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| {{Adams | | {{Adams |
| | number = ML20217K888 | | | number = ML20202D435 |
| | issue date = 10/23/1997 | | | issue date = 12/03/1997 |
| | title = Insp Rept 50-382/97-17 on 970929-1003.Violations Noted. Major Areas Inspected:Licensed Operator Requalification Program Following Guidelines in Insp Procedure 71001, Licensed Operator Requalification Program Evaluation | | | title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/97-17.Reply Found to Be Responsive to NRC Concern About Emergency Operating Procedures |
| | author name = | | | author name = Pellet J |
| | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) | | | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| | addressee name = | | | addressee name = Dugger C |
| | addressee affiliation = | | | addressee affiliation = ENTERGY OPERATIONS, INC. |
| | docket = 05000382 | | | docket = 05000382 |
| | license number = | | | license number = |
| | contact person = | | | contact person = |
| | document report number = 50-382-97-17, NUDOCS 9710300105 | | | document report number = 50-382-97-17, NUDOCS 9712050023 |
| | package number = ML20217K868 | | | title reference date = 11-24-1997 |
| | document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | | | document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE |
| | page count = 14 | | | page count = 6 |
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| - ENCLOSURE 2 ;
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| l U.S. NUCLEAR REGULATORY COMMISSION
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| | /p?'*'Out,k_. . - NUCLEAR REGULATORY COMMISSICN , |
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| | !* I REotoN IV - |
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| | - ARLINGTON. TEXAS 76011 8064 |
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| | December 3,1997 |
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| | Charles M. Dugger, Vice President . |
| | Operations - Waterford 3 Entergy Operations, Inc. |
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| | - P.O. Box B Killona, Louisiana 70066 a SUBJECT: NRC INSPECTION REPORT 50-382/9717 |
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| | ==Dear Mr. Dugger:== |
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| | Thank you for your letter of November 24; 1997, in response to our letter and Notice of Vi >Iation dated October 23,1997, We have reviewed your reply and find it responsive to our concern about emergency operating procedures raised in our Notice of Violation. We wili review the implementation of your ccrrective actions during a future inspection to determine that full r |
| | compliance has been achieved and will be maintained. |
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| ==REGION IV==
| | Sincerely, hGJohn L. Pellet, Chief Operations Branch Division of Reactor Safety Docket'No.: 50-382 / |
| Docket No.: 50-382 License No.: NPF 38 | | License No.: NPF 38 l |
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| | Executive Vice President and Chief Operating Officer / |
| | Entergy Operations. Inc. |
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| Report No.: _ _50-382/97-17
| | P.O. Box 31995 Jackson. Mississi.o pi 39286 1995 9712050023 971203 7 PDR ADOCK 05000302 0 pg . |
| - Licensee: Entergy Operations, In Facility: Waterford Steam Electric Station, Unit 3 Location: Hwy.18 Killona, Louisiana Dates: September 29 through October 3,1997
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| Inspectors: Ryan Lantz, Reactor Engineer, Operations Branch Tom _McKernon, Reactor Engineer, Operations Branch Approved By: John Pellet, Chief, Operations Branch
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| _ ATTACHMENT: _ Supplemental Information 9710300105 971023 PDR 8 ADOCK 05000382 PM
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| EXECUTIVE SUMMARY Waterford Steam Electric Station, Unit 7 NRC Inspection Report 50 382/97-1~
| | P.O. Box 31995 Jackson, Mississippi 39286-1995- - |
| This inspection inc!uded a review of the licensed operator requalification program following the guidelines in inspection Procedure 71001, " Licensed Operator Requalification Program Evaluation."
| | t Wise, Carter, Child & Caraway P.O. Box 651 Jackson, Mississippi 39205 General Manager, Plant Operations . - |
| | Waterford 3 SES Entergy Operations, Inc. |
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| Q0erations The facility's annual operating test for licensed operator requalification during the inspection period was administered September 29 and 30. The biennial comprehensive requalification written examination was administered on October 2. Inspection results are as follows:
| | P.O. Box B Killona, Louisiana 70066 Manager Licensing Manager ' |
| * Severalimprovements were noted in the licensed operator requalification progra The most significant changes required operations management to observe and evaluate licensed operator training and improved the quality of training review group meetings and program feedback (Sections 05.1 and 05.4).
| | Waterford 3 SES Entergy Operations, Inc. |
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| * The licensed operator requalification facility examiners administered and evaluated 3 the examinations professionally. The inspectors concurred with the facility evaluations (Section 05.1).
