ML18319A379

NRC Problem Identification and Resolution Inspection Report 05000382/2018008 and Notice of Violation

ML18319A379
Person / Time
Site:	Waterford
Issue date:	11/15/2018
From:	Geoffrey Miller Division of Reactor Safety IV
To:	Dinelli J Entergy Operations
References
IR 2018008
Download: ML18319A379 (28)

See also: IR 05000382/2018008

Text

November 15, 2018

Mr. John Dinelli

Site Vice President

Entergy Operations, Inc.

17265 River Road

Killona, LA 70057-0751

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

IDENTIFICATION AND RESOLUTION INSPECTION

REPORT 05000382/2018008 AND NOTICE OF VIOLATION

Dear Mr. Dinelli:

On October 4, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed a problem

identification and resolution inspection at your Waterford Steam Electric Station, Unit 3. The

NRC inspection team discussed the results of this inspection with you and other members of

your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations corrective action program and the stations

implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating,

and correcting problems, and to confirm that the station was complying with NRC regulations

and licensee standards for corrective action programs. Based on the samples reviewed, the

team determined that your staffs performance in each of these areas adequately supported

nuclear safety. However, the team identified an area for improvement in the prioritization

process for security-related condition reports. Specifically, unless associated with a significant

NRC violation, plant corrective action procedures do not provide steps that would direct

security-related condition reports to be assigned as a Category A, Significant Condition

Adverse to Quality, which requires corrective actions to preclude repetition.

The team also evaluated the stations processes for use of industry and NRC operating

experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of

these areas adequately supported nuclear safety. However, in the area of self-assessment and

audits, some examples were identified where extent of condition was not pursued in a timely

fashion or apparently not considered.

Finally the team reviewed the stations programs to establish and maintain a safety-conscious

work environment, and interviewed station personnel to evaluate the effectiveness of these

programs. Based on the teams observations and the results of these interviews the team found

that the Waterford Steam Electric Station, Unit 3, had an effective safety-conscious work

environment. Your employees appeared willing to raise nuclear safety concerns through at

J. Dinelli 2

least one of the several means available. However, in the area of security, the team found

evidence of challenges to your organizations safety-conscious work environment. Specifically,

the staff complained that a number of non-safety work condition issues had not been

successfully addressed, and that attempts to check on the progress of these issues went

unanswered. As a result, the team concluded that the lack of tracking mechanisms or

effectiveness reviews for actions taken to improve these work condition issues has created an

environment where condition reports for non-safety issues may seem ineffectual.

The NRC inspection team documented two findings of very low safety significance (Green) in

this report. These two findings involved violations of NRC requirements; one of these violations

was determined to be Severity Level IV under the traditional enforcement process. The NRC is

treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the

Enforcement Policy.

The enclosed report also discusses a third violation associated with a finding of very low

safety significance (Green). The NRC evaluated this violation in accordance with

Section 2.3.2 of the NRC Enforcement Policy, which can be found at

http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The violation is cited in

the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in

detail in the subject inspection report. The violation is being cited in the Notice because the

violation did not meet the criteria to be treated as an NCV because your staff did not restore

compliance within a reasonable period of time after the violation was previously identified by the

NRC as NCV 05000382/2016008-01.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. If you have additional information that you

believe the NRC should consider, you may provide it in your response to the Notice. The NRCs

review of your response to the Notice will also determine whether further enforcement action is

necessary to ensure your compliance with regulatory requirements.

If you contest the violations or significance of these NCVs, you should provide a response within

30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with

copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the

NRC resident inspector at the Waterford Steam Electric Station, Unit 3.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a

response within 30 days of the date of this inspection report, with the basis for your

disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,

Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the

NRC resident inspector at the Waterford Steam Electric Station, Unit 3.

J. Dinelli 3

This letter, its enclosure, and your response will be made available for public inspection and

copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room

in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

To the extent possible, your response should not include any personal privacy or proprietary

information so that it can be made available to the public without redaction.

Sincerely,

/RA/

Geoffrey B. Miller, Team Leader

Inspection Program and Assessment Team

Division of Reactor Safety

Docket No. 50-382

License No. NPF-38

Enclosures:

1. Notice of Violation

2. Inspection Report 05000382/2018008

w/ Attachment: Information Request

cc: Electronic Distribution to Waterford

Steam Electric Station

NOTICE OF VIOLATION

Entergy Operations, Inc. Docket No. 50-382

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

During a NRC inspection conducted September 17 through October 4, 2018, a violation of NRC

requirements was identified. In accordance with the NRC Enforcement Policy, the violation is

listed below:

10 CFR Part 50, Appendix B, Criterion XV, requires, in part, that nonconforming items shall

be reviewed and accepted, rejected, repaired or reworked in accordance with documented

procedures.

Contrary to the above, in May 2016, the licensee failed to review and accept, reject, repair

or rework nonconforming items in accordance with documented procedures. Specifically,

following receipt of information from Electroswitch that a number of basic components within

relays and switches did not conform to quality requirements, the licensee failed to dedicate

these commercial-grade parts as described in 10 CFR Part 21.

This violation is associated with a Green significance determination process finding.

Pursuant to the provisions of 10 CFR 2.201 Entergy Operations, Inc. is hereby required to

submit a written statement or explanation to the U.S. Nuclear Regulatory Commission,

ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional

Administrator, U.S. Nuclear Regulatory Commission, Region IV, 1600 E. Lamar Blvd, Arlington,

Texas 76011 and a copy to the NRC Resident Inspector at the Waterford Steam Electric

Station, Unit 3, within 30 days of the date of the letter transmitting this Notice of Violation

(Notice). This reply should be clearly marked as a, Reply to a Notice of Violation, NRC

Inspection Report 05000382/2018008 and should include for each violation: (1) the reason for

the violation, or if contested, the basis for disputing the violation or severity level; (2) the

corrective steps that have been taken and the results achieved; (3) the corrective steps that will

be taken; and (4) the date when full compliance will be achieved. Your response may reference

or include previous docketed correspondence, if the correspondence adequately addresses the

required response.

If an adequate reply is not received within the time specified in this Notice, an Order or a

Demand for Information may be issued as to why the license should not be modified,

suspended, or revoked or why such other action as may be proper should not be taken. Where

good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response, with

the basis for your denial, to the Director, Office of Enforcement, United States Nuclear

Regulatory Commission, Washington, DC 20555-0001.

Your response will be made available electronically for public inspection in the NRC Public

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

site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, it should not include

any personal privacy or proprietary information so that it can be made available to the public

without redaction. If personal privacy or proprietary information is necessary to provide an

acceptable response, then please provide a bracketed copy of your response that identifies the

Enclosure 1

information that should be protected and a redacted copy of your response that deletes such

information. If you request withholding of such material, you must specifically identify the

portions of your response that you seek to have withheld and provide in detail the bases for your

claim of withholding (e.g., explain why the disclosure of information will create an unwarranted

invasion of personal privacy or provide the information required by 10 CFR 2.390(b), to support

a request for withholding confidential commercial or financial information).

