ML20198S952
| ML20198S952 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/29/1998 |
| From: | Harrell P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Dugger C ENTERGY OPERATIONS, INC. |
| References | |
| NUDOCS 9901120053 | |
| Download: ML20198S952 (21) | |
Text
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pM UNITED STATES f
-y j 'kg. NUCLEAR REGULATORY COMMISSION ti ' ' .j PEctONIV Gl, 4 611 RYAN PLAZA DRIVE. SUITE 400 ARLINGTON TEXAS 76011-8064
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dif 29-ES Charles M. Dugger, Vice President Operations - Waterford 3 Entergy Operations, Inc.
P.O. Box B Killona, Louisiana 70066
SUBJECT:
INSPECTION PLANNING REVIEW (IPR)-
WATERFORD STEAM ELECTRIC STATIOW, UNIT 3
Dear Mr. Dugger:
On December 2,1998,' the NRC staff completed a newly instituted inspection Planning Review (IPR) of the Waterford Steam Electric Station, Unit 3. The staff normally conducts Semiannual Plant Performance Reviews for all operating nuclear power plants to develop an integrated understanding of safety performance and accordingly adjust inspection resources.
However, due to the suspension of the Systematic Assessment of Licensee Performance (SALP) process, we implemented an abbreviated inspection Planning Review process for plant issues and to develop inspection plans. The IPR for the Waterford Steam Efectric Station.
- Unit 3, involved the participation of both the Reactor Projects and Safety Divisions in evaluating
- inspection results and safety performance trends for the period of April 23 to October 28,1998.
Based on this review, inspection resources have been prioritized and scheduled. A change to the core inspection program was made in that inspection Procedure 93809, " Safety System Engineering Inspection," will not be performed during this inspection cycle. The basis for this change is the recently completed Architect / Engineering inspection and the scheduled inspection followup to that inspection. It was determined that these activities constituted an inspection equivalent to the inspection mandated by inspection Procedure 93809. In addition, two regionalinitiative inspections have been scheduled to review corrective actions taken to address identified perimeter equipment and detection aid performance problems.
Enclosure 1 contains an historical listing of plant issues since October 1,1997, referred to as the Plant issues Matrix (PIM), that was considered during this IPR process to arrive at an integrated view of performance trends. The PIM includes only items from inspection reports and other docketed correspondence between the NRC and Entergy Operations, Inc. The IPR may also have considered some predecisional and draft material that does not appear in the attached PIM, including observations from events and inspections that had occurred since the last NRC inspection report was issued, but had not yet received full review and consideration.
Enclosure 2 is a general description of the PIM table labels. This material will be placed in the NRC Public Document Room.
' This letter also advises you of our planned inspection effort resulting from the Waterford Steam Electric Station, Unit 3, IPR. It is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector 9901120053 901229 PDR- ADOCK 05000302 ?
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Entergy Operations, Inc. .
arrival on site.' Enclosure 3 details our inspection plan for the Waterford Steam Electric Station,
~
~ Unit 3, over the next 8 months.' The rationale or basis for each inspection outside the core .
inspection program is provided so that you are aware of the reason for emphasis in these -!
program areas. Resident inspections are not listed because of their ongoing and continuous
- nature. We will inform you of any changes to the inspection ' plan.
If you have any questions, please contact mel at (817) 860-8250.
Sincerely, LA'2 4 1e P. H. Harrell, Chief Project Branch D Division of Reactor Projects !
Docket No. 50-382 License No. NPF-038 ,
Enclosures-
- 1. Plant Issues Matrix ,
- 2. General Description of PIM Table Labels
- 3. Inspection Plan i cc w/ enclosures:
Executive Vice President and Chief Operating Officer ,
Entergy Operations, Inc. ,
t P.O. Box 31995 !
Jackson, Mississippi 39286-1995 Vice President, Operations Support {
Entergy Operations, Inc.
P.O. Box 31995 Jackson, Mississippi 39286-1995 i
Wise', Carter, Child & Caraway P.O. Box 651 ,
Jackson, Mis's issippi 39205 General Manager, Plant Operations Watedord 3 SES Entergy Operations, Inc. l P.O. Box B l
.Killona, Louisiana 70066 -
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' Entergy. Operations, Inc. ' Manager - Licensing Manager Waterford 3 SES
- Entergy Operations, Inc. ,
P.O. Box B
~ Killona, Louisiana 70066 Chairman' i Louisiana Public Service Commission '
One American Place, Suite 1630 - ,
- Baton Rouge, Louisiana 70825-1697 l
Director,' Nuclear Safety & '
Regulatory Affairs Waterford 3 SES
,: Entergy Operations, Inc. '
P.O.~ Box B Killona, Louisiana 70066 William H. Spell, Administrator Louisiana Radiation Protection Division P.O. Box 82135 Baton Rouge, Louisiana 70884-2135
- Parish President
- St. Charles Parish P.O. Box 302 Hahnville, Louisiana 70057 Winston & Strawn
- 1400 L Street, N.W. '
Washington, D.C. ' 20005-3502
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- E-Mail report to T. Frye (TJF); i 2 9 1598 l
' E Mail report to D. Lange (DJL)
E-Mail report to NRR Event Tracking System (IPAS) ;
E-Mail report to Document Control Desk (DOCDESK).- '
E-Mail report to. Richard Correia (RPC)
E-Mail report to Frank Talbot (FXT) t 4
bec to DCD (IE01) ,
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': Regional Administrator Resident inspector ,
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DRP Director DRS-PSB Branch Chief (DRP/D) MIS System Project Engineer (DRP/D) RIV File -
Branch Chief (DRP/TSS) .
