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Category:Letter type:W
MONTHYEARW3F1-2023-0056, Owner'S Activity Report Form for Inservice Inspection Performed During Operating Cycle 24 / Refuel 242023-12-19019 December 2023 Owner'S Activity Report Form for Inservice Inspection Performed During Operating Cycle 24 / Refuel 24 W3F1-2023-0055, Reply to a Notice of Violation2023-12-14014 December 2023 Reply to a Notice of Violation W3F1-2023-0052, Core Operating Limits Report (COLR) - Cycle 26, Revision O2023-11-0707 November 2023 Core Operating Limits Report (COLR) - Cycle 26, Revision O W3F1-2023-0049, Revise Technical Specification 3/4.3.2 to Remove Exemption from Testing Certain Relays at Power to Support Elimination of Potential Single Point Vulnerability - Withdrawal2023-09-28028 September 2023 Revise Technical Specification 3/4.3.2 to Remove Exemption from Testing Certain Relays at Power to Support Elimination of Potential Single Point Vulnerability - Withdrawal W3F1-2023-0048, Special Report SR 2023-004-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days2023-09-25025 September 2023 Special Report SR 2023-004-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days W3F1-2023-0035, Application for Technical Specification Change to Revise Surveillance Requirements Included in the Surveillance Frequency Control Program2023-07-26026 July 2023 Application for Technical Specification Change to Revise Surveillance Requirements Included in the Surveillance Frequency Control Program W3F1-2023-0036, Special Report SR-2023-003-01 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days2023-05-0404 May 2023 Special Report SR-2023-003-01 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days W3F1-2023-0032, Annual Radioactive Effluent Release Report (ARERR) 20222023-04-27027 April 2023 Annual Radioactive Effluent Release Report (ARERR) 2022 W3F1-2023-0033, Submittal of Annual Radiological Environmental Operating Report - 20222023-04-27027 April 2023 Submittal of Annual Radiological Environmental Operating Report - 2022 W3F1-2023-0025, Annual Report of Individual Monitoring of Radiation Exposure for 2022 Per 10 CFR 20.22062023-04-11011 April 2023 Annual Report of Individual Monitoring of Radiation Exposure for 2022 Per 10 CFR 20.2206 W3F1-2023-0018, Updated Final Supplemental Response to NRC Generic Letter 2004-022023-03-30030 March 2023 Updated Final Supplemental Response to NRC Generic Letter 2004-02 W3F1-2023-0022, Registration of Dry Fuel Storage Cask Use2023-03-22022 March 2023 Registration of Dry Fuel Storage Cask Use W3F1-2023-0021, Submittal of Special Report SR 2023-003-00 Radiation Monitor Inoperable Greater than 7 Days2023-03-17017 March 2023 Submittal of Special Report SR 2023-003-00 Radiation Monitor Inoperable Greater than 7 Days W3F1-2023-0016, Registration of Dry Fuel Storage Cask Use2023-03-0303 March 2023 Registration of Dry Fuel Storage Cask Use W3F1-2023-0014, Reply to a Notice of Violation; EA-22-1192023-02-20020 February 2023 Reply to a Notice of Violation; EA-22-119 W3F1-2023-0013, Notification of Readiness for Supplemental Inspection2023-02-15015 February 2023 Notification of Readiness for Supplemental Inspection W3F1-2023-0007, Registration of Dry Fuel Storage Cask Use2023-02-0606 February 2023 Registration of Dry Fuel Storage Cask Use W3F1-2023-0010, Special Report SR 2023-002-00, Radiation Monitor Inoperable Greater than 7 Days2023-01-25025 January 2023 Special Report SR 2023-002-00, Radiation Monitor Inoperable Greater than 7 Days W3F1-2023-0002, SR 2023-001-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 30 Days2023-01-0505 January 2023 SR 2023-001-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 30 Days W3F1-2022-0067, Commitment Change Notification for Generic Safety Issue 191 and Generic Letter 2004-022022-12-20020 December 2022 Commitment Change Notification for Generic Safety Issue 191 and Generic Letter 2004-02 W3F1-2022-0054, Revise Technical Specification 