Dated this 15 day of November 2018

2

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number: 05000382

License Number: NPF-38

Report Number: 05000382/2018008

Licensee: Entergy Operations, Inc.

Facility: Waterford Steam Electric Station, Unit 3

Location: Killona, Louisiana

Inspection Dates: September 17, 2018 to October 4, 2018

Inspectors: R. Azua, Senior Reactor Inspector

J. Josey, Senior Resident Inspector

C. Jewett, Physical Security Inspector

C. Speer, Resident Inspector

Approved By: G. Miller, Team Leader

Inspection Program and Assessment Team

Division of Reactor Safety

Enclosure 2

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees

performance by conducting a problem identification and resolution inspection at the Waterford

Steam Electric Station, Unit 3 in accordance with the Reactor Oversight Process. The Reactor

Oversight Process is the NRCs program for overseeing the safe operation of commercial

nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more

information. NRC-identified and self-revealed findings, violations, and additional items are

summarized in the table below. Licensee-identified non-cited violations are documented in the

Inspection Results at the end of this report.

List of Findings and Violations

Failure to Identify and Correct a Condition Adverse to Quality

Cornerstone Significance Cross-cutting Inspection

Aspect Procedure

Mitigating Green [H.14] - 71152

Systems NCV 05000382/2018008-02 Conservative Problem

Bias Identification

and

Resolution

The team identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI,

Corrective Action, associated with the licensees failure to identify and correct condition

adverse to quality associated with the breeching of hazard barriers. Specifically, while

developing corrective actions for failure to close exterior doors the licensee identified that they

had no process for tracking impaired hazard barriers such that control room operators would

be aware of which barriers are impaired and which equipment may not be able to perform its

specified function to protect safety-related structures, systems and components, but the

licensee then failed to correct this issue. The licensee entered this issue into the corrective

action program as Condition Report CR-WF3-2018-05273.

Failure to Update the Final Safety Analysis Report

Cornerstone Significance Cross-cutting Inspection

Aspect Procedure

NA Green None 71152

SL-IV 05000382/2018008-03 Problem

Closed Identification

and

Resolution

The team identified a Severity Level IV non-cited violation of 10 CFR 50.71(e), Maintenance

of Records, Making Reports, associated with the licensees failure to correctly update the

Updated Final Safety Analysis Report (UFSAR). Specifically, the licensee had incorrect

information in the UFSAR with regard to codes used (CEFLASH and TRANFLO). The

licensee entered this issue into the corrective action program as Condition Report CR-WF3-

2018-01612

2

Failure to Control Nonconforming Parts

Cornerstone Significance Cross-cutting Inspection

Aspect Procedure

Mitigating Green [P.2] - Problem 71152

Systems NOV 05000382/2018008-01 Identification and Problem

Open Resolution Identification

and

Resolution

The team identified a Green cited violation of 10 CFR Part 50, Appendix B, Criterion XV, which

occurred when the licensee failed to dedicate commercial-grade relays for use in safety-related

applications. After receiving information from a vendor that more than 124 relays potentially

installed in safety-related applications did not conform to quality assurance standards, the

licensee failed to take appropriate steps to accept these commercial-grade relays as basic

components. The licensee entered this issue into the corrective action program as Condition

Report CR-WF3-2018-05590.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs)

in effect at the beginning of the inspection unless otherwise noted. Currently approved

IPs with their attached revision histories are located on the public website at

http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.

Samples were declared complete when the IP requirements most appropriate to the inspection

activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor

Inspection Program - Operations Phase. The team reviewed selected procedures and records,

observed activities, and interviewed personnel to assess licensee performance and compliance

with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES - BASELINE

71152Problem Identification and Resolution

Biennial Team Inspection (1 Sample)

The team performed a biennial assessment of the licensees corrective action program, use

of operating experience, self-assessments and audits, and safety-conscious work

environment. The assessment is documented below.

(1) Corrective Action Program Effectiveness: Problem Identification, Problem Prioritization

and Evaluation, and Corrective Actions - The team reviewed the stations corrective

action program and the stations implementation of the program to evaluate its

effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to

confirm that the station was complying with NRC regulations and licensee programs and

procedures. The sample included approximately 250 condition reports and other

documents reviewed. This included an in-depth 5-year review of condition reports

associated with Control Room and Auxiliary Building Ventilation systems.

(2) Operating Experience, Self-Assessments, and Audits - The team evaluated the stations

processes for use of industry and NRC operating experience. The team also evaluated

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the effectiveness of the stations audits and self-assessment program. The sample

included industry operating experience communications including 10 CFR Part 21

notifications and other vendor correspondence, NRC generic communications, and

publications from various industry groups including INPO and EPRI, plus associated site

evaluations.

(3) Safety-Conscious Work Environment - The team evaluated the stations safety-

conscious work environment. The team interviewed station personnel and the employee

concerns program manager.

(4) Beyond Design Basis Procedures - The team reviewed the licensees actions to address

an identified concern with beyond design basis procedures addressing control room

ventilation following a loss of power.

Corrective Action Program Assessment 71152Problem

Identification and

Resolution

Corrective Action Program: Based on the samples reviewed, the team determined that the

licensees performance in each of these areas adequately supported nuclear safety.

Effectiveness of Problem Identification: Overall, the team found that the licensees

identification and documentation of problems were adequate to support nuclear safety.

Effectiveness of Prioritization and Evaluation of Issues: Overall, the team found that the

licensees prioritization and evaluation of issues were adequate to support nuclear safety.

However, the team identified an area for improvement in the assessment process of

security-related condition reports. The Condition Report Classification Guidance found on

page 45

of procedure EN-LI-102, Revision 33, did not provide guidance for security-related

CRs to reach the level of Category A, Significant Condition Adverse to Quality,

without an associated significant NRC violation. The team determined that the lack of

mention of security or physical protection program in this section could lead to potential

security issues that require corrective actions to prevent recurrence, to be missed. Of note,

10 CFR 73.55 (b)(10) explicitly states the need to prevent recurrence of failures and

deficiencies in the physical protection program. The licensee entered this issue into their

corrective action program as a corporate condition report HQN-2018-2201.

Effectiveness of Corrective Actions: Overall, the team concluded that the licensees corrective

actions adequately supported nuclear safety.

Operating Experience, Self-Assessments, and Audits Assessment 71152Problem

Identification and

Resolution

Operating Experience and Self-Assessments and Audits: Based on the samples reviewed,

the team determined that the licensees performance in each of these areas adequately

supported nuclear safety. However, though the licensee appeared to do an adequate job in

addressing identified issues, the team identified some examples where extent of condition

was not pursued in a timely fashion or apparently not considered.

4

For example, the licensee repeatedly identified shortcomings in the engineering department in

a variety of areas (design control, acceptance testing, 10 CFR 50.59 reviews) from a variety of

sources (Nuclear Independent Oversight, Safety Review Committee), as well as declining

performance trends in both design and system engineering throughout 2017. For each

observation, the licensee initiated a condition report to document and evaluate the condition.

