W3F1-2019-0045, Updated Reply to a Notice of Violation; NRC Inspection Report 05000382/2018008

Updated Reply to a Notice of Violation; NRC Inspection Report 05000382/2018008

ML19171A426
Person / Time
Site:	Waterford
Issue date:	06/20/2019
From:	Wood P Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation, NRC Region 4
References
W3F1-2019-0045 IR 2018008
Download: ML19171A426 (8)

Text

Entergy Operations, Inc.

17265 River Road Killona, LA 70057-3093 Tel (504) 464-3786 Paul Wood Manager, Regulatory Assurance 10 CFR 2.201 W3F1-2019-0045 June 20, 2019 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Updated Reply to a Notice of Violation; NRC Inspection Report 05000382/2018008 Waterford Steam Electric Station, Unit 3 (Waterford 3)

NRC Docket No. 50-382 Renewed Facility Operating License No. NPF-38 In Reference 1, the NRC transmitted a Notice of Violation to Entergy Operations, Inc.

(Entergy). The Notice of Violation was associated with a failure to review and accept, reject, repair or rework nonconforming items in accordance with documented procedures. provides Entergy's updated response to the Notice of Violation. The reason for this update is that discoveries made during testing have necessitated expanding the scope of the corrective actions. This information is provided in accordance with the provisions of 10 CFR 2.201.

This letter contains one new regulatory commitment.

Should you have any questions regarding this letter, please contact the Regulatory Assurance Manager, Paul Wood, at (504) 464-3786.

Rpectfu.lly,

' .._..\ _,l '

tJ <f('.)u(

Paul I. Wood PIW/rrd

W3F1-2019-0045 Page 2 of 2 Attachments: 1. Updated Reply to Notice of Violation, NRC Inspection Report 05000382/2018008

2. List of Regulatory Commitments

References:

1. NRC Letter to Entergy, "Waterford Steam Electric Station, Unit 3 - NRC Problem Identification and Resolution Inspection Report 05000382/2018008 and Notice of Violation," (ADAMS Accession Number ML18319A379), dated November 15, 2018

2. Entergy Letter to NRC, "Reply to a Notice of Violation; NRC Inspection Report 05000382/2018008," (ADAMS Accession Number ML18348B003),

dated December 14, 2018 cc: NRC Region IV Regional Administrator NRC Senior Resident Inspector - Waterford Steam Electric Station, Unit 3 NRR Project Manager

ATTACHMENT 1 W3F1-2019-0045 Entergy Operations, Inc.

Updated Reply to Notice of Violation, NRC Inspection Report 05000382/2018008

W3F1-2019-0045 Page 1 of 3 Entergy Operations, Inc.

Updated Reply to Notice of Violation, NRC Inspection Report 05000382/2018008 In U.S. Nuclear Regulatory Commission (NRC) letter to Entergy Operations, Inc. (Entergy)

"Waterford Steam Electric Station, Unit 3 - NRC Problem Identification and Resolution Inspection Report 05000382/2018008 and Notice of Violation," dated November 15, 2018 (ADAMS Accession Number ML18319A379), the NRC issued a Notice of Violation to Entergys Waterford Steam Electric Station, Unit 3 (Waterford 3).

Entergy concurs with the violation as cited in the Notice of Violation regarding the failure to review and accept, reject, repair or rework nonconforming items in accordance with documented procedures.

In accordance with the provisions of 10 CFR 2.201, this attachment provides Entergy's reply to the Notice of Violation.

Description of Violation Violation During a NRC inspection conducted September 17 through October 4, 2018, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:

10 CFR Part 50, Appendix B, Criterion XV, requires, in part, that nonconforming items shall be reviewed and accepted, rejected, repaired or reworked in accordance with documented procedures.

Contrary to the above, in May 2016, the licensee failed to review and accept, reject, repair or rework nonconforming items in accordance with documented procedures. Specifically, following receipt of information from Electroswitch that a number of basic components within relays and switches did not conform to quality requirements, the licensee failed to dedicate these commercial-grade parts as described in 10 CFR Part 21.

This violation is associated with a Green significance determination process finding.

End of Violation Reason for the Violation Entergy personnel did not adequately follow procedure EN-LI-102, "Corrective Action Program" resulting in a failure to properly review and accept, reject, repair or rework nonconforming items.

W3F1-2019-0045 Page 2 of 3 Corrective Steps That Have Been Taken and the Results Achieved The identified condition was entered into Entergy's corrective action program. A review was completed to identify installed Electroswitch relays and switches that are affected by this condition. The condition did not adversely affect the operation of any installed plant components nor did it result in a loss of a safety-related function. Entergy has also developed a corrective action plan to address the violation and to correct the nonconforming condition.

These corrective actions have been entered into Entergy's corrective action program. The corrective steps that will be taken are provided below.

Action 1: Obtain appropriate test specimens. A sample of six switch assemblies, one from each design family at Waterford 3, was selected.

Action 2: Develop validation testing plans for each of the different Electroswitch switch and relay family types installed at Waterford 3. Validation testing plan was developed based on commercial grade dedication testing requirements for future procurement from Electroswitch.

Action 3: Perform validation testing. During validation testing of securing rods harvested from the sample population by a third party vendor laboratory, three of the securing rods were identified as not meeting Electroswitch material specification requirements. Functional validation and seismic testing were successful on all samples.

Action 4: Former Action 5 - Completed an Adverse Condition Analysis (ACA) to determine cause and identify actions required to correct the condition. This ACA included analysis of the identified cross cutter, Problem Identification and Resolution (P.2),

and the actions needed to address it. Additional actions identified by the ACA were added to the corrective action plan.

Corrective Steps That Will Be Taken The discovery of the non-conforming materials used in the securing rods (identified during performance of Action 3) has resulted in an expanded scope of testing. A search will be conducted to determine the scope of material differences within the families that were found to have the material discrepancy. Any additional material non-conformances discovered will have the securing rods harvested from those switches and will be subjected to the same material verification testing. Action 5 has been added to the corrective action plan.

The following Actions will be completed:

Action 5: Perform expanded scope validation testing.

Action 6: Former Action 4 - Determine appropriate disposition of results. Document the validation testing in an approved Engineering Change evaluation.

W3F1-2019-0045 Page 3 of 3 Date When Full Compliance Will Be Achieved Waterford 3 will be in full compliance by November 15, 2019.

ATTACHMENT 2 to W3F1-2019-0045 List of Regulatory Commitments

W3F1-2019-0045 Page 1 of 1 Attachment 2 List of Regulatory Commitments This table identifies actions discussed in this letter for which Entergy commits to perform.

Any other actions discussed in this submittal are described for the NRCs information and are not commitments.

TYPE (Check one) SCHEDULED COMMITMENT COMPLETION ONE-TIME CONTINUING DATE (If Required)

ACTION COMPLIANCE Waterford 3 will be in full compliance with 10 CFR Part 50, Appendix B, x November 15, 2019 Criterion XV.