ML20086L363

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Responds to SALP Rept for Period of 931031-950429.Licensee Recognizes Effeort & Resources Expended in Overall Performance Assessment Process
ML20086L363
Person / Time
Site: Waterford Entergy icon.png
Issue date: 07/19/1995
From: Barhurst R
ENTERGY OPERATIONS, INC.
To: Callan L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
W3F1-95-0106, W3F1-95-106, NUDOCS 9507210160
Download: ML20086L363 (97)


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Ross P. Barkhurst

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,'jp r e W3F1-95-0106 A4.05 PR July 19, 1995 Mr. L.J. Callan Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011

Subject:

Waterford 3 SES Docket No. 50-382 License No. NPF-38 Response to the SALP Report for the Period of October 31, 1993 through April 29, 1995

Dear Mr. Callan:

i The purpose of this letter is to respond to the Systematic Assessment of 3 Licensee Performance (SALP) Report for Waterford 3 for the period October 31, 1993 through April 29, 1995. Entergy Operations, Inc. recognizes the effort and resources expended in the overall performance assessment process and believes that the SALP process has provided meaningful feedback to Waterford 3 management regarding our performance. We are appreciative of the open and candid discussions at the public meeting held on June 23, 1995. Of particular benefit, were the remarks that clarified, for us, the reason the SALP board and Regional Management rated the Operations Functional Area as a SALP category 2. Wg were also able to convey to you information that we believe provides a solid foundation for Waterford 3 being recognized as a superior performer with SALP 1's in all functional areas. Although the comments contained in this letter are direct and may be strongly worded, they should not be interpreted as defensive. Instead, we wish to continue the positive and constructive dialogue begun at the public meeting. This letter and it's accompanying attachments form a comprehensive package that should provide you insight into the programs and _

processes that management at Waterford 3 uses to ensure and maintain the highest safety performance of the plant. Based on this response we ask that you raise the Category 2 rating in the functional area of Plant Operations to a Category 1 rating.

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Response to the SALP Report for the Period of October 31, 1993 through April 29, 1995 W3F1-95-0106 j Page 2 i July 19, 1995

  • In the Plant Support and Maintenance Areas, we are pleased to have maintained a Category I rating. Strong programs and management involvement continue to keep Plant Support and Maintenance at Superior Levels. We are also pleased to have received a Category I rating in Engineering. To .

maintain our superior performance, it is recognized that continuous improvements are necessary. Integration of engineering into all phases of plant operations will continue to be stressed.

The Category 2 rating in the Plant Operations functional area was disappointing. You stated, during our SALP public meeting, that the performance of the Operations Department at Waterford 3 has been strong.

We agree. Provided in Attachment I are some of the details discussed at the SALP public meeting that we believe provide clarification of issues specific to the Plant Operations section of the SALP Report. Your reservations in grading the Operations area a SALP 1 seemed to center around a lack of confidence in the organizations that support Plant Operations and their ability to sustain a high level of safety performance.

Lacking this, you felt that the reduction in inspection hours that a rating of SALP 1 in all areas would bring could not be justified. Waterford 3 believes that Superior Safety Performance has been achieved and will be maintained regardless of the degree of NRC oversight. This conclusion is based on the overal1 superior performance of the plant and the institutfonalizedprocesses and safety culture that 1s the 6as1s for this performance.

Waterford 3 has achieved sustained superior performance when measures that best represent overall performance are considered. This performance could not be achieved without superior performance in the Operations functional area, and is consistent with or better than the performance of plants with ratings of SALP 1 in all functional areas. Specifically, during this SALP period Waterford 3 set plant records in electrical generation for an outage year, unit capability factor for en outage year, corrective maintenance ,

backlog (240), and 3 year scram rate. Additionally for the 3 year period l ending in 1994, Waterford 3 set the following four Entergy System records for 3 year averages: collective radiation exposure, unit capability l factor, equivalent availability, and forced outage rate. Finally, in reviewing the performance indicators tracked by the NRC, Waterford 3 has performed as well or better than the other sites rated with SALP l's in all categories.  ;

Response to the SALP Report for the Period of October 31, 1993 through April 29, 1995 W3F1-95-0106 Page 3 ,

July 19, 1995 Specifically, of the 9 sites rated superior, only Davis Bessie had a capacity factor better than Waterford 3 for the 3 year period ending 1994, and in the areas of Safety System Actuations and Safety System Failures, Waterford 3's performance was equal to or better than 5 of the 9 sites.

Additional details of this superior performance are provided in Attachment 2.

The level of safety performance reflected. in the above results do not just happen, nor is it meaningful without the substance and quality of the institutionalized processes and safety culture that led to its achievement.

These institutionalized processes and safety culture have resulted from activities that can be categorized into three key areas: A core corrective action (CA) process, assessment activities that provide additional defense in depth, and strong management direction. Together, they establish redundant barriers that will ensure continued superior safety performance.

The core corrective action process is one that we believe sets an industry standard :tnd was developed and refined through an Entergy, system wide initiative. It was fully implemented at Waterford 3 in June 1994. It is a one document corrective action process that makes all site personnel responsible fcr the identification of adverse conditions at a low threshold via a Conditior Report (CR) and is simple and user friendly for the initiator. Tha process can be fed by other site processes such as Condition Identification (CI, Waterford 3's work order initiation process),

Zone Inspections, or plant walkdowns by operators, engineers or management.

The effectiveness and widespread use of this process was best demonstrated during the SALP public meeting where we showed the cumulative results of our efforts for the past year. Of the 1178 CRs generated, 34% were written by Operations (see Attachment 3). The CR also triggers complete and thorough root cause analyses (RCA) for significant conditions adverse to quality, for adverse trends, or whenever management feels that an RCA is warranted. There is also a process for performing a more detailed adverse trend analysis for multiple events where individual event RCA's may not have revealed all the common contributing causes.

i Response to the SALP Report for the Period of October 31, 1993 through April 29, 1995 W3F1-95-0106 Page 4 July 19, 1995 It is worth noting at this point in our discussion that there is really no '

way Waterford 3 could have achieved overall high and steadily improving plant performance without superior performance in Operations. In fact, we did not. Operations was a SALP 1 for three consecutive cycles. During that time, the corrective action process discussed above did not even exist and thresholds for initiating corrective action were in fact higher than for this last period. This, in combination with the fact that Operations has been leading the way in implementation of the much improved process (as indicated in the public meeting) gives us confidence in our assessment of that department. Its performance is clearly higher than the benchmark previously set with four years of SALP 1 performance.

Our core c9rrective action process, described above, is also surrounded by organization 1 barriers that provide the appropriate checks and balances as well as active management oversight. These are as follows:

  • Review of all CR's and CI's by the Operations Shift Supervisor e Working level review of all CI's by the CI Review Committee (CIRC) e Management review of all CI's and CR's by the Condition Review Board (CRB) e In line review of all RCA's by QA for consistency and thoroughness
  • CRB and Management review of Corrective Action Trend Reports and required actions
  • Regular review of Corrective Action process, activities and trends by the Safety Review Committee (SRC) ,

Outside of the core corrective action process are numerous assessment activities that provide additional defense in depth and support a long lasting safety culture with a focus on continuous improvement. The Quality Assurance organization, with aggressive and proactive leadership has conducted effective and insightful audits and assessments that go beyond the traditional QA role. Additionally, a rapid response team has been established to quickly investigate and root out emerging problem areas so that appropriate and timely corrective action can be taken. These initiatives have resulted in a strong QA presence that is both independent and actively involved in day to day activities. Other assessment activities that provide additional defense in depth are as follows:

4 Response to the SALP Report for the Period of October 31, 1993 through April 29, 1995 W3F1-95-0106 Page 5 July 19, 1995

  • In-house Plant assessments e Key process Teams
  • Independent Corporate Assessments a Peer Groups
  • Reliability Improvement Team (RIT) .

Natural Work Teams (NWT's)

Figure 1 is a pictorial that best represents our defense in depth which provides barriers to any degradation in plant performance.

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Response to the SALP Report for the Period of October 31, 1993 through  !

April 29, 1995  :

W3F1-95-0106-Page 6  ;

July 19,'1995 i

The final key ingredient that has led to Waterford 3's superior safety: >

performance is strong management direction.' You are aware that Waterford 3 .

and Entergy Operations have identified superior safety / regulatory i performance as one of three key goals that we feel ensure the success 'of - l our company. This goal is implemented via site business plans;which have  !

driven alignment of programs, processes and people that support achievement j of superior performance. One outfall from this has been management development through training and rotational job assignments - a long term strength at Waterford 3. This has resulted in a management team with a i broad experience base that is technically sound and diverse. This approach ,

coupled with regular senior management involvement has fostered a strong  :

safety culture throughout the organization. Additionally, management . _  !

direction permeates the processes and assessment activities described above t in various ways. Executive sponsors are assigned:and are actively involved  ;

in Peer groups and Key Process Teams; Total Quality Initiatives receive  !

complete and thorough support from the executive level down, including a  :

site lead team headed by the site'Vice President and his Directors; the Entergy Nuclear Committee advises and assists the Board of. Directors of j Entergy in the proper and complete discharge of its responsibilities  :

relating to the Company's nuclear operations. Clearly, ~ management at l Waterford 3 and Entergy is committed to superior safety performance.

l Attachment 4 provides additional details on the processes and activities l described above.

I In summary, we are confident that superior safety performance has been i attained at Waterford 3 and that ratings of Category 1 in all SALP l functional areas are warranted. This superior performance is evidenced not  !

only by the plant's superior operating record, but most importantly,' by the  !

institutionalized processes and safety culture that are the basis for this i performance. These processes and safety culture are exemplified by the core corrective action process that sets an industry standard, a wide l variety of assessment activities that provide additional' defense in ' depth  !

and strong management direction that fosters an ever improving safety culture. These activities also establish multi-dimensional barriers that l will ensure continued superior safety performance.

J l

. l Response to the SALP Report for the Period of October 31, 1993 through-April 29, 1995 W3F1-95-0106 Page 7 July 19, 1995 The actions and performance of the staff in general and the Operations Department in particular, deserve the positive feedback necessary to sustain such efforts. We request that you raise the Category 2 rating in the functional area of Plant Operations to a Category 1 rating.

Very' truly yours, R.P. Barkhurst Vice President, Operations Waterford 3 RPB/DMU/ssf Attachments cc: C.P. Patel, NRC-NRR R.B. McGehee N.S. Reynolds

NRCT
Document Control Desk- /

NRC'ResidentJInspectors' Office i

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.. j List of Attachents l l

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Attachment 1: Clarification of Issues Specific to the Plant Operations  !

Section of the SALP Report 1 Attachment 2: Data Supporting Superior Performance Attachment 3: Condition Reports Written During Last Year Attachment 4: Details of Activities that Support Processes and Safety 'I Culture ,

I Attachment 1 to W3F1-95-0106

Attachment 1 to W3F1-95-0106 Page 1 of 5 Clarification of Issues Specific to the Plant Operations Section of the SALP Report The SALP report cover letter states that "Although strong performance by operators contributed to a long continuous run, improvements could be made with operations training, procedures and problem identification." In the Plant Operations section of the SALP report, a number of items perceived as weaknesses have been identified in these three areas. Waterford 3 would like to clarify these issues and provide further information for your consideration. These issues will be discussed below by area.

TRAINING The SALP report states that some weaknesses were identified with "the training program for operators" and that "some less experienced licensed and non-licensed operators demonstrated performance and knowledge deficiencies that should have been remedied by the training and qualification program".

Waterford 3 agrees that weaknesses in several areas of the operator training program did exist, but this example typifies how Waterford 3 handles a self identified weakness. The results of the reactor operator class which ended in March,1994 did not meet our expectations. As a result, a thorough evaluation of the operator training program was performed, and significant changes and improvements were made. Testing was revised to included oral boards with management and management walkthroughs. Test questions were modified to include written answer and system drawing questions in addition to multiple choice questions during requalification quizzes. Licensed operators are now required to make an 80% grade on requalification quizzes, as well as the annual examination.

The results of these improvements were dramatic. All SR0 candidates passed the exam given in March, 1995. The average score was 94.3, and no one made less than a 90. In addition, each candidate had strong simulator and walkthrough scores.

In conjunction with licensed operator training program improvements, significant enhancements were also made in nuclear auxiliary operator (NAO) training. Specifically, auxiliary operators are now required to complete job performance measures, take plant field trips during training, and take an annual exam. In addition, each auxiliary operator is given a plant

Attachment 1 to W3F1-95-0106 Page 2 of 5 Clarification of Issues Specific to the Plant Operations Section of the SALP Report walkthrough by his SS or CRS every quarter. Lead instructors have also been specifically assigned to the NA0 program. Operations training is better than it has ever been.