As of September 2018 the licensee had planned but not initiated a condition report to evaluate

and assess the overall performance of the engineering department to identify any other

potential shortcomings. Though not procedurally required, the team determined that more

timely action to evaluate and address the potential for overall degrading performance in

engineering would have been appropriate.

The team reviewed a variety of sources of Operating Experience including 10 CFR Part 21

notifications and other vendor correspondence, NRC generic communications, and

publications from various industry groups including INPO and EPRI. The team determined

the licensee is adequately screening and addressing issues identified through operating

experience that apply to the station, and that this information is evaluated in a timely manner

once it is received.

The team did identify an example where the licensee failed to correct a previously identified

NRC non-cited violation (NCV) related to a 10 CFR Part 21 notification. This issue is

documented in the Inspection Results section of this report.

Safety-Conscious Work Environment Assessment 71152Problem

Identification and

Resolution

Safety-Conscious Work Environment: The team reviewed the stations programs to establish

and maintain a safety-conscious work environment, and interviewed station personnel to

evaluate the effectiveness of these programs. Based on the teams observations and the

results of these interviews the team found that the licensee had an effective safety-conscious

work environment. Plant employees appeared willing to raise nuclear safety concerns

through at least one of the several means available.

However, in the area of security, the team found evidence of challenges to this organizations

safety-conscious work environment. Specifically, the staff complained that a number of non-

safety work condition issues had not been successfully addressed. The team reviewed a

number of condition reports in security and observed that there were a number of repeat

condition reports that have been frustrating the security staff related to the secure owner

controlled area fence and the air conditioning system in the security roving vehicle. The

security staff also complained that they had written a number of reports regarding conditions

in the bullet-resistant enclosures and felt that these issues have not been addressed.

Furthermore, the security staff indicated that emails sent to ask about the progress on these

condition reports went unanswered. One officer complained that he/she felt that writing

condition reports for these issues was a waste of time. As a result, the team concluded that

the lack of tracking mechanisms or effectiveness reviews for actions taken to improve these

work condition issues has created an environment where condition reports for non-safety

security-related issues may seem ineffectual.

5

Beyond Design Basis Procedures 71152Problem

Identification and

Resolution

The team identified that the licensee had made limited progress in this area in the short period

of time that had passed since Violation 05000382/2017009-01 was identified. The team

reviewed those actions that the licensee was planning to take and determined that these

actions appear to be appropriate to address NRC concerns if implemented as described. The

team determined that any conclusions regarding NRC concerns will require a final review of

licensee actions in a future inspection. .

INSPECTION RESULTS

Failure to Control Nonconforming Parts

Cornerstone Significance Cross-cutting Inspection

Aspect Procedure

Mitigating Green [P.2] - 71152

Systems NOV 05000382/2018008-01 Problem Problem

Open Identification Identification

and and

Resolution Resolution

The team identified a Green cited violation of 10 CFR Part 50, Appendix B, Criterion XV,

Nonconforming Materials, Parts, or Components, when the licensee failed to dedicate

commercial-grade relays for use in safety-related applications. After receiving information

from a vendor that more than 124 relays potentially installed in safety-related applications did

not conform to quality assurance standards, the licensee failed to take appropriate steps to

accept these commercial-grade relays as basic components.

Description: On May 10, 2016, Electroswitch submitted a 10 CFR Part 21 report to the NRC

(ML16139A834) documenting that a large population of rotary switches and relays it had

manufactured since 1984 had not conformed to quality assurance program requirements.

(Electroswitch discontinued its 10 CFR Part 50, Appendix B, quality assurance program

effective March 24, 2016). The 10 CFR Part 21 notification noted that, Electroswitch did not

procure materials, parts, equipment, and/or services from an Appendix B supplier nor were

applicable Commercial Grade Surveys, Source Inspections, and Material Analyses

performed, for a number of materials used in the manufacture of these components, which it

sold as safety-related basic components. The Waterford Steam Electric Station, Unit 3 was

listed as an affected facility in a May 11, 2016, update to Electroswitchs report.

On May 27, 2016, the NRC issued Inspection Report 99900833/2016-201 for the vendor

inspection of Electroswitch and issued a Notice of Nonconformance (ML16147A211). This

inspection report states:

Electroswitch did not use any form of commercial grade dedication (CGD) for their

commercially procured materials, parts, and services, and instead chose to

manufacture and test final products under their 10 CFR Part 50, Appendix B program.

This approach is acceptable, provided all safety function characteristics for their

products are verified or tested to ensure the products can meet their intended safety

function under the most adverse design conditions. However, Electroswitch used

commercial materials, components, and services without performing adequate

verification during the receipt, testing, or other phases of their manufacturing process

to ensure that the materials and components are equivalent to what was originally

6

qualified, and the services were suitable for use in that they had the capability and

traceability to perform the required tests. The NRC inspection team noted this practice

had been in place since Electroswitch began offering products under their 10 CFR

Part 50, Appendix B program. Electroswitch decided to discontinue their Appendix B

program as of March 2016.

On May 25, 2016, the licensee initiated Condition Report CR-WF3-2016-03525 to evaluate

Electroswitchs Part 21 report. On June 13, 2016, the licensee performed a Part 21 screening

using procedure EN-LI-108-01, Attachment 9.1, which required that for safety-related parts

installed in the plant, personnel performing the screen must, assure that the issue has been

or is being evaluated under 10 CFR 50.72 and/or 50.73, and includes the requirement of

10 CFR Part 21. Issue a new condition report if needed. The evaluator noted that,

Electroswitch has determined it does not have the capability to perform the evaluation to

determine if a defect, which could create a substantial safety hazard, exists. On June 21,

2016, the licensee documented that no Part 21 notification was required because a Part 21

notification had been issued by the vendor. However, the licensee failed to account for

Electroswitchs statement that it lacked information to determine whether the identified

deviation could create a substantial safety hazard, and was therefore a defect, at any

individual station.

On July 19, 2016, the licensee completed an engineering evaluation concluding the following:

Electroswitch relays and rotary switches have been designed by Electroswitch for

decades and have been proven through testing and performance (i.e., OEs) as being

reliable. Based on corrective actions taken by Electroswitch and the applications and

reliability of these relays and switches, it is concluded that the nonconformance issues

on Electroswitch products described in this Part 21 report does not create a

substantial safety hazard such that the loss of a safety-related function is initiated.

Therefore, the function of a Technical Specification system, structure, or component is

not adversely affected as a result of this Part 21 report.