| | P.O. Box B Killona, Louisiana 70066 |
| | , Chairman Louisiana Public Service Commission |
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| | One American Place, Suite 1630 Baton Rouge, Louisiana 70825-1697 Director, Nuctsar Safety & .. |
| | Regulatory Affairs Waterford 3 SES Entergy Operations, Inc. |
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| * Requalification examinations and remedial examinations were comprehensive, discriminated at the appropriate level, and were responsive to identified weaknesses (Sections 05.2 and 05.3).
| | P.O. Box B Killona, Louisiana 70066 William H.-Spell, Administrator lo 'isiana Radiation Protection Division P.O. Box 82135 ' |
| | Baton Rouge, Louisiana 70884-2135 Parish President St Charles Parish-P.O. Box 302 - |
| | Hahnville; Louisiana --70057 |
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| * Overall, the licensed operator requalification training program effectively implemented a systems approach to training (Section 05.4). | | - |
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| * Licensed operator requalificr/ ion f acility audits were comprehensive, self-crit l cal, and identified areas for potential improvement (Section 07.1).
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| | - Mr. William A. Cross - |
| | . Bethesda Licensing Office- |
| | ' 3 Metro Center Suite 610 i |
| | - Bethesda, Maryland 20814 - - |
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| | -Winston & Strawn - ; |
| | - .1400 L Street, N.W. |
| | :. Washington, D.C. 20005-3502 - , |
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| * Two instances were noted where operators were challenged by proceoures. For instance, one f ailure to maintain the emergency operating procedures as required by Technical Specifications resulted in a violation (Section 04.1).
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| * Good operator performance was observed in all aspects of the examination with some significant exceptions noted. All operators participating in the licensed operator requalification tests passed their evaluated examinations (Section 05.1).
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| Three-legged communications, procedure use, and peer checks were noted strengths (Section 04.1).
| | Entergy Operations, Inc. -4-E-Mail report to T. Frye (TJF) - |
| | E-Mail report to T. Hiltz (TGH)- |
| | E-Mail report to NRR Event Tracking System (IPAS) . |
| | E Mail report to Document Control Desk (DOCDESK) |
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| | bec to DCD ('E01)(IE42) |
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| Weaknesses were observed in crew direction and oversight on the part of senior operators in the control room supervisor position (Section 04.1).
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| | DRS Director DRS Deputy Director DRP Director DRS-PSB |
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| | , - Branch Chief (DRP/D) MIS System i Project Engineer (DRP/D) RIV File Branch Chief (DRP/TSS) i |
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| Reoort Details Summarv of Plant Status The f acility_was at 100 porcent power for the duration of the inspection, and all observations were conducted during the day shift, coincident with conduct of the walkthrough examinations, l. Onorations 01- ' Conduct of Operations-01.1 General Observations Insoection Scoce During the in plant' task walkthrough section of the examinations,-the oxaminars observed the on-shift operators during routine operations of the f acility, Observations and Findinas The on shif t crews exhibited professional demeanor and the senior operators m'aintained a position of crew direction and oversight. Shift operators were professional and aware of current plant evolutions and work in progress, Conclusions .
| | 4 DOCUMENT NAME: R:\_WAT\WT717ak.jlp To receive copy of document. Indicate in box:"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy |
| The control room staff exhibited professionalism and good awareness of work in progres _04 _ Operator Knowledge and Performance 04.1 Ooerator Performance on Annual Reaualification Examinations
| | ;- C:OB 0, JLPELLET /)?/ |
| - insoection Scooe (71001)
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| The inspectors observed the performance of two crews, one shif t and one staf f, of-licensed operators during the dynamic simulator and job performance measure portions of the annual requalification operating examinatio [o
| | , OFFICIAL RECORD COPY |
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| -5-b. Observatioris and Findinos The crews in the dynamic simulator consisted of two reactor operators, two senior operators, and one shift engineer who acted as the shift technical adviser. Each licensed operator was administered five job performance measures and participated in two dynamic simulator scenarios. The inspectors observed the licensee staff administer the dynamic simulator scenarios and some job performance measure The inspectors observed generally good examinee performance during the job performance measure section of the operating tes During the dynamic simulator and job performance measure portions of the examination, the inspectors observed the following generic behaviors among the operato s:
