ML20217Q314
| ML20217Q314 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/09/1998 |
| From: | Ewing E ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-382-97-26, W3F1-98-0029, W3F1-98-29, NUDOCS 9803120183 | |
| Download: ML20217Q314 (16) | |
Text
I O
Ente perations, Inc.
Killona. LA 70006 i
Tel 504 739 6242 Early C. Ewing,111 Jety & Reguiatory Affairs C
ue W3F1-98-0029 A4.05 PR j
March 9,1998 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 NRC Inspection Report 50-382/97-26 Reply to Notice of Violation l
Gentlemen:
In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in
, the response to the violations identified in Enclosure 1 of the subject inspection Report.
The subject violations were discussed with the NRC in an enforcement conference l
on January 23,1998. The corrective actions included in the responses to the violations include any commitments discussed during the enforcement conference and clarifies key information from that conference not included in the subject inspection report or the notice of violation.
j As presented at the enforcement conference, Waterford 3 believes that having both j
l trains of Auxiliary Component Cooling Water inoperable in violation of Technical i
Specification 3.7.3 was one issue that was due to:
- 1. the controller not being placed in automatic,
- 2. missed opportunities to identify the controller left in manuel and
- 3. the missed opportunity to verify redundant train operability.
The issue was self identified and promptly corrected once identified.
9903120183 900309
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NRC Inspection Report 50-382/97-26 Reply to Notice of Violation W3F1-98-0029 Page 2 March 9,1998 Due to the interrelated nature of the six individual violations that, in aggregate, form the Level lil violation, portions of the individual responses apply to more than one violation. In an effort to reduce the level of repetition of the responses, the information is stated under the violation that is most specific to that response, in summary prompt action, common to the cited violations include:
Operations performing a walkdown of control panel indications and switches for CCW and ACCW equipment, the Shift Supervisor meeting with the Operations crew and stressing the e
importance of thorough board walkdowns in light of the switch misposition (Controller ACC-126A) and both trains being taken out of service concurr.;ntly, the Operations Superintendent meeting with Shift Superintendents to reaffirm i
e management expectations about shift turnover and control board walkdowns, the Operations Superintendent meeting with each shift to discuss and reinforce e
management expectations, and Operations management meeting with the shifts and stressing Performance Improvement Intemational techniques.
If you have any questions concerning this response, please contact me at (504) 739-6242 or T.J. Gaudet at (504) 739-6666.
Very truly yours, E.C. Ewing
- Director, Nuclear Safety & Regulatory Affairs i
ECE/ OPP /ssf Attachment cc:
E.W. Merschoff (NRC Region IV)
C.P. Patel (NRC-NRR)
J. Smith N.S. Reynolds NRC Resident inspectors Office
Attachmsnt to W3F1-98-0029 Page 1 of 14 ATTACHMENT 1 j
ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATIONS IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 50-382/97-26 VIOLATION NO. 9726-01013 Technical Specification 3.7.3 states that at least two independent trains of auxiliary component cooling water shall be operable while in Modes 1,2, 3, and 4.
Contrary to the above, on November 10,1997, two independent trains of auxiliary component cooling water were not maintained operable in Mode 1. Specifically, both trains of the auxiliary component cooling water were inoperable for approximately 7.5 I
hours with the plant in Mode 1. (01013)
RESPONSE
(1)
Reason for the Violation Entergy admita this violation. The failure to adequately verify that the redundant train of ACCW was operable prior to removing ACCW train 'B' from service is attributed to insufficient procedure detail. Operations procedures required the shift to verify that no LCO/TRM checklist existed for the '
component. The procedures did not require verification of actual component configuration. A contributing cause was inadequate supervisory oversight by the Control Room Supervisor.
(2)
Corrective Steps That Have Been Taken and the Results Achieved -
Procedures OP-100-007, " Shift Turnover", OP-100-001, " Duties and Responsibilities of Operators on Duty," and OP-100-010, " Equipment Out of Service," have been revised to clarify verification of redundant train operability. In addition to prescribing review of the Equipment out of Service Log, the revised procedures now prescribe verification of actual component configuration in the redundant train prior to removing a safety related i
component or system from service. The verification prescribed now entails j
verifying that each switch, controller, bypass status indicating lamp, and setpoint indicator in the other safety train is in its required position.