The licensee further concluded that, No additional corrective actions are required and

Electroswitch materials in the warehouse may be issued as required. The team determined

these conclusions were not valid because they accepted nonconforming components as fully

qualified and permitted further installation of commercial grade components in safety-related

applications with no acceptance testing or other dedication, contrary to the requirements of

10 CFR Part 21.

On January 26, 2017, the NRC issued a non-cited violation of 10 CFR 50, Appendix B,

Criterion XV, for the licensees failure to adequately address the two nonconformance issues

identified in the Electroswitch 10 CFR Part 21 report (ML16139A834). The licensee

addressed the first identified nonconformance sufficiently through Condition Report CR-WF3-

2016-07710, Corrective Action 15, which developed and completed an Adverse Condition

Analysis. However, the 10 CFR Part 21 also identified the failure to utilize an Appendix B

supplier and the failure to perform the applicable Commercial Grade Surveys, Source

Inspections, and Material Analyses on a list of materials. This portion of the 10 CFR Part 21

report was not addressed through corrective actions.

On October 3, 2018, the licensee provided the NRC team a white paper outlining their

justification for not verifying the basic components of the products listed as potentially

nonconforming (found in Appendix A, Nonconformance 2, of the Electroswitch 10 CFR

7

Part 21 letter to the licensee, dated May 11, 2016). The white paper was based on the

assumption that previous Nuclear Procurement Issues Corporation (NUPIC) audits

(completed from 2003-2015) and a source surveillance completed in 2015 (which reviewed

drawings and purchase orders) provided assurance that the basic components of the

switches currently installed in the plant conform to the vendors design documents. While the

team agreed the source surveillance and NUPIC audits did not identify a nonconformance,

the licensee did not inspect the receipt of actual material in a manner that compared them

against the vendor design specifications. The 2016 NRC inspection of Electroswitch

Corporation identified a nonconformance that has existed since Electroswitch began offering

products under their 10 CFR Part 50, Appendix B program.

The team determined that because Electroswitch failed to either: a) utilize an Appendix B

vendor for the parts/pieces or b) perform a Commercial Grade Dedication for the

commercially procured materials, parts, and services, and because the licensee failed to

address the nonconformance identified in the Electroswitch Part 21 letter and the non-cited

violation issued in NRC Inspection Report 05000382/2016008-01, the violation remained

uncorrected.

Corrective Action(s): The licensee initiated efforts to perform operability evaluations for those

systems and components impacted by the Electroswitch relays.

Corrective Action Reference(s): Condition Report CR-WF3-2018-05590

Performance Assessment:

Performance Deficiency: The failure to dedicate commercial-grade relays used as, or

intended for use as, basic components (in safety-related applications) as required by plant

procedures and by 10 CFR Part 21, was a performance deficiency.

Screening: This performance deficiency was more-than-minor because it was associated

with the design control attribute of the Mitigating Systems Cornerstone and adversely affected

the objective of ensuring the availability, reliability, and capability of systems that respond to

initiating events.

Significance: Using Inspection Manual Chapter 0609, Appendix A, dated June 19, 2012, the

team determined that this finding was of very low safety significance (Green) because it was

a deficiency affecting the design or qualification of a structure, system, or component,

however operability was maintained.

Cross-cutting Aspect: The team determined that the finding has a cross-cutting

aspect in the area of Problem Identification and Resolution associated with evaluation,

because the organization did not take effective corrective actions to thoroughly evaluate

issues to ensure that resolutions address cause and extent of conditions commensurate

with their safety significance. Specifically, the licensee failed to effectively address

NCV 05000382/2016008-01 in the corrective actions contained in Condition Report

CR-WF3-2016-07710 [P.2].

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion XV, requires, in part, that

nonconforming items shall be reviewed and accepted, rejected, repaired or reworked in

accordance with documented procedures.

8

Contrary to the above, in May 2016 the licensee failed to review and accept, reject, repair or

rework nonconforming items in accordance with documented procedures. Specifically,

following receipt of information from Electroswitch that a number of basic components within

relays and switches did not conform to quality requirements, the licensee failed to dedicate

these commercial-grade parts as described in 10 CFR Part 21. Because this violation was

previously issued as very low safety significance and was entered into the licensees

corrective action program (CR-WF3-2016-07710), but not fully addressed, it is being treated

as a Notice of Violation in accordance with Section 2.3.3 of the NRC Enforcement Manual:

NOV 05000382/2018008-01, Failure to Control Nonconforming Parts.

Enforcement Action: A Notice of Violation is enclosed (Enclosure 1). This violation is being

cited because the licensee failed to restore compliance within a reasonable period of time

after the violation was identified consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Identify and Correct a Condition Adverse to Quality

Cornerstone Significance Cross-cutting Inspection

Aspect Procedure

Mitigating Green [H.6] - 71152

Systems NCV 05000382/2018008-02 Human Problem

Closed Performance, Identification

Challenge the and

Unknown Resolution

The team identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI,

Corrective Action, associated with the licensees failure to identify and correct condition

adverse to quality associated with the breeching of hazard barriers. Specifically, while

developing corrective actions for failure to close exterior doors, the licensee identified that

they had no process for tracking impaired hazard barriers such that control room operators

would be aware of which barriers are impaired and which equipment may not be able to

perform its specified function to protect safety-related structures, systems and components,

but the licensee then failed to correct this issue.

Description: While developing corrective actions for NCV 05000382/2017002-01, Failure to

Prepare the Site for Impending Adverse Weather, in Condition Report CR-WF3-2017-06756

the licensee identified that formal controls did not exist for the operations department to track

hazard barriers that were out of service for maintenance. Corrective action 1 directed

coordinating and developing a plan with outage management to control door access during

refuel outages to include evaluating the need for creating an impairment process for tracking

disabled hazard barriers. However, corrective action 2 (closed January 25, 2018),

determined that station procedure MM-006-106, Plant Door Maintenance, contained

procedural guidance to contact the control room prior to performing maintenance on doors,

and this action was sufficient.

The team reviewed the licensees corrective actions and determined the doors identified as

not being shut in NCV 05000382/2017002-01 had been blocked open for maintenance

activities and were not shut because of this, and operators were not aware that these doors

were not capable of performing their specified function at the time. Based on this information,

the team determined that the licensee had failed to correct an identified condition adverse to

quality. Specifically, while station procedure MM-006-106 provided guidance to craft

personnel to contact the control room prior to performing maintenance on doors, there was no

process in place for tracking impaired hazard barriers such that the operations department

9

would be aware of which barriers were impaired and which equipment may not be able to

perform its specified function to protect safety-related structures, systems and components

should the need arise. The team determined that the lack of a process in place for tracking

impaired hazard barriers was a condition adverse to quality the licensee had failed to correct.

Corrective Action: At the time of discovery all doors were closed so there was not an ongoing

safety concern. The licensee initiated Condition Report CR-WF3-2018-05273 to assess how

to correct the condition.

Corrective Action Reference: CR-WF3-2018-05273

Performance Assessment:

Performance Deficiency: The licensees failure to identify and correct a condition adverse to

quality was a performance deficiency.