3/4.3.2 to Remove Exemption from Testing Certain Relays at Power to Support Elimination of Potential Single Point Vulnerability2022-11-0101 November 2022 Revise Technical Specification 3/4.3.2 to Remove Exemption from Testing Certain Relays at Power to Support Elimination of Potential Single Point Vulnerability W3F1-2022-0063, Submittal of Emergency Preparedness Documents. Includes EP-001-001, Revision 372022-10-27027 October 2022 Submittal of Emergency Preparedness Documents. Includes EP-001-001, Revision 37 W3F1-2022-0059, Response to Clarification Questions Concerning Supplement to License Amendment Request to Adopt TSTF-5052022-10-13013 October 2022 Response to Clarification Questions Concerning Supplement to License Amendment Request to Adopt TSTF-505 W3F1-2022-0058, Reply to a Notice of Violation; EA-22-0332022-10-12012 October 2022 Reply to a Notice of Violation; EA-22-033 W3F1-2022-0049, Response to Request for Additional Information Regarding License Amendment Requests to Adopt 10 CFR 50.69 and TSTF-5052022-08-19019 August 2022 Response to Request for Additional Information Regarding License Amendment Requests to Adopt 10 CFR 50.69 and TSTF-505 W3F1-2022-0037, Submittal of Owner'S Activity Report Form for Inservice Inspection Performed During Operating Cycle 24 / Refuel 242022-08-0808 August 2022 Submittal of Owner'S Activity Report Form for Inservice Inspection Performed During Operating Cycle 24 / Refuel 24 W3F1-2022-0044, SR-2022-004-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days2022-07-0606 July 2022 SR-2022-004-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days W3F1-2022-0042, SR-22-003-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days2022-06-27027 June 2022 SR-22-003-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days W3F1-2022-0015, Response to Request for Additional Information to License Amendment Request to Revise Technical Specifications to Adopt TSTF-505, Revision 2, Provide Risk Informed Extended Completion Times - Ritstf.2022-05-16016 May 2022 Response to Request for Additional Information to License Amendment Request to Revise Technical Specifications to Adopt TSTF-505, Revision 2, Provide Risk Informed Extended Completion Times - Ritstf. W3F1-2022-0026, Report of Facility Changes, Tests, and Experiments and Commitment Changes for Two Year Period Ending April 28, 20222022-04-28028 April 2022 Report of Facility Changes, Tests, and Experiments and Commitment Changes for Two Year Period Ending April 28, 2022 W3F1-2022-0028, Annual Radiological Environmental Operating Report - 20212022-04-26026 April 2022 Annual Radiological Environmental Operating Report - 2021 W3F1-2022-0029, Annual Report of Individual Monitoring of Radiation Exposure for 2021 Per 10 CFR 20.22062022-04-26026 April 2022 Annual Report of Individual Monitoring of Radiation Exposure for 2021 Per 10 CFR 20.2206 W3F1-2022-0009, Supplement to Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components (Sscs) for Nuclear Power Reactors2022-04-25025 April 2022 Supplement to Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components (Sscs) for Nuclear Power Reactors W3F1-2022-0031, Proposed Revision to Reactor Vessel Surveillance Capsule Withdrawal Schedule to Reflect Location of Standby Capsules 3/W-104 and 6/W-2842022-04-25025 April 2022 Proposed Revision to Reactor Vessel Surveillance Capsule Withdrawal Schedule to Reflect Location of Standby Capsules 3/W-104 and 6/W-284 W3F1-2022-0020, Review of Preliminary Accident Sequence Precursor Report2022-04-11011 April 2022 Review of Preliminary Accident Sequence Precursor Report W3F1-2022-0017, Annual Report on Westinghouse Electric Company LLC Combustion Engineering Emergency Core Cooling System Performance Evaluation Models for Calendar Year 20212022-04-0707 April 2022 Annual Report on Westinghouse Electric Company LLC Combustion Engineering Emergency Core Cooling System Performance Evaluation Models for Calendar Year 2021 