 20, 2018 (ADAMS Accession No. ML18201A492), the NRC issued Notice of Violation EA-18-020 to Entergy Operations' Waterford Steam Electric Station, Unit 3 (Waterford 3).
Pursuant to the provisions of 10 CFR 2.201, this enclosure provides Entergys reply to Notice of Violation EA-18-020.
Description of Violation Violation During an NRC inspection conducted from September 18, 2017, through June 7, 2018, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond-Design-Basis External Events, dated March 12, 2012,Section IV.A.2, requires, in part, that all licensees identified in Attachment 1 to this Order comply with the requirements described in Attachment 2 of this Order except to the extent that a more stringent requirement is set forth in the license.
Order EA-12-049, Attachment 1, identified Entergy Operations, Inc., Waterford Steam Electric Station, Unit 3, (Waterford 3) as a power reactor licensee subject to Section IV of the Order.
Order EA-12-049, Attachment 2, requires, in part, that licensees develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment and spent fuel pool cooling capabilities following a beyond-design-basis external event.
The transition phase requires providing sufficient, portable, on-site equipment and consumables to maintain or restore these functions until they can be accomplished with resources brought from off site. Licensees must also provide reasonable protection for the associated equipment from external events, and full compliance includes, in part, the staging or installation of equipment needed for the strategies.
ENTGWF081-REPT-001, Waterford Steam Electric Station Unit 3 Final Integrated Plan, Revision 1, dated July 20, 2016, provides the necessary guidance on strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities following a beyond-design-basis external event.
- Section 2.2, Strategies, states, in part, that Phase 2 strategies support the transition from installed plant equipment to FLEX equipment which is deployed by the on-shift personnel to maintain essential functions.
Attachment to W3F1-2018-0056 Page 2 of 4
- Section 2.3.2, Phase 2 Strategy, states, in part, that the capability for reactor core cooling is accomplished from a pre-staged FLEX core cooling pump to provide feedwater to the steam generators in the event the turbine-driven emergency feedwater pump fails or sufficient steam pressure is no longer available to drive the turbine-driven emergency feedwater pump turbine, and that the FLEX core cooling pump is powered by the FLEX diesel generator. Section 2.3.2 also states, in part, that reactor coolant system inventory control involves the use of refueling water storage pool or boric acid makeup tank inventory through a repowered charging pump which receives its power from the FLEX diesel generator. Section 2.3.2 further states, in part, that the FLEX diesel generator is capable of supplying power to a battery charger such that DC power for controls and instrumentation continues to be available to support the reactor coolant system core cooling function.
- Section 2.4.2, Phase 2 Strategy Modes 1-4, states in part, that the capability to provide spent fuel pool make-up and/or spray during Phase 2 is accomplished using the component cooling water make-up pumps which are powered by the FLEX diesel generator.
- Section 2.7, Planned Protection of FLEX Equipment, states, in part, that in order to assure reliability and availability of the FLEX equipment required by the FLEX strategy, Waterford 3 has sufficient equipment to address all functions on-site, plus one additional spare (i.e., an N+1 capability). Section 2.7 further states, in part, that the N+1 diesel generator provides the capability to restore the N function by relocating the N+1 diesel generator to the reactor auxiliary building from the N+1 storage building.
- Section 2.15.1, Method of Storage and Protection of FLEX Equipment, states, in part, that to assist with unanticipated unavailability of the N set, evaluations have been performed and pre-planned strategies have been developed to provide reasonable protection of specific N+1 equipment for predictable external events with pre-warning (i.e., Mississippi River flood and hurricanes) and instances where the N set is unavailable for conditions other than conduct of routine maintenance and testing during normal operations.
Contrary to the above, from June 1, 2016, to June 7, 2018, the licensee failed to adequately develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment and spent fuel pool cooling capabilities following a beyond-design basis external event. Specifically, the licensee failed to establish appropriate design and procedures associated with providing electrical power using the N+1 FLEX diesel generator to support transition phase (Phase 2) strategies necessary to maintain or restore the core cooling and spent fuel pool cooling capabilities in mitigating a beyond-design-basis external event.
