|
---|
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
[Table view] |
Text
Entergy Operations, Inc.
17265 River Road kEn tergy Killona, LA 70057-3093 Tel 504 739 6685 Fax 504 739 6698 jjarrel@entergy.com John P. Jarrell III Managr, Regulatory Assurance Waterford 3 W3F1-2013-0072 10 CFR 2.201 December 18, 2013 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
Subject:
Reply to a Notice of Violation: EA-12-257 Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38
Reference:
- 1) NRC letter to Entergy Operations, Inc. "Waterford Steam Electric Station, Unit 3 - NRC Integrated Inspection Report 05000382/2013004," dated November 20, 2013 (ADAMS Accession No. ML113324B1 33)
Dear Sir or Madam:
In reference 1, the U.S. Nuclear Regulatory Commission (NRC) issued Notice of Violation EA-12-257 to Entergy Operations' Waterford Steam Electric Station, Unit 3 (Waterford 3).
Pursuant to the provisions of 10 CFR 2.201, Attachment 1 provides Waterford 3's reply to Notice of Violation EA-12-257.
This letter contains no new commitments.
If you have any questions or require additional information, please contact the Regulatory Assurance Manager, John Jarrell, at (504) 739-6685.
Sin(
JPJ/RJl
Attachment:
Reply to Notice of Violation: EA-1 2-257
W3F1-2013-0072 Page 2 cc: Mr. Marc L. Dapas RidsRgn4MailCenter@nrc.gov Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 E. Lamar Blvd.
Arlington, TX 76011-4511 NRC Senior Resident Inspector Marlone.Davis@nrc.gov Waterford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751 U. S. Nuclear Regulatory Commission Kaly.Kalyanam@nrc.gov Attn: Mr. N. Kalyanam Mail Stop O-07D1 Washington, DC 20555-0001
Attachment to W3FI-2013-0072 Reply to Notice of Violation: EA-12-257
Attachment to W3F1-2013-0072 Page 1 of 3 Reply to Notice of Violation EA-12-257 In U.S. Nuclear Regulatory Commission (NRC) letter to Entergy Operations, Inc. "Waterford Steam Electric Station, Unit 3 - NRC Integrated Inspection Report 05000382/2013004," dated November 20, 2013 (ADAMS Accession No. ML13324B1333), the NRC issued Notice of Violation EA-12-257 to Entergy Operations' Waterford Steam Electric Station, Unit 3 (Waterford 3).
Pursuant to the provisions of 10 CFR 2.201, this enclosure provides Waterford 3's reply to Notice of Violation EA-1 2-257.
Description of Violation Violation Title 10 CFR, Part 21.21(a)(1) requires, in part, that entities subject to the regulations in this part shall evaluate deviations and failures to comply to identify defects associated with substantial safety hazards as soon as practicable, and except as provided in paragraph (a)(2) of this section, in all cases within 60 days of discovery, in order to identify a reportable defect that could create a substantial safety hazard, were it to remain uncorrected.
Title 10 CFR, Part 21.21 (a)(2) requires, in part, that entities subject to the regulations in the part shall ensure that if an evaluation of identified deviation or failure to comply potentially associated with a substantial safety hazard cannot be completed within 60 days from discovery of the deviation or failure to comply, an interim report is prepared and submitted to the Commission. The interim report must be submitted in writing within 60 days of discovery of the deviation of failure to comply.
Contrary to the above, from December 14, 2008 to April 29, 2010, the licensee failed to evaluate deviations and failures to comply to identify defects associated with substantial safety hazards as soon as practicable and to submit a report or interim report within 60 days of its discovery, in order to identify a reportable defect or failure to comply that could create a substantial safety hazard, were it to remain uncorrected.
Specifically, on October 14, 2008, the licensee performed bench testing on an Agastat E7024PB relay with date code 0835 and noted that the relay had a loose terminal point. Two more relays were obtained from the warehouse; one of these also had a bad terminal point. On October 27, 2008, the licensee quarantined the remaining four relays in stock. Two of these quarantined relays were identified to have similarly deficient terminal points. The licensee identified these relays as "defective" and returned them to the manufacturer, for cause evaluation. All four affected relays shared a date code of 0835. On January 28, 2009, the licensee received a report from the manufacturer, which did not provide a cause evaluation. On August 18, 2009, the licensee submitted Licensee Event Report 2009-003-00, (ML092310548).