The SALP report also states that " inspectors identified that compensatory measures for degraded fire detection equipment" did not have sufficient guidance. Waterford 3 takes exception to this statement. After interviewing the operators questioned by your inspectors, we believe there was considerable confusion and misunderstanding over both the question asked and the answers received. Normal containment temperature is between 108-112 F. The technical specification limit is 120 F and is well known to all operations personnel. It is our understanding that all operators queried knew that they were logging containment temperatures as compensatory actions for degraded fire protection equipment. We are confident that if the question asked were, "What would you do if you saw any of these temperatures beginning to rise?" the answers would have been consistent and proper, and would have included immediate investigation.

Another concern stated was that "some weaknesses were identified with the training program for fuel handling operators". A training task analysis was performed to determine areas for improvement in the training program for fuel handling operators. Information from the analysis, such as a need for training on off normal events, was used to enhance the training l program.

PROCEDURES The SALP report states that the "overall quality of procedures at the site was mixed". Waterford 3 takes exception to this statement as an overall assessment of the operations procedures. We recently finished an imergency Operating Procedure (EOP) upgrade that was favorably reviewed by the Institute of Nuclear Power Operations. The E0Ps are again undergoing revision to include new information and technology as it becomes available.

Our Off-Normal procedures were also upgraded. Hard sequencing has been j implemented for all appropriate Operation's procedures. The procedure I review process has been revised to incorporate verification and validation  !

(V&V) and whenever possible walkthroughs are performed. A departmental goal for 1995 is to ensure that no operations procedure has more than three

m ,

AttachmGnt I to W3F1-95-0106 Page 3 of 5 Clarification of Issues Specific to the Plant Operations Section of the SALP Report changes against it. As of this date that task is approximately 2/3 complete. Operation's procedures are better than they have ever been.

L

[ The SALP report also states "that procedures for locally resetting an emergency diesel generator following certain emergency trips did not have sufficient guidance". Waterford 3 again takes exception to this statement.

Adequate information and instructions are contained in procedures to reset l the EDGs. There was however a training issue involved with NA0s not being l able to reset the EDG without having the procedure. Weaknesses in the NA0 '

training program had been previously identified. As a result, program enhancements were being implemented to increase the level of training ,

received by NA0s.

Another concern stated in the SALP report was the " backlog of temporary revisions in control room drawings". The need to revise the Document Revision Notice (DRN) posting process on control room drawings was self- j identified by QA on a Process Survey. This survey was performed at the l request of Quality Assurance management as part of the Rapid Response Team  !

effort. The results of this survey and the identified need to expedite I changes to control room drawings were presented to the SRC. The SP.C I assigned Design Engineering the responsibility of correcting this situation. As a result, the following process improvements have begun, with full implementation by August 15, 1995.

  • All critical changes to drawings maintained in the control room will be updated in one working day following installation in the field.
  • Non-critical changes to drawings maintained in the control room will be updated in 7 working days.
  • Posting of DRNs in the " Installed" state in the control rcom will be eliminated. 1 i

PROBLEM IDENTIFICATION The SALP report states that "several minor boron dilutions repeatedly  ;

occurred" and that "the licensee was slow to take actions for boron dilution control problems".

Attachment I to W3F1-95-0106 Page 4 of 5 Clarification of Issues Specific to the Plant Operatfons Section of the sal.P Report Waterford 3 takes exception to these statements. The " minor boron l

dilutions" were indeed minor; not one of the events was reportable.

However, each event was promptly and thoroughly investigated. A root cause analysis (RCA) was performed after each event. Although not reportable, a licensee event report (LER) was voluntarily submitted for each event.

l Corrective actions specific to that event were made following each event, but no common mode of failure was apparent. A special inspection team from your office conducted a review of these events and could not identify a Common Cause.

Following the last event on 9-16-94, a Reactivity Management Task Force was forced to determine if any common threads existed between the events. The task force consisted of six plant personnel and one person from INP0 who assisted in establishing a process for determining the common root causes for adverse trends. The task force examined training, supervision, conduct of Operations, work control, procedures and personnel. This extensive and in-depth review provided significant additional in-sight to these events and the team identified five common causes: difficulty maintaining operating limits, procedural inadequacies, teamwork / communication deficiencies, training inadequacies and CVCS design inadequacies. Specific corrective actions were recommended in each area and assigned to the appropriate groups for implementation.

After each reactivity event, Waterford 3 evaluated the event. As the events continued, so did our efforts to correct the situation. The boron dilution events took place over four months. Our investigations into these events took six months. Our thorough and timely actions have eliminated this type of precusor event and no significant events related to reactivit<

control have occured.

The SALP report also states that " Licensee self assessment activities were slow to identify problems". Waterford 3 takes exception to this statement.

As a result of aggressive self assessment and prompt corrective action, significant improvements have been made in the areas of equipment positioning, tagging, and reactivity management. Personnel errors for the last six months are less than half what they were for the previous six months

l Attachment I to W3F1-95-0106 Page 5 of 5 Clarification of Issues Specific to the Plant Operations Section of the SALP Report i

AB Bus components not being tested for LOOP conditions were self identified and promptly addressed. NRC Inspection Report 94-25 states, "The inspectors noted that the licensee's response to the operators 'and training instructors ' discovery of the Train AB swing electrical buses'not being subjected to surveillance testing was timely...".

Another concern stated in the SALP report was that the Operations staff

" occasionally demonstrated a high threshold for initiating corrective actions". Waterford'3 takes exception to this statement. As displayed at the public meeting, for the 12 month period ending June 1995, Waterford 3 generated 1178 Condition Reports (CRs). Of these, 1/3 were initiated by

  • Operations. In addition, two licensed operators are assigned full time to '

investigate CRs and coordinate implementation of resulting corrective actions. ,

The SALP report also identified a concern about "a work around for a design deficiency involving the safety-related ventilation systems prevented prompt identification and correction for a significant design deficiency" Waterford 3 takes exception to this statement. The design deficiency of the ,

ESF ventilation system was never "a work-around" by Operations. The syste operated the same way it always had. It was, however, a shift supervisor that identified the problem, ensured that an investigation was conducted  !

and that corrective action was implemented. ,

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Attachment 2 to W3F1-95-0106 l

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9 Overall Waterford 3 Performance

- Superior Plant I

1994 Plant Records .

. Electrical generation (outage year)

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OveraII Waterford 3 Performance

- Superior Plant 1994 System Records for 3-Year Averages Collective radiation exposure Unit capability factor (UCF)

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Forced outage rate (FOR)  !!!

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l Attachment 2 to W3F1-95-0106 Page 13 of 13 Data Supporting Superior Performance The plants listed below received a 1 rating in all four functional areas during their last SALP rating period.

Davis Bessie Byron Kewaunee North Anna Diablo Canyon Turkey Point Grand Gulf St. Lucie Harris

  • The 3-year average capacity factors for each plant listed below are from the Utility Data Institute (UDI).

PLANT- -l 1992-94 AVG Davis Bessie 87.51%

Kewaunee 87.17%

Diablo Canyon 85.85% 1 Grand Gulf 85.46%

Harris 83.96%

Byron 81.27%

North Anna 81.06% l Turkey Point 80.57%

St. Lucie 78.16%

  • Comparison of Performance Indicators for Operating Commercial Nuclear Power Reactors from the NRC Office for Analysis and Evaluation of Operational Data. The events listed are those that occurred over a 12 month period; beginning the second quarter of 1994. Plants that are 2 l unit sites have the events listed for each unit individually. l

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PLANT Number of . Safety System- l -Safety System Scrams 'Actuations - (SSA)L l Failures (SSF)

Davis Bessie 0 0 1

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',,_ . , l Attachment'4 to l W3F1-95-0106 Page 1 of 66 Deta11s of Act1yities that Suwort '

Processes anti Safety Culture a

WATERFORD 3 CORE CORRECTIVE ACTION PROGRAM

'Several years ago, Entergy Operations, Inc., initiated a corporate-wide effort to overhaul and improve its corrective action programe A corporate level task force was formed to review other industry based  ;

programs, with the intent of pulling together the best' aspects of proven programs into a single. state-of-the-art program for implementation at all Entergy facilities. The first elements of this program were put into place at Waterford 3 in early 1993, with implementation of a new Condition Report process.

In February, 1993, the process was streamlined, consolidating several  :

7 corrective action documents into a single document, the Condition Report (CR), designed to document non-hardware deficiencies. The  ;

.Nonconformance Condition Identification (NCI) remained in place to i document hardware related deficiencies. ,

1 On June 1,1994,- to further streamline the process, the NCI was ,

eliminated and the CR became the single Waterford 3 corrective action document. The CR is used to document adverse conditions which l negatively impact the safe, efficient operation of Waterford 3. Adverse  ;

i conditions include nonconforming conditions, conditions adverse to quality, industrial safety concerns, and plant reliability concerns. l The program is based on a defense-in-depth strategy that integrates the j following essential elements 4

e Centralized corrective action program responsibility within the Quality Assurance organization, with cognizant root cause evaluation personnel matrixed into line organization corrective action activities j

. Well scoped and comprehensive administrative procedures e Consolidated problem reporting into a single, easy-to-use CR process having a low initiation threshold e Prompt Quality Assurance (QA) evaluation, prioritization, and assignment recommendation for each CR generated L .- - , ,

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Page 2 of 66 Deta11s of Actiy1tles that Support- l Processes and Safety Culture l l

WATERFORD 3 CORE CORRECTIVE ACTION PROGRAM (Cont'd)

  • A Condition Review Board (CRB) providing prompt senior level . review J and concurrence with QA recommendations for each CR i

e Clear assignment of evaluation and corrective action responsibility for each CR l

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' ZONE INSPECTION /0WNERSHIP PROGRAM e Reinforces Maintenance & Operations responsibility for the materiel condition of the plant.

  • Each zone has a maintenance foreman and operations SR0s assigned.

e Philosophy - if something does not look right or does not look like it belongs 'in the area, then it should be corrected. i e Periodic tours are made by management and by other zone owners.

e Zone inspection cards assist in identifying items and seeing that the responsible group is advised.  !

RESULTS l l

  • Hundreds of minor deficiencies have been corrected. 1 e Significant contribution to equipment performance and housekeeping.

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Attachment 4 to W3F1-95-0106 Page 4 of 66 Details of Activities that Support Processes and Safety Culture ROOT CAUSE ANALYSIS Waterford 3 has also implemented significant improvements to the. root cause analysis program to ensure that fundamental causes of human performance events, as well as trends are determined and corrected. A Waterford 3 Root Cause Analysis Desk Guide has been issued to provide users with a complete set of analytical tools. The purpose of this guide is to assist Entergy personnel its conducting an effective root cause analysis and in documenting the results of the analysis.

Standardizing the process ensures a consistent approach to root cause investigation and analysis and enables identification of generic problems and recurring trends. This guide is intended for use only as a reference by evaluators who have had formal root cause training, and training on the use of this guid A core group of people matrixed from various site organizations have been trained and qualified as root cause evaluators. The core group method was established to reduce the number of individuals responsible for reviewing root cause analyses and thereby increasing proficiency. The techniques used at Waterford 3 to gather and evaluate information during a root cause investigation are:

  • Situational Data Sheet
  • Document Review l
  • Interviewing
  • Task Analysis
  • Change Analysis
  • Barrier Analysis
  • Event and Causal Factor Charting (E&CF)
  • Fault Tree Analysis e Behavioral Analysis and How-to-Why Matrix  !

In addition, Quality Assurance is conducting reviews of root cause analysis results to ensure consistency in the process prior to management approval. Performance measures indicate that the recent i changes have greatly enhanced the quality of the root cause analysis process.

4 Attachment 4 to

-W3F1-95-0106 Page 5 of 66 Deta1is of Activities that Support Processes and Safety Culture ADVERSE TREND ANALYSIS Waterford 3 is currently proceduralizing the process that was used to conduct the analysis of identified adverse trends in the areas of boron control, clearance practices, component positioning and work practices.

Multidisciplinary teams performed evaluations to identify and correct the common underlying causes of each area. This multidisciplinary team approach was found extremely effective in systematically identifying the common underlying causes. The new method incorporates the familiar root cause analysis techniques with the process evaluation tools included in our Total Quality Program. This combination resulted in a team of-diverse, talented representatives from the key departments openly and candidly discussing the problems within their respective areas, as well as the problems with the various interfaces. The process led the team members through each event and facilitated the development of potential causes. The team conducted extensive interviews and research to validate the causes and to develop recommended corrective actions. The ,

success of these teams has lead to the development of a Team  ;

Leader /Facilitator class to be scheduled for select individuals frc:a key -

departments. Waterford 3 intends to make effective use of this new analytical approach when future potential adverse trends are identified.

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Attachment 4 to W3F1-95-0106 Page 6 of 66 Deta1is ^of Activities that Support Processes and Safety Culture

-CONDITION REPORT TREND ANALYSIS Waterford 3 has implemented significant improvements in condition report trend analysis. In addition to the traditional approach of trending causal factors, a new problem code trend system has been developed.

Using a simple annunciator window format, Waterford 3 management is regularly provided the results of trend analysis in all of the major functional areas. The initial report has been issued for the first quarter of 1995.