Operators have been made aware of the procedure changes through Operations shift meetings and Operator required reading.
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Attachment to VV3F1-98-0029 Page 2 of 14 (3)
Corrective Steps Which Will Be Taken to Avoid Further Violations The above stated corrective steps taken address the subject violation.
(4)
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
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Attachment to W3F1-98-0029 Paga 3 of 14 VIOLATION NO. 9726-01023 Technical Specification 6.8.1.a states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33," Quality Assurance Program.
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Requirements (Operations)," Revision 2, February 1978. Regulatory Guide 1.33, item 1.b requires that administrative procedures be established for safe operation and shutdown of the facility.
Procedure OP-100-001, " Duties and Responsibilities of Operators on Duty," Revision 12, described the responsibilities for the control room supervisor and the nuclear plant operators related to personnel conduct and control of operating activities.
These responsibilities are described, in part, by the following steps in this procedure:
Step 4.4.5: Nuclear plant operators will" Continuously monitor performance of plant control systems and Control Room instrumentation to verify operability."
Step 5.4.1.1: "On-duty operators shall be attentive to all status indicators and plant parameters and investigate abnormal conditions or trends "
Step 5.4.1.2: "On-duty Operators must make every effort to keep themselves aware of the status of safety systems and major power generating components."
Contrary to the above, on November 9-10,1997, the control room supervisor, primary nuclear plant operator, and secondary nuclear plant operator failed to
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continuously monitor performance of Control Room instrumentation to verify 1
operability, to remain attentive to all status indicators, and to keep themselves aware of the status of safety systems as stated in Steps 4.4.5, 5.4.1.1 and 5.4.1.2, respectively. Specifically, the operators failed to recognize that the manual / auto controller for Valve ACC-126A was not in the required automatic position, rendering Train A of the ACCW system inoperable. (01023) l
RESPONSE
~(1)
Reason for the Violation Entergy admits this violation. The violation is attributed to human error due to inattention to detail. This resulted in the on-duty Operations personnel within the Control Room not noticing (during continuous monitoring) that the controller for ACC-126A had been inadvertently left in manual. Factors that contributed to the inattention to detail include Operator focus tending more toward operating equipment coupled with (in some cases) a tendency to focus on controller pushbuttons as having only an indication function rather than an indication and switch function.
y, Attrchm::nt to W3F1-98-0029 Page 4 of 14 l
(2)
Corrective Steps That Have Been Taken and the Results Achieved Operations' management met with Operations' shift ciews to increase awareness that controller pushbuttons have an indication and a switch q
function and to accentuate management expectations regarding continuous monitoring of Control Room instrumentation.
(3)
Corrective Steps Which Will Be Taken to Avoid Further Violations
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1 The above stated corrective steps adequately address the subject violation.
(4)
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
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AttochmGnt to VV3F1-98-0029 Page 5 of 14 VIOLATION NO. 9726-01033 Technical Specification 6.8.1.a states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, item 1.b requires that administrative procedures be j
established for safe operation and shutdown of the facility.
Procedure OP-100-001, Revision 12, Step 4.3.2.4 stated, in part, that the control room supervisor will" Monitor the Nuclear Plant Operators in the performance of their duties."
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Contrary to the above, on November 9-10,1997, the control room supervisor failed to monitor the activities of the secondary nuclear plant operator who secured Auxiliary Component Cooling Water Pump A without placing the manual / auto controller for Valve ACC-126A in automatic. (01033) l
RESPONSE
(1)
Reason for the Violation l
Entergy admits this violation. The violation resulted from control room supervisor (CRS) inattention due to distraction (preparing for shift meeting).