W3F1-2022-0019, WAT-2022-02 Post Exam Analysis2022-03-0909 March 2022 WAT-2022-02 Post Exam Analysis W3F1-2022-0011, Special Report SR-22-002-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days2022-02-0808 February 2022 Special Report SR-22-002-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days W3F1-2022-0008, SR-22-001-00, Waterford Steam Electric Station, Unit 3, Radiation Monitors Inoperable Greater than 7 Days2022-02-0101 February 2022 SR-22-001-00, Waterford Steam Electric Station, Unit 3, Radiation Monitors Inoperable Greater than 7 Days W3F1-2021-0074, Commitment Change Notification for Generic Safety Issue - 191 and Generic Letter 2004-022021-12-16016 December 2021 Commitment Change Notification for Generic Safety Issue - 191 and Generic Letter 2004-02 W3F1-2021-0064, Proposed Revision to Reactor Vessel Surveillance Capsule Withdrawal Schedule to Support Relocation of Capsules 104 and 2842021-11-30030 November 2021 Proposed Revision to Reactor Vessel Surveillance Capsule Withdrawal Schedule to Support Relocation of Capsules 104 and 284 W3F1-2021-0061, Supplement to License Amendment Request to Relocate Chemical Detection Systems Technical Specifications to Technical Requirements Manual2021-10-14014 October 2021 Supplement to License Amendment Request to Relocate Chemical Detection Systems Technical Specifications to Technical Requirements Manual W3F1-2021-0063, Request for One-Time Exemption from 10 CFR 50, Appendix E Biennial Emergency Preparedness Evaluated Exercise Requirements Due to Severe Storm Recovery2021-10-12012 October 2021 Request for One-Time Exemption from 10 CFR 50, Appendix E Biennial Emergency Preparedness Evaluated Exercise Requirements Due to Severe Storm Recovery W3F1-2021-0050, Response to U. S. Nuclear Regulatory Commission Request for Additional Information Regarding License Amendment Request to Adopt2021-10-0101 October 2021 Response to U. S. Nuclear Regulatory Commission Request for Additional Information Regarding License Amendment Request to Adopt W3F1-2021-0060, Response to Request for Additional Information Regarding License Amendment Request to Relocate Chemical Detection Systems Technical Specifications to Technical Requirements Manual2021-09-30030 September 2021 Response to Request for Additional Information Regarding License Amendment Request to Relocate Chemical Detection Systems Technical Specifications to Technical Requirements Manual W3F1-2021-0039, Application for Technical Specification Change to Revise Pressure/Temperature and Low Temperature Overpressure Protection for 55 Effective Full Power Years2021-08-25025 August 2021 Application for Technical Specification Change to Revise Pressure/Temperature and Low Temperature Overpressure Protection for 55 Effective Full Power Years W3F1-2021-0055, Supplement to License Amendment Request to Relocate Boration Systems Technical Specifications to the Technical Requirements Manual2021-08-20020 August 2021 Supplement to License Amendment Request to Relocate Boration Systems Technical Specifications to the Technical Requirements Manual W3F1-2021-0057, (Waterford 3) - Emergency Plan Revision 0522021-08-18018 August 2021 (Waterford 3) - Emergency Plan Revision 052 W3F1-2021-0054, License Amendment Request to Implement a Digital Upgrade to the Core Protection Calculator (CPC) System and Control Element Assembly Calculator (Ceac) System, Dated July 23, 20202021-07-29029 July 2021 License Amendment Request to Implement a Digital Upgrade to the Core Protection Calculator (CPC) System and Control Element Assembly Calculator (Ceac) System, Dated July 23, 2020 W3F1-2021-0051, Revised Licensing Technical Report for the Common Q Core Protection Calculator System - License Amendment Request to Implement a Digital Upgrade to the Core Protection Calculator System and Control Element Assembly Calculator2021-07-19019 July 2021 Revised Licensing Technical Report for the Common Q Core Protection Calculator System - License Amendment Request to Implement a Digital Upgrade to the Core Protection Calculator System and Control Element Assembly Calculator 2023-09-28