Carof Gordon. * ,
The Chairman (MS; 16-G-15) Records Center, INPO -
' Deputy Regional Administrator . C. A. Hackney e Commissioner Dicus - B. Henderson, PAO C B. Murray, DRS/PSB i-7 ommissioner Diaz- SR!s at all RIV sites Commissioner McGaffigan l Commissioner Merrifield W. D.- Travers, EDO (MS: 17-G-21) ,
Associate Dir for Projects, NRR Associate Dir. for losp., and Tech. Assmt, NRR
- SALP Program Manager, NRR/lLPB (2 copies) 3
. J. Hannon, NRR Project Director (MS: 13-H-3) ;
C. Patel, NRR Project Manager (MS: 13-H-3) i e
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- E-Mail report to D. Lange (DJL) .
E-Mail report to NRR Event Tracking System (IPAS) .
. E-Mail report to Document Control Desk (DOCDESK)
E-Mail report to Richard Correia (RPC) -
E-Mail report to Frank Talbot (FXT) ~ 'l I
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bec distrib. by RIV:
Regional Administrator. Resident inspector.
DRP Director DRS-PSB Branch Chief (DRP/D) - MIS System i
Project Engineer (DRP/D) RIV File Branch Chief (DRP/TSS) Carol Gordon ;
.The Chairman (MS: 16-G-15) . Records Center, INPO Deputy Regional Administrator _ C. A. Hackney Commissioner Dieus~ B. Henderson, PAO J Commissioner Diaz . . B. Murray, DRS/PSB
' Commissioner McGaffigan . SRis at all RIV sites Commissioner Merrifield -
W. D. Travers, EDO (MS: 17-G-21)'
Associate Dir. for Projects, NRR Associate Dir. for insp., and Tech. Assmt, NRR SALP Program Manager, NRR/lLPB (2 copies)
' J. Hannon, NRR Project Director (MS: 13-H-3)
C. Patel, NRR Project Manager (MS: 13-H 3)
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WATERFORD 3 PLANT ISSUES MATRIX ENCLOSURE 1 UATE TYPE SOURCE ID SFA ITEM DESCRIPTION unsusum ammuseuumuums N ummu '
07/22/98 POS IR 98-12 NRC OPS IB The control room operators' performance during a rapid down power event was very good. Upon noting a decrease in feedwater flow, the operators quickly reduced reactor power to below the point that could result in an automatic transient. All evolutions were conducted in accordance with the appropriate procedures 07/16/98 POS IR 98-12 NRC OPS 1B 2A The operators performed very well following a manually indiated reactor trip. Rapidly changing plant conditions were monitored effectively. An unexpected emergency feedwater system response was promptly identified and appropriately corrected by taking manual control of feedwater flow to the steam generators. Appropriate actions were taken to correct the cause of the trip and the uwxpected plant responses. The subsequent reactor startup was conducted in accordance with appropriate procedures with a slow and deliberate approach to criticality. Operator performance during the conduct of the startup was very goi>d 06/13/98 POS IR 98-09 NRC OPS 1C 3B Implementation of ongoing emergen;y operating procedure training was very good, during the upgrade to dual column emergency operating procedures. The methodology used for the traini.1g was sound and continuous interaction between operators and instructors was observed.
06/07/98 NCV IR 98-12 LIC OPS 1A A noncited violation of Technical Specification 4.3.1.1, consistent with Section V!!.B.1 of the NRC LER LER 98-012 Enforcement Policy, was identified related to failure of licensed operators to perform channel checks f#
the Channel A reactor coolant low flow. The licensee attributed the decision to stop taking the readings as inattention to detail. Even though the control panelinstrument used to take the readings was inoperable, operators had failed to review all the facts related to the use of a computer point for the readings prior to discontinuing its use 05/29/98 POS IR 98-09 NRC OPS 1B The control room operators' actions following an unexpected insertion of a part length control element assembly were as expected. Good command and control techniques were employed and plant power changes were performed in accordance with approved procedures. The efforts to recover the control element assembly were very good. The control element assembly dropped when a power switch failure occurred and the control power fuses blew.
05/19/98 VIO IR 98-09 NRC OPS 1A Contrary to Technical Specification 6.8.1.a. operators failed to declare Emergency Diesel Generator A SLIV inoperable. The operators failed to recognize that sources of missiles other than from tomadoes should have been considered when removing a missile barrier door protecting the Emergency Diesel Generator A diesel fuel oil feed tank. The door remained open for 30 minutes.
l 05/19/98 WK IR 98-09 NRC OPS 1C SC A weakness was identified in the decision making process when a spent resin transfer pump casing i
drain valve was not replaced at the time it was identified as the cause of a coi.taminated spent resin spil!
in December 1997. As a result of this decision, a second spent resin spill occurred during the next i
attempt to transfer resin. The cause of the second spill was identified as being the same as the first, l
which was a cacked open casing drain valve. The licensee replaced the installed globe valve with a ball l
valve. No root cause identified for how the casing drain valve opened.
t l
l October 28,1998 1 Waterford Steam Electric Station, Unit 3 l
WATERFORD 3 PLANT ISSUES MATRIX ENCLOSURE 1 DATE TYPE SOURCE ID SFA ITEM DESCRIPTION nummmu - m 04/20/98 VIO IR 98-08 NRC OPS 1C Contrary to Technical Specificaton 6.8.1.a. a procedure failed to provide adequate instructions to specify SLIV the proper operation of the emergency desel generator at no or low load cond:tions.
03/06/98 WK 1R 98-301 NRC OPS 3C Inconsistent implementatbn of senior operator review and approval of radological release permits.