Screening: The team determined the performance deficiency was more than minor because

it adversely affected the equipment performance attribute of the Mitigating Systems

Cornerstone and adversely affected the cornerstone objective to ensure the availability,

reliability, and capability of systems that respond to initiating events to prevent undesirable

consequences. Specifically, the licensee had no process for tracking impaired hazard

barriers such that control room operators would be aware of which barriers are impaired and

which equipment may not be able to perform its specified function to protect safety-related

structures, systems and components.

Significance: The team assessed the significance of the finding using Inspection Manual

Chapter 0609, Attachment 04, Initial Characterization of Findings, dated October 7, 2016,

and Inspection Manual Chapter 0609, Appendix A, Significance Determination Process for

Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, the team

determined the finding was of very low safety significance (Green) because: (1) it was not a

design deficiency; (2) it did not represent a loss of system and/or function; (3) it did not

represent an actual loss of function of at least a single train for longer than its technical

specification allowed outage time; and (4) it did not result in the loss of a high safety-

significant non-technical specification train.

Cross-cutting Aspect: The team determined that the finding has a cross-cutting aspect in the

area of Human Performance associated with conservative bias because the licensee failed to

use decision making practices that emphasize prudent choices over those that are simply

allowed. Specifically, the licensee failed to evaluate conditions beyond those that were

identified to correct NRC NCV 05000382/2017002-01 [H.14].

Enforcement:

Violation: 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part,

measures shall be established to assure that conditions adverse to quality are promptly

identified and corrected.

Contrary to the above, from January 25 through October 4, 2018, the measures established

by the licensee failed to promptly identify and correct a condition adverse to quality.

Specifically, while developing corrective actions for breeching of hazard barriers, the licensee

identified that they had no process for tracking impaired hazard barriers, but failed to correct

this issue, a condition adverse to quality.

10

Enforcement Action: This violation is being treated as a non-cited violation, consistent with

Section 2.3.2 of the Enforcement Policy.

Failure to Update the Updated Final Safety Analysis Report

Cornerstone Severity Cross-cutting Aspect Inspection Procedure

Not Applicable Green Not Applicable 71152

SL-IV Problem Identification

05000382/2018008-03 and Resolution

Closed

The team identified a Severity Level IV non-cited violation of 10 CFR 50.71(e), Maintenance

of Records, Making Reports, associated with the licensees failure to correctly update the

Updated Final Safety Analysis Report (UFSAR). Specifically, the licensee has incorrect

information in the UFSAR with regard to computer codes used (CEFLASH and TRANFLO)

which has not been removed. The licensee entered this issue into the corrective action

program as Condition Reports CR-WF3-2017-07782 and CR-WF3-2018-01612.

Description: Inspection Report 05000382/2016008 (ML17026A338) documented an issue

where the licensee failed to obtain a license amendment prior to using the computer code

TRANFLO (NCV 05000382/2016008-04, Departure from Approved Method to Determine

Steam Generator Internal Loads During Main Steam Line Break). For this issue the NRC

determined that the licensee had failed to obtain a license amendment prior to using the

computer code TRANFLO. The licensee initiated Condition Report CR-WF3-2017-07782 to

address this issue in the corrective action program. On April 12, 2018, the licensee submitted

a license amendment request (W3F1-2018-0014) to allow the use of the computer code

TRANFLO. As of October 4, 2018, this amendment had not been approved.

While preparing their license amendment request the licensee discovered that the UFSAR

contained incorrect information. Specifically, UFSAR, Section 3.9.1.2.2.1.28, stated that the

computer program CEFLASH-4A was used to calculate steam generator internal loadings

following a postulated steam line break for the original steam generators. However, the

licensee determined that these calculations were actually performed as hand calculations.

The licensee initiated Condition Report CR-WF3-2018-01612 to address this issue in the

corrective action program.

Inspection Report 05000382/2018002 (ML18199A643) documented an unresolved item (URI)

associated with a modification made by the licensee to the emergency feedwater logic

(URI 05000382/2018002-02, 10 CFR 50.59 Evaluation Associated with Emergency

Feedwater Logic Modification). This modification changed the emergency feedwater logic,

as described in the UFSAR, Section 7.3.1.1.6, from flow control mode to level control mode

during a safety injection actuation signal. The NRC team questioned whether the emergency

feedwater modification required additional information to determine if the 10 CFR 50.59

evaluation was adequate or if NRC approval was needed for the change. Specifically, the

NRC team questioned if the emergency feedwater logic change:

• Used a method of evaluation other than what was described in the UFSAR (e.g. the

use of the TRANFLO program) or

• Would result in a more than minimal increase in the likelihood of occurrence of a

malfunction of a system important to safety. Specifically, because the emergency

feedwater logic change introduced the potential to overcool the reactor and

11

substituted a previous automatic action for manual operator action, the NRC team

questioned if the change and associated 50.59 evaluation addressed these concerns.

The team reviewed the licensee actions in response to NCV 05000382/2016008-04 and

URI 05000382/2018002-02. During this review, the team determined that the corrective

action of submitting a license amendment was appropriate to address

NCV 05000382/2016008-04. With regard to URI 05000382/2018002-02 the team determined

that:

• The use of the computer code TRANFLO for the emergency feedwater logic

modification did not represent a change in method of evaluation because the original

analysis was done by hand calculations.

• The emergency feedwater logic modification would not result in a more than minimal

increase in the likelihood of occurrence of a malfunction of a system important to

safety. Specifically, emergency feedwater flow for all events will be higher and result

in a more rapid cooldown rate of the reactor coolant system than previously

experienced, but it would not result in a cooldown rate that would exceed technical

specifications nor would it result in cooling the reactor coolant system down to the

safety injection setpoint.

Based on this information, the team concluded the licensees 10 CFR 50.59 evaluation was

adequate and NRC approval was not required. However, the team noted that UFSAR

Section 3.9.1.2.2.1.28 still stated that the original computer code used for determining

pressure drop across the original steam generator secondary side components was

CEFLASH-4A, and UFSAR Section 3.9.1.2.2.1.35 still stated that the computer code

TRANFLO had been evaluated and benchmarked against CEFLASH-4A and was acceptable.

The team determined that the facilitys UFSAR did not contain the most current information

with regard to approved analysis for either the original or replacement steam generators

which created the potential that future changes to the facility could be made using incorrect

information.

Corrective Actions: On April 12, 2018, the licensee submitted a license amendment request

(W3F1-2018-0014) to allow the use of the computer code TRANFLO and initiated Condition

Reports CR-WF3-2017-07782 and CR-WF3-2018-01612 to determine what additional

corrective actions are necessary.

Corrective Action References: CR-WF3-2017-07782 and CR-WF3-2018-01612

Performance Assessment:

Performance Deficiency: The licensees failure to update the UFSAR was a performance

deficiency.

Screening: Because this performance deficiency had the potential to impact the NRCs ability

to perform its regulatory function, the team evaluated the performance deficiency using

traditional enforcement. Using Inspection Manual Chapter 0612, Power Reactor Inspection

Reports, dated January 24, 2013, Appendix B, Issue Screening, the Reactor Oversight

Program aspect of this performance deficiency was minor.