The CRS indicated during the follow-up investigation that he had intended to conduct a post-job review for the evolution (chemical mixing of the Wet Cooling Tower Basin). However, he was in the process of preparing for the upcoming shift meeting and became distracted. A post-job review was not performed. The evolution had been conducted in the hour between the oncoming shift taking the watch (1830 on 11/9/97) and the Shift Meeting held at 1930 on 11/9/97.
l (2)
Corrective Steps That Have Been Taken and the Results Achieved I
Operations management has met with shift supervisors and control room supervisors and emphasized the importance of prioritizing work to reduce Operator self imposed pressures and distractions. Additionally, management has reemphasized principles that had been conveyed earlier to Operations staff during recently conducted Human Error Reduction training.
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(3)
Corrective Steps Which Will Be Taken to Avoid Further Violations The above stated corrective steps adequately address the subject violation.
(4)
Date When Full Compliance Will Be Achieved i
l Full compliance has been achieved.
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AMachment to W3F1-98-0029 Page 6 of 14 VIOLATION NO. 9726-01043 Technical Specification 6.8.1.a states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February _1978.
Regulatory. Guide 1.33, item 1.b requires that administrative procedures be I
established for safe operation and shutdown of the facility.
Procedure OP-100-001, Revision 12, described the responsibilities of the control room supervisor and the nuclear plant operators related to personnel conduct and control of operating activities. Specifically, these responsibilities are described by
. the following steps in this procedure:
Step 4.3.2.9: The control room supervisor will, in part, " Direct the preparation and installation of Danger tags, verifying that Technical Specification requirements are observed."
Step 5.8.2.1.B: " Redundant subsystems or components shall be verified to be operable. Upon discovery of inoperable components, or prior to initiating maintenance on components required by Technical Specificatiori Limiting Condition for Operation, their redundant counterparts shall be verified to be operable."
g Contrary to the above, on November 10,1997, at 3 a.m._ (CST) the control room supervisor failed to direct the preparation of danger tags, verifying that Technical Specification requirements were observed; and the nuclear plant operators failad to i
verify redundant subsystems were operable and failed to verify a redundant
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counterpart to an auxiliary component cooling water train was operable prior to ir.itiating maintenance on the opposite train. Specifically, nuclear plant operators removed Auxiliary Component Cooling Water Train B from service, which iricluded
- a placing danger tags, for routine maintenance without ensuring operability of Auxiliary i
Component Cooling Water Train A. (01043)
RESPONSE
(1)' '
Reason for the Violation Entergy admits this violation. The violation is attributed to insufficient i
pe>cedure detail. Operations procedures required the shift to verify that no LCO/TRM checklist existed for the redur. dant train. The procedures did not r&.4uire verification of actual component configuration. - A contributing cause nas inadequate supervisory oversight by the Control Room Supervisor. The control room supervisor did direct preparation of danger tags. However, he failed to adequately verify that operability of the redundant train had been established prior to preparation of the danger tags for Train 'B'.
Attachment to W3F1-98-0029 Page 7 of 14 (2)
Corrective Steps That Have Been Taken and the Results Achieved Procedures OP-100-007, " Shift Turnover", OP-100-001, " Duties and Responsibilities of Operators on Duty", and OP-100-010, " Equipment Out of Service" have been revised to clarify verification of redundant train operability.
The revised procedures now require verification of actual component configuration in the redundant train prior to removing a safety related component or system from service. The procedures aescribe this as verifying that each switch, controller, bypass status indicating li. np, and setpoint indicator in the other safety train is in its required position and by review of documented systems in the Equipment out of Service Log.
Operators have been briefed on the procedure changes through Operations shift meetings and Operator required reading.
(3)
Corrective Steps Which Will Be Taken to Avoid Further Violations The corrective steps stated above address the subject violation.
(4)
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
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Attachm:nt to W3F1-98-0029 Page 8 of 14 VIOLATION NO. 9726-01053 Technical Specification 6.8.1.a states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, item 1.d states requirements will be established for procedure adherence and temporary change methods and item 3.m states requirements for startup, operation, and shutdown of the service water system.
Procedure OP-100-001, Revision 12, described the responsibilities of the nuclear plant operators related to use of procedures. Specifically, these responsibilities are described by the following steps in this procedure:
Step 4.4.1 1: Nuclear plant operators will " Operate plant systems in accordance with plant procedures and as directed by the SS/CRS."