Potentially generic to other senior operator review functions / senior operator oversight. Procedures do not desenbe management expectations. Expectations for senior operator review are not consistentty understood by the operators or management. A similar root cause resutted in recent escalated enforcement (LVL 3. no Civil Penalty, IR 97-26) 03/06/98 STR 1R 98-301 SELF OPS 3B 3A Control room on shift operators and license applicants during dynamic simulator examinatens, displayed consistently good communications and oversight of panel activities. Good coupling between operatons and training staffs a!!ow operations
- expectations to be reinforced in training.
03/06/98 POS IR 98-301 SELF OPS 38 All applicants (11 senior operators) passed their initial Icense examinatens. One appi; cant rr.arginally passed the written test.
02/15/98 NCV IR 98-06 LIC OPS 1A Inattentiveness to licensed duties by a senior reactor operator resutted in a failure to meet Technical Specifcaton 6.2.2.b shift-manning requirements when both the shift superintendent and the control i room supervisor were absent from the control room for 1 minute 38 seconds 02/04/98 POS IR 98-06 NRC OPS 1A Operators performed in a professional manner and demonstrated excellent knowledge and understanding of the safety consequences of the loss of instrument power event 01/31/98 NCV IR 97-28 LIC OPS 3A Identified that a default constant for the azimuthal power tilt loaded into the COLSS prevented monitoring L.ER LER 96-010 core performance as required by Technical Specification, in August 199E. Procedures did not require verifying COLSS constants prior to exceeding 20% power or upon rebooting the computer. No limits exceeded 12/06/97 WK IP. 97-26 NRC OPS 3A Several root causes for failure to place controller for Va!ve ACC-126A in auto were same as configuration problems in October 1996.
11/10/97 VIO IR 97-26 LIC OPS 3A 3C Failure to retum contro!!er for Valve ACC-126A to automatic following a routine operation resulted in both SL 111 EA 97-589 trains of the auxiliary component cooling water being inoperable once Train B removed from service for LER 97-027 7.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Six separate violations combined into a Seventy Level 111 problem. Problems inc!uded failure to follow procedure, failure to verify operability of Train A prior to removing Train B, failure to conduct appropriate control board walkdowns, failure to conduct a proper shift tumover, failure to have supervisory oversight, and failure to comply with the action requirements. These causes resulted in violatons of Technical Specifications 6.8.1.a and 3.7.3.
10/03/97 VIO IR 97-17 NRC OPS 3C Failed to maintain the emergency operating procedures as required by Techncal Specifications. Recent SLIV modifcation allowed operators to override permissive signal to isolate containment. Emergency plant procedures revised but not emergency operating procedures.
October 28,1998 2 Waterford Steam Electric Station, Unit 3
WATERFORD 3 PLANT ISSUES MATRIX , ENCLOSURE 1 DATE TYPE SOURCE ID SFA ITEM DESCRIPTION umumuu umummmuunnuh m uumsme N 10/03/97 STR 1R 97-17 NRC OPS 1C Improvements were noted in the licensed operator requalification program. Operations Management required to observe and evaluate licensed operator training and improved tho quality of Training Review Group meetings.
07/25/98 POS IR 98-12 NRC MAINT 2B External material condition of all systems and components observed during routine tours was very good C3/30/98 NEG IR 90-12 NRC MAINT 3A A poor work practice and the lack of a questioning attitude were identified conceming work performed on an open tube oil system and dril!ing in the power frame of the charging pump. These two jobs were performed simultaneously, which resulted in several particles being introduced into the tube oil reservoir.
06/2/98 NEG IR 98-09 NRC MAINT 2A 3A inattention to details were observed during the conduct cf a high-pressure safety injection pump surveillance test. A small, actNe oilleak on the inboard bearing was not identified by licensee personnel upon completion of the test.
04/22/98 NCV IR 98-08 Ltc MAINT 3A Lack of attention to detail by the control room supervisor and the nuclear plant operator resulted in failure to verify the positions of control element assemblies wnhin the Technical Specification-required time period.
03/30/98 VIO IR 98-08 LIC MAlNT 2B Contrary to Technical Specification 4.8.4.2.b.1 the licensee failed to test the thermal overload relays for SLIV all cordainment isolation valves as required. The initial scope of the review to identify missed surveillances on all effected safety-related valves was narrowly focused 03/21/98 VilO IR 98-06 NRC MAINT 3C Valve CVC-103 did not properly perform allits design functions during an event. Testing was not SLIV performed after completion of maintenance contrarj to Criterion XI 02/02/98 VIO IR 98-06 NRC MAINT SC Failed to review the stop nut adjustment on similar valves since the stop nut adjustment was considered SLIV a contributing factor to the overflow of the spent fuel pool contrary to Criterion XVI. Personnel failed to implement broad, effective corrective actions following the spent fuel pool overflow event.
01/22/98 POS IR 97-28 NRC MAINT 3A Conduct of the control element assembly operability check was very good. Operators supplemented the shift complement and a high level of supervisory oversight was evident 01/21/98 NEG IR 97-28 NRC MAINT 3A instrumentation and control attempted to expand a work package scope without appropriate authorization. The technicians wanted to test a component not listed in the work package 12/17/97 eel IR 97-25 NRC MAINT 3A During the high pressure safety injection flow balance test , failed to consider test instrumentation EA 98-022 uncertainties and valve position variability in the test acceptance limits. An additional example was identeed for the auxiliary component cooling water flow balance test related to the inclusion of measurement uncertainty in the test acceptance limits.
11/04/97 URI 1R 97-24 NRC MAINT 1C Dirt and debris in the reactor auxiliary building drains potentially affected flooding safety anatysis. No program existed for routinely cleaning the drains.