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| * Three-legged communications, procedure usage, and peer checks were noted strength * Although adequate, operators in the control room supervisor position displayed waak direction and oversight of crew activities. In each case, the observed weakness was compensated for by other crew member * The staff crew was weak in sharing information, which significantly challanged their ability to perform a prompt diagnosis of plant condition The operators have adopted three-way communications as a natural and expected practice. The inspectors observed consistent use of this method among control room operators a; well as with other technicians or managemenit outside of the control roo The inspectors observed consistent and generally apptcpriate use of alarm response procedures, abnormal operating procedures, and the emergency operating proceduret. Two challenges to the operators were noted in procedural guidance; one in response to a secondary system leak, such as feedwater, into the containment, and another in the interpretation of conditions required to meet the containment isolation safety function. Given clear indications of a feedwater leak inside containment, both crews entered the abnormal operating procedure for a reactor coolant system leak, which only provided guidance to confirm a reactor coolant leak was not in progress. Neither crew entered the procedure for abnormal steam generator water level control, which was more appropriate and provided more effective guidance for the feedwater leak. Additionally, one crew f ailed to recognize the indications for a feedwater break inside containment until post-emergency operating procedure entry formal diagnosis was conducte I | | . - . . _ _ _ . . . . _m |
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| | Entergy Operations, Inc. -4-E-Mai! report to T. Frye (TJF) |
| | E Mail report to T. Hiltz (TGH) |
| | E-Mail report to NRR Event Tracking System (IPAS) |
| | E-Mail report to Document Control Desk (DOCDESK) |
| | bec to DCD (IE21)(ik2)- |
| | L bec distrib, by RIV: |
| | Regional Administrator Resident inspector DRS Director DRS Deputy Director DRP Director DRS-PSB Branch Chief (DRP/D) MIS System Project Engineer (DRP/D) RIV File Branch Chief (DPP/TSS) |
| | DOCUMENT NAME: R:\_WAT\WT717ak.jlp To receive copy of document, indicate in box:"C" = Copy without enclosures "E" a Copy wdh enclosures "N" = No copy |
| | '' C:OB 0, l l JLPELLET Q}/ |
| | 12/$/97 |
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| | Ec-01-of 18:40 'Fros:ENTERGY QPERATICNS 5047396t90 T-350 P.02/0 JoH l4 |
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| 6-One crew f ailed to close Containment Spray isolation Valves CS125A(B) following a manually initiated containment isolation and spray actuation, with f ailure of the containment spray pumps to properly operate. The operators also, subsequently and erroneously, declared the containment isolation safety function to be satisfie The guidance for closure of these valves to meet the containment isolation safety function was provided in Emergency Plan Procedure EP-002100, "TSC Activation, Operation, and Deactivation," however, this procedure was not referenced by tSe operators prior to TSC activation and manning, and no additional guidance was provided in the emergency operating procedures to ensure the containment spray containment isolation valves were closed given the above conditions. The licensee had modified these valves during the past outage to allow overriding the permissive signal for closure, but had not revised the emergency operating procedure The inspectors considered this condition as a violation of Technical Specifications 6.8.1.a for a f ailure to maintain the emergency operating procedures (50-382/9717-01).
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| | W3F1-97-0260 A4.05 PR l |
| | November 24,1997 U.S. Nuclear Regulatory Commission , |
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| | ATTN: Document Control Desk Washington, D.C. 20555 Subject: Waterford 3 SES Docket No. 50-382 , |
| | License No. NPF-38 NRC Inspection Report 50-382/97-17 Reply to Notice of Violation Gentlemen-In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submns in Attachment 1 the response to the violatica identified in Enclosure 1 of the sut' ject inspection Report. |
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| | if you have any questions concoming this response, please contact me at (504) 739-8242 or T.J. Gaudet at (504) 739-6666. |
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| Additionally, the senior operators in the control room supervisor positions had to be prompted in several instances by the board operators or the shif t supervisor to provide specific, timely direction to the crew. One contral room supervisor gave several broad scope directions, such as, " perform a rapid down power," without providing pertinent limitations or procedural references. The board operators compensated by adding the specific limitations on rate and procedural reference in the repeat back communication, which the control room supervisor acknowledged as conect. Both crews' control room supervisors required prompting by the shift supervisor to initiate the required actions in several instances. For example, one control room supervisor was directed to perform a crew brief then conduct a rapid shutdown. Following the brief, the control room supervisor hesitated, then sought the shift supervisor's concurrence to begin the shutdown, in another instance, the control room supervisor was procedurally guided to start a low pressure safety injection pump to meet containment temperature / pressure safety function success path criteria. The control room surervisor again sought the shift supervisor's permission to initiate low pressure safety injection instead of first performing the action, then informing the shift supervisor, Conclusions Operators exhibited general! _ cod knowledge and ability in all aspects of the requalification examination? Three-way communications, peer checking, and procedural usage were not i strengths. Crew direction and oversight was effective, although challenged by observed control room supervisor weaknesses. Procedures were observed to challenge the crews' timely and effective diagnosis of plant condition h.