This violation is associated with a Green Significance Determination Process finding.
End of Violation
Attachment to W3F1-2018-0056 Page 3 of 4 Reason For the Violation The reason for the violation described above is during the development of the stations Final Integrated Plan (FIP) Waterford 3 personnel inappropriately interpreted the guidance in NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, revision 0, regarding what was required to maintain N FLEX capability (in this case the FLEX diesel generator) when the N becomes unavailable.
NEI 12-06, revision 0, step 11.5.3, states:
- Portable equipment may be unavailable for 90 days provided that the site FLEX capability (N) is available.
- Portable equipment that is expected to be unavailable for more than 90 days or expected to be unavailable during forecast site specific external events (e.g., hurricane) should be supplemented with alternate suitable equipment.
- If portable equipment becomes unavailable such that the site FLEX capability (N) is not maintained, initiate actions within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore the site FLEX capability (N) and implement compensatory measures (e.g., use of alternate suitable equipment or supplemental personnel) within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Waterford personnel did not fully understand that to maintain N FLEX capability, the equipment replacing the N, in this case the N+1 diesel generator (DG), had to be fully protected from all site specific external hazards. This would be in compliance with step 11.3 of NEI 12-06, revision 0, which states FLEX mitigation equipment should be stored in a location or locations informed by evaluations performed per Sections 5 through 9 [of NEI 12-06, revision 0]
such that no one external event can reasonably fail the site FLEX capability.
Additionally, during the development of Waterfords FIP, Waterford personnel learned through industry sources that NEI was developing guidance to be endorsed by the NRC which would be incorporated into revision 2 of NEI 12-06. This revision, in part, allowed for required FLEX equipment unavailability for 45 days provided that the sites FLEX capability (N) was met but not protected for all of the sites applicable hazards. Waterford personnel assumed that incorporating this alternative into the stations Technical Requirements Manual (TRM) to comply with the FLEX strategy was acceptable. However, because Waterford failed to identify that this alternative needed to be reviewed and approved by the NRC, it was unacceptable to incorporate it.
Corrective Steps That Have Been Taken and the Results Achieved Current station procedures for severe weather direct the relocation of the N+1 DG to inside the Nuclear Plant Island Structure (NPIS) as a precaution for flooding and hurricanes.
On January 10, 2018, Operations Department issued the following Standing Order:
Since the current TRM 3.13.2, [Diverse and Flexible Coping Strategies (FLEX)
Equipment,] Action b.2 may not be allowed, more restrictive administrative controls are being put in place to suspend use of this TRM action until this condition is resolved. In the interim, should the FLEX N Diesel become Inoperable, the following actions should be taken:
Attachment to W3F1-2018-0056 Page 4 of 4
- 1. Relocate the FLEX N+1 Diesel to inside the Protected Area within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Although it would not be able to be credited per the TRM, this remains a safe, conservative action to potentially mitigate some ELAP events.
- 2. Enter TRM 3.13.2 Action c. This is the most appropriate interim action although the FLEX N+1 Diesel could still be utilized to mitigate some ELAP events.
- 3. If the FLEX N Diesel is not restored within the 72 hr requirement of TRM 3.13.2 Action c, then enter TRM 3.0.3. Seasonal considerations (such as no Hurricane threats and or river flooding threats) could potentially be utilized under TRM 3.0.3 to support justification of continued operation.
Corrective Steps That Will Be Taken Actions have been issued to develop the design, modification, and procedural guidance to provide the ability to stage and operate the N+1 FLEX DG inside the NPIS when the N FLEX DG is out of service. These actions shall ensure that the N+1 FLEX DG can be staged and operated where it is protected from all site specific external hazards ensuring N FLEX capability can be maintained when the N FLEX DG is out of service.
An action has been issued to revise the TRM and associated bases for Diverse and Flexible Coping Strategies (FLEX) Equipment to align with the FLEX Final Integrated Plan Safety Evaluation.
These corrective actions have been entered into Entergys corrective action program.
Date When Full Compliance Will Be Achieved Waterford 3 will be in full compliance by November 8, 2019.