October 28,1998 3 Waterford Steam Electric Station, Unit 3
WATERFORD 3 PLANT ISSUES MATRIX ENCLOSURE 1 DATE TYPE SOURCE 10 SFA ITEM DESCRIPTION nummmmmum nummmmmusum nummmmu -
mumN . . -
10/17/97 VIO IR 97-24 LIC MAINT 28 During quarter!y inservice testing, identified that valve to conta'nment fan coo!ers was partially gagged SL IV EA 97-588 and went only 80 percent open. Root cause noted as inadequate postmaintenance testing followir'g work LER LER 97-025 on the actuator. No safety consequences identifed 10/15/97 WK 1R 97-22 NRC MAINT 4B SA Following weld repair of a cracked charging pump vent line,line again cracked after short period of operation. Vibration-induced fatigue that resu!!ed from inattention to detail by craft personnel 10/t)8/97 VIO IR 97-29 'S MAINT 3A 4A Two examples for failure to establish a new baseline inservice test for Low Pressure Safety injection SL IV Pump A. Repeat, within last 2 years, of NRC-identified problem October 28,1998 4 Waterford Steam Electric Station, Unit 3
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WATERFORD 3 PLANT ISSUES MATRIX FNCLOSURE1 DATE TYPE SOURCE- ID SFA ITEM DESCRIPTION OD October 28,1998 5 Waterford Steam Electric Station, Unit 3
WATERFORD 3 PLANT ISSUES MATRIX , ENCLOSURE 1 DATE TYPE SOURCE ID SFA ITEM DESCRIPTION
.s 07/25S 8 NEG 1R 98-12 NRC ENG 4B 4C Following questioning by the insp+ctors, the Isensee fabncated and staged jumpers and identified the terminals for installation of the jumpers required as a contingency action to close Valves SI-602A(B),
safety injection system containment sump isolation valves, with a recirculation actuation signal present 07/20!98 POS 1R 98-12 NRC ENG 4B 2B The system engineer assigned to the emergency diesel generator and associated support systems demonstrated a good level of knowledge during a routine walkdown of the systems. A systematic approach was employed to ensure all important components were inspected. The matenal condition of the emergency diesel generators was considered good 05n2/98 POS 1R 98-09 NRC ENG 2B 48 The conduct of a thermal performance test on Wet Cooling Towers A and B demonstrated that the towers were capable of remoing sufficient heat following a design-basis accident. The tests were well planned and coordinated. The corrective actions following an indication of a degraded penormance condition on Wet Cooling Tcwer B were appropriate. Engineering determined Wet Cooling Tower B remained capable of removing the accident heat load and initiated plans to clean the wet cooling towers during a future maintenance outage.
04/15/98 VIO IR 98-08 LIC ENG 2B Contrary to 10 CFR 50, Appendix B, Criterion ill, the licensee failed to implement adequate measures to SLIV ensure that correct response time acceptance enteria for the emergency feedwater, containment fan coolers, and injection systems was established to meet the Updated Final Safety Analysis Report assumptions and the design basis requirements 03/05/98 VIO IR 98-06 LIC ENG 3A An engineer inappropriately operated equipment in the plant without the shift supervisor or control room SL IV supervisor knowledge or concurrence. This was a repeat of a similar occurrence within the last 2-years 02/20/98 WK IR 98-02 NRC ENG 58 initially, the licensee concluded that an 18-month test of each core protection calculator channel was LER LER 98-004 unnecessary following discussions with the Nuclear Steam Supply System vendor. Following inspector questions, the licensee reevaluated the need to perform the testing and determined that Technical Specification 4.3.1.1 required a test of all four channels each refueling outage 02/20/98 STR IR 98-02 NRC ENG 5A The assessment program changes implemented during the last year resulted in greater accountability because of increased formality. Included creating a tracking system monitored at the corporate level and concurrence by the site Vice President of the planned corrective actions 02/20/98 STR 1R 98-02 NRC ENG 5B 4C Engineering response to Potter Brumfield motor-driven relay failures was good. The reported failures resulted in a 10 CFR Part 21 report being issued by the vendor. The licensee established an appropriate monitoring program to detect malfunctions prior to failure of the relays.
02/20/98 STR 1R 98-02 NRC ENG 5B Engineering provided effective resolution of 13 condition reports reviewed with one exception. Personnel incorrectly credited the corrective actions for a different condition report when those corrective actions would not have corrected the identified deficiency 02/20/98 STR 1R 98-02 NRC ENG 58 5A The corrective action program had improved since the last inspection of the program was completed.
Evidenced by an increased identification of adverse conditions, management involvement throughout the process, and generally thorough resolution of significant condition reports October 28,1998 6 Waterford Steam Electric Station, Unit 3
WATERFORD 3 PLANT ISSUES MATRIX ENCLOSURE 1 ID SFA
^ ITEM DESCRIPTION DATE TYPE SOURCE 02/20/98 STR 1R 98-02 NRC ENG SC The licensee performed very good assessments based on the identified findings and recommendations made in five assessments. The extent of the planned corrective actions to the recommendations reflect a willingness by some managers at the facility to implement corrective actions to address recognized deficiencies 02/20/98 STR IR 98-02 NRC ENG SC Overall, quahty assurance personnel provided entical, effective oversight of the hne organizations, as evidenced by the issues identified during the three audits and three assessments reviewed 02/06/98 MISC Meeting NRC ENG 3A Meeting included detailed discussions regarding actions taken to improve the engineering organization and actions taken to resolve corrective action program concems identi!!ed by your self-assessment. We found your self-assessment to be highly self-critcal. In addition, we noted that statistically design engineering did not identdy as many condition reports as their engineering peers. Further, with the design basis review identifying issues that required resolution, NRC questioned whether design engineers initiated corrective action documents in a timely fashion for conditions adverse to quality.
02/06/98 eel IR 97-25 NRC ENG SC Failure to promptly correct the high pressure safety injection flow balance test acceptance hmit deficiency.