| | Very truly yours, |
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| | E.C. Ewing Director, Nuclear Safety & Regulatory Affairs ECE/OPPlasf |
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| | cc: E.W. Merschoff (NRC Region IV), C.P. Patel (NRC-NRR), |
| | J. Smith, N.B. Reynoide, NRC Restdont Ins.pectors Office |
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| [ Operator Training c.d Qualification 0 ReauaP'. cation Examination Administration Insoection Scoce (710011
| | DEC-01-Ifc13:40 - Fros:tRTERGY GPERAT40Mt 50478tC680 T458 P.03/05 Job-ll4 ' |
| - The inspectors observed the administration of all aspects of the requalification examination to determine the evaluators' ability to administer an examination and assess adequate performance through measurable criteria. The inspectors conducted interviews to determine the knowledge level of the managers, supervisors, and instructors with regard to the requalification program implementation. The inspectors also observed the fidelity of the plant simulator to support training and examination administratio Observations and FindiDSS Six training staff evaluators were observed administering the examinations, including preexamination briefings, observations of operator performance, individual and group | | .- . |
| , evaluations of observations, techniques for job performance measure cuing, and final ,
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| evaluation documentation. The evaluators conducted the examinations professionally, with no inadvertent cuing, and were thorough in their documentation of observed weaknesses and areas for improvement. The inspectors also noted that the timing of the malfunctions during the dynamic simulator evaluations enabled evaluation of senior operator competencies, such as crew direction and oversight,
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| - and ability to prioritize and integrate plant status. The plant simulator fidelity supported the examinations and no fidelity issues were observe '
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| The inspectors observed the post scenario crew evaluation process. The evaluations were led by the designated lead examiner, with the operations manager participating in the evaluation. Each of the examiners participated in discussions of event observations, and strengths and weaknesses observed. The operations manager provided immediate operations feedback for expectations, as well as, an independent observation of crew actions. The inspectors noted that the involvement of an operations department representative in examination observations and evaluations was a significant strength of the training program, and although not formally documented in program requirements, revisions were in the approval process to make the operations evaluation involvement a requirement of the licensed operator training progra The evaluators passed all of the operators on all portions of the examinations. The inspectors concurred with the f acility evaluation F}
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| | NRC Inspection Report 97-17 RepW to Notice of Violation W3F197 0260 l |
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| | l Novemoor 24,1997 oc: Mail:- : D.C. Hintz : (M-ECH46) , |
| | J.W Yelverton (M-ECH45) ~ l |
| | ! (W.G88-300) |
| | T.R. Leonard (W-MSB4-300) |
| | F.J. Drummond (W G85-305) ; |
| | A..l. Wrape (W-GSB-315) . |
| | G.D. Pierce - (W-ADM-686)- |
| | R.E. Allen (W-G88-102) |
| | B.E. Meyers (W-ADM-565) |
| | J.J. Zabritski . (W4M-567) , |
| | J.G. Hoffpauir (W-MSB4-336) |
| | J.G. Dewease (M-ECH46) - . |
| | L.F. Daughtery (GGNS - ADMILIC) |
| | S.J. Bethey - |
| | C.A. Bottomiller |
| | . T.W. Gates T.J. Goudet K. Godfrey C. Gunn |
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| | W.K.Hughey 4 IEA f R.J. King D.N. Lorfing J.M. Manzella D.C. Mims (ANO) |
| | R. Thomas bec: SRC Secretary - (W-GSB-102) |
| | T.J. Sibley _ (W-GSB-318) |
| | Waterford 3 Records Center (W-G08-100) , |
| | NRC Inspootion Report 97-17 Licensing Green Folder File c |
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| - Conclusions -
| | DEC-01*S? 13:40 Froa: ENTER 1Y QPERA? IONS 504?396698 T-358 P.04/05 h b-!$4 |
| -The f acility examiners administered and evaluated the requalification examinations professionally. - Operations management involvement in the observation and evaluation of dynamic simulator scenarior. was a noted strength. The inspectora concurred with the facility evaluation .2 Recualification Written Examinations insoection Scone (71001) ' | | |
| The inspectors reviewed the biennial comprehensive written examination that was-administered October 2,-1997. The examination was reviewed to evaluate its-
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| | ATTACHMENT 1 ENTERGY OPERATIONS. INC. RESPONS'i TO THE VIOLATION IDENTIFIED IN EMCLOSURE 1 OF INSPECTION REPORT 50-382/97-17 VIOt.ATION NO. 9717-01 Technical Specification 6.8.1.a states, in part that written procedures shall be established, implemented, and maintained covering emergency operating procedures. |
| validity and compliance with facility program requirements. The examinations were reviewed using guidance of NUREG 1021, " Operator Licensing Examiner Standards,"
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| for construction, scope of coverage, and cognitive leve Observations and Findinos The biennial examinatiori c',uestions tested at the appropriate level of comprehension and were linked to important leaming objectives. The questions were operationally oriented and realistic. The examinations were well structured and comprehensiv The inspectors noted that the sample plan for the biennial written examinations specifically identified senior reactor operator only questions. The inspectors reviewed the designated questions and agreed that they were senior reactor operator level questions, sampled appropriately from 10 CFR 55.43 items and met the program requirements as described in NTI-OP-004, " Examination / Quiz Development," Revirion 5, Section 5. Conclusions
| | Subprocedure V, " Containment Isolation,' of the licensee's Emergency Operating Procedure OP 902-008, Revision 10, contair,ed instructions necessary to satisfy the success path for the containment isolation safety function. |
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| 'The comprehensive biennial written requalification examinations administered by the facility were valid examinations, with appropriate scope, depth and cognitive leve l 9 .