In addition to the quarterly report, condition reports are coded and are evaluated for trends on a daily basis. The results of this "real time" analysis are documented on the applicable condition report and submitted to our Condition Review Board, providing prompt, high level management review of identified and potential trends. This real time trending allows management to place the appropriata level of resources and l attention to the problem area almost immediately. The program's goal is to prevent adverse trends by identifying and correcting in earlier stages. .

Waterford 3 has also identified other problem identification mechanisms ,

to assure that areas of lesser significance are periodically reviewed to  ;

identify adverse trends requiring escalation to the condition report  !

process. This requirement is being added to the Waterford 3 Plant Trending procedure.

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Attachment 4 to W3F1-95-0106 Page 7 of 66  :

Detaffs of Activities that Support Processes and Safety Culture CONDITION' IDENTIFICATION & CONDITION IDENTIFICATION REVIEW COMMITTEE The Condition Identification Review Committee (CIRC) is a standing committee which reviews new condition identifications and whose membership is comprised of representatives from the following departments:

e Operations e Planning & Scheduling e Mechanical Maintenance

. Electrical Maintenance e I&C Maintenance e System Engineering

  • Maintenance Engineering
  • Reactor Engineering & Performance  :

l The Condition Identification Review Committee is responsible for reviewing Condition Identifications and determining the following:

  • Appropriate priority

. Equipment mode  :

  • Proposed schedule date based on priority i e Disposition as a Minor Maintenance item e P1 ant mode e Lead discipline for disposition
  • Status of priority work in planning

. Items needing review by a multi-discipline team to define problem

. Determining the lead discipline, priority, schedule date and whether a component outage is required for the Ops Workaround Input Form

. Identifying CIs which need operational tests requiring system or component operation, outside the scope of the post maintenance test matrix

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Page 8 of 66- l Detaiis of ActiV1 ties that Suwort  :

Processes ami Safety Culture ;l i

CONDITION REVIEW BOARD The Condition' Review Board (CRB) is a standing board whose membership is comprised of the:'

  • General Manager, Plant Operations or designee l
  • Director, Nuclear Safety or the Quality Assurance Manger l e Director, Design Engineering or designee i e Licensing Manager or designee  !'
  • Operational Experience Engineering Manager or designee
  • Training Manager or designee Also, represented at the CRB daily meeting is a QA representative and a l Planning & Scheduling representative.

The Condition Review Board is responsible for maintaining cognizance and i ensuring proper identification of emerging conditions through review of l new Condition Reports and Controlled Maintenance Condition i Identifications. The CRB is also responsible.for assuring that adverse .

conditions receive commensurate attention and dedication of resources.

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Attachment 4 to W3F1-95-0106 Page 9 of 66 Deta11s of Act1y1 ties that Support Processes and Safety Culture SAFETY REVIEW COMMITTEE l l

The Safety Review Committee (SRC) is a standing committee composed of Waterford 3 management and supervisory personnel, representative (s) of Entergy Operations, Inc., and consultants. Consultants are utilized as determined by the SRC Chairman to provide expert advice to the SRC. The !

SRC functions to provide independent review and audit of designated I activities in the areas of: I I

e Nuclear power plant operations e Nuclear engineering

  • Chemistry and radiochemistry e Metallurgy

. Instrumentation and control e Radiological safety e Mechanical and electrical engineering

  • Quality Assurance practices Significant issues recently addressed by the SRC:
  • INDEX Program (Unescorted Access Authorization)
  • Control Room Drawings e Crosby Relief Valve Nozzle Ring Settings
  • Setpoint Point Document Control (control of data) e Reactivity Management (Boron Dilution Events)  !
  • Training Issues (Plant Modifications incorporated into training, GET j reconciled with INPO requirements) {
  • Corrective Action Program (Routine Agenda Item Discussed at Each Regularly Scheduled Meeting)
  • Warehouse Material Problems
  • Leak Repair - Industry event discussion e Control of Potentially Radioactive Material Outside of the RCA e Component Parameter Trending

. New fuel Receipt Inspection e Post Modification Testing

  • ESF Ventilation System e Tag Out Issues

i Attachment 4 to W3F1-95-0106 Page 10 of 66 Details of Act1y1 ties that Support Processes and Safety Culture l'

OA RAPID RESPONSE TEAM The mission of the Rapid Response Team (RRT) effort is to focus QA resources on emergent industry and plant issues to ascertain '

effectiveness of the program, process, or personnel relating to the issue. Listed below are assessments performed by the RRT since its inception in November of 1994.

Date Issue (Source) Sort Field #1 Reported 11/03/94 CR-94-1026 (abnorrral appearance of Housekeeping Ist - 95 oil Valve FW-104 '8")

11/04/94 Hazardous material spill in Water Housekeeping Ist - 95 Treatment Building 11/09/94 Westinghouse molded case breakers Electrical 1st - 95 (in W3 DC System) failed in Spain 11/09/94 Reset alarms for CC 134 and CC 135 Operations 1st - 95 11/16/94 Fabrication of ICI quik lock Engineering 1st - 95 device 11/17/94 HPSI (SI-P-1A) failed surveillance Operations 1st - 95 on high vibration  ;

11/30/94 Update (not DRN) of Control Room Engineering 1st - 95  !

Dwgs. -

l 01/05/95 Leaking Pressurizer Relief Valve Operations 1st - 95  ;

at Calvert Cliff after Reactor i Trip  !

01/06/95 Failed to adequately load reject Operations 1st - 95 test Emergency Diesel Gen. (A/B Bus) 01/06/95 Is independent verification Operations 1st - 95 necessary after sury. testing 01/06/95 Essential Chiller "B" Tube Maintenance 1st - 95 Replacement 01/06/95 Atmospheric Dump Valve Leakage Operations 1st - 95 01/11/95 RCS Metal Sensible Heat Transfer Operations 1st - 95 to Reactor Coolant during LOCA not addressed in Calvert Cliff FSAR 01/12/95 Reactivate R0/SR0 License from Operations 1st - 95 inactive to active 01/17/95 Use of SPEER Process Engineering 1st - 95 j

1 Attachm:nt 4 to W3F1-95-0106 Page 11 of 66 Detaffs of Activities that Support Processes and Safety Culture 0A RAPID RESPONSE TEAM (Cont'd)

Date Issue (Source) Sort Field #1 Reported 01/17/95 Use of TAR Process Engineering 1st - 95 01/17/95 Erosion Corrosion of MSR manways Operations 1st - 95 at WNP #2 01/30/95 ID of Q1 piping in Storage Yard is Site Support 1st - 95 pitted .

01/30/95 MIC discovered in Fire protection Engineering Ist - 95 System Piping 02/16/95 How are we ensuring that all Construction 2nd-95 pieces of steel painted are inspected. (QA) 02/16/95 Inappropriate action for Low Electrical 1st - 95 Battery Cell Voltage (OE 7109) .

02/16/95 Agastat relays exceeded qualified Electrical 1st - 95 life (PS 3545) l 03/01/95 Browns Ferry QC suggests-a review Electrical 1st - 95 of Licensee Inspection requirements for installation of Raychem tubing regarding sealant flow at both ends of the tubing.

(OE 7120) 03/22/95 W3 Preparations in case second RCP Operations 2nd-95 i seal failure (QA)  ;

03/22/95 Discussed Diablo Canyon's App. R Fire 1st - 95 problem with Pyrocrete at P0D Protection (POD) 03/31/95 W3 activities involving the new Construction  ;

Rad Waste Storage Building being built by NOC (QA) 04/12/95 ANO had positive amphetamine Fitness For 2nd-95 >

result that Smith-Kline Beecham Duty  ;

lab screened negative & then later j notified ANO results were positive  !

(S-95-0007)  :

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Attachment 4 to W3F1-95-0106 Page 12 of 66 Detaffs of Activities that Support Processes and Safety Culture OA RAPID RESPONSE TEAM (Cont'd)

Date Issue (Source) Sort Field #1 Reported 04/12/95 Stroke time for CHW 129 may be Engineering 2nd-95 unnecessary & over interpretation of Section XI (P00) 04/12/95 RX Drain Tank may be taken out of Operations 2nd-95 leakage calculation due to negative unidentified leak numbers (P00) 04/13/95 Effectiveness of W3 actions taken Operations 2nd-95 regarding SIT Leakage (QA) 04/13/95 Investigate for possible adverse Maintenance trend the failure of Steam Traps in the Turbine Building (P0D) 04/14/95 Evaluating primary & secondary Chemistry 2nd-95 Chemistry Lab techniques due to significant CR-95-0246 (QA) 04/18/95 Evaluate process for possible Maintenance 2nd-95 adverse trend regarding history of hydromotors testing problems on chilled water (P0D) 04/19/95 Investigate why personnel can't Health Physics 2nd-95 leave the PA if body frisk indicates no particles instead of waiting for gas to decay (QA) 04/20/95 Evaluate equipment trending Maintenance process (consider high amount of failures of Dry Cooling Tower Monitors) (QA) 04/21/95 Evaluate adequacy of processes for Maintenance painting equipment and QA i oversight in light of deficiencies identified in CR-95-0295 (QA) 04/25/95 Evaluate adequacy of NA0 Training Operations in areas necessary to ,

satisfactorily perform all assigned duties (0A) i

Attachment 4 to W3F1-95-0106 Page 13 of 66 Detafis of Act1y1tles that Support Processes and Safety Culture OA RAPID RESPONSE TEAM (Cont'd)

Date Issue (Source) Sort Field #1 Reported 04/25/95 ANO discovered that Access Fitness For 2nd-95 Authorization took administrative Duty actions associated with confirmed positive drug test before confirmed by MRO (ANO CR S-95-0008) (Violation of C5.801, Para. 5.12.3) 04/26/95 Evaluate warehouse receipt Materials 2nd-95 inspection process regarding Management possible high rejection by Material Technical of parts returned from vendor after repair (QA) 04/26/95 Evaluate process for Operations identification of failed instruments for RCP IB bleed off on CP2 and similar instrumentation -

(QA) ,

05/04/95 Evaluate adequacy of Non Environmental 2nd-95 l Radiological Environmental l activities regarding diesel fuel (QA) 05/05/95 Investigate adequacy of activities Chemistry 2nd-95 l involving corrosion in the ACCW system (QA) 05/08/95 Determine if DNs are being written Materials 2nd-95 to document conditions adverse to Management quality (QA) 05/10/95 Determine if electricians are Electrical maintaining material taken from level B warehouse storage in a trailer on site (QA) 05/11/95 Investigate use of a CR & WA for Design 2nd-95 repair of a Sump Pump to add an Engineering '

annunciator in the control room instead of a Plant Change (QA) i

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L Attachment 4 to W3F1-95-0106 l Page 14 of 66 Detaffs of Activities that Support Processes and Safety Culture 0A RAPID RESPONSE TEAM (Cont'd)

Date Issue (Source) Sort Field #1 Reported 05/11/95 Evaluate process that allows parts Design- l to abandoned in place but fails to Engineering update FSAR regarding operability.

(QA) 05/11/95 Evaluate process that allows MODS Design to be voided but not the Engineering associated DRNs (QA) 05/19/95 Follow-up on Lessons Learned Operations regarding Reactivity Management Rollup CR #94-918 (QA) 05/22/95 Evaluate processes involved that Design led to Engineering T-hot rollup CR #95-0414 (QA) 05/22/95 Evaluate process regarding the Site Support control of departmental procedures, drawings &

calculations. (Contact C. Packer)

(QA) 06/01/95 Investigate actions taken & Maintenance planned regarding numerous failures of Dry Cooling Tower Rad Monitors 06/01/95 Evaluate process for pulling Security badges for departed employees both under favorable & unfavorable conditions (QA) 06/07/95 Investigate the issue of Air Operations Intrusion in systems (CRs) 06/13/95 Evaluate the action taken by the Numerous Event Review Team regarding the Departments 6/10/95 fire in the TGB (QA) 06/13/95 Evaluate action taken by EP Emergency regarding method & timing of VNS Preparedness activation for 6/10/95 fire in the TGB (QA)

.,. -+:ncm:. ~. = ,, a, n . m . . . - .~ .

m l Attachment 4 to W3F1-95-0106 Page 15 of 66 i Details of Activities that Support l Processes and Safety Culture OA RAPID RESPONSE TEAM (Cont'd)

Date Issue (Source) Sort Field #1 Reported 06/13/95 Determine adequacy of process Security ,, l regarding Contractor Behavioral  !

Observation Program (CBOP) (CR )

1 1086) 06/19/95 Investigate conditions regarding Operations 3 the failure of SI 405 A&B to open (P00)  !