EA 93-022 fo!!owing identification of the issue in a self assessment. Apparent vWa~. Y ^ 0 CFR Part 50. Appendix B, Criterion XVI 02/06/98 WK IR 97-25 NRC ENG 4C The licensee took appropriate actions to establish and improve calculations for air-operated valves, but d:d not include safety-related hydrauhc-operated valves in the scope of the calculation upgrade program.
02/06/98 STR 1R 97-25 NRC ENG 4C The discovery phase of the licensee's design basis review and calculation upgrade program was effective for the safety injection system. The licensee had previously identified the same substantive issues, that were identified by the team.
02/06/98 NEG IR 97-25 NRC ENG 4A The current seismic quahfication of the Waterford 3 safety related station batteries was acceptabie.
However, the seismic qualifcation from ftfteen to twenty years quahfied hfe, was not clearly established.
The licensee initiated an engineering request to further evaluate the quahtication of the batteries during this period.
02/05//98 eel IR 97-25 NRC ENG 4B Failure to perform a written safety evaluation for a change to the loss of coolant accident emergency EA 98-022 operating procedure, which potentially conflicted with the Updated Final Safety Analysis Report.
Apparent violation of 10 CFR 50.59(b)(1) was identified 01/15/98 LIC LETTER NRC ENG 4C Two inadequate submittals provided for Appendix J Amendment request 01/12/98 VIO IR 97-24 NRC ENG 4A Failure to account for pump recirculation flow to the refueling water storage pool resulted in non-SL IV EA 97-587 conservative determination for the onset of vortexing 01/06/98 NCV IR 98-02 LIC ENG 4A Engineers failed to perform a commercial grade dedication prior to installation of a nonsafety-related manual valve actuator on a dry cooling tower valve that had an active function to close. The licensee successfully completed a commercial grade dedication of the valve actuator. This deficiency resulted from poor interdepartmental communications October 28,1998 7 Waterford Steam Electric Station, Unit 3
WATERFORD 3
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PLANT ISSUES MATRIX ENCLOSURE 1 SFA TEMPWE ITEM DESCRIPTION DATE TYPE SOURCE ID nummmmmmmum - muuuuuuum N 12/18/97 eel IR 97-25 NRC ENG 4B One apparent violation of 10 CFR 50.59(a)(1) involved approving three changes to the facihty, which EA 98-022 apparently involved unreviewed safety questions, prior to obtaining NRC approval. The licensee 1) revised a high pressure safety injection flow instrument uncertainty calculation,2) reduced the emergency feedwater pump capability requirements in the Technical Specification Bases section and 3) changed the hydrogen analyzer containment isolation valve classification from automatic to remete/ manual 12/18/97 . LIC NPF-38-137 NRC ENG 4C License amendment request to increase condensate storage pool volume lacked quality and evidenced inattention to detail. Method for calculating vortex margin inappropriate, intormation on cooling tower basin volume inconsistent, required two additional submittats 12/5/97 eel IR 97-25 NRC ENG 4A Two apparent violations of 10 CFR Part 50.46 were identified. The first involved the failure to assess the EA 98-022 impact of the lower high pressure safety injection flow on peak fuel clad temperature. The second involved the failure to report operation outside the design basis of the facihty and the subsequent failure to submit the schedule for revising the emergency core cooling system analysis within 30 days 11/17/97 NCV IR 98-02 LIC ENG 4A Failure to control design inputs for the containment pressure accident analysis. The licensee credited a higher containment spray flow than that achievable during originallicensing of the facility. An operability assessment demonstrated that a lower design flow would prevent exceeding peak containment pressure.
The licensee implemented corrective actions for the identified condition. Further, the design basis reconstituticn program tnat is established should identify similar design value discrepancies. The 4r licensee continues to experience problems in the fidelity of design basis information 11/05/97 STR 1R 97-24 NRC ENT 48 5A Evaluation for the single component failure effects on the condensate storage pool was thorough and LER LER 97-026 timely. Single failure analysis for the condensate makeup pumps failed to identify all potential failure ER 33221 mechanisms. On loss of offsite power and pump restart,if tank level switch fails, pumps run continuously and inventory loss from condensate storage pool occurs 10/29/97 VIO 1R 97-25 NRC ENG SA Failure to initiate a condition report as required by plant procedures. The licensee's evaluation of the SL IV applicability of NRC Information Notice 96-48,' Motor-Operated Valve Performance issues," was inadequate. As a result, the licensee did not promptly initiate a condition report, when they identified that main feedwater isolation valve performance did not conform with the initial sizing calculation assumptions for the valve 10/10/97 VIO IR 97-21 NRC ENG 3A Failed to update Technical Requirements Manual per site procedures after identifying a number of SL IV inaccuracies. Safety significance of identified items minor October 28,1998 8 Waterford Steam Electric Station, Unit 3
WATERFORD 3 PLANT ISSUES MATRIX ENCLOSURE 1 DATE TYPE SOURCE ID SFA 7 fTEM DESCRIPTION 10/08/98 VIO IR 98-17 NRC FS ' 3A A violation of 10 CFR 20.1501(a) was identified for the failure to survey an overhead work area prior to SLIV workers entenng the area. The general work area dose rate was 20-22 millirems per hour. The licensee implemented proper corrective actions during the inspection. No wntten response to the violation is required.
10/08/98 VIO IR 98-17 NRC PS 3A A violation of Technical Specihcation 6.2.2(e) was identified for failure to limit the hours worked by an SLIV ,
acting health physics supervisor to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7-day period. The acting health physics supervisor had worked 82 hours9.490741e-4 days <br />0.0228 hours <br />1.35582e-4 weeks <br />3.1201e-5 months <br /> in a 7-day period. This cited violation is similar to a violation identified in Inspection Report 382/97-04.