| | The licensee had completed recent moditications to the plant, which pxmitted overriding a containment spray permissive signal to allow the operators to cicse Containment Spray Valves CS-125A(B) in order to isolate the containment and satisfy the safety function success path. |
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| -9-05.3 He. Qualification Annual Ooerating Test inmestfon Scone (71001)
| | Contrary to the above, written procedures were not maintained for en)ergency operating procedures in that the Itcenses failed to revise the Emergency Operating Procedure OP-902-008 following valve modifications to provide the operators with adequate instruction for closing Containment Spray Valves CS125A(B) to isolate the Containment. |
| The inspectors reviewed the annual operating test cdministered on September 29 and 30,1997. The inspectors used the guidance in NUilEG 1021 to determine the validity of the examinations to provide a basis for evaluating the examinee's knowledge of abnormal and emergency operating procedures and operation of plant systems. The inspectors also reviewed the licensee's administrative procedures for developing, administering, grading, and evaluating the examinations and conducted interviews with training management, instructors, evaluators, and examinees, Observations and Findings The licensee's training staff indicated that the guidelines of NUREG-1021 were substantially utilized for the development and edministration of the licensed operator requalification examination, in addition to the facility requalification training procedures. The licensee supplemented the guidance of NUREG-1021 with training instructions for the development, control, and cdministration of licensed operator requalification examinations and quizzes,2 year training plan development, makeup training, and remediation guidelines. The licensee's procedures were comprehensiv The job performance measures were in accordance with the guidance of NUREG-1021, contained performance standards that were clear and objective, and the critical task acceptance criteria were well defined and measurable. The scenarios were also developed using the guidance of NUREG 1021 and contained clearly stated objectives. The initial conditions of the scenarios were realistic and the scenarios consisted of related event The inspectors noted that a recent modif' cation to the plant involving the capability for remote closing of Containment Spray Containment Isolation Valves CS125A(B)
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| had been reviewed in training lectures, and was incorporated into the annual operating test dynamic simulator scenarios. However, the inspectors noted that, while t'.te design change package identified the emergency plan procedures for the technical support center requiring revision, it did not identify the emergency operating procedures. As such, the operators were required to rely upon memory and their training to close the valves rather than specific emergency operating procedure instructions. This condition was identified as a violation of regulatory requireinents and is further discussed in Section 04.1. Overall, dynamic simulator scenarios used during the requalification examination were adequately challenging and provided a good evaluative tool for operator competencie ,
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| | This is a Severity Level IV vielation (Supplement I) (50-382/9717-01). |
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| i-10- Conclusiorui The annuel operating examinations were comprehensive and discriminated at the appropriate leve .4. Review of Reaualification Prooram Guidance
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| ^ IDsoection Scone (71001)
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| The inspection determined the effectiveness of the methodology used to develop and construct the requalification examinations and to assess the effectiveness of the examinations to identify retraining needs and measure the examinees' subject knowledge. The inspectors utilized the guidance of NUREG-1220, " Training Review Criteria and Procedures," Revision 1, to evaluate the requalification program's ability to meet Elements 4 and 5 of a systems approach to training. This evaluation included review of the feedback tracking system and remedial training progra Observations and Findinas The inspectors reviewed the requalification program guidance and verified that it met and implemented the requirements of 10 CFR 55.59, "Requalification."
