ML25114A260

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Notification of Commercial Grade Dedication Inspection (05000382/2025010) and Request for Information
ML25114A260
Person / Time
Site: Waterford 
Issue date: 04/28/2025
From: Cale Young
NRC/RGN-IV/DORS
To: Sullivan J
Entergy Operations
R. Kumana
Shared Package
ML25114A260 List:
References
IR 2025010
Download: ML25114A260 (1)


See also: IR 05000382/2025010

Text

April 28, 2025

Joseph Sullivan, Site Vice President

Entergy Operations, Inc.

17265 River Road

Killona, LA 70057

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NOTIFICATION OF

COMMERCIAL GRADE DEDICATION INSPECTION (05000382/2025010) AND

REQUEST FOR INFORMATION

Dear Joseph Sullivan:

The purpose of this letter is to notify you that U.S. Nuclear Regulatory Commission (NRC) staff

will conduct the commercial grade dedication baseline inspection at Waterford Steam Electric

Station, Unit 3, beginning on September 8, 2025. The inspection team will be composed of three

personnel from the NRC Region IV office. The inspection will be conducted in accordance with

NRC Inspection Procedure (IP) 71111.21N.03, Commercial Grade Dedication, dated

February 16, 2023.

The inspection will evaluate the implementation of Waterford Steam Electric Stations process

for dedicating commercial grade items, as required in applicable portions of Appendix B to

Title 10 of the Code of Federal Regulations Part 50, to ensure reasonable assurance is provided

that these items will perform their intended safety function. Additionally, this inspection will

evaluate implementation of Waterford Steam Electric Stations procurement process for safety-

related structures, systems, and components, as required in Appendix B.

The inspection will include an onsite information gathering visit by the team lead and two weeks

of onsite inspection by the team. The schedule for the inspection is as follows:

Onsite Information Gathering Visit: August 4-7, 2025

Offsite Preparation Week: September 1-5, 2025

Onsite Inspection Weeks: September 8-12, 2025, and September 22-26, 2024

The purpose of the information gathering visit is to meet with your staff to become familiar with

the process of dedicating commercial grade items and the process for procuring safety-related

structures, systems, and components at Waterford Steam Electric Station. A high-level

presentation of site-specific commercial grade dedication and safety-related procurement

activities would be beneficial. This visit may include a tour of onsite commercial grade item

dedication facilities, receipt inspection facilities, storage facilities, and installed plant

components associated with potential inspection samples. During the visit, the team lead will

J. Sullivan

2

also review the information provided in the initial information request to select a list of potential

inspection samples. The team lead may also identify other information needed to support the

inspection during this visit.

To minimize the impact on your staff and to ensure an effective and efficient inspection, we

have enclosed two separate requests for information needed prior to the onsite information

gathering visit and offsite inspection preparation week. The first request (Enclosure 1) is

generally for information that will be used to choose the inspection samples or information that

will be applicable to all inspection samples throughout the inspection. This information should be

made available to the team lead prior to the information gathering visit. The second request

(Enclosure 2) is for information that is specific to an individual sample and should be made

available prior to the offsite preparation week.

Additional information requests, interviews with your staff, and/or walkdowns of facilities or

installed plant components will be made by the team throughout the inspection to complete their

review of the selected inspection samples. It is important that all documentation provided to the

team is complete and upto-date to minimize the number of additional documents requested

during the preparation and/or the onsite portions of the inspection. Additionally, to facilitate an

efficient inspection, we request that a contact individual be assigned to each inspector to ensure

information requests, questions, and concerns are addressed in a timely manner.

We understand that Ramon Peter from your Regulatory Assurance organization is our contact

for this inspection. If there are any questions about the inspection or the information requested,

please contact the team lead, Rayomand Kumana, by telephone at 817-200-1426 or by email at

Rayomand.Kumana@nrc.gov. Enclosure 3 contains additional contact information for the

inspection team.

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget, under Control

Number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to

respond to a request for information or an information collection requirement unless the

requesting document displays a currently valid Office of Management and Budget control

number.

J. Sullivan

3

In accordance with 10 CFR 2.390 of the NRC rules and practices, a copy of this letter and its

enclosures will be available electronically for public inspection in the NRC public document

room or from the publicly available records (PARS) component of NRCs document system

(ADAMS). ADAMS is accessible from the NRC website.

Sincerely,

Cale Young, Acting Chief

Engineering Branch 1

Division of Operating Reactor Safety

Docket No. 05000382

License No. NPF-38

Enclosures:

1.

Documents Requested Prior to

Information Gathering Visit

2.

Documents Requested Prior to

Inspection Preparation Week

3.

Inspection Team Contact Information

cc w/encl: Distribution via LISTSERV

Signed by Young, Cale

on 04/28/25

ML25114A260

X

SUNSI Review

by RJK

X

Non-Sensitive

Sensitive

X

Publicly Available

Non-Publicly Available

OFFICE

BC:DORS/EB1

SRI:DORS/EB1

C:DORS/EB1

NAME

WCullum

RKumana

CYoung

SIGNATURE

/RA/

/RA/

/RA/

DATE

04/28/25

04/28/25

04/28/25

Enclosure 1

Documents Requested Prior to Information Gathering Visit

The documents and information requested below should generally be made available to the

inspection team for the team's use both onsite and offsite during the information gathering visit.