10/08/98 STR IR 98-17 NRC PS 3A 3C The extemal and internal exposure control programs were effectively implemented. Radiation areas and high radiatior areas were properly posted and controlled. Radiation work permits were clear!y wntten.
Proper dosimetry was wom by radiation workers. A prcper air sampling program was implemented.
Radioactive materiai, laundry, and trash containers were properly labeled, posted, and controlled. An effective ALARA program was implemented. The 1998 exposure goal of 13 person-rem was aggressive.
The station's 3-year exposure average of 109 peson-rem for 1997 was below the industry average c! 132 person-rem and continued to trend downward. The projected 3-year exposure average for 1998 is 62 person-rem. However, the ALARA committee was not fu:!y supported by the t!aining, instrument and controls, and system engineenng departments. A good radiation protection department training program was implemented. An effective quality assurance audit, quality assurance surveillances, and radiation protection department self-assessment were completed. Timely, effective corrective actions were implemented in response to aud:t findings.
10/08/98 POS IR 98-17 NRC PS 3A Housekeeping throughout the controlled access area was good.
09/16/98 V!O IR 98-16 NRC PS 2A Contra y to the requirements of paragraph 6.1.1 of the physical security plan, two perimeter detection zones failed during performance tests. The licensee implemented proper corrective actions during the inspection. No written response to the violation was required.
07/23/98 eel IR 98-16 LIC PS 3A An apparent violation was identified involving the failure to secure safeguards information in accordance with 10 CFR 73.21 and paragraph 5.11.1 of Waterford Procedure W5.503. The physical security plan was left unattended in an office outside of the protected area.
07/15/98 POS 1R 98-12 NRC PS 1C in general, the conduct of an emergency preparedness exercise was very good. Minor weaknesses observed in communications between plant operators were identified to the licenses for resolution 07/02/98 POS IR 98-12 NRC PS 1C A meeting of an ALARA (as low as reasonably achievable) committee to discuss a plant modification to re-rack the spent fuel pool was considered an excellent example of preplanning to minimize radiation exposure to workers. The discussions were highly detailed and lessons teamed from similar jobs at other facilities were fully incorporated 06/30/98 NEG IR 98-12 NRC PS 3A A poor radiological work practice was identified conceming the radiological posting of the area.
Potentially contaminated metal particles produced during the drilling were deposited in a clean area without first being monitored for radiation October 28,1998 9 Waterford Steam Electric Station, Unit 3
WATERFORD 3 PLANT ISSUES MATRIX ENCLOSURE 1 OATE TYPE SOURCE ID SFA ITEM DESCRIPTION
-m nunumusumum suummune manusul N uuum .
06/22/98 NEG IR 98-10 NRC PS 1C Concems were identified in two recently revised procedures. Compensatory measures procedures for a degraded vehicle barrier did not specify the type of weapon a compensatory off,cer must have. The patrol tours procedure only defined a watch tour but discussed protected and vital area patrol tours.
06/22/98 POS IR 98-10 NRC PS 1C Performance in the physical secunty area was good with improvements noted in several areas.
Adequate compensatory measures were implemented to maintain the redundancy and protection of alarm stations during the installation of the new security computer. Alarm station operators were alert and effectively trained. Security events were correctly reported. The logs and supporting reports were neat and contained suhicient detail for the reviewer to determine root cause, reportability, and corrective action taken. Senior management support for the security organization was good. New X-ray machine video monitors were purchased, a new security computer was being installed, the access authorization and fitness-for-duty physical f acilities were being remodeled, and secunty staffing was maintained at a proper level. An effective program had been established for the timely deactivation of key cards following termination of an individual.
03/13/98 NEG IR 98-09 LIC PS 1C An error in the annual mailing in Apni 1998 of the public information booklets resulted in some residents receiving the booklets that did not requim this information and others within the 10-mile emergency planning zone not receiving the booklets. The licensee identified the error and took appropriate corrective action by mailing the appropriate residents the books in May 1998. The licensee implemented process changes to include future venfications during mailing instead of following mailing.
05/21/98 POS IR 98-07 NRC PS 1C An effective fitness-for-duty program was in place. The specimen collection facility was well maintained and proper procedures were in place that prevented circumventing of tests with false specimens.
Fitness-for-duty procedures were comprehensive and thorough.
05/21/98 POS !R 98-07 NRC PS 1C Testing and maintenance of the security equipment were excellent. The individual conducting the tests was knowledgeable of proper testing procedures and conducted performance-based tests.
05/21/98 VIO !R 98-09 NRC PS 1C Contrary to Technical Specification 6.8.1.f and the fire protection program, a fire door in the reactor SLIV auxiliary building was observed to be open with no controls in place.
05/02/98 POS (R 98-08 NRC PS 1C The root cause investigation for a contaminated spent resin spill was comprehensive. The proposed corrective actions were appropriate.
05/02/98 POS IR 98-08 NRC PS 1C The chemistry monitoring and biological control programs for cooling water systems were very good.
Chemistry conducted continuous monitoring and treatment program specific to each closed and open system in order to treat microbiologicals and zebra mussels.
04/01/98 POS IR 98-08 NRC PS 1C In general, conduct of the licensee's practice emergency exercise was very good, with the exception that simulator time was not real time.
October 28,1998 10 Waterford Steam Electric Station, Unit 3 L -- - - - - - - - - - - . _ _ _ _ - - - - - - - - - - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - .
WATERFORD 3 PLANT ISSUES MATRIX ENCLOSURE 1 DATE TYPE SOURCE ID SFA m[ ITEM DESCRIPTION Overall, an effective radiation protection program was implemented. Locked high radiation areas were 03/06/98 STR 1R 98-07 NRC PS 1C ~
locked and posted property. Proper pre-job ALARA briefings were condected. Neutron personnel dosimeters provided an accurate response to the neutron energies workers encountered during containment entries. The whole body counting system calibration and quality control prograrns were maintained property. In general, the personnel contamination survey program was implemented property. The cahbration and source response check programs for neutron and portable radiation protection survey instruments were implemented property. A good temporary shielding program was properly implemented. Housekeeping throughout the controlled access area was very good.
02/25/98 VIO 1R 98-07 NRC PS 1C SC Failure to perform adequate radiological surveys to prevent t% release of radioactive particles from the SL IV controlled access area. Five events of radioactive particles found in carpeted work areas outside the controlled access area over a five month penod were identified by the hcensee. The correctrve actions regarding the first event were not effective to prevent the subsequent events.
02/20/98 POS IR 98-03 NRC PS 3A 3C Performance was good dunng emergency preparedness walkthroughs using the plant simulator.
Operational support center staff performance during the remedial exercise was very good. Operational support center briefings were identified as a strength because of the enhanced focus on personnel safety.
02/20/98 STR 1R 98-03 NRC PS 1C The emergency preparedness program was properfy implemented. Declared events were property classified and notifications to offsite agencies were made in a timely manner. The emergency response facilities were weit maintained. Changes to the emergency preparedness prog *am were incorporated into the emergency plan and implementing procedures. Emergency response e ganization personnel and emergency planning department staffing were trained appropriately. The process for identifying and incorporating corrective actions was very good. Emergency preparedness program audits were effective.
02/20/98 NCV 1R 98-03 LIC PS 3C Various problems associated with respiratory protection equipment were identified including a noncited violation for failure to maintain an adequate supply of small and large air-supplied respirators in the control room. Lack of management oversight 02/20/98 NCV 1R 98-03 NRC PS 3A Failure to document results c! the assessment of offsite interfaces and make the results available to management and offsite agencies.
02/12/98 POS IR 98-05 NRC PS 1C Background investigation screening files were complete and through. A good program had been established for denying, revoking, and appealing unescorted access.
02/12/98 NEG 1R 98-05 NRC PS 1C A marginally adequate program for searching personnel, packages, and vehicles was maintained.
Overtime hours worked by secunty officers averaged over 20 percent a month for the past seven months.
02/12/98 STR IR 98-05 NRC PS 1C Testing and maintenance of the security equipment were a program Strength. The audit of the security program was thorough and very good quahty October 28,1998 11 Waterford Steam Electric Station, Unit 3
"~
WATERFORD 3 PLANT ISSUES MATRIX ENCLOSURE 1 E
DATE TYPE SOURCE ID SFA ITEM DESCRIPTION
- - -- 'im 02/12/98 STR IR 9845 NRC PS 1C Performance in the physical security area continued to be adequate with no imprnvement trend. Several positive attnbutes were noted. Alarm stations were redundant and well protected. Good ra6o and telephone communication systems were maintained. Assessment aids provided effective assessment of the perimeter detection zones. A good secunty event reporting program was in place. A good training program for security contingency drills had been imple nented. A good security event reporting program was in place. A good training program for security officers had been implemented. Senior management support for the security organization was good. The secunty program was adequately managed 02/1138 VIO IR 98-05 NRC PS 3B 3C Fa:Iure to have a derailer in place in accordance with the security plan was identified by the inspector.
SLIV Inadequate procedures and personnel error by secunty supervision.
02/06/98 WK IR 98-04 LIC PS 3B Radiation protection technician training was marginal.
02/06/98 VIO 1R 98-04 NRC PS 3C A violation was identified because of the failure to prepare and maintain a procedure for personnel SL(V radiation protection consistent with the requirements of 10 CFR Part 20. Procedure inadequacy 02/06/98 STR 1R 98-04 NRC PS 5A Good oversight was provided by quality assurance audits. Self-assessments were noteworthy for their thoroughness and detail.
02/02/98 VIO IR 98-04 NRC PS 3A Personnel failed to implement the site covective action program to address deficiencies associated with SL IV the initial entry into the spent resin tank pump room. Poor worker performance 01/29/98 STR 1R 98-01 NRC PS 1C Very good solid radioactive waste manageraent program was implemented.
01/15/98 STR 1R 98-01 NRC PS 1C An effective radioactive waste inventory system was maintained 12/26/97 VIO IR 98-04 NRC PS 3A Evaluations were inadequate to assess the potential radiation dose to the extremities of the body, prior to SLIV entry into a locked high radiation area. Poor worker performance 12/10/97 NCV IR 98-05 LIC PS 38 3C Failure to search emergency vehicles and personnel responding to a drill was identified. Inadequate LER LER 97-S05 procedures and personnel error.
12/01/97 NEG IR 97-28 NRC PS 2A Trash located inside a support in Diesel Generator Room A and oil was found in a sunport in Room B.
The additional fire loading created by these items remained well below the actual fire loading 11/07/97 MISC IR 97-18 NRC PS 3A 1C Operational support center staff performance was adequate. Exercise weaknesses: failure to irnplement proper radiological exposure controls (dosimetry and contamination controls) and fire brigade dd not use required respiratory protection for a fire with toxic smoke 11/07/97 MISC IR 97-18 NRC PS 3A 1C Emergency operations facility staff performance was generally good. Briefing frequency degraded during last half of exercise; classifications were correct and ti'mely, with one exception; exercise Weakness identified because a protective action recommendation upgrade decision was unnecessarily delayed 11/07/97 STR 1R 97-18 NRC PS 3A Overall, emergency exercise performance was generally good. The integrated critique process was very comprehensive and considered a program strength October 28,1998 12 Waterford Steam Electric Station, Unit 3
]
l WATERFORD 3 PLANT ISSUES MATRIX ENCLOSURE 1 .
l DATE TYPE SOURCE ID SFA ITEM DESCRIPTION
- - r 10/23/97 VIO IR 97-22 NRC PS 1A 3A Failure to property secure wheeled items near safety-related equipment St.IV l- .10/10/97 STR 1R 97-23 NRC PS 1C Overall, very good implementation of Equid and gaseous radioactive effluent waste program Offsite j doses from liquid and gaseous effluent releases for 1996-97 seduced compared to 1994-95 l.