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| The inspectors noted that program guidance contained in NTC-108, " Licensed Operator Requalification," Revision 5, contained specific guidance for development and securi:y of examinations, post examination activities, removal from shift for f ailures of examinations, and remedial training of individuals. The inspectors also noted that the program was planned for revision to additionally require that any operator who f ailed a periodic cycle simulator quiz would also be removed from on shift licensed duties until completion of remediation. The inspectors reviewed three remedial training programs that had beta established for operators that failed a training cycle examination. The remedial programs focuseo on identified weaknesses and adequately retested the operators prior to returning them to licensed dutie The inspectors noted that additional program revisions were planned by the licensee to address recent audit and self-assessment findings. The most significant of these
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| . changes involved mandatory operations management participation in evaluated dynamic simulator crew examinations and quizzes, a modification of the instructor feedback mechanism, and a more defined requirement for training review group meeting attendance and frequency. Although none of these changes had been formally adopted into the program, they were in the process of being implemented and the governing procedures were being rev%e ,
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| | (1) Reason for the Violation Entergy attributes the violation to a combination of the inefficient location of procedural guidance and to the lack of clearly defined management expectations for Operations in this area. Entercy a0rees that appropriately located procedural guidance is needed to ensure the proper and appropriate operation of Containment Spray Valves (CS-125A(B)). The location of the procedural guidanca in an Emergency Planning Procedure (EP-002-100, Revision 25, Attachment 7.12) versus in an 5mergency Operating Procedure (OP-902-008) was a conscious decision, which had been reached after much deliberation. Waterford 3 is committed to meeting the strategies for Emergency Operating Procedures outlined in CEN-162, CE Emergency Operating Procedure Guidelines. The NRC approved the use of the strategies in CEN-152 Revisions 03 and 04. The strategies that CE recommends in the guidelines do not include specific steps to iriate containment in the case of equipment failure (e.g. a Containe.< ' Jpray Pump |
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| | DEC-C H T 18141 1Ftre:lNTERGY GPERAfl0M$ 50409808 Mll P.06/06 Job-494 l |
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| -: .Conclusiog , | | W3F1-97 0260 |
| . - The lice 1 sed operator requalification program effectively implemented a systems
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| approac h to training to identify operator performance and training weaknesses and *
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| modify the training and evaluation program to correct identified weaknesses.
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| 07 ~ Quality Assurance in Operr. tor Training
| | not running).7 The Safety Function Success Path for containment isolation in - |
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| | the Fundlunal Recovery Guideline (CEN-152) states to ensure an isolation |
| L .1 Review of Ooerations Quality Assurance Audits Insoection Scone (71001)
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| 'he inspectors reviewed the asults of Qualie, Assurance Audit SA 97-003.1,
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| " Performance, Training, and Qualification." dated August 21,1997, which included
| | valve is clossd for each containment penetration required to be closed. The |
| ; an audit of the licensed operator requalification program. The inspectors reviewed i additional audits of the licensed operator requalification program dated August 7 and t
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| September 3,1997, that were conducted by peer groups and outside organization ,
| | 1 Waterford 3 Safety Function Recovery Procedura (OP-902 008) states that et least one containment isolation valve must be closed for sech containment |
| c Qhsgivations and Findinas
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| ! The qur.fity assurance audit and the additional audits both utilized perso'nnel from
| | penetration not in usec The EOPs are written assuming that safety-equipreent s is operable and will perform its intended function. - To assume safety-related ! |
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| out:.ide the licensee's organization. All three audits were comprehensive and -
| | equipment failures in developing EOPs would drastically increase the volume - |
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| | c - of information necessary in the body of the E0Ps, thus potentially increasing - |
| critical, with items for improvement noted in the reports. Training requests were __
| | operator complication ar'd response time. Based on the above considerations, we have assessed that the procedural guidance would more appropriately ba located in a standard appendices to the EOPs rather than in ; |
| initiated and tracked regarding the identified areas for improvement, f' Conclusion The licensed operator requalification program audits were comprehensive, self-
| | ; the body of the EOPs. |
| - critical, and identified areu, for potential improvement, which were being
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| ~ incorporated by the licensee.
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| p . [V. Plant Sunopri -
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| F8- Miscellaneous Fire Protection issues
| | It should be noted that the NRC is currently evakating Entergy's position on the Containment Spray Containment isolation Vatves presentad at the Enforcement Conference held in Ariington, Texas on July 29,1997. Final |
| - F General Comments The inspectors observed general plant housekeeping incident to administration of the in plant job performance _section of the operating test. The f acility was reasonably
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| - clean and welllighted and the floors were clear and free from debris. The applicants | | resolution tan that issue la pending. Waterford 3 will address the results accordingly. . |
| < were conscientious to note discrepancies and inform the main control room.