06/19/95 Determine adequacy of process that Operations requires CRS to leave Control Room during an emergency to act as Fire Brigade Leader (QA) 06/20/95 Evaluate the process in place for Security consistency regarding issue of key cards at the PAP (QA) 06/26/95 Assess Outage Risk Assessment Team Operations (ORAT) activities for planned or forced outages such as ORAT not seeing work until after completed (QA) 06/27/95 Evaluate action taken regarding Maintenance the rebuild work on RCP 2B (QA) 06/27/95 Evaluate Peer Inspection Program QA/ Maintenance regarding overview of Peer Inspectors 06/27/95 Evaluate process for removal of Maintenance Hold Points from procedures (QA) 06/28/95 Evaluate response to 6/28/95 Operations Hazardous Material Spill (QA)

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Attachment 4 to W3F1-95-0106 Page 16 of 66 Deta11s of ActiV1 ties that Support Processes and Safety Culture IN-HOUSE PLANT ASSESSMENT PROGRAM Quality Assurance, which reports to the Director of Nuclear Safety, is responsible for implementing a synergistic assessment program that blends performance-based concepts and objectives with their compliance-based counter-parts. The pivotal objective is to enhance the effectiveness of station operation by concurrently verifying compliance and evaluating performance.

Assessment activities mainly consist of audits and process surveys that are initiated by the Quality Assurance organization. Assessments are also performed as a support function when requested by management external to QA.

Results of assessments are reportad to management. The Condition Report process is used to address conditions adverse to quality, while potential enhancements are identified and tracked as " opportunities for improvement."

l In a move to enhance Waterford's assessment capability, an improvement item was recently implemented that formally utilizes QA inspection personnel in the performance of plant assessments.

In addition to QA, the Operational Experience Engineering Group (0EEG) functions as part of the In-House Plant Assessment Program. The OEEG Independent Technical Review function is intended to examine multiple sources of information and when applicable, make recommendations to management regarding the improvement of plar.t safety. A primary component of the Independent Technical Review function is the self-assessment of Waterford 3 programs, procedures, and activities conducted during the applicability reviews of recent industry experience.

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Attachment 4 to W3F1-95-0106 Page 17 of 66 Details of Activities that Support Processes and Safety Culture l

IN-H0VSE PLANT ASSESSMENT PROGRAM (Cont'd) l l

Below are lists of the QA Process Surveys, Service Assessments and Audits and OEE Assessments performed over the last 18 month period.

QUALITY ASSURANCE PROCESS SURVEYS PROCESS SURVEY # TITLE  ;

QS-94-001 Verification of Compliance with 40CFR82 - Protection of Stratospheric Ozone; Refrigerant Recycling QS-94-002 VOTES Testing of MS EMTR313A 6J Motor Operated Valve QS-94-003 Review of Waterford 3's actions to address NRC Information Notice 93-87, Fuse Problems with Westinghouse 7300 Printed Circuit Cards QS-94-004 Welder Qualification Testing QS-94-005 Adequacy of Fire Watch Patrols QS-94-006 Nuclear Fuel Receipt QS-94-007 Administrative Procedure OP-100-009, Control of Valves and Breakers QS-94-008 Inspection of ACC "A" Piping Internals QS-94-009 Preventative Maintenance of Containment Spray Pump "A' 4.16KV Breaker QS-94-010 High pressure Safety Injection Pump A/B Outage Performed from 2/10/94 through 2/14/94 QS-94-011 Review of Waterford 3's actions to address NRC Information Notice 92-26, Pressure Locking of Motor-0perated Flexible Wedge Gate Valves QS-94-012 Rework Emergency Diesel Generator Air Compressor IB QS-94-013 Technical Specification Surveillance for "A" Containment Spray (CS) Pump and the Re-test of Valve CS-117A (Backshift)

QS-94-014 Performance of Special Test Procedure STP-01117875, Component Cooling Water Discharge Check Valve Test QS-94-015 5th Refueling Outage Post Outage Report Recommendations

Attachment 4 to W3F1-95-0106 Page 18 of 66 Detaffs of Activities that Support Processes and Safety Culture IN-HOUSE PLANT ASSESSMENT PROGRAM (Cont'n 1

PROCESS SURVEY # TITLE QS-94-016 Adequacy of Fire Watch Patrols QS-94-017 Welding and Heat Treating Activities QS-94-018 Replacement of Extraction steam Piping for Erosion Control During Refuel 6 QS-94-019 Adequacy of Fire Watch Patrols QS-94-020 Replacement of MDR Relay During Refuel 6 QS-94-021 Spent Fuel Handling Machine Operability Check QS-94-022 Component Cooling Water (CCW) Heat Exchanger Chemical Cleaning - Refuel 6 05-94-023 Refuel Outage 6 Core Inventory Mapping QS-94-024 Fuel Shuffle / FME Control 05-94-025 Functional Testing of Mechanical Snubbers QS-94-026 Hydraulic Snubber Functional Test / Contract Order Number W-1263-0005 (Backshift)

QS-94-027 Radwaste LSA Shipment 94-1006 QS-94-028 Compliance with Overtime Restrictions During Outage Period QS-94-029 Equipment Control During Outage Period 05-94-031 TBCCW Pump Maintenance QS-94-032 Refueling (Backshift)

QS-94-033 Motor Operated Valve V0TES Testing QS-94-034 Corrective Maintenance on SI MVAAA 512A 0S-94-035 Sampling of Thermo-Lag Assemblies (Backshift)

QS-94-036 Welding of the Extraction Steam Line I QS-94-037 Eddy Current Testing of the Steam Generator by ABB Combustion Engineering i Q5-94-038 Evaluation of X-Ray Machines for Regulatory Compliance QS-94-039 Calibration of CEDMEC Breaker Position Relays QS-94-040- Calibration of EFW Header A to S/G #1 Flow Loop QS-94-041 Sludge Lancing of Steam Generators QS-94-042 Refuel 6 Plant Walkdowns - Health Physics Postings and Radioactive Material Storage Areas Q5-94-043 Overspeed Trip Test of "B" main Feedwater Pump Turbine QS-94-044 Radwaste LSA Shipment 94-1008 ,

QS-94-045 Refuel 6 Plant Walkdowns - Control of Consumable Materials

Attachment 4 to i W3F1-95-0106 Page 19 of 66 Detaffs of Activities that Support Processes and Safety Culture IN-HOUSE PLANT ASSESSMENT PROGRAM (Cont'd)

' PROCESS SURVEY # TITLE QS-94-046 Control Element Assembly Insertion Time Measurement 4 QS-94-047 Design Change 3384, Emergency Diesel Generator Overhead l Rigging System QS-94-048 Cooperheat Heat Treatment of the Extraction Steam Pipe Welds  ;

I QS-94-049 Adequacy of Fire Watch Patrols QS-94-050 Radwaste Resin Shipment 94-1009  :

QS-94-051 Survey of Special Test Procedure STP-01121620 " Test of Containment Spray Header Isolation Valve CS-125B" QS-94-052 Radioactive Waste Shipment 94-1002 QS-94-053 Skin and Clothing Contamination Reports QS-94-054 CVC "A" Component Outage 1 QS-94-055 Groundwater Level and Chloride Analysis for the Basemat Monitoring Program QS-94-056 Tech. Spec. Surveillance for Battery Banks and Associated  ;

Chargers QS-94-057 Information Notice 93-37, Eyebolts with Indeterminate Properties Installed In Limitorque Valve Operator Housing Covers QS-94-058 Design Change DC-3388 05-94-059 Auxiliary Boiler Installation l QS-94-060 Refuel Outage 6 Activities of the Maintenance, and NOC  !

Groups j QS-94-061 Adequacy of Fire Watch Patrols QS-94-062 Verification of Locked Valves QS-94-063 Technical Support Center - Dose Assessment l QS-94-064 SBV "A" Temperature Instrument Calibration QS-94-065 Materials Management Receipt Inspection QS-94-066 Operations Monthly Clearance Audit and Shift Meeting i QS-94-067 OP-903-068, Rev. 9, Emergency Diesel Generator and Subgroup Relay Operability Verification 05-94-068 Calibration of Keithley Model 197 Digital Multimeter QS-94-069 Mechanical Maintenance Valve Rework / Testing QS-94-070 MI-003-372, Control Room Outside Air Intake Isolation .

Radiation Monitor Functional Test, ARMIR0200.1

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.W3F1-95-0106 ,

Page 20 of 66 l Detaffs of Activities that Support -

Processes and Safety Cultune i t

IN-HOUSE PLANT ASSESSMENT PROGRAM (Cont'd)

PROCESS SURVEY # TITLE QS-94-071 Weapons Qualification for Waterford 3 Security Personnel  ;

QS-94-072 Plant Monitoring Computer Configuration Management I QS-94-074- Analysis of QA Process Surveys to Determine Average Number l of Days to Issue QS-94-075 Activities Associated with the Issuance of M&TE from the Issue Facility (Tool Room)  ;

QS-94-076 Torquing of Intercell Connections for the Plant Computer Battery QS-94-077 Corrosion Product Monitoring - Sampling and Analyses l

QS-94-078 Preventive Maintenance on Batteries and Chargers QS-94-079 Inservice Test of High Pressure Safety Injection Pump "A" .

QS-94-080 Radi& tion Worker Training - GET 2A l QS-94-081 DC-3408 - Replacement of the E7000. Series Agastat  :

Electropneumatic Time Delay Relays  !

QS-94-082 Walkdown of the Protected Area 05-94-083 Red Tag Clearances QS-94-084 Adequacy of Fire Watch Patrols  ;

QS-94-085 Discharge of Waste Condensate Tank A QS-94-086 Security Search of Maintenance Support Building and. Testing  !

of Security Perimeter Zone .

l QS-94-087 Capacitor Replacement in SUPS Inverter 3014AB QS-94-088 Field Control of Procedures QS-94-089 Emergency Operating Facility - Dose Assessment i QS-94-090 Tech. Spec. Surveillance for the Functional Test of Waste I Condensate and Laundry Waste Discharge Liquid Effluent i Radiation Monitor Channel (PRMIR0647) j QS-94-091 Work Authorization Packages Completed But Not Closed  ;

QS-94-092 N.I. Safety Channel Functional Test l QS-94-093 NRC Information Notice 92-27, Thermally Induced Accelerated Aging and Failure of ITE/Gould A.C. Relays Used In Safety-Related Applications, April 3, 1992 i QS-94-094 Fire Brigade Drill (C Heater Drain Pump)

QS-94-095 Inspection and Repair of Reactor Vessel 0-Ring by ABB Combustion Engineering 05-94-096 Health Physics Computer Software Control 1

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Processes and Safety Culture  :

l IN-HOUSE PLANT ASSESSMENT PROGRAM 1 Cont'd)

PROCESS SURVEY # .,

TITLE ,

QS-94-097 Maierials Management Testing Facility QS-94-098 Environmental Qualification Surveillance of Charging Pump AB Motor QS-94-099 Annual Land Use Census QS-94-100 Thermography Activities QS-94-101 Calibration and Control of Measuring & Test Equipment QS-94-102 Rework and VOTES Testing of HVREMTR 313 A 05-94-104 Unannounced Fire Drill - Diesel Fire Pump #2 j QS-94-105 QS-94-106 National Nuclear Corporation Test of High Density Fuel Storage Racks and Foreign Material Control QS-94-107 Hazardous Materials Incident - November 4, 1994 QS-94-108 Transfer of Spent Filters from a Shielded High Integrity Container (HIC) to an Outside Shielded Storage Enclosure (OSSE) (Backshift) 05-94-109 Incorrect Vibration Survey Readings on HPSI Pump A QS-94-110 Adequacy of Fire Watch Patrols 0S-94-111 Sampling and Replacement of FW-184A Hydraulic Fluid Q5-94-112 Reworking of the Air Handling Unit B Recirculating Damper Hydramotor (HRVMVAAA403B) i QS-94-113 Application of 10CFR50.59 Process to Site Support Procedures j QS-94-114 Shelf-Life Program l Spare Part Equivalency Evaluation Reports 05-94-115 05-94-116 Radiation Protection Backshift Activities 05-94-117 Technical Specification Surveillance for EGFMPMP0001B Q5-94-118 Quarterly TLD Exchange QS-94-119 Reactor Coolant Chemistry QS-94-120 1994 Annual Exercise QS-94-121 Rework Pyrocrete Equipment Hatch +46 Per Engineering Evaluation and the Manufacturer's Specifications l

Attachment 4 to W3F1-95-0106 Page 22 of 66 Detaffs of Activities that Support Processes and Safety Culture IN-HOUSE PLANT ASSESSMENT PROGRAM (Cont'd)

PROCESS SURVEY # TITLE QS-95-001 Clearance Procedure (0 pen Clearances)

QS-95-002 Main Steam & Pressurizer Safety Relief Valve Maintenance Procedure Pertinent to NRC Info. Notice 94-56 05-95-003 Condition Report Trending QS-95-004 Preparation and Quarterly REMP TLD Exchange QS-95-005 EFW A/B Component Outage Activities QS-95-006 CCW & ACCW Motor 18 Month Task QS-95-007 License Operator Upgrade From Inactive to Active Status QS-95-008 Containment Spray Pump Outage QS-95-009 Verification of Heat Transfer from RCS Metal to Reactor Coolant in Safety Analysis QS-95-010 Emergency Diesel Generator (A&B) Fuel Rack Linkage Bolt

! QS-95-011 Erosion / Corrosion of the Moisture Separator Reheater Shell I

Manway QS-95-012 Transfer of Charcoal & Demin Liner from a HIC to an Outside Shielded Storage Enclosure QS-95-013 CC-134 A(B) & CC-135 A(B) Concerns '

l QS-95-014 Fire Wrap, Fire Seal and Radflex Insulation Q5-95-015 Drawing / Document Updating QS-95-016 Investigation of Materials Stored on Site Prior to Issue QS-95-017 Comparison of Valve & Spec List to SIMS database QS-95-018 DG "B" Outage QS-95-019 Installation of EDG Air Dryers IAW OC-3407 QS-95-020 Temporary Alteration Control 0S-95-021 SPEERS QS-95-022 Fire Watch Patrol /QTR. 1995 QS-95-023 MIC of Plant System QS-95-024 RAYCHEM 05-95-025 Survey of COLSS Steam Calorimetric QS-95-027 Replace Gasket on Fuel Pool Purification Pump Q5-95-028 I&C TS Surveillance QS-95-029 Fabrications / Coatings QS-95-030 Reactor Coolant Pump Seal Failure Contingency Plan QS-95-031 Installation of New Primary & Secondary Met Tower Equip.