Step 5.13.8: " Operators shall comply with both the content and intent of approved procedures."
Procedure OP-002-001, " Auxiliary Component Cooling Water System," Revision 11, Section 7, Step 6 required oporators to set the manual / auto controller setpoint for Valve ACC-126A(B), auxiliary component cooling water system flow control, to s 95 F and to place the controller in automatic.
Contrary to the above, on November 9-10,1997, the secondary nuclear plant operator failed to comply with the intent of Procedure OP-002-001 for securing an auxiliary component cooling water train. Eoecifically, the operator failed to perform Procedure OP-002-001, Section 7, Step 6 that required placing the manual / auto controller for Valve ACC-126A to automatic. (01053)
RESPONSE
(1)
Reason for the Violation Entergy admits this violation. The violation is attributed to a failure of Operators to follow procedure due to human error involving inattention to detail. The primary contributing cause for the error was the procedure step that required placing the controller back in automatic had two actions prescribed in one step. The Operator performed the first action prescribed in OP-002-001, Section 7.0, Step 6 (adjusting the controller setpoint for valve ACC-126A), but inadvertently failed to perform the second action (to place the control ar in automatic).
Some instructions contained in operations procedures may appropriately be joined by "and" where the instructions are for a concurrent action in a single step (e.g. " depress AND hold the TEST push buttons on Bistable Control
Attrchm3nt to W3F1-98-0029 Page 9 of 14 Panel"). However, it is not appropriate for a single procedure step to contain more than one action statement where the actions are consecutive (one follows the other).
j OP-002-001, Section 7.0, Step 6 is an infrequently performed activity. The procedure is not required when the ACCW system is running. The ACCW
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system had been running continuously for approximately a year (preceding the violation), while ACCW system air intrusion / waterhammer concerns were j
being resolved. Normally the system runs continuously in the summer months and is not required in the winter conths. Even under normal conditions, the chemical mixing evolution (in the ACCW basin) is an infrequent one.
This condition differed from a previous condition (approximately one year ago)
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that involved the placement of the ACC-126A controller in manual with valve ACC-126A gagged in the 50% position, in that earlier case, the controller was I
placed in manual prior to obtaining results of an Engineering determination of the impact this would have on ACCW Train 'A' operability. The earlier case differed from the current case in that (in the earlier case) the Operators were complying with a technically inadequate procedure. While, the current case involved a failure to perform a procedure step due to a human factors procedure deficiency (dual actions in a single procedure step).
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(2)
Corrective Steps That Have Been Taken and the Results Achieved The violation was identified by an interim watch reik f during a Secondary Nuclear Plant Operator turnover to the relief. After entering Technical i
Specification 3.0.3 and promptly determining that there was no need for ACC-126A to be in manual, the shift placed the controller for ACC-126A in automatic, which restored ACCW Train 'A' to operable status and then exited Technical Specification 3.0.3. The violation was self identified.
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Initial prompt actions taken by Operations after placing the controller for ACC-126A in automatic included:
i performing a walkdown of other control panel indications and switches for e
CCW and ACCW equipment, the Shift Supervisor meeting with the crew and stressing the importance of e
thorough board walkdowns in light of the discovery, the Operations Superintendent meeting with Shift Superintendents to e
reaffirm management expectations about shift turnover and control board walkdowns, and the Operations Superintendent meeting with each shift to discuss and e
reinforce management expectations.
Procedure OP-002-001 was revised to separate the two action steps into separate steps in the procedure.
Att:chment to VV3F1-98-0029 Page 10 of 14 (3)
Corrective Steps Which Will Be Taken to Avoid Further Violations The single occurrence of dual actions being prescribed in a single step is considered to be an isolated case. However, as a conservative measure, Operations procedures will be reviewed for multiple actions in a single procedure step as the procedures are revised. Operators have been briefed to observe for multiple actions in a single step while generating, revising and/or implementing Operations procedures. The scope of these actions include procedures for ope-
~. outside of the Control Room (outside watch stations).