This Licensee Event Report did not mention the date code 0835 relays or loose terminal points.
Rather, the Licensee Event Report described relays that failed due to incorrect adjustment of terminal blocks, a deviation different from that observed in the 0835 date code relays. On April 29, 2010, the licensee issued updated Licensee Event Report 2009003-01 (ML101230323).
This revision to the Licensee Event Report described loose terminal points on two spare date
Attachment to W3F1-2013-0072 Page 2 of 3 code 0835 relays as one of the defects identified in its Agastat E7024PB relays. The April 29, 2010, Licensee Event Report revision would have met Part 21 evaluation and reporting requirements, but it was 501 days late.
End of Violation This violation was issued as a Traditional Enforcement Violation due to its impact on the regulatory process. The violation was assessed as Severity Level IV in accordance with the NRC's Enforcement Policy because the affected components were already removed from service as part of an unrelated manufacturer's recall. Cross-cutting aspects are not assigned to traditional enforcement violations.
Inspection Report 05000382/2013004, that accompanies the Notice of Violation, provides additional insight, indicating that though the licensee's initial actions to have the vendor perform an evaluation may have been appropriate, it was the licensee's responsibility and obligation under Part 21 to complete such an evaluation within 60 days of the initial discovery, or issue an interim report within 60 days of the initial discovery. The initial LER or Part 21 report should have been made in December 2008 (60 days after the date of discovery in October 2008).
However, the Part 21 report that describes relay 0835 was made approximately 16 months later (April 2010). In April 2010, the licensee issued an updated LER 2009-003-01 (ML101230323).
This revision discussed relay 0835 and listed loose terminal points on two spare relays as a Part 21 reportable defect.
Reason for the Violation The apparent cause for the violation described above is that Waterford 3 did not implement an effective process to meet its responsibility and obligation under Part 21 to complete an evaluation to identify a reportable condition. Instead, Waterford 3 requested the component's supplier to perform the Part 21 evaluation. This was manifested in the following issues:
Procedural guidance in use at the time did not give specific responsibility to a site organization for ownership of the component failure analysis to ensure it was driven to completion.
At the time, it is believed there was a misconception that the vendor was primarily responsible for performing Part 21 evaluations for material that had not been installed in the plant. It is also believed there was a misconception that material with manufacturing issues that were not actually installed in the plant inherently did not pose an identifiable substantial safety hazard.
With the inadequate procedural guidance and process misconceptions discussed above, the corrective action tracking a review of the reportability for CR-WF3-2008-4782 was inappropriately closed on December 17, 2008. The closure stated "Licensing revisited reportability review and determined condition not reportable pursuant to 10CFR21. Degraded parts were not used in plant and Supplier QA Vendor CR review tracking potential manufacturer Part 21 issue."
Additionally, the vendor had determined that there was no Part 21 report required for the 0835 relays based on their evaluation dated April 24, 2009. This determination was communicated to Entergy Corporate Supplier QA where the response was accepted without further processing or review by the licensee, Waterford 3.
Attachment to W3F1 -2013-0072 Page 3 of 3 Corrective Steps That Have Been Taken and the Results Achieved An Entergy Fleet procedure EN-LI-1 08-01, 10 CFR 21 Evaluations and Reporting was issued on September 23, 2010 that replaced the procedures in use at the time. This procedure establishes specific responsibilities for ownership of 10 CFR 21 Evaluations that maintains ownership with the licensee, Waterford 3 and requires evaluation of parts not installed in the plant. The procedure is effectively controlling Waterford 3's ownership of Part 21 evaluations.
Waterford 3 Licensee Event Report 2009-003-01 (ML101230323) submitted the Part 21 information associated with the loose terminals on the Agastat E7024PB relays with date code 0835. This LER was closed in NRC inspection report 05000382/2011004 (ML113180605).
Agastat E7024PB relays with date code 0835 have been removed from the plant and are no longer available for use at Waterford 3.
Corrective Steps That Will Be Taken No additional corrective action is needed to address this violation.
Date When Full Compliance Will Be Achieved Waterford 3 is currently in full compliance with Title 10 CFR, Parts 21.21(a)(1) and 21.21(a)(2).