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| | (2) Corrective Stans That Have Baan Takan and the Resulta Achieved |
| | ! Operating crews have been briefed on the violation scenario in various |
| | : Operations Department meetings and are awere of the current location of the subject procedural guidance and management's expectations in that regard. |
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| | (3) Corrar*ive Bi= = Which Will Be Taken to Avoid Further Violations ; |
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| | . Waterford 3 has plans to develop a standard appendices to the EOPs l wherein guidance will be included to provide dinction to the operators for i closing Containment Spray Valves CS 125A(B) with Containment Spray l Pumps not running. The Operator imining program will include training for l |
| | . the Operators on the new standard appendices. l |
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| | (4) Date When Full Compliance Will Be Achieved The EOP standard appendices will be completed by June 30,1996. |
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| | l Operations Training inclusion of the appendices in the treining program will l |
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| | be completed by August 31,'1998. , |
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| -12-V. Managsment Mee]]Dgs X1 Exit Meeting Summary The inspectore presented the inspection results to members of the licensee management and s;aff at the conclusion of the inspection on October 3,1997. The licensee acknowled0ed the findings presente The licensee did not identify as proprietary any intermetion or materials examined during the inspectio >
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| _ _ ATTACHMENT
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| - SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSCNS CONTACTED - | |
| Lingriten M. Brandon, Licensing Supervisor R. Burski, Director, Plant Modifications and Constructinn E. Ewing, Director, Nuclear Safety and Regulatory Aff airs R. Fletcher,- Operations Training Supervisor T. Gaudet, Licensing Manager J. Hoffpauir, Operations Manager S. Hymel, Licensed Operator Trainer
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| . R. Killian, Quality Engineering Supervisor
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| -- T. Leonard, General Manager, Plant Operations | |
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| J. Lewis, Emergency Planning Manager-
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| -J. O'Hern, Director, Training-
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| - O. Pipkins, Licensing Engineering W. Smith, Simulator Supervisor LIST OF INSPECTION PROCEDURES USED IP 71001 Licensed Operator Requalification Program Evaluation
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| -LIST OF ITEMS OPENED-Onened 50-382/9717-01.-- VIO Failure to maintain emergency operating procedures
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| PROCEDURES REVIEWED Trainina Audits
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| .- "Waterford Tieree Operations Assessment" September 3,1997
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| . -WESlRAIN Assessment "W3 Requalification Program" August 4-7,1997
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| . "W3 Quality Assurance Audit SA 97-003.1, Performance, Training and Qualification" August 21,199 ;
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| -2 Trainino Procedures
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| . NTP-006, " Control and Administration of Examinations," Revision 8, March 21, 1997
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| . NTC-108, " Licensed Operator Requahfication," Revision 5, September 27,1995
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| * NTI-OP-004, " Examination / Quiz Developmer.t," Revision 5
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| . NTI-OP-005, " Examination Administration," Revision 5
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| . NTI-OP-008, " Licensed Operator Requalification," Revision 2 Ooeratina Procedurej
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| . OP 901-201, " Steam Generator Level Control System Malfunction"
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| . OP 500 012, Revision 12, Annunciator Response Procedure for L20 " Containment Water Leakage Hi"
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| . OP 902-008. Revision 10 " Safety Function Recovery Procedure" Other Documentation
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| . Condition Reports: 96-0281, 97-0770, 0771,-0781,-0812,-1702,-2381