Attachment 4 to W3F1-95-0106 Page 23 of 66 Detaffs of Activities that Support Processes and Safety Culture IN-H0VSE PLANT ASSESSMENT PROGRAM (Cont'd)  !

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PROCESS SURVEY # TITLE <

05-95-032 Testing of Hydro Motors l 0S-95-033 Routine Primary Chemistry Lab Analyses l QS-95-034 Labeling, Handling and Storage of Radioactive Material  ;

05-95-035 Radiological Posting & Key Control of High and Very HRA QS-95-036 OP-903-024 Rev. 9, Changes 1 0S-95-037 CHW-129 Section XI Testing QS-95-038 Observation of HP, Radwaste & Maintenance Activities QS-95-039 Dose Assessment Training - E0F QS-95-040 Condition of ACCW System QS-95-041 Systems Engineering Action Regarding Safety Injection Tank Leakage QS-95-042 Verification of Regulatory Compliance for EOF Underground Tank 0S-95-043 Quarterly Fire Watch Tour (Mar Apr May)

QS-95-044 Operations Monthly Fire Locker Equipment Inventory (Backshift) 05-95-045 Low Level Radwaste Storage Facility 0S-95-046 Repair WA Packages QS-95-047 Maintenance Rule QS-95-048 Equipment Trending 05-95-049 Announced Fire Drill - (Backshift)

QS-95-050 Comparing Pipeline List Against SIMS Database (Engineering)

QS-95-051 T-Hot Reduction QS-95-052 Equipment Abandoned in Place QS-95-053 Protected Train Applicability in a Forced Outage QS-95-054 Station Information Management System QS-95-055 BD-102B Rework QS-95-056 Root Cause Analysis Report on the Failure of SI-405A & SI-405B to open on 6/11/95 05-95-057 June 10, 1995 Reactor Trip QS-95-058 Mechanical Maintenance Reworking the 2B RCP Seals i

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- Processes and Safety Culture IN-HOUSE PLANT ASSESSMENT PROGRAM (Cont'd) 1 l

QUALITY ASSURANCE i SERVICE ASSESSMENTS ASSESSMENT NO. TITLE 94-001 _ Health Physics Procedure Compliance Assessment ,94-002 ' Erection of Scaffolding Above the "A" and "B" Emergency Diesel Generators94-003 Containment Piping Penetration Walkdown - Identification of :

Multi-Ply Bellows That Have Transportation Tabs  !94-004 Weld Repair /0verlay of MSR A and B by Welding Services, Inc.94-005 Foreign Material Exclusion in the Reactor Cavity and Spent Fuel Pool  ;94-006 Waterford 3 Pump and Valve Inservice Test Plan 94-007 DC-3073 RCB Air Conditioning 94-008 Use of Ludlum 12 for Field Monitoring l 94-009 Review of MPR Associates Inc. l 94-010 Review of Effluent Release Permits and Composite Sample  ;

Analyses l 95-001 SIMS Setpoint Verification ,95-002 UNT-005-032, Steam Generator Primary to Secondary Leakage 95-003 PRES - Corrective Actions t

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W3F1-95-0106 Page 25 of 66 Detaffs of Activities that Support Processes and Safety Culture IN-HOUSE PLANT ASSESSMENT PROGRAM (Cont'd)

QUALITY ASSURANCE 1994 AUDITS AUDIT # TITLE SA-94-001.1 Technical Specifications SA-94-003.1 Performance, Training & Qualification SA-94-004.1 Corrective Action /Nonconformance SA-94-004.2 Corrective Action /Nonconformance SA-94-007.1 Procurement SA-94-011.1 Inspections SA-94-012.1 Test Control SA-94-015.1 QA Program SA-94-016.1. Fire Protection & Loss Prevention Program SA-94-017.1 Primary Coolant Leakage Sources SA-94-018A.1 Health Physics Program - ALARA SA-94-018C.1 Health Physics Program - Instruments, Process & Area Monitors SA-94-0180.1 Health Physics Program - Radioactive Contamination /

Respiratory Control SA-94-019.1 Secondary Water Chemistry ,

SA-94-020.1 Post Accident Sampling SA-94-021.1 Basemat Monitoring j SA-94-022.1 Radiological Environmental Monitoring SA-94-025.1 Personnel Access Authorization SA-94-026.1 Radiological Emergency Plan ,

Nuclear Material Control & Accountability SA-94-027.1 SA-94-029.1 Maintenance  ;

SA-94-030.1 Security Program SA-94-031.1 Environmental Monitoring (Non-Radiological)

SA-94-032.1 In-service Inspection SA-94-035.1 Computer Codes and Software SA-94-036.1 Fitness For Duty I

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QUALITY ASSURANCE 1995 AUDITS AUDIT # TITLE SA-95-003.1 Performance, Training & Qualification <

SA-95-004.1 Corrective Action /Nonconformance SA-95-006.1 Design Control SA-95-008.1 Document Control SA-95-013.1 Control of M&TE '

SA-95-022.1 Rad. Envoronmental Monitoring SA-95-024.1 Rad. Waste Processing / Packaging & Shipping SA-95-026.1 Radiological Emergency Plan SA-95-031.1 Environmental Monitoring (Non-Radiological)

I SA-95-034.1 Operations l

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9 Attachment 4 to W3F1-95-0106 Page 27 of 66 Detaiis of ActiV1 ties that Support Processes and Safety Culture IN-HOUSE PLANT ASSESSMENT PROGRAM (Cor M ODERATIONAL EXPERIENCE ENGINEERING 1994 ASSESSMENTS ASSESSMENT NO. TITLE 94-001 Monitoring of CEDMCS for Grounds94-002 E0P Assessment of Waterford 3 (Nuclear Assurance Team Audit) .94-003 Review of St. Lucie Trip on High Main Generator Hydrogen Temperature on 11/02/93 ,94-004 Effectiveness Review of Operating Experience Program at PVNGS94-005 Effectiveness Review of Operating Experience Program at River Bend Station 94-006 Incorrect Statement in W3F1-93-0169, " Inservice Testing (IST) Plan - Pumps and Valves"94-007 Compression Fitting Failure Results in Personnel Injury 94-008 Review of Plant Computer Data Entry Errors, CR-93-212 and i l

CR-93-234 94-009 NRC Inspection Report 93-28 on 1993 Waterford 3 E-Plan Drill Weaknesses94-010 Report to SRC Corrective Action S/C on Differences Between )

OEE & QA on CRs l 94-011 1994 Operator Training Assessment 1 94-012 Vendor Equipment Technical Information Program (VETIP) 94-012R Vendor Equipment Technical Information Program (VETIP)94-013 OE 6811: Testing Method for Nuclear Grade Activated Charcoal 94-014 Closure of Condition Reports94-015 Assessment of Reactor Engineering Requested by General  !

Manager Plant Operations )94-016 Shift Manning for Simultaneous Fire and E0P Requirements94-017 1994 Maintenance Training Assessment 94-018 Loss of Off-Site Power with Safety Injection and Steam Generator Dryout-SEN 109 94-019 Enhancement of Training and Procedures to Prevent Steam Generator Overfill

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Processes and Safety Culture IN-H0VSE PLANT ASSESSMENT PROGRAM (Cont'd)

)

OPERATIONAL EXPERIENCE ENGINEERING l 1995 ASSESSMENTS ASSESSMENT NO. TITLE 95-001 SOER 94-01 Training Asssessment 95-002 Licensed Operators Training Assessment l 95-003 Berthold Systems Potential Defect in Source Shield Shutter  !

Mechanism 95-004 Review of Implementation of 10CFR55.53(f)(2), Reactivation of Licenses

'95-005 Assist in QA Audit of Operations l

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s Attachment 4 to W3F1-95-0106 Page 29 of 66 Deta1is of ActiV1tles that Support Processes and Safety Culture CORPORATE-SPONSORED SELF-ASSESSMENT PROCESS In 1994, the Corporate Nuclear Safety & Licensing group performed 46 assessments, a 44% increase over 1993. These assessments conservatively represented almost 19,000 man-hours of direct assessment effort; 14,150 Entergy participant man-hours (plant and corporate) and 4,800 industry PEER participant man-hours. The 96 industry PEERS who participated in the 1994 assessments represented 33 utilities, EPRI and INP0. An outline describing this program is presented below.

1. Self-assessments are performed by customer request.

Requests may be made verbally to any of the assessment group individuals in Corporate Nuclear Safety & Licensing or to the Director, Corporate Nuclear Safety & Licensing.

2. Assessments are typically performed in the following areas:

2.1 Operations 2.2 Maintenance 2.3 Radiation Protection 2.4 Design Engineering 2.5 Plant Engineering 2.6 Chemistry 2.7 Training 2.8 Industrial Safety 2.9 Outage Management 2.10 Project Management / Modifications 2.11 Materials Management / Procurement i 2.12 Planning / Scheduling 1

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2.13 Operating Experience Assessments can also be performed in other areas.

Assessment group individuals should be contacted to discuss specific assessment needs/ requirements.

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CORPORATE-SPONSORED SELF-ASSESSMENT PROCESS (Cnnt'd)

3. The assessment scope and the performance objectives for each -

assessment are determined by the team leader and the customer. Performance objectives are typically derived from documentation such as:

3.1 INP0 Criteria. Principally, INP0 90-015, " Performance i Objectives and Criteria for Operating and Near-term Operating License Plants" 3.2 INP0 Guidelines 3.3 INP0 Good Practices 3.4 INP0 Training Academy documentation 3.5 Entergy policies, directives, goals and objectives, etc.

3.6 Other applicable industry documentation

4. Self-assessments are performance based and modeled after INP0 Plant Evaluations or Assist Visits. Typical assessments are five days in duration. The team leader and the customer control the assessment scope and the team size to complete the assessment in this time period.
5. Assessment teams include the Team Leader (process expert, from the assessment group of Corporate Nuclear Safety &

Licensing) and Entergy and Industry Peers (subject matter experts). Peers may include individuals from the following organizations:

5.1 Entergy operating plant staffs 5.2 Entergy corporate staff 5.3 Other industry operating plant or corporate staffs 5.4 Other industry groups (eg., INP0, EPRI)

A typical assessment team is composed of 5-8 individuals.

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6. A written assessment report is the vehicle used to formally present the assessment results to the customer. The report provides the Strengths and Areas for Improvement identified  ;

by the assessment team. Customer concurrence is obtained before the final report is issued. Distribution is limited to the customer, the customer's chain of command through the Site Vice President, the Vice President, Operations Support and the Chief Operating Officer. Additional distribution is made only with the permission of the customer.  ;

7. The customer is requested to provide feedback on the assessment process at the conclusion of each assessment.

The feedback is used to continuously improve the self-assessment process.

8. The purpose of self-assessment is not to determine regulatory compliance, but to provide feedback to allow customers to achieve excellence in their areas of responsibility.

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Attachm:nt 4 to i W3F1-95-0106 j Page 32 of 66 Details of Activities that Support Processes and Safety Culture CORPORATE-SPONSORED SELF-ASSESSMENT PROCESS (Cont'd) 1994 Corporate Soonsored Self-Assessment Contribution At Waterford 3 Assessments were performed in the following areas:

Emergency Operating Procedures Management Expectations / Communication Operations Training Reactor Engineering Maintenance Operating Experience Radiation Protection Technical Training Design Engineering Software Control These assessments included 48 Entergy participants (plant and corporate) which represented approximately 2400 man-hours of assessment effort.

Fifteen Industry PEERS from the utilities / organizations shown below also participated in these assessments. The Industry PEER participation represented approximately 750 man-hours of assessment effort.

Atomic Energy Canada Baltimore Gas and Electric Carolina Power and Light Florida Power and Light Houston Lighting and Power INP0 Nebraska Public Power District Northern States Power Southern California Edison Texas Utilities Electric Co.