(4)
Date When Full Compliance Will Be Achieved Based on the affected procedure (OP-002-001) deficiency (two actions in a single step) being an isolated case, and the affected procedure revision being complete, full compliance has been achieved. The additional conservative measure, involving review for multiple actions in a single procedure step, will
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be ongoing as Operations procedures are generated, revised and/or
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implemented. Adjustments to the review effort will be based on review results.
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4 Attichment to W3F1-98-0029 Page 11 of 14 VIOLATION NO. 9726-01063 l~
Technical Specification 6.8.1.a states, in part, that written procedures shall be
. established, implemented, and maintained cevering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
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Regulatory Guide 1.33, item 1.g states that requirements be established in administrative procedures for shift relief and turnover.
Procedure OP-100-007, " Shift Turnover," Revision 16, described the requirements for control room operators to perform control panel walkdowns during shift turnover i
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and during the shift. Specifically, Step 5.1.7 stated, "Every shift the Shift i
Superintendent, Control Room Supervisor, Primery Nuclear Plant Operator, and the l-Secondary Nuclear Plant Operator shail perform two control board walkdowns. One control board walkdown per watch stander shall be documented by signing the control board walkdown signature block of the appropriate turnover sheet." Step 5.1.8 stated, "A complete control board walkdown is performed by thoughtfully -
observing every light, every indicator, every switch, and every button. Further, Step
- 5.5.3_ stated, "The oncoming and off-going NPOs should walk down the control panels together. Discussiona should include, but are not limited to, the following items: Status of safety-rslated systems; operating equipment and system alignments; Contrary to the above, on November 9-10,1997, numerous opportunities existed for the night shift watchstanders to identify the mispositioned indicator when evaluating every indicator and every switch as specified in Procedure l
OP-100-007, Steps 5.1.7 and 5.1.8. Also, several missed opportunities occurred during shift turnover control panel walkdowns while the nuclear plant i
operators discussed the status of the safety-related auxiliary component j
cooling water system and the respective equipment status / alignment.
i Specifically, from 7:21 p.m. on November 9 until 10:25 a.m. (CST) on November 10,1997, several operators failed to comply with Procedure OP-l 100-007, in that, at least eight opportunities during the night shift and at least l-three opportunities during shift turnover occurred to identify that the controller
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for Valve ACC-126A was misaligned. (01063)
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RESPONSE
(1)
Reason for the Violation
\\
p Entergy admits this violation. The violatiore is attributed to inadequate control l
board walkdowns by Operating Shifts in accordance with OP-100-007, " Shift Turnover". This was due to:
Organization to program interface deficiency: Inadequate program e
monitoring. There was no established method to gauge the effectiveness j
of the control board walkdown as described in OP-100-007, " Shift Tumover".
I
l Attichm:nt to W3F1-98-0029 -
Pega 12 of 14 Programmatic Deficiency: Excessive implementation Requirements.
Control Room Staffs were not performing thorough control board walkdowns in accordance~with OP-100-007 because a literal interpretation of the procedure was an unreasonable expectation for each operator to perform this activity twice per shift concurrent with normal Control Room
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~ activities.
J Human error due to inattention to detail: Unawareness. The Control e
Room Operators performing their control board walkdowns on the night of November 9,1997 did not notice that the controller for ACC-126A was in manual.
Human error due to inattention to detail: On-the job distraction. The Control Room Operators performing their control board walkdowns were overloadod by the number of lights / switches / indictors required to be thoughtfully observed in addition to performing the day-to-day operations of the plant. Also the Control Room Supervisor was distracted by being effectively taken out of a supervisory role by being required by procedure to perform the same board walkdowns that the board operators were y
required to perform.
A contributing cause of this violation was:
Inappropriate action due to misjudgment: Spacial orientation.
e Manual / Automatic controllers, such as the one for ACC-126A, have the same colored lights for the manual and automatic pushbuttons. This may 4
have contributed to the actual condition of the controller being overlooked.
There are no alarms or annunciators that indicate when the controller for ACC-126A(B) are in manual. The only indication to the operator in the control room (assuming no accident in progress) are the lighted pushbuttons on the controllers.
Board walkdowns and the shift turnover walkdowns are performed differently.