Electronic format is the preferred media. If electronic media is made available via an internet

based remote document management system, then the remote document access must allow

inspectors to download, save, and print the documents in the NRC's regional office. Electronic

This document request is based on typical documents that a generic plant might have. As such,

this document request is not meant to imply that any specific plant is required to have all the

listed documents. In addition, your plant-specific document titles may vary from the document

titles listed below. We also request that the information provided be sorted by the list below.

Documents requested by July 28, 2025:

1.

Copy of procedures for dedicating commercial grade items/services, procuring safety-related

structures, systems, and components (SSCs), performing receipt inspections, controlling

counterfeit, fraudulent, and suspect items, and 10 CFR Part 21 evaluations and reporting.

2.

Sortable list of commercial grade items/services that completed the dedication process

within the past six years. These items/services may have been dedicated by Waterford

Steam Electric Station or by a vendor (or other licensee) and procured by Waterford Steam

Electric Station. Include, as applicable, relevant information such as the item/services

material/catalog identification number and description, parent/host equipment identification

number and description, purchase order number, installation work order/job number, and

date of issue/installation.

3.

Sortable list of SSCs that were procured as safety-related within the past six years. Include,

as applicable, relevant information such as the SSCs material/catalog identification number

and description, parent/host equipment identification number and description, purchase

order number, installation work order/job number, date of issue/installation, and end-use

safety classification.

4.

Sortable list of dedicated commercial grade items/services or procured safety-related SSCs

that were placed on hold within the past six years because of concerns identified during

receipt, dedication, or from operating experience or the corrective action program as

applicable.

5.

Sortable list of dedicated commercial grade items/services or procured safety-related SSCs,

with a brief description, where dedication/procurement activities were expedited within the

past six years.

6.

Sortable list of dedicated commercial grade-items/services or procured safety-related SSCs

that failed after completing dedication/procurement activities or required corrective

maintenance within the past six years.

7.

Sortable list of corrective action program documents, with a brief description, related to

commercial grade item/service dedication, safety-related SSC procurement, receipt

inspection, and storage activities within the past six years.

E1-2

8.

Copy of any self-assessments or audits of commercial grade item/service dedication and/or

safety-related SSC procurement activities performed within the past six years.

9.

Copy of the updated final safety analysis report, technical specifications, and technical

requirements manual, including applicable bases documents.

10. Sortable list of systems, including identifying designators and corresponding names.

11. List of individuals who will be supporting the inspection and their contact information.

Enclosure 2

Documents Requested Prior to Inspection Preparation Week

For the samples identified by the team lead, the documents and information requested below

should generally be made available to the inspection team for the team's use both onsite and

offsite during the inspection. Electronic format is the preferred media. If electronic media is

made available via an internet based remote document management system, then the remote

document access must allow inspectors to download, save, and print the documents in the

NRC's regional office. Electronic media on compact disc or paper records (hardcopy) are

acceptable. At the end of the inspection, the documents in the team's possession will not be

retained.

This document request is based on typical documents that a generic plant might have. As such,

this document request is not meant to imply that any specific plant is required to have all the

listed documents. In addition, your plant-specific document titles may vary from the document

titles listed below. We also request that the information provided be sorted by the list below for

each sample.

Documents requested by August 25, 2025:

1.

Complete commercial grade item dedication package including relevant documentation such

as the following, as applicable: description of item/service, identification of safety functions

and safety classifications of item/parent component, like-for-like or equivalency evaluations,

credible failure modes/failure modes and effects analysis, critical characteristics and

acceptance criteria, identification of the suppliers commercial quality assurance program or

other documented controls.

2.

Complete purchase order including relevant documentation such as the following, as

applicable: purchase requisition, catalog specifications, item product data sheets/vendor

manuals, shelf-life information, service/qualified life information, certificates of

conformance/compliance/quality, vendor test and inspection reports, third-party or sub

vendor test and inspection results, vendor dedication or partial dedication information,

material receiving reports, packing list/invoices or other shipping documents, and other

pertinent vendor/licensee correspondence.

3.

Receipt inspection reports and any related test reports, documents noting any deviations

from design, material, and performance characteristics relevant to the safety function

(nonconformance dispositions).

4.

Documents showing objective evidence of special test and inspection procedures used to

verify technical and quality requirements have been met, commercial grade survey reports,

or source verification reports; any other documents to trace the item from the time it was

dedicated to the time it was installed, tested, and accepted.

5.

Completed installation work orders and stock or material issue forms; completed post-

installation test procedures and results.

6.

Design basis information of the inspection sample or parent/host component such as:

normal/accident service environment, normal/accident performance requirements, design

basis document/system description, relevant UFSAR/technical specification sections,

calculation/drawing/procedure updates, etc.

E2-2

7.

10 CFR 50.59 documentation, if required.

8.

Sortable list of corrective action program documents, with a brief description, associated

with the inspection sample or parent/host equipment.

Enclosure 3

Inspection Team Contact Information

Rayomand Kumana (Lead)

Senior Reactor Inspector

817-200-1426

Rayomand.Kumana@nrc.gov

Dustin Bryen

Reactor Inspector

817-200-1078

Dustin.Bryen@nrc.gov

Beatrice Nwafor

Reactor Inspector

817-200-1462

Beatrice.Nwafor@nrc.gov

Mailing Address:

U.S. NRC, Region IV

Attn: Rayomand Kumana

1600 East Lamar Blvd.

Arlington, TX 76011-4511