Assessments in 1994 continued to provide line managers the capability to assess the health of functions / processes within their areas of responsibility and promote continuing improvement throughout the organization. Some examples of these assessments include:

. - .- . - - - - . .- .. . -. .~ - .

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Processes and Safety Culture .  :

-i CORPORATE-SPONSORED SELF-ASSESSMENT PROCESS (Cont'd) 1994 Coroorate Soonsored Self-Assessment Contribution At Waterford 3 ,

(Cont'd)  !

Emeraency Operatina Procedures (February)-

This was a _ focused assessment to evaluate whether a proposed  !

revision to the Waterford Safety Function Recovery Procedure fully _  !

addressed a previous INP0 finding and fully incorporated the guidance provided by the Combustion Engineering Owners Group in CEN-152. The assessment team determined that both conditions had been met. Additionally, the team provided several_' suggestions for enhancements to the Emergency Operating Procedure process for consideration by Operations Department management. There'were no findings in this area in the subsequent INP0 evaluation. ,

Reactor Enaineerina (May) ,

An assessment of the. Reactor Engineering group was performed utilizing INP0-type and customer-developed criteria for procedure, i

interface, training and fuel integrity areas. This assessment was initiated by the Reactor Engineering-Peer Group. The program was viewed as meeting most of_ the assessment criteria for the 4- procedures and fuel integrity areas. Interfaces with other groups i had noticeably improved over past performance according to most of the personnel interviewed. o Maintenance (June)

Three sites had Maintenance assessments. The assessments were performed by teams consisting of Maintenance personnel from both inside and outside E0I using the INPO performance objectives as their basis to gauge the current level of performance.by the departments. Portions of the plants were also given detailed walkdowns by the teams to determine the materiel- condition of the plants.

  • w ' + - . + -,v- ._<w--,e-

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Pmcesses and Safety Culture CORPORATE-SPONSORED SELF-ASSESSMENT PROCESS (Cont'd) 1994 Coroorate Soonsored Self-Assessment Contribution At Waterford 3 (Cont'd) -

Operatina Exoerience (June) .

This was one in a series of assessments conducted by customer request at three of the four stations. The objectives of each of  ;

these assessments were essentially similar and some of the same Entergy peers were utilized in more than one assessment to achieve consistency. Two outside Entergy peers were utilized at each of these assessments, representing five different nuclear utilities and INPO. At Waterford 3, the team concluded that process '

improvements could be made to better distribute information and eliminate non-value added activities.

Radiation Protection (Auaust)

A series of Radiation Protection (RP) Assessments were performed at each of the four nuclear sites at the request of the RP PEER Group. Each of these assessments had peer team members from the other sites and corporate staff support. In addition, at least <

one external peer was on each team. At Waterford 3, the team concluded that there was excellent communication between groups and good radworker practices by workers. The team also concluded that contamination control practices could be improved.

Desian Enaineerina Software Control (December)

Control of Design Engineering software was assessed using INPO _;'

criteria. The assessment confirmed the customer's perception that software control was weak and identified areas where improvements  !

could be made. This assessment was strongly supported by the l customer who provided three peers as team members.  :

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Pmcesses and Safety Cultum  !

CORPORATE-SPONSORED SELF-ASSESSMENT PROCESS (Cont'd)

Corporate Assessments - 1995 (Completed) ,

P DAla Assessment flig March 6-10 Fitness For Duty WNP2 ,

March 6-10 Operations WNP2 March 29-May 16 NRB/FRC QA Audit Assist RBS April 10-14 Training (Accreditation) RBS i April 24-28 Materials, Purchasing & Contracts W3  :

i April 24-28 Simulator Certification /Config. Control CNS  ;

May 8-12 System Engineering W3 May 22-26 Check Valve Program RBS  :

May 22-26 Operations RBS l May 22-26 HVAC RBS June 5-9 Nuclear Engineering ECH ,

June 19-23 Planning and Scheduling ANO June 19-23 Operating Experience GGNS b

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CORPORATE-SPONSORED SELF-ASSESSMENT PROCESS (Cont'd) ,

Corporate Assessments - 1995 (Scheduled)

D111 Assessment litt July 17-21 Operating Experience W3 ASL/

July 17-21 Chemistry RBS i

July 17-21 Fitness for Duty W3 July 17-21 and EFW SSFI W3

-July 31-Aug 4 July 25-28 Digital FW Control ANO July 31-Aug 4 Thermal Performance RBS July 31-Aug 4 Radiation Protection RBS  ;

July 31-Aug 4 Operating Experience AN0 August 14-19 Operating Experience RBS August 14-19 System Engineering RBS September 11-15 Chemistry ANO f September 25-29 Design Engineering RBS l

September 25-29 Outage Readiness RBS October Training Review Group Effectiveness RBS October 9-13 Maintenance RBS October / November Human Performance Improvement Program RBS October / November Corrective Action W3 i

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Corporate Assessments - 1995 (Scheduled)(Cont'd)

Dat.t Assessment lits November 6-10 Fire Protection ANO November 6-10 Setpoint Control Process W3 November 6-10 PM Program ANO November 10CFR50.59 Process GGNS November / December Operations W3 December 4-8 Materials, Purchasing & Contracts ANO December 11-15 Service Water (GL 89-13) W3 Dry Cask Storage ANO Planning and Scheduling W3 MOV Program ANO  !

l MOV Program RBS

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CORPORATE-SPONSORED SELF-ASSESSMENT PROCESS (Cont'd) i 59f.gorate Assessments - 1996 (Scheduled)

QRig Assessment litt January 22-26 Maintenance W3-l l

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Page 39 of 66 Deta1is of ActiV1 ties that Support Processes and Safety Culture

' CORPORATE PEER GROUPS Puroose To provide a process for similar functional areas to optimize their ,

process and structure as appropriate, and to identify, review, and resolve emerging issues; to monitor consolidation and merger studies; to-administer company-wide contracts; and to share lessons learned.

Comoosition ,

Composed of senior person from the same functional area at each station, an executive sponsor, and a representative from headquarters.

Process Elements e established by Vice President's request and approved by executive ,

staff a meets periodically e members trained in TQI principles

  • TQI techniques used to conduct meeting e chairman selected by group,, rotated overy two years e the designated chairman has signature authority on policy / procedure documents e the executive sponsor will sign in the event the chairperson is not available i e minutes prepared and distributed to executive staff, and Executive sponsor briefed on meeting results j e routinely a periodic calendar or schedule of peer group meetings i provided to executive staff i e summary report on all peer groups provided to executive staff semi-annually (this report should' include assignments from executive management)

Attachment 4 to W3F1-95-0106 Page 40 of 66 Deta11s of Activitles that Support Processes and Safety Culture CORPORATE PEER GROUPS (Cont'd) e significant activities such as rule changes are brought to the attention of executive staff by executive sponsor e assignment of sponsorship will be reportees to officers after each officer has two peer-groups assigned e executive sponsor meets with group as appropriate to provide strategic direction, coaching, and support Vice President, Operations Support, oversees process; provides guidance for consistency; maintains peer group listing and assignments current; assesses process for effectiveness and efficiency; and provides semi-annually summary to executive staff.

Responsibility of Peer Group Members e monitors implementation of consolidation and merger studies e shares lessons learned e review and implements applicable best practices e review policy / procedures that apply to a specific peer group, implement changes where applicable, and coordinate a schedule for completion with the policy / procedure coordinator in Management Services (See AD-101, sections 4.6, 5.0 and 6.5 for reference) e conducts assigned or self-identified studies for process and structure improvements e cognizant of emerging issues; keeps executive staffed informed of issues e develops company-wide contracts

Attachment 4 to W3F1-95-0106 Page 41 of 66 Detaiis of Actiy1 ties that Support Processes amt Safety Culture CORPORATE PEER GROUPS (Cont'd) e develop and maintain Philosophy documents when applicable, and provide availability of these documents to other sources e executive sponsor provides evaluation of members pe-formances to their supervisors e Headquarters member prepares summary report for Chairman's approvals and inclusion in Nuclear's peer-group summary report e Headquarters members prepares periodically a calendar of peer-group meetings ENTERGY OPERATIONS PEER GROUPS i

e Chemistry ,

e Design Engineering l e Emergency Preparedness I e Environmental e Financial e General Plant Managers e Health Physics / Radiation e Industrial Safety e Licensing j e Low-Level Radwaste e Maintenance e Operations

  • Outage Management
  • Plant Modification and Construction e Policies and Procedures e Procurement / Materials e Quality Assurance e Reactor Engineering
  • Records Management l

e Security L e System Engineering

  • Training i l

. - n ~ . . m, ., -- . ,. -- m Attachment 4 to W3F1-95-0106 Page 42 of 66 Detaiis of Act1y1 ties that Support Processes and Safety Culture DESIGN ENGINEERING PEER GROUPS As part of the consolidation of the Entergy Operations' Design Engineering departments into one organization, a decision was made to maintain a strong site presence with a small centralized staff. However, to achieve the maximum benefits of consolidation, a mechanism was needed to share best practices, improve processes and provide an on-going mechanism for self assessments. The peer _ group concept was implemented.

The Entergy Operations Design Engineering Peer Groups are composed of a management sponsor and members from each of the Entergy Operations' locations.

The purpose of these peer groups is as follows:

  • Exchange information and ideas related to specific technical issues, procedures, and processes;
  • Provide a mechanism to develop and maintain consistency in methodologies utilized, principles implemented and programs developed, while allowing for logical differences between implementation at each site. The differences are to account for different site organizational structure, plant design and commitments to standards and codes; and

. Identify opportunities to improve quality and cost effectiveness.

Each peer group maintains a stated set of objectives which may be modified at any time depending on industry events, regulatory emphasis or department objec.tives. There are currently 22 peer groups. Each group issues a quarterly status report to the Corporate Vice President, Engineering. The report includes activities in progress and completed, issues requiring management attention and recommendations.

Typically peer groups meet quarterly and achieve substantial progress toward their objectives'. Some specific examples of peer group activities are:

  • Development of a Standard to be used at all Entergy sites for repairs and replacements.

Attachment 4 to W3F1-95-0106 Page 43 of 66 Details of Activities that Support Processes and Safety Culture DESIGN ENGINEERING PEER GROUPS (Cont'd)

  • Common standards have been developed for MOV test data review, including the approach for MOV Program Closure.
  • Shared expertise / processes between the sites has resulted in program enhancements and more efficient approaches in areas such as:

. Erosion / Corrosion Evolutions.

  • A consolidated contracting process was implemented to reduce the number of contractors providing general engineering services.
  • A Welding Consolidation Program to censolidate the welding standards at the Entergy sites.

l l Peer Groups are expected to continue me? ting as long as the subject of the group remains active. Peer Groups may be added or discontinued based on the emphasis needed on particular issues. Below is a list of the current Design Engineering PEER Groups:

. Electrical Design

  • Welding Programs

. Environmental Qualification

. Fire Protection . Training

. Flow Accelerated Corrosion e Business Practices

. I&C e CAD

. Mechanical Design . Computer Applications

. Motor and Air Operated Valves . . Configuration Management

. Piping Stress and Support

  • Design Process

. ASME Programs e PSA/IPE e Security . Procurement Engineering

. Seismic Qualification / Structural e Safety Analysis

Attachment 4 to W3F1-95-0106 Page 44 of 66 Deta11s of Activities that Support Processes and Safety Culture KEY PROCESS TEAMS In 1993, the Entergy Operations, Inc. (E01) Total Quality Lead Team selected four Key Processes to be evaluated. A Key Process is as the name implies, a process which is important or key to the achievement of our established goals of Safety, Generation, and Cost. A Key Process Team is a permanent cross-functional team charged with taking actions to ensure that a process is continuously monitored, supported, and improved. Each key process was assigned an E01 Vice President as a process owner, and teams were made up of management from each plant site and the corporate office. The E0I Key Processes are listed below:

Process Name: Corrective Action / Root Cause Analysis Process Definition And Team

Purpose:

The Corrective Action / Root Cause Analysis process is used to identify and correct problems affecting safety, cost or power generation capabilities at our company facilities.

The process requires significant employee involvement and is reliant on early problem identification and timely, effective resolutions. The process provides a structured approach for problem identification; root cause analysis; corrective action planning and implementation; and measures to assure that corrective actions were effective.

Process Name: Outage Management and Work Control Process Definition And Team

Purpose:

Develop a plan to continuously improve the Outage Management and Work Control Key Process emphasizing outage planning and effective outage implementation to:

  • Ensure personnel safety
  • Assure shutdown safety e Reduce personnel radiation expesure e Improve plant availability l
  • Reduce outage cost )
  • Optimize outage duration

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Detaffs of Activities that Support Processes and Safety Culture KEY PROCESS TEAMS (Cont'd)

Outage planning is a continuous process defined by the pre-outage j milestone schedule. -

i Outage implementation begins when the unit is removed from service to start outage work and ends when the unit is returned to service with the completion of outage work.