[Table view] Category:Licensee Response to Notice of Violation
MONTHYEARW3F1-2023-0055, Reply to a Notice of Violation2023-12-14014 December 2023 Reply to a Notice of Violation W3F1-2023-0014, Reply to a Notice of Violation; EA-22-1192023-02-20020 February 2023 Reply to a Notice of Violation; EA-22-119 W3F1-2022-0058, Reply to a Notice of Violation; EA-22-0332022-10-12012 October 2022 Reply to a Notice of Violation; EA-22-033 W3F1-2021-0028, Response to an Apparent Violation in NRC Inspection Report 05000382/2021013; EA-20-1142021-04-0202 April 2021 Response to an Apparent Violation in NRC Inspection Report 05000382/2021013; EA-20-114 W3F1-2019-0045, Updated Reply to a Notice of Violation; NRC Inspection Report 05000382/20180082019-06-20020 June 2019 Updated Reply to a Notice of Violation; NRC Inspection Report 05000382/2018008 W3F1-2019-0033, (Waterford 3) - Reply to Notice of Violation EA-18-020 Supplement2019-05-17017 May 2019 (Waterford 3) - Reply to Notice of Violation EA-18-020 Supplement W3F1-2018-0073, (Waterford 3) - Reply to a Notice of Violation; NRC Inspection Report 05000382/20180082018-12-14014 December 2018 (Waterford 3) - Reply to a Notice of Violation; NRC Inspection Report 05000382/2018008 W3F1-2018-0056, Reply to Notice of Violation EA-18-0202018-09-12012 September 2018 Reply to Notice of Violation EA-18-020 W3F1-2013-0072, Reply to a Notice of Violation: EA-12-2572013-12-18018 December 2013 Reply to a Notice of Violation: EA-12-257 W3F1-2012-0097, Reply to a Notice of Violation: EA-12-1982012-12-0303 December 2012 Reply to a Notice of Violation: EA-12-198 W3F1-2009-0043, Reply to Non-Cited Violation2009-09-16016 September 2009 Reply to Non-Cited Violation ML0629303022006-10-18018 October 2006 Response to NRC Inspection Report 05000382/2006009 Notice of Violation W3F1-2006-0053, Reply to Notice of Violation: EA-06-1362006-09-29029 September 2006 Reply to Notice of Violation: EA-06-136 W3F1-2006-0048, Reply to Notice of Violation: EA-06-1922006-09-18018 September 2006 Reply to Notice of Violation: EA-06-192 W3F1-2004-0040, Reply to Notice of Violation, EA-03-230, NRC Inspection Report No. 50-382/03-0072004-05-12012 May 2004 Reply to Notice of Violation, EA-03-230, NRC Inspection Report No. 50-382/03-007 2023-02-20
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Entergy Nuclear South Entergy Operations Inc.
17265 River Road Killona, LA 70057
"~Entier Tel 504 739 6247 Fax 504 739 6698 kcook@entergy.com Kimberly S. Cook Director, Nuclear Safety Assurance Nuclear Safety Assurance Waterford 3 W3F1 -2006-0053 September 29, 2006 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Reply to Notice of Violation: EA-06-136 Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38
REFERENCE:
- 1. Letter from A. T. Howell (NRC) to J.E. Venable (Entergy) dated August 30, 2006, Waterford Steam Electric Station, Unit 3 - NRC Inspection Report 05000382/2006009 and Notice of Violation
Dear Sir or Madam:
In the referenced letter, the NRC documented two examples of a violation of 10 CFR 50.9 related to Waterford 3 reporting to the NRC inaccurate information associated with the NRC's Safety System Unavailability (SSU), High Pressure Injection and Residual Heat Removal, Performance Indicators ("PIs"). Entergy and the NRC have discussed this matter at length, and we accept the NRC Severity Level IV violation as the final resolution.
The reason for the violation of 10 CFR 50.9 is that Waterford 3 relied on complex technical analyses for reporting performance indicator data for Safety Injection (SI) train B and Containment Spray (CS) train B. However, the analyses provided by Waterford 3 did not fully recognize the potential application of differing assumptions and conservatisms to bound the condition of past availability between November 11 of 2003 and September 11 of 2004.