12

Significance: Using the NRC Enforcement Policy, dated January 28, 2013, the traditional

enforcement performance deficiency was determined to be a Severity Level IV violation in

accordance with Section 6.1.d.3, because the lack of up-to-date information in the UFSAR

had not resulted in any unacceptable changes to the facility or procedures.

Cross-cutting Aspect: The finding was not assigned a cross-cutting aspect because the

finding was not indicative of current performance.

Enforcement:

Violation: 10 CFR 50.71(e), requires, in part that licensees shall update periodically, as

provided in paragraphs (e) (3) and (4) of 10 CFR 50.71, Updated Final Safety Analysis Report

originally submitted as part of the application for the license, to assure that the information

included in the report contains the latest information developed.

Contrary to the above, from 2016 through October 4, 2018, the licensee failed to update the

Updated Final Safety Analysis Report to assure that the information included in the report

contained the latest information developed. Specifically, UFSAR Section 3.9.1.2.2.1.28

incorrectly indicated that the original computer code used for determining pressure drops

across the original steam generator secondary side components was CEFLASH-4A and

UFSAR Section 3.9.1.2.2.1.35, indicated that the computer code TRANFLO had been

evaluated and benchmarked against CEFLASH-4A.

Disposition: This violation is being treated as a non-cited violation, consistent with

Section 2.3.2 of the Enforcement Policy.

The disposition of this violation closes URI 05000382/2018002-02

EXIT MEETINGS AND DEBRIEFS

On October 4, 2018, the team presented the inspection results to Mr. J. Dinelli, Site Vice

President and other members of the licensee staff. The team confirmed that proprietary

information was controlled to protect from public disclosure.