Process Name: Daily Work Planning and Control Process Definition And Team

Purpose:

The Daily Work Planning and Control process begins with the generation of work requests, goes through planning work packages, scheduling work, performing work in the field (including post maintenance testing), then ends with work package close-out.

l The purpose is to develop a plan to continuously improve the Daily Work Planning and Control Key Process with an emphasis on:

e personnel safety e nuclear safety

. ALARA  :

e plant availability .

e cost Process Name: Materials, Purchasing, and Contracts .

l Process Definition And Team

Purpose:

. The Materials Management Key Process Team will develop a specific plan of action to focus on process improvements for the Materials, Purchasing & Contracts processes as an Entergy Operations critical i processes. The plan of action will address the following issues: (1)  !

eliminating inventory growth, (2) building a defensible inventory, (3) constructing a materials management program that is direct, consistent,  ;

and auditable, and (4) cost effectiveness. I I

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W3F1-95-0106 Page 46 of 66 Detaffs of Activities that Support  ;

Processes and Safety Culture KEY PROCESS TEAMS (Cont'd)

This team will also ensure completion of a one-time Inventory Justification Project, requiring participation and support at each site. l l

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Processes and Safety Culture RELIABILITY IMPROVEMENT TEAM (RIT)

The Reliability Improvement Team (RIT) was established to emphasize and focus on issues affecting nuclear and personnel safety, availability, reliability, and performance of the plant and its systems. The team reviews important issues and facilitates implementation of corrective action measures.

-Problems are categorized and assigned to " Trip / Transient" rnd "High O&M" lists including the priority issues that impact power generation (i.e., cause unplanned energy losses). Potential plant problems which result in the following fall under the category of " Trip / Transient:"

. tu"bine/ reactor trips

. nent trips

. lost megawatts (MW) greater than 1000 MW over 12 months for a particular piece of equipment

. lost MW greater than 2000 MW over 12 months for a particular system The "High 0&M" list includes priority issues that impact plant resources.

Potential plant problems which result in the following would fall under the category of "High 0&M:"

. industrial safety concerns

. considerations for ALARA

. excessive manpower requirements

. excessive consumption of spare parts or other materials

' . inadequate equipment efficiency

. poor equipment reliability resulting in excessive maintenance or expenditure of resources Resolution of problems on the " Trip / Transient" and "High 0&M" lists receive high priority and management attention. In order to focus attention, each RIT issue has an action plan generated by the responsible individual. The action plans provide the following information:

. detailed problem description

. lead individual

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RELIABILITY IMPROVEMENT TEAM (RIT) (Cont'd)

. actions taken

. results checked for effectiveness

. status

. references The RIT is chaired by the Maintenance Superintendent and other members of the team include:

e Operations Superintendent e System Engineering - Electrical Supervisor e System Engineering - Mechanical Supervisor

  • Radiological Superintendent .

. STA Supervisor e Chemistry Superintendent

  • Reactor Engineering & Performance Supervisor e Design Engineering /PRA ,

e Senior Reliability Engineer

Attachment 4 to W3F1-95-0106 Page 49 of 66 Details of Activities that Support Processes and Safety Culture NATURAL WORK TEAMS Natural Work Teams (NWTs) were developed as part of the Total Quality Improvement (TQI) program in 1994. A NWT is defined as a team made up of a supervisor and direct reports. Other groups may be considered a NWT if they are involved in a work activity that constitutes the primary work for the participants, the activity is a repetitive work process and there is a common leader for the group. The goal of the NWT is to improve on its selected major work process. Below is a listing of the Natural Work Teams at Waterford 3.

PLANT OPERATIONS Work Group Function Process Ops. & Maint. Ops. Administration Procedure Review Ops. & Maint. Ops. Administration Procedure Changes 01-19 Ops. & Maint. Ops. Administration Ops. Use of MMIS Ops. & Maint. Ops. Administration Operations Work Schedule Ops. & Maint. Ops. Administration Key Control Ops. & Maint. Ops. Administration Completed Clearance Review Ops. & Maint. Ops. Administration Clearance Process Operation Operations Site Labeling Ops. & Maint. Ops. Administration Operations Truck Maint.

Ops. & Maint. Electrical Maintenance Motor Operated Valve Maint.

Ops. & Maint. Electrical Maintenance Predictive Motor Maintenance Progra Team Ops. & Maint. Electrical Maintenance E0 Data Report Ops. & Maint. Electrical Maintenance Maint. & Repair of Emergency Battery Lights Ops. & Maint. Electrical Planning Improve Access to Common Planner Information Oos. & Maint. Mechanical Maintenance Hot Work Permit Oos. & Maint. Mechanical Maintenance Diesel Enspecs Testing Ops. & Maint. Mechanical Maintenance Air Compressor Rework Ops. & Maint. Mechanical Maintenance Hydromotor Rework

Attachment 4 to W3F1-95-0IO6 Page 50 of 66 Detaffs of Activities that Support Processes and Safety Culture NATURAL WORK TEAMS (Cont'd)

PLANT OPERATIONS (Cont'd)

Work Group Function Process Ops. & Maint. Mechanical Planning Shop / Planner Coordination /Commun.

Ops. & Maint. I&C. Maintenance Usage and Storage of Consumables Ops. & Maint. I&C. Maintenance I&C Backshift Technician Qualifications Ops. & Maint. I&C. Maintenance Spare Parts Procurement Ops. & Maint. I&C. Maintenance Security - System Camera Maintenance Ops. & Maint. I&C. Maintenance PMI Task Levelization Ops. & Maint. I&C. Maintenance Evaluating the Issue and Recall of Major Measuring and Test Equipment Technical Services STA In-Service Testing Chemistry Chemistry Chemistry Corrosion Control Chemistry Chemistry Chemistry Laboratory 0A/0C Chemistry Chemistry Chemistry Procedure Improvement System Engineering Electrical Engineering Work Authorization Processing System Engineering Mechanical Special test Procedures Reactor Engineering & Reactor Engineering Routine Core Parameter Trending Performance Reactor Engineering Performance Engineering Thermal Performance Committee

& Performance Reactor Engineering & Plant Monitoring Computer PMC Database Management Performance Software Configuration Control Fire Protection Fire Protection Fire Protection Impairments Radiation Protection Radwaste Waste Sample Collection and Isotopic Evaluation Radiation Protection Radwaste Leak Containment Device Control Radiation Protection Health Physics Waste Container Coordination Radiation Protection Health Physics Scheduling of Rad Effluent Sampling

& Release Permit Update Radiation Protection Dosimetry Form 4 Generation & Retention Radiation Protection Rad. Protection Support Computer Software Control Radiation Protection Health Physics Daily Source Check of HP Instruments

Attachment 4 to W3F1-95-0106 Page 51 of 66 Deta11s of Actfy1tles that Support Processes qnd Safety Culture NATURAL WORK TEAMS (Cont'd)

PLANT OPERATIONS (Cont'd)

Work Group Function Process Planning & S-heduling Outage Schedule Containment Coordination ~

Planning &Schduling Scheduling Daily Scheduling Security & General Support Security Training Training /0ualification Security & General Support Security Operations Contractor Administration Security & General Support P1 ant Key Security P1 ant Key Contr01s Controls Security & General Support Security Shift Shift Operations Activities Security & General Support Invest./ Badging Personnel In-Processing Security & General Support Security Controls Reduction Safeguards Information Security & General Support Security Operations O&M Security Support P1anning &

Scheduling Security & General Support Security Operations 3 Year Security (E0I) Business Plan Personnel Assurance Personnel Assurance Fitness for Duty (FFD)

Supervisory Requirements Personnel Assurance Personnel Assurance FFD Testing Eligibility Tracking Personnel Assurance Personnel Assurance EAP Referrals / Return to Work Personnel Assurance Personnel Assurance FFD Specimen Collection &

Results Reporting Plant Operations Medical EFAT Locker Supplies / Control Plant Operations Medical Accident Notification Plant Operations Medical Medical Records Plant Operations Medical Site Physicals Scheduling &

Tracking Plant Operations Medical Patient Scheduling Environmental Environmental Hazardous Waste Disposal Environmental Environmental Environmental Regulatory Commitment Controls Industrial Safety Industrial Safety Lost Time Accident Mitigation

Attachment 4 to W3F1-95-0106 Page 52 of 66 Details of Activities that Support Processes and Safety Culture NATURAL WORK TEAMS (Cont'd)

PLANT OPERATIONS (Cont'd)

Wort Group Function Process Office Services General Support Plant Procedure Distribution Library Industrial Safety Industrial Safety Heat Stress Implementation / Effectiveness Office Services Clerical Support Meeting Rooms: Supplies, Scheduling Coordination &

Control Office Services Clerical Support Waterford 3 Travel Human Resources Human Resources Resume / Application Process Plant Maintenance Maintenance Corrective Maintenance Activities Radiation Protection Radiation Protection. Inventory of Radioactive ,

Chemistry, I&C and Sources Warehouse Plant Operations Improving Human Human Performance Award Program ,

l Performance Plant Operations Outages Bus Outages Improvement Information Technology Information Technology Help Desk Radiation Protection Radwaste Protective Clothing Process Ops & Maintenance Mechanical Maintenance Oil Recycling vs. Oil Replacement Ops & Maintenance Mechanical Maintenance Motor Pump Coupling PM Reduction Ops & Maintenance Mechanical Maintenance Pump Mechanical Seal Failures Op. & Maintenance Mechanical Maintenance Predictive Maintenance PM Reduction l

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Attachment 4 to W3F1-95-0106 Page 53 of 66 Detaffs of Activities that Support Processes and Safety Culture NATURAL WORK TEAMS (Cont'd)

PLANT MODIFICATIONS & CONSTRUCTION Work Group Function Process Modification Management Modification Modification Management Management Modification Estimating Modification Estimating Estimating Construction Field Construction Construction Supervision (Firewatch)

Construction Field Engineering Managing / Standardizing Electronic Files Project Management Facilities Maintenance Facilities Maintenance Plant Modification & N/A Scaffolding Construction Plant Modification & Scheduling Integrated Schedules Construction Modification Scheduling / Modification Scheduling / Estimating Estimating Scheduling / Estimating Construction Field Engineering NOC Work Packages l

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Attachment 4 to W3F1-95-0106 Page 54 of 66 Detaffs of Activities that Support l Processes anct Safety Culture NATURAL WORK TEAMS (Cont'd)

DESIGN ENGINEERING Work Group Function Process-Proc./ Programs Engr. Procurement Commercial Grade Evaluation Process Proc./ Programs Engr. Drafting / CAD W3 Drawing Numbering System Proc./ Programs Engr. In-Service Inspection ISI Procedure Electrical I&C Engineering Electrical Engineering WATS Process Electrical I&C Engineering I&C Engineering Setpoint Calculations Electrical I&C Engineering I&C Engineering Design Verification Mechanical / Civil Engineering Applied Mechanics Applied Mechanic / Civil Interface Mechanical / Civil Engineering Mechanical Specialties DBD Update Process Mechanical / Civil Engineering Mechanical Systems DRN Processing Mechanical / Civil Engineering Civil Engineering SORT File Review and Handling Design Engineering Plant Design Change Plant Change Process Design Engineering Design Engineering Design Engineering Procedures Administrative Guides Design Engineering & Work Authorizations Work Authorizations Maintenance Programs Engineering Support & Database Routing, Tracking and Completion of CI/WAs in D.E.

Safety & Engineering Analysis Safety & Engineering PRA Model and Documentation Analysis Update Process Design Engineering Support and Database Close-Dut Process for Design Change Work Authorizations Proc./ Programs Engr. Procurement Engr. Engr. Evaluation of Vend.

Exceptions - PDCR Proc./ Programs Engr. Procurement Engr. Engr. Evaluation of Receipt Inspection Discrepancies - PC~;

Proc./ Programs Engr. Drafting Database Closing and Transmitting Plan; Support Changes to Records 4

Attachment 4 to W3F1-95-0106 Page 55 of 66 Detaffs of Activities that Support Processes and Safety Culture NATURAL WORK TEAMS (Cont'd)

SITE SUPPORT Work Group Function Process Site Business Serv. Budgeting Plant Cost Control System Site Business Serv. Accounting Payroll Process Emergency Planning & Onsite Emergency Emergency Plan Administrative Services Planning Emergency Planning & Administration Emergency Planning Support Administrative Services Emergency Planning & Administrative Indexing R/ Type Administrative Services Services Emergency Planning & Administrative Data Conversion Administrative Services Services ._

Emergency Planning & Administrative Controlled Drawings Administrative Services Services Materials, Purchasing & Purchasing Faxing P0s and Bids Contracts Materials Purchasing & Contracts Purchase Order Close Out Contracts Materials, Purchasing & N/A Outage Report Update Contracts Materials, Purchasing & N/A Comitted Dollars / Spent Dollars Contracts Materials, Purchasing & N/A Certificate of Insurance Contracts Materials. Purchasing & N/A QCL Approval List Contracts Materials, Purchasing & Materials Management Material Receipt Contracts Materials. Purchasing & Materials Management Material Stocking Contracts Materials. Purchasing & Materials Management Material Issuing Contracts Materials, Purchasing & Materials Management Inventory Control Contracts i

Attachment 4 to W3F1-95-0106 Page 56 of 66 Details of Activities that Support Processes and Safety Culture NATURAL WORK TEAMS (Cont'd)

SITE SUPPORT (Cont'd)

Work Group Function Process Materials, Purchasing & Materials Technical Major Exception Contracts Materials. Purchasing & Materials Management Maintaining Optimum Inventory Contracts Levels Emergency Planning & Administrative Data Base Cleanup Administrative Services Services Site Support Management Management Programs & Employee Awards & Recognition -

Excellence Shining Through (Supervisory Awards)

Materials, Purchasing & Materials Management Material Test Lab - Record.