The technical issue of concern was whether the as-found position of valve SI-602B would have prevented SI train B and CS train B from performing their intended safety functions. Waterford 3 in good faith completed an extensive analysis using engineering practices and procedures which indicated with reasonable assurance that these systems would have performed their intended safety functions during the time that valve SI-602B was not fully in the required "closed" position. Therefore, Waterford 3 continued to report the SI and CS systems as "available" during this time interval. The NRC's analysis concluded that the safety function was not adequately demonstrated which would therefore require reporting these systems as "unavailable".
W3FI-2006-0053 Page 2 Entergy understands and believes in our obligation to provide complete and accurate information to the NRC. Entergy places a high priority on promptly resolving technical differences with the staff.
Table 1 in Attachment 1 of this letter provides the pre-MSPI SSU unavailability values for Safety Injection and Containment Spray systems.
Pursuant to the provisions of 10 CFR 2.201, Entergy hereby submits the reply to the Notice of Violation. The reply is provided in Attachment 1 to this letter. The reply addresses (1) the reason for the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.
This submittal contains new.commitments that are identified in Attachment 2. If you have any questions or require additional information, please contact Robert Murillo at (504) 739-6715.
Sincerely, KSC/RJM/ssf Attachments: 1. Reply to Notice of Violation: EA-06-136
- 2. List of Regulatory Commitments
W3F1 -2006-0053 Page 3 cc: (w/Attachments)
Dr. Bruce S. Mallett Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Waterford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751 U.S. Nuclear Regulatory Commission Attn: Mr. Mel B. Fields MS O-7D1 Washington, DC 20555-0001 (w/o Attachment 2)
Wise, Carter, Child & Caraway ATTN: J. Smith P.O. Box 651 Jackson, MS 39205 Winston & Strawn ATTN: N.S. Reynolds 1700 K Street, NW Washington, DC 20006-3817 Morgan, Lewis & Bockius LLP ATTN: T.C. Poindexter 1111 Pennsylvania Avenue, NW Washington, DC 20004 Louisiana Department of Environmental Quality Office of Environmental Compliance Surveillance Division P. O. Box 4312 Baton Rouge, LA 70821-4312 American Nuclear Insurers 95 Glastonbury Blvd - Suite 300 Glastonbury, CT 06033-4443
Attachment I to W3FI-2006-0053 Reply to Notice of Violation, EA-06-136
Attachment 1 to W3F1 -2006-0053 Page 1 of 3 Reply to a Notice of Violation; EA-06-136 1.0 Restatement of Violation "During an NRC Inspection conducted on March 6 through May 11, 2006, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
10 CFR 50.9 requires, in part; 'Information provided to the Commission by a licensee shall be complete and accurate in all material respects.'
Contrary to the above, from approximately November 1, 2004, (when the licensee initially submitted the subject performance indicator information) to May 11, 2006, information provided to the Commission in the form of system unavailability statistics for the high pressure safety injection (Train B) and containment spray (Train B) systems was not complete and accurate in all material respects. The licensee significantly under-reported the unavailability hours for each train. This was material because the NRC used the information to determine its response (e.g., inspection) to the data.
This is a Severity Level IV violation (Supplement VII)."
2.0 Reason for the Violation The reason for the violation of 10 CFR 50.9 is that Waterford 3 relied on complex technical analyses for reporting performance indicator data for Safety Injection (SI) train B and Containment Spray (CS) train B. However, the analyses provided by Waterford 3 did not fully recognize the potential application of differing assumptions and conservatisms to bound the condition of past availability between November 11 of 2003 and September 11 of 2004.
The technical issue of concern was whether the as-found position of valve SI-602B would have prevented SI train B and CS train B from performing their intended safety functions. Waterford 3 in good faith completed an extensive analysis using engineering practices and procedures which indicated with reasonable assurance that these systems would have performed their intended safety functions during the time that valve SI-602B was not fully in the required "closed" position. Therefore, we continued to report the SI and CS systems as "available" during this time interval. Waterford 3 recognizes that we should have established more robustness in the methods, measurements, and analysis by employing more diversity and conservatism in establishing the valve as found position. The NRC's analysis concluded that the safety function was not adequately demonstrated which would therefore require reporting these systems as "unavailable".