Boerd walkdowns are performed to ensure that components are in their required positions and to mitigate the consequences in the event a component is found out of position, in a timely manner. Board walkdowns performed by the Secondary Nuclear Plant Operator (SNPO) and the Primary Nuclear Plant Operator (PNPO) should be conducted component by component, checking that each switch, controller, bypass status indicating lamp, and setpoint indicator is in its required position. Whereas, shift tumover walkdowns involve the on-coming and off-going NPOs walking down the control panels together and discussing safety system status, operating equipment and system alignments, inoperable equipment, reasons for panel alarms, etc. The latter walkdown is not intended to be a switch by switch, component by component review. The Operator that identified the mispositioned switch was assuming
l Att:chment to
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W3F1-98-0029 Pcgn 13 of 14 l
mid-shift relief and was in the process of performing a shift turnover walkdown when he noticed the switch out of position. The individual taking the relief is a
assigned to administrative duties (Shift Support Center) and had not been on I
operating shift for a while. Due to his shift support activitier, the Operator coming on in relief was keenly aware of work status on the redundant train of ACC.
The Operators felt that they were meeting management expectations with the level of detail of the board walkdowns being performed. Management confirmed that the Operators' interpretation of walkdowns was in accordance with management expectations, although the procedures governing the walkdowns needed to be simplified and clarified to reduce the potential for unreasonable interpretations.
i The mispositioned controller switch for ACC-126A was the first indication that earlier corrective actions had taken the Control Room Supervisor out of a supervisory role by requiring him to perform the same level of Board l
Walkdown as the SNPO and the PNPO.
(2)
Corrective Steps That Have Been Taken and the Results Achieved I
l OP-100-007 was revised to simplify the control board walkdown for the I
l Control Room staff by requiring it once per shift by the PNPO and SNPO; l
specifying that each switch, controller, bypass status indicating lamp, and setpoint indicator should be checked; directing an independent check of controls manipulated during the shift on safety systems be conducted during the last two hours of shift; and suggesting the Shift Superintendent perform a walk down once per shift of Safety Related controls manipulated during the shift.
UNT-007-011," Duties and Responsibilities of the Shift Technical Advisor (STA)," was changed to include a requirement for the On-coming STA to i
complete an assessment of control panels prior to turnover. A Technical l
Specification / Technical Requirements Manual control panel walkdown checklist was developed to ensure consistent and thorough assessments.
I Reviewed and evaluated OP-100-001, " Duties and Responsibilities of Operators on Duty", OP-100-007, " Shift Turnover," 01-004-000, " Operations Narrative and Shift Logs",01-035-000," Notification Matrix", and Operations Policies for expectations that cannot reasonably be met by Operations
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Personnel. During procedure reviews, identified an item concerning unreasonable expectations associated with Nuclear Auxiliary Operator (NAO) watchstation tours (revision addressing this is complete).
A Standing instruction (97-07) was issued to clarify the role of Peer Checker.
Att:chment to W3F1-98-0029 Pcgs 14 of 14 Operations management stressed Performance Improvement International techniques during meetings with the shifts.
Operations management performed a control board walkdown observation on all cre'us to reinforce expectations. Acceptable results were obtained from the observations performei (3)
Corrective Steps Which Will Be Taken to Avoid Further Violations An overall corrective actions effectiveness review will be performed by Operations management within six months of this response.
Waterford 3 will make effectiveness improvements in the Operations walkdown process to p event future occurrences of this violation. The improvements may include the use of a control bcard walkdown tool, or other effective techniques as determined through effectiveness reviews.
Waterford 3 currently is evaluating a change in the pushbutton lamp cover colors on Manual / Automatic controllers to provide for easier evaluation of the condition of the controllers. However, this is considered to be an enhancement and is not necessary to achieve full compliance.
Waterford 3 will benchmark shift turnover and board walkdown methods, practices, and expectations at nuclear plants to identify board walkdown improvements.
(4)
Date When Full Compliance Will Be Achieved Full compliance has been achieved. Remaining actions are effectiveness monitoring functions, which are expected to be complete by September 9, 1998.
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