Contracts Track & Trending Tests i Site Support Management Management Programs & Maximum Utilization of Copy I Excellence Machines at W3 I I

Attachment 4 to l W3F1-95-0106 l Page 57 of 66 j Deta1is of Act1y1 ties that Support  ;

Processes and Safety Culture l l

l NATURAL WORK TEAMS (Cont'd)  !

TRAINING Work Group Function- Process Operations Training Operations Training Conduct of Simulator Training Simulator Training Simulator Training Simulator Problem Report Process Maintenance Training Maintenance Training Job Performance Measures Technical Training Technical Training Engineering Training & Engineering Documentation of Off Site Accreditation Instruction Vendor Training Engineering Training & Developmental Qualification Cards Accreditation Instruction Operations Training Operations Training Maintenance of Training Materials for Operations

f Attachment 4 to W3F1-95-0106 Page 58 of 66 Detaffs of Activities that Support '

Processes and Safety Culture I

1 NATURAL WORK TEAMS (Cont'd) l i

NUCLEAR SAFETY l Work Group Function Process Licensing Licensing Support Part 21 & Reportability Licensing Operational Licensing Part 21 & Reportability (CFR ,

Reporting)  ;

Licensing NSR&A Commitments Maintenance Licensing NSR&A Commitments Closure Licensing NSR&A Commitments I.D. - Outgoing Licensing NSR&A Commitments I.D. - Incoming Operational Experience Operations Experience Evaluation of Industry Engineering Review Experience Quality Assurance OA Inspection Plant Walkdown Quality Assurance 0A Audit / Assessment Audit Process Quality Assurance Corrective Action OA CA/ Review Review Safety Review 0-Team Employee Concern Safety Review Technical Review Technical Review

Attachment 4 to -

W3F1-95-0106 Page 59 of 66 Deta11s of Act1y1 ties that Support Processes and Safety Culture BUSINESS PLAN The information listed below is taken from the Waterford 3 1995-1997 Nuclear i Business Plan. This is only a summary of portions of the Business Plan.

Title of Program: Excellence in Self Assessments and Strong .

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Corrective Action Program Program Lead: Director, Nuclear Safety Strategic Objective: Safety / Regulatory Performance critical Success Factor: Strong Safety Culture Description of Program:

Conduct a review of the assessment function and implement changes that capitalize on internal expertise through activities such as Peer Group exchanges of information. The Corrective Action Root Cause Analysis process is used to identify and correct conditions affecting safety, cost or power generation capabilities at Waterford 3. Waterford 3 will continue to review the existing site corrective action processes in detail to identify and implement opportunities for improvement of site specific processes. The key process team for corrective action will play a major role in identifying these changes.

Title of Program: Training Improvements Program Lead: Manager, Licensing Strategic Objective: Safety / Regulatory Performance Critical Success Factor: Technical Competance Description of Program:

Pursue the hiring and promotion of technically competent personnel and ensure development plans address techncal competence development.

Title of Program: Technical Understanding Program Lead: Director, Design Engineering Strategic Objective: Safety / Regulatory Performance critical Success Factor: Technical Competance a

AttachmGnt 4 to W3F1-95-0106 Page 60 of 66 Detaffs of Activities that Support Processes and Safety Culture BUSINESS PLAN (Cont'd)

Description of Program:

Improve technical understanding of safety margin through the use of Deterministic and Probabilistic calculation tools, Design Basis Documentation, and severe accident management programs.

Title of Program: Excellence in Written Regulatory Communications Program Lead: Manager, Licensing Strategic Objective: Safety / Regulatory Performance Critical Success Factor: Open Comunications Description of Program:

Maintain standards and programs that ensure accuracy, completeness and timeliness of written NRC communications.

Title of Program: Excellence in Verbal External Communications Program Lead: Manager, Licensing Strategic Objective: Safety / Regulatory Performance critical success Factor: Open Communications Description of Program:

Develop and maintain processes to ensure that verbal communications with the NRC are accurate, open and timely. This will provide for a common ,

understanding of the organizations and their roles. I Title of Program: Cost Beneficial Licensing Actions Program Lead: Manager, Licensing l Strategic Objective: Safety / Regulatory Performance critical Success Factor: ,

Open Communications l Description of Program:

Continue to pursue regulatory burden reductions that maintain plant safety margins while eliminating unnecessary and costly requirements.

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Attachment 4 to W3F1-95-0106 Page 61 of 66 Detafis of ActiVitles that Support Prccesses and Safety Culture TOP DECILE GOALS l

Entergy has established goals in 3 broad areas for it's nuclear plants that are critical to the success of the company. Specifically, industry top decile status is targeted for each of these 3 areas by 1998. The specific goals for Waterford 3 are as follows:

Safety / Regulatory Performance Goal by 1998 - INPO 1 and SALP 1.25 Cost Performance Goal by 1998 - 17.0 Mills / KWHR Operating Performance Goal by 1998 - 87% Capacity Factor l

Attachment 4 to i' W3F1-95-0106 Page 62 of 66 Deta1is of Activities that Support Processes and Safety Culture TOTAL 00ALITY IMPROVEMQil Total Quality Improvement (TQI) at Waterford 3 began January 1991. The initial efforts began at Entergy Corporation in mid-1990. TQI, an Entergy improvement initiative, was designed to help achieve the five corporate priorities:

. Become more customer oriented j

. Become more cost competitive

. Energize our people

. Satisfy internal and external constituencies

. Prepare for the future As these initiatives have been deployed down through the corporation, Entergy l has become even more aware of the need for a different culture, new set of skills, improved systems, a new way of leading and managing, and meeting customer needs. TQI is the change management vehicle selected by Entergy under the corporate priority of " prepare for the future," to plan and drive the transformation.

TQI is a philosophy supported by a set of guiding principles that represent  ;

the foundation of a continuously improving organization. It is the effective application of quantitative methods and human resources to improve material and services supplied to an organization, all the processes within an organization, and the degree to which the needs of the customer are met, now and in the future. It integrates fundamental management techniques, existing improvement efforts, and technical tools under a disciplined approach focused on continuous improvement. In other words, it is an integrated management system which is customer focused, process oriented, prevention based, and i built around employee involvement and continuous improvement.  ;

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Page 63 of 66 Details of Act1y1 ties that Support  :

Processes and Safety CIAture  :

TOTAL OVALITY IMPROVEMENT (Cont'd)

The TQI process is designed to secure leadership and management support to create a supporting environment, followed by building the necessary mind-set and capabilities for employees to contribute to Total Quality. Focus will be -

directed fully to continuous improvement of all aspects of Waterford's  ;

operations. Continuous improvement at Waterford means: ,

. Using the Plan-Do-Check-Adjust Cycle (PDCA) to raise the performance levels of people and work processes

. Using the 4-D problem-solving process: define the problem, determine the cause, develop solutions and deliver recommendations

. Activities are motivated by a strong focus on customer needs and  :

requirements l

. Using benchmarking to set goals for quality

. Quality is a process that never ends  ;

. Continuous improvement means that everyone at Waterford 3 does things better today than yesterday.

Active leadership is also vital to Total Quality, but another central element I is empowered employees. Empowered employees have confidence in their ability to make improvement and remove barriers to quality. They have the skills and I the willingness to try new things and take calculated risks in creatively addressing problems or opportunities for improvement.

Three initial total quality training courses were designed to help employees  !

'i speak the same language of quality and help them focus on internal as well as '

external customers.

Introduction to Total Quality (ITQ) is aimed at creating the mind-set of ,

continuous improvement in employees, while Quality Through Empowerment (QTE) teaches the elements central to empowering employees to seek out quality. The  ;

Quality Action Team Leader (QATL) Training prepares facilitators and team l 1eaders for their roles in working with Quality Action Teams (QAT). j 1

l A QAT is comprised of a process owner, team leader, four to six team members and a facilitator. Team members are chosen from those employees most I knowledgeable of the process being improved, and represent all organizations or functions' involved in the process being reviewed.

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Attachment 4 to W3F1-95-0106 Page 64 of 66  ;

Detaffs of Activities that Support Processes and Safety Culture  ;

TOTAL QUALITY IMPROVEMENT (Cont'd)

Total Quality Improvement training focuses on the following concepts, tools and strategies: ,

. Quality is defined by the customer

  • Quality means work is seen as a process  !
  • Quality requires continuous improvement

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e Quality is achieved through teamwork e PDCA work cycle e Right things done right the first time .

  • Seven elements of quality
  • Customer / supplier relationships ,

e 1-10-100 rule e Benchmarking

  • Prevention Planning

. 4-D problem solving process e Defining customer requirements e Input-Output model e Flowchart e Measuring quality

. Natural Work Teams j e Reengineering Currently, Natural Work Teams (NWT's) are the primary vehicle used to analyze and improve site processes. NWT's and total quality tools and techniques have become ingrained in day to day Waterford 3 activities.

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Attachment 4 to W3F1-95-0106 Page 65 of 66 Detaffs of Activities that Support Processes and Safety Culture l

ENTERGY NUCLEAR COMMITTEE OF THE BOARD OF DIRECTORS PURPOSE The Entergy Nuclear Comittee is established to advise and assist the Board of Directors in the proper and complete discharge of its responsibilities relating to the Company's nuclear operations. The Entergy Nuclear Committee may be requested by the Board of Directors to investigate any nuclear related activity of the Company.

AUTHORITY AND RESPONSIBILITIES The Entergy Nuclear Comittee assists the Board of Directors in fulfilling its l responsibilities for the safe and efficient operation of the Grand Gulf '

Station, Unit No. 1; Waterford Nuclear Station, Unit No. 3; River Bend Station, Unit No.1; and Arkansas Nuclear One, Units 1 and 2. The Chairman of the Entergy Nuclear Comittee reports to the full Board of Directors at each.

regularly scheduled meeting. As a general rule, the Entergy Nuclear Comittee communicates its recommendations and observations to the' Board of Directors and not Directly to the Company's nuclear personnel. However, as to matters of immediate concern, members of the Committee may communicate directly with j the Company's senior management and, thereafter, to the Company's Board of Directors.

Specific responsibilities and , authority of the Entergy Nuclear Committee include, but are not limited to, the following:

A. Review significant inspection and evaluation reports, including the Company's responses, performed by regulatory authorities in connection with the operation of the nuclear units operated by the Company, including SALP, INPO, ANI, and state regulatory bodies' reports.

B. Evaluate any significant incidents or events relating to the nuclear units operated by the Company.

C. Review monthly reports of plant " key indicator" trends and monthly report letters from the Company's senior management on the operation and costs of the nuclear units operated by the Company.

D. Visit and inspect each nuclear facility operated by the Company at least annually and hold at least one of its meeting each year at each of the nuclear facility sites.

_ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ - . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _________J

1 Attachm:nt 4 to W3F1-95-0106 Page 66 of 66 Detaiis of ActiV1tles that Support Processes and Safety Culture ENTERGY NUCLEAR COMMITTEE OF THE BOARD OF DIRECTORS (Cont'd)

E. Review and approve minutes of each Entergy Nuclear Committee meeting and provide copies to all members of the Board of Directors and to the Secretary of the Company for the Company's files.

F. Request, as desired, special reports or briefings by the Company's senior management on the operation of ANO, Units 1 and 2, Waterford 3, Grand Gulf 1 or River Bend 1.

G. Request, as desired, and evaluate quarterly presentations from the Company's senior management on the performance and status of ANO, Units 1 and 2, Waterford 3, Grand Gulf 1 and River Bend 1.

H. As appropriate, meet with NRC officials, INP0 officials, station quality assurance management, the Chairman or other members of each site's Safety Review Committee, and the Company's senior management to discuss matters relating to performance and safety of each of the units.

I. Request, as desired, the Company to conduct any special reviews or studies considered necessary. The Committee has access to all Company files, data, reports, and personnel, as in its judgment are deemed necessary to carry out its responsibilities.

J. Retain at the Company's expense, legal counsel, consultants or other persons from within or outside the Company having special competence as .

necessary to assist the Committee in fulfilling its responsibility, j MEETINGS The Entergy Nuclear Committee meets as often as desired, but in no event less than quarterly, to accomplish the aforementioned duties and responsibilities.

The Committee's Chairman may call meetings at any time to review matters of responsibility or interest with the Committee. As deemed necessary by the Committee, meetings are attended by Company personnel. j l

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