Entergy understands and believes in our obligation to provide complete and accurate information to the NRC. Entergy places a high priority on promptly resolving technical differences with the staff.
Attachment 1 to W3FI-2006-0053 Page 2 of 3 3.0 Corrective Steps Taken and the Results Achieved The following are the corrective steps that have been taken and the results that have been achieved.
Upon discovery, Waterford 3 initiated Condition Report CR-WF3-2004-2847 on September 9, 2004. Valve SI 602B was returned to service on September 11, 2004.
Table 1 provides the pre-MSPI SSU unavailability values for SI and CS systems.
Table 1 1 PI System PI Color PI Transition Time PI Unavailability HPSI White 2003-Q4 2.6%2 HPSI Yellow 2004-Ql 7.0% 3 HPSI Red 2004-Q2 11.3% 4 CS White 12004-Q1 3.6%
CS Yellow 2004-Q2 5.8%
Notes:
The PI transition time is the initial quarter the PI would have transitioned to the given color. HPSI would have stayed red and CS would have stayed yellow until April 1, 2006 upon transition to MSPI.
2 NRC calculated unavailability value is 2.5%
3 NRC calculated unavailability value is 6.9%
4 NRC calculated unavailability value is 11.2%
4.0 Corrective Steps to be taken to Avoid Further Violations Waterford 3 will focus oversight to better ensure that complex performance indicator issues are promptly resolved and that performance indicator information is accurate and complete. Accordingly, Waterford 3 will implement the following enhancements:
a The Nuclear Safety Assurance Director will develop and administer a case study on this issue with the objective to reinforce to cognizant personnel lessons learned to ensure performance indicator issues are promptly resolved with bounding conservatism and are accurately and completely reported to the NRC.
b The Engineering Director will develop and administer a case study on this issue with the objective to reinforce to engineering site supervision lessons learned to ensure robustness, conservatism, and diversity in the methods employed to determine component status for safety system readiness.
to W3F1-2006-0053 Page 3 of 3 c The Licensing Manager will conduct training for selected Waterford 3 personnel on the Reactor Oversight Process per RIS 2006-13.
d The Manager, Corrective Actions and Assessments, will conduct a review of industry operating experience including NRC violations and Entergy Condition Reports in the last two years applicable to performance indicators and 10 CFR 50.9, and appropriate lessons learned will be communicated to personnel.
e Quality Assurance will perform an independent review of the reporting of Waterford 3 PIs for two consecutive quarters.
These enhancements will be completed by March 30, 2007, and the enhancements will be tracked for closure in the Waterford 3 Commitments Management System (CMS).
5.0 Date when Full Compliance will be Achieved Entergy is in full compliance with 10 CFR 50.9 with the submittal of this letter and the documentation of the SSU PI unavailability values.
Attachment 2 to W3FI -2006-0053 List of Regulatory Commitments
Attachment 2 to W3F1 -2006-0053 Page 1 of I List of Regulatory Commitments The following identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
One Time Commitment:
Waterford 3 will implement the following enhancements:
a The Nuclear Safety Assurance Director will develop and administer a case study on this issue with the objective to reinforce to cognizant personnel lessons learned to ensure performance indicator issues are promptly resolved with bounding conservatism and are accurately and completely reported to the NRC.
b The Engineering Director will develop and administer a case study on this issue with the objective to reinforce to engineering site supervision lessons learned to ensure robustness, conservatism, and diversity in the methods employed to determine component status for safety system readiness.
o The Licensing Manager will conduct training for selected Waterford 3 personnel on the Reactor Oversight Process per RIS 2006-13.
d The Manager, Corrective Actions and Assessments, will conduct a review of industry operating experience including NRC violations and Entergy Condition Reports in the last two years applicable to performance indicators and 10 CFR 50.9, and appropriate lessons learned will be communicated to personnel.
e Quality Assurance will perform an independent review of the reporting of Waterford 3 PIs for two consecutive quarters.
These enhancements will be completed by March 30, 2007, and the enhancements will be tracked for closure in the Waterford 3 Commitments Management System (CMS).