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217L0421999-10-21021 October 1999 Forwards Insp Rept 50-382/99-20 on 990815-0925 & Notice of Violation.Two Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20217N2111999-10-19019 October 1999 Forwards Insp Rept 50-382/99-14 on 990913-17 & 1004-08.No Violations Noted.Licensed Operator Requalification Program, Effective,Utilized Systems Approach to Training & Showed Continued Improvements Over Previous Insp Findings ML20217L0101999-10-18018 October 1999 Provides Update of Waterford 3 Effort for Review of Ufsar. Info Listed Includes Background Mgt Expectations,Review Status & Results,Clarifications Re Review & Conclusions ML20217L0141999-10-18018 October 1999 Submits Update to NRC Staff Re Circumstances & Plans for Submitting Certification Rept on Waterford 3 Plant Specific Simulator ML20217G7051999-10-14014 October 1999 Forwards Comments on Four of NRC RO Examination Questions for Exam Administered During Week of 991004 05000382/LER-1999-014, Forwards LER 99-014-00,providing Details of Reactor Shutdown Due to Loss of RCP Controlled bleed-off Flow.Attached Commitment Identification/Voluntary Enhancement Form Identifies All Commitments Contained in Submittal1999-10-12012 October 1999 Forwards LER 99-014-00,providing Details of Reactor Shutdown Due to Loss of RCP Controlled bleed-off Flow.Attached Commitment Identification/Voluntary Enhancement Form Identifies All Commitments Contained in Submittal ML20217D5151999-10-0707 October 1999 Forwards Application for Renewal of SRO License for C Fugate License SOP-43039-3,IAW 10CFR55.57.Without Encls ML20217C6251999-10-0505 October 1999 Informs That NRC Reviewed Util Ltr & Encl Exercise Scenario Package for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Based on Review,Nrc Determined That Exercise Appropriate to Meet Objectives ML20212J6921999-09-29029 September 1999 Forwards Insp Rept 50-382/99-18 on 990830-0902.One Noncited Violation Identified Re Failure to Follow Procedural Instructions to Ensure That Members on Fire Brigade Shift Were Qualified ML20216G2441999-09-27027 September 1999 Forwards Insp Rept 50-382/99-19 on 990830-0903.No Violations Noted 05000382/LER-1999-013, Forwards LER 99-013-00,providing Details of Exceeding TS Limits for RCS Cooldown Rates.All Commitments Contained in Submittal Are Identified on Encl Commitment Identification/ Voluntary Enhancement Form1999-09-23023 September 1999 Forwards LER 99-013-00,providing Details of Exceeding TS Limits for RCS Cooldown Rates.All Commitments Contained in Submittal Are Identified on Encl Commitment Identification/ Voluntary Enhancement Form IR 05000382/19993011999-09-21021 September 1999 Informs That NRC License Exam Previously Associated with NRC Insp Rept 50-382/99-301 Will Be Incorporated Into NRC Insp Rept 50-382/99-14 ML20212D8761999-09-16016 September 1999 Informs That on 990818,NRC Staff Completed Midcycle PPR of Waterford 3.During Assessment Period,Number of Personnel Errors Occurred,Which Demonstrated Lack of Attention to Detail by Plant Personnel.Historical Listing of Issues,Encl ML20212C2471999-09-16016 September 1999 Forwards Five Final Applications for RO Licenses for G Esquival,Jm Hearn,Md Lawson,Re Simpson & PI Wood.Written Exam & Operating Test to Be Administered,Is Requested. Encls Withheld ML20212C2391999-09-16016 September 1999 Requests Cancellation of SRO Licenses for Bn Coble,License SOP-43835,due to Job Assignment Location & CA Rodgers, License SOP-43537-1,due to Resignation from Company, Effective 990901 ML20212C5881999-09-14014 September 1999 Forwards Insp Rept 50-382/99-15 on 990719-23 with Continuing in Ofc Insp Until 0819.No Violations Noted ML20211Q4421999-09-0909 September 1999 Forwards Insp Rept 50-382/99-07 on 990601-11.Three Violations Being Treated as Noncited Violations ML20211P4121999-09-0707 September 1999 Requests NRC Staff Review & Approval of Integrated Nuclear Security Plan (Insp) & Integrated Security Training & Qualification Plan (Ist&Q), for Use by All Entergy Operations,Inc.Encl Withheld,Per 10CFR2.790(d) ML20211M8391999-09-0303 September 1999 Forwards Revised Epips,Including Rev 25 to EP-001-020,rev 24 to EP-001-030,rev 25 to EP-001-040,rev 30 to EP-002-100,rev 22 to EP-001-010,rev 27 to EP-002-010,rev 26 to EP-002-102 & Rev 16 to EP-002-190.Listed Proprietary Revs to Epips,Encl ML20211L3681999-09-0202 September 1999 Forwards Five Preliminary Applications for Reactor Operator Licenses for Individuals Listed,Iaw 10CFR55.31.Encls Withheld ML20211K9741999-09-0101 September 1999 Forwards Insp Rept 50-382/99-16 on 990704-0814.Two Severity Level IV Violations Identified & Being Treated as Noncited Violations,Consistent with App C of Enforcement Policy 05000382/LER-1999-011, Forwards LER 99-011-00,providing Details of Reactor Shutdown Due to Loss of Controlled bleed-off Flow.All Commitments Contained in Submittal Identified on Attached Commitment Identification/Voluntary Enhancement Form1999-08-31031 August 1999 Forwards LER 99-011-00,providing Details of Reactor Shutdown Due to Loss of Controlled bleed-off Flow.All Commitments Contained in Submittal Identified on Attached Commitment Identification/Voluntary Enhancement Form ML20211M3641999-08-30030 August 1999 Forwards Written Examination,Operating Tests & Supporting Ref Matl Identified in Attachment 2 of ES-210,in Response to NRC .Encl Withheld ML20211G5751999-08-27027 August 1999 Forwards RAI Re IPEEE Submittal.Please Provide RAI within 60 Days of Receipt of Ltr,Per Util Response to GL 88-20,suppl 4 ML20211E3281999-08-26026 August 1999 Forwards fitness-for-duty Performance Data for Period of 990101-0630,IAW 10CFR26.71(d).Ltr Does Not Contain Commitments 05000382/LER-1999-009, Forwards LER 99-009-00 Re Discovery of Condition of Noncompliance with App R Involving Inadequate Separation of Essential Cables Routed in Fire Area RAB-30 in Rab. Compensatory Measures Were Established Immediately1999-08-26026 