13

DOCUMENTS REVIEWED

Condition Reports

CR-HQN-2018-01259 CR-HQN-2018-00792 CR-WF3-2011-06852 CR-WF3-2011-06956

CR-WF3-2012-02332 CR-WF3-2013-04561 CR-WF3-2013-04843 CR-WF3-2013-04857

CR-WF3-2013-04860 CR-WF3-2013-04986 CR-WF3-2013-05053 CR-WF3-2013-05091

CR-WF3-2014-00922 CR-WF3-2014-02250 CR-WF3-2014-04633 CR-WF3-2014-04187

CR-WF3-2015-02606 CR-WF3-2015-03900 CR-WF3-2015-04094 CR-WF3-2015-04387

CR-WF3-2015-05155 CR-WF3-2015-05234 CR-WF3-2015-05580 CR-WF3-2015-05660

CR-WF3-2015-06760 CR-WF3-2015-06782 CR-WF3-2016-00170 CR-WF3-2016-00521

CR-WF3-2016-00797 CR-WF3-2016-01577 CR-WF3-2016-02516 CR-WF3-2016-02807

CR-WF3-2016-03522 CR-WF3-2016-03525 CR-WF3-2016-03761 CR-WF3-2016-04581

CR-WF3-2016-04957 CR-WF3-2016-04986 CR-WF3-2016-05039 CR-WF3-2016-05155

CR-WF3-2016-06222 CR-WF3-2016-06322 CR-WF3-2016-06410 CR-WF3-2016-06477

CR-WF3-2016-06905 CR-WF3-2016-07050 CR-WF3-2016-07092 CR-WF3-2016-07219

CR-WF3-2016-07337 CR-WF3-2016-07379 CR-WF3-2016-07477 CR-WF3-2016-07487

CR-WF3-2016-07551 CR-WF3-2016-07639 CR-WF3-2016-07710 CR-WF3-2016-07782

CR-WF3-2016-07847 CR-WF3-2017-00100 CR-WF3-2017-00102 CR-WF3-2017-00277

CR-WF3-2017-00365 CR-WF3-2017-00571 CR-WF3-2017-00628 CR-WF3-2017-00648

CR-WF3-2017-00752 CR-WF3-2017-01056 CR-WF3-2017-01063 CR-WF3-2017-01064

CR-WF3-2017-01212 CR-WF3-2017-01233 CR-WF3-2017-01250 CR-WF3-2017-01414

CR-WF3-2017-01433 CR-WF3-2017-01481 CR-WF3-2017-01483 CR-WF3-2017-01562

CR-WF3-2017-01723 CR-WF3-2017-01958 CR-WF3-2017-02707 CR-WF3-2017-03055

CR-WF3-2017-03273 CR-WF2-2017-03566 CR-WF3-2017-03610 CR-WF3-2017-03726

CR-WF3-2017-03961 CR-WF2-2017-04094 CR-WF3-2017-04294 CR-WF3-2017-04313

CR-WF3-2017-04535 CR-WF3-2017-04552 CR-WF3-2017-04748 CR-WF3-2017-04770

CR-WF3-2017-04944 CR-WF3-2017-05006 CR-WF3-2017-05046 CR-WF3-2017-05108

CR-WF3-2017-05173 CR-WF3-2017-05329 CR-WF3-2017-05397 CR-WF3-2017-05571

CR-WF3-2017-05572 CR-WF3-2017-05614 CR-WF3-2017-05688 CR-WF3-2017-05753

CR-WF2-2017-05802 CR-WF2-2017-05842 CR-WF2-2017-05844 CR-WF2-2017-05882

CR-WF2-2017-06182 CR-WF2-2017-06218 CR-WF3-2017-06343 CR-WF3-2017-06458

CR-WF3-2017-06463 CR-WF3-2017-06499 CR-WF3-2017-06542 CR-WF3-2017-06617

CR-WF3-2017-06620 CR-WF3-2017-06698 CR-WF3-2017-06709 CR-WF3-2017-06715

CR-WF3-2017-06753 CR-WF3-2017-06755 CR-WF3-2017-06756 CR-WF3-2017-07148

CR-WF3-2017-07390 CR-WF3-2017-07433 CR-WF3-2017-07464 CR-WF3-2017-07565

CR-WF3-2017-07605 CR-WF3-2017-07710 CR-WF3-2017-07819 CR-WF3-2017-07847

CR-WF3-2017-07853 CR-WF3-2017-07881 CR-WF3-2017-08257 CR-WF3-2017-08574

CR-WF3-2017-08611 CR-WF3-2017-08635 CR-WF3-2017-08716 CR-WF3-2017-08720

CR-WF3-2017-08721 CR-WF3-2017-08752 CR-WF3-2017-08757 CR-WF3-2017-09106

CR-WF3-2017-09109 CR-WF3-2017-09125 CR-WF3-2017-09143 CR-WF3-2017-09150

CR-WF3-2017-09177 CR-WF3-2017-09201 CR-WF3-2017-09207 CR-WF3-2017-09373

CR-WF3-2017-09494 CR-WF3-2017-09513 CR-WF3-2017-09574 CR-WF3-2017-09901

CR-WF3-2017-09913 CR-WF3-2017-09952 CR-WF3-2017-09953 CR-WF3-2017-09954

14

Condition Reports

CR-WF3-2017-09955 CR-WF3-2017-00031 CR-WF3-2018-00054 CR-WF3-2018-00387

CR-WF3-2018-00399 CR-WF3-2018-00490 CR-WF3-2018-00560 CR-WF3-2018-00785

CR-WF3-2018-00951 CR-WF3-2018-00951 CR-WF3-2018-00983 CR-WF3-2018-01001

CR-WF3-2018-01259 CR-WF3-2018-01821 CR-WF3-2018-01302 CR-WF3-2018-01491

CR-WF3-2018-01612 CR-WF3-2018-01969 CR-WF3-2018-01994 CR-WF3-2018-01997

CR-WF3-2018-02037 CR-WF3-2018-02038 CR-WF3-2018-02058 CR-WF3-2018-02097

CR-WF3-2018-02104 CR-WF3-2018-02105 CR-WF3-2018-02106 CR-WF3-2018-02109

CR-WF3-2018-02111 CR-WF3-2018-02154 CR-WF3-2018-02186 CR-WF3-2018-02233

CR-WF3-2018-02735 CR-WF3-2018-03042 CR-WF3-2018-03086 CR-WF3-2018-03104

CR-WF3-2018-03111 CR-WF3-2018-03145 CR-WF3-2018-03167 CR-WF3-2018-03179

CR-WF3-2018-03276 CR-WF3-2018-03340 CR-WF3-2018-03398 CR-WF3-2018-03503

CR-WF3-2018-03509 CR-WF3-2018-03587 CR-WF3-2018-03669 CR-WF3-2018-03900

CR-WF3-2018-03948 CR-WF3-2018-03971 CR-WF3-2018-03991 CR-WF3-2018-04242

CR-WF3-2018-04443 CR-WF3-2018-04580 CR-WF3-2018-04908 CR-WF3-2018-04909

CR-WF3-2018-04910 CR-WF3-2018-05234 CR-WF3-2018-05272 CR-WF3-2018-05273

CR-WF3-2018-05401 CR-WF3-2018-05531 CR-WF3-2018-05546 CR-WF3-2018-05569

CR-WF3-2018-05590 CR-WF3-2018-06067

Work Orders

52394076 52727106 52790268 00393027

Procedures Revision

Number Title or Date

EN-DC-115 Engineering Change Process 20, 21

EN-DC-306 Acceptance of Commercial-Grade Items/Services in 1

Safety-Related Applications

EN-LI-102 Corrective Action Program 28 - 33

EN-LI-108-01 10 CFR 21 Evaluations and Reporting 6

EN-HU-102 Human Performance Traps and Tools 16

EN-HU-106 Procedure and Work Instruction Use and Adherence 6

EN-OP-104 Operability Determination Process 11 - 16

IP-ENG-001 Design Standard Process 33

ME-004-004 Isophase Bus Maintenance and Inspection 302

ME-004-155 Reactor Trip Switchgear 307

OI-037-000 Operations Risk Assessment Guideline 313

OP-902-003 Loss of Offsite Power/Loss of Forced Circulation Recovery 10

15

Procedures Revision

Number Title or Date

OP-903-029 Safety Injection Actuation Signal Test 22

OP-903-035 Containment Spray Pump Operability Check 24

OP-903-115 Integrated Emergency Diesel Generator/Emergency 39, 40

Safety Features Test - train A

OP-903-124 CVAS Pressure Boundary Testing 305, 306

QA-1-2017-W3-1 Fitness For Duty/Access Authorization QA Report August 2017

QA-14-15-2016- Combined Radiation Protection and Radwaste QA Report October 2016

W3-1

QA-14-15-2016- Combined Radiation Protection and Radwaste QA Report October 2017

W3-1

QA-16-2016-W3-1 Security QA Report December

2016

QA-16-2017-W3-1 Security/Cyber Security QA Report December

2017

Quality Assurance Program Manual 307

Miscellaneous

Documents Revision

Number Title or Date

17-4/0 EC64801 Emergency Feedwater Logic Modification

CP-NPSD-1107 Guidance for Developing A CRMP March 1998

LTR-SCC-16-017 Non-LOCA Transient Analysis Impact Evaluation for EFW 0

System Modification at Waterford Steam Electric Station,

Unit 3

LO-WLO-2017- Design Engineering - Modification/50.59 Pre-NRC February 16,

00012 Focused Self-Assessment 2018

QA-8-2017-W3-1 Quality Assurance Audit Report, Engineering Programs 0

QA-8-2017-W3-2 Quality Assurance Audit Report, Engineering Programs 0

QA-4-2018-W3-1 Quality Assurance Audit Report, Engineering (Design 0

Control)

System Health Report: HVCC - Control Room Cooling 3rd & 4th Qtr

and Envelope 2013

System Health Report: HVCC - Control Room Cooling 1st - 4th Qtr

and Envelope

2014

16

Miscellaneous

Documents Revision

Number Title or Date

System Health Report: HVCC - Control Room Cooling 1st - 4th Qtr

and Envelope

2015

System Health Report: HVCC - Control Room Cooling 1st - 4th Qtr

and Envelope

2016

System Health Report: HVCC - Control Room Cooling 1st - 4th Qtr

and Envelope

2017

System Health Report: HVCC - Control Room Cooling 1st & 2nd Qtr

and Envelope 2018

Nuclear Independent Oversight Function Area June 16, 2018

Performance Report

Nuclear Independent Oversight Function Area March 1, 2018

Performance Report

Calculations

Number Title Revision

CN-TAS-08-30 Waterford Steam Electric Station, Unit 3, Post-Trip Main 1

Steam Line Break Analysis for RSGs

CN-TAS-08-40 Waterford Steam Electric Station, Unit 3, Feedwater Line 0

Break Analysis for RSGs

ECS00-007 PSA-Study Calc - Basis for Qualitative Level 2, External 2

Events, and Non-PSA SSC Guidance

WCAP-17066-P Waterford Steam Electric Station, Unit 3, Steam Electric 0

Station Delta 110 Replacement Steam Generator Design

Report

17

Information Request

Biennial Problem Identification and Resolution

Inspection Waterford Nuclear Generating Station, Unit 3

July 24, 2018

Inspection Report: 50-482/2018007

On-site Inspection Dates: September 17-21 & October 1-5, 2018

This inspection will cover the period from December 16, 2016, through October 5, 2018. All

requested information is limited to this period or to the date of this request unless otherwise

specified. To the extent possible, the requested information should be provided electronically

in word-searchable Adobe PDF (preferred) or Microsoft Office format. Any sensitive

information should be provided in hard copy during the teams first week on site; do not

provide any sensitive or proprietary information electronically.

Lists of documents (summary lists) should be provided in Microsoft Excel or a similar sortable

format. Please be prepared to provide any significant updates to this information during the

teams first week of on-site inspection. As used in this request, corrective action documents

refers to condition reports, notifications, action requests, cause evaluations, and/or other

similar documents, as applicable to the Waterford Nuclear Generating Station, Unit 3.