I u
October 28,1998 13 Waterford Steam Electric Station, Unit 3
-_____ ___-______ - -____-__ _______ - _ - _____________ _ __________ - . - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _.~'
ENCLOSURE 2 GENERAL DESCRIPTION OF PIN 1 TABLE LABELS Actual date of an event or significant issue for those items that have a clear date of occurrence, the date the source of the information was issued (such as the LER Date date), or, for inspection reports, the last date of the inspection period. If the event date is earlier than the current assessment (plant performance resiew) period, the document issue date/end ofinspection should be used and the event date documented in the ITE31 DESCRIPTION column.
Fype The categorization of the issue - see the T3 pe item Code table.
SFA SALP Functional Area Codes: OPS for Operations; 31 AINT for 31aintenance; ENG for Engineering; and PS for Plant Support.
Sources 'Ihe document that contains the issue information: IR for NRC Inspection Report; LER for Licensee Esent Report; letter for NRR letter.
ID Identification of w ho discovered issue: NRC for NRC; LIC for Licensee; or SELF for Self Identif3 ing tevents).
Issur Description Details of the issue from the LER text or from the IR Executive Summaries.
Ceder Template Codes - see table.
TEA 1 PLATE CODES TYPE ITE51 CODES 1 Operational Performance: A - Normal Operations; B Operations During Transients; EA Enforcement Action Letter with Civil Penalty and C - Programs and Processes ED Enforcement Discretion - No Civil Penalty 2 Alaterial Condition: A - Equipment Condition or B - Programs and Processes STR Overall Strong Licensee Perforriance 3 Iluman Performance: A - Work Performance; B - Knowledge, Skills, and Abilities /
WK Overall Weak Licensee Perform me- Training; C - Work Environment EFI
- Escalated Enforcement item - Waiting Final NRC Action .
4 Engm.eermg/ Design: A - Design; B - Engineering Support; C - Programs and Processes VIO Violation Level I, II, Ill, or IV 5 Problem Identification and Resolution: A - Identification; B - Analysis; and C -
NCV Noncited Wlation Resolution DEV Desiation from Licensee Commitment to NRC NOTES:
POS Individual Good Inspection Finding
- Eels are either: (1) apparent violations of NRC requirements that are being considered for escalated NEC* Indisidual Poor Inspection Finding enforcement acti n in accordance with the " General Statement of Policy and Procedure f r NRC Enforcement Action" (Enforcement Policy), NUREG-160d, or (2) issues, which may represent a SL IV LER Licensee Event Report to the NRC potential violation. that remain open pending receipt of the licensee's corrective actions to determine if an NCV or VIO exists. Iloweser, the NRC has not reached its final enforcement decision on the issues URI " Unresolved Item from Inspection Report identified by the Eels and the PIN 1 entries will be modified when the final decisions are made. Before LIC Licensing Issue from NRR the NRC makes its decision for escalated enforcement items, the licensee will be prosided with an opportunity to either: (1) respond to the apparent violation or (2) request a predecisional enforcement SilSC Atiscellaneous - Emergency . eparedness Finding (EP), conference.
Declared Emergency, Nonconformance Issue. etc.
"URIs are unresolved items about w hich more infbrmation is required to determine whether the issue in question is an acceptab!e item, a deviation, a nonconformance, or a violation. Ilowever, the NRC has not reached its final conclusions on the issues, and the PI51 entries will be modified n hen the final conclusions are made.
WATERFORD STEAM ELECTRIC STATION, UNIT 3 ENCLOSURE 3 INSPECTION PLAN IP - Inspection Procedure Ti- Temporary instruction Core Inspection - Minimum NRC Inspection Program (mandatory all plants)
Regional Initiative - An inspection conducted base 3d on licensee performance concerns INSPECTION TITLE / NUMBER OF PLANNED TYPE OF PROGRAM AREA .
INSPECTORS INSPECTION DATES INSPECTION COMMENTS IP 92904 Followup - Plant Support 1 01/25 - 29/99 Regional Initiative - Followup to Security inspection issues IP 73753 Inservice Inspection 1 03/01 - 05/99 Core Inspection IP S3750 Occupational Radiation Exposure 1 03/08 -12/99 Core inspection IP 92903 Followup - Engineering 4 04/05 -09/99 Regional Initiative - Followup to Architect 04/26-30/99 Engineering inspection issues 05/10 -14/99 IP 40500 Effectiveness of Licensee Controls in 3 06/01 -11/99 Core inspection Identifying, Resolving, and Preventing Problems IP 82701 Operational Status of the Emergency 1 05/17 - 21/99 Core Inspection Preparedness Program IP 84750 Radioactive Waste Treatment, and 2 05/24 - 28/99 Core inspection Effluent and Environmental Monitoring IP 92904 Followup - Plant Support 1 06/07 -11/99 Regional Initiative - Followup to Security inspection issues IP 86750 Transportation of Radioactive Material 1 07/19 -23/99 Core inspection IP 83750 Occupational Radiation Exposure 2 07/19 -23/99 Core Inspection
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