Please provide the following information no later than September 3, 2018:

i. Document Lists

Note: For these summary lists, please include the document/reference number, the

document title, initiation date, current status, and long-text description of the issue.

a. Summary list of all corrective action documents related to significant

conditions adverse to quality that were opened, closed, or evaluated during

the period

b. Summary list of all corrective action documents related to conditions adverse

to quality that were opened or closed during the period

c. Summary list of all apparent cause evaluations (or equivalent) performed

during the period; if fewer than approximately 20, provide full documents

d. Summary list of all currently open corrective action documents associated

with conditions first identified any time prior to January 1, 2017, including

prior to the beginning of the inspection period

e. Summary lists of all corrective action documents that were upgraded or

downgraded in priority/significance during the period (these may be limited

to those downgraded from, or upgraded to, apparent-cause level or higher)

f. Summary list of all corrective action documents initiated during the period

that identify an adverse or potentially adverse trend in safety-related or risk-

Attachment

significant equipment performance or in any aspect of the stations safety

culture.

g. Summary lists of operator workarounds, operator burdens, temporary

modifications, and control room deficiencies (1) currently open and (2) that

were evaluated and/or closed during the period; this should include the date

that each item was opened and/or closed.

h. Summary list of all prompt operability determinations or other

engineering evaluations to provide reasonable assurance of operability

i. Summary list of plant safety issues raised or addressed by the Employee

Concerns Program (or equivalent) (sensitive information should be made

available during the teams first week on sitedo not provide

electronically)

j. Summary list of all Apparent Cause Evaluations completed during the

period

2. Full Documents with Attachments

a. Root Cause Evaluations completed during the period; include a list of

any planned or in progress

b. Quality Assurance audits performed during the period

c. Audits/surveillances performed during the period on the Corrective

Action Program, of individual corrective actions, or of cause

evaluations

d. Functional area self-assessments and non-NRC third-party assessments (e.g.,

peer assessments performed as part of routine or focused station self- and

independent assessment activities; do not include INPO assessments) that

were performed or completed during the period; include a list of those that are

currently in progress

e. Any assessments of the safety-conscious work environment at the

Waterford Nuclear Generating Station, Unit 3, including any safety

culture survey results; if none performed during the inspection period,

provide the most recent

f. Corrective action documents generated during the period associated with

the following:

A-2

i. NRC findings and/or violations issued to the Waterford Nuclear

Generating Station, Unit 3

ii. Licensee Event Reports issued by the Waterford Nuclear Generating

Station, Unit 3

g. Corrective action documents generated for the following, if they were

determined to be applicable to the Waterford Nuclear Generating Station, Unit

3 (for those that were evaluated but determined not to be applicable, provide a

summary list):

i. NRC Information Notices, Bulletins, and Generic Letters

issued or evaluated during the period

ii. Part 21 reports issued or evaluated during the period

iii. Vendor safety information letters (or equivalent) issued or

evaluated during the period

iv. Other external events and/or Operating Experience evaluated

for applicability during the period

h. Corrective action documents generated for the following:

i. Maintenance preventable functional failures which occurred or

were evaluated during the period

ii. Adverse trends in equipment, processes, procedures, or

programs that were evaluated during the period

iii. Action items generated or addressed by offsite review committees

during the period

3. Logs and Reports

a. Corrective action performance trending/tracking information generated during

the period and broken down by functional organization (if this information is

fully included in item 3.b, it need not be provided separately)

b. Current system health reports, Management Review Meeting package, or

similar information; provide past reports as necessary to include 12 months of

metric/trending data

A-3

c. Radiation protection event logs during the period

d. Security event logs and security incidents during the period (sensitive

information should be made available during the teams first week on sitedo

not provide electronically)

e. Employee Concern Program (or equivalent) logs (sensitive information should

be made available during the teams first week on sitedo not provide

electronically)

f. List of training deficiencies, requests for training improvements, and

simulator deficiencies for the period

Note: For items 3.c-3.d, if there is no log or report maintained separate from the

corrective action program, please provide a summary list of corrective action

program items for the category described.

4. Procedures

Note: For these procedures, please include all revisions that were in effect at any time

during the period.

a. Corrective action program procedures, to include initiation and evaluation

procedures, operability determination procedures, cause evaluation

procedures, and any other procedures that implement the corrective action

program at the Waterford Nuclear Generating Station, Unit 3

b. Quality Assurance program procedures (specific audit procedures are

not necessary)

c. Employee Concerns Program (or equivalent) procedures

d. Procedures which implement/maintain a Safety Conscious Work Environment

e. Conduct of Operations procedure (or equivalent) and any other procedures or

policies governing control room conduct, operator burdens and workarounds,

etc.

f. Operating Experience (Ope) program procedures and any other procedures or

guidance documents that describe the sites use of Ope information

A-4

5. Other

a. List of risk-significant components and systems, ranked by risk worth; if the list

uses system designators, provide a list of the associated equipment/system

names

b. List of structures, systems and components and/or functions that were in

maintenance rule(a)(1) status or evaluated for (a)(1) status at any time during

the inspection period; include dates and results of expert panel reviews and

dates of status changes

c. Organization charts for plant staff and long-term/permanent contractors

d. Electronic copies of the UFSAR (or equivalent), technical specifications,

and technical specification bases, if available

e. Table showing the number of corrective action documents (or equivalent)

initiated during each month of the inspection period, by screened

significance

f. For each day the team is on site,

i. Planned work/maintenance schedule for the station

ii. Schedule of management or corrective action review meetings (e.g.

operations focus meetings, condition report screening meetings,

CARBs, MRMs, challenge meetings for cause evaluations, etc.)

iii. Agendas and materials for these meetings

Note: The items listed in 5.f may be provided on a weekly or daily basis after

the team arrives on site.

All requested documents should be provided electronically where possible. Regardless of

whether they are uploaded to an internet-based file library (e.g., Certrecs IMS), please provide

copies on CD or DVD. One copy of the CD or DVD should be provided to the resident

inspector office at the Waterford Nuclear Generating Station, Unit 3; three additional copies

should be provided to the team lead, to arrive no later than September 3, 2018:

Ray Azua

Senior Reactor Inspector

Inspection Program and Assessment Team

Division of Reactor Safety, Region IV

1600 E. Lamar Blvd, Arlington, TX 76011

Office: (817) 200-1445

A-5

ML18319A379

SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword: NRC-002

By: RVA Yes No Publicly Available Sensitive

OFFICE SRI:DRS/I SRI:DRP/PBA RI:DRP/PBD PSI:DRS/PSB1 C:DRP/PBD TL:DRS/IPAT TL:IPAT

PAT

NAME RAzua JJosey CSpeer CJewett NOKeefe MVasquez GMiller

SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA by /RA by /RA/

JDixon JKramer

Acting For/ Acting For/

DATE 11/08/18 11/10/18 11/10/18 11/10/2018 11/14/18 11/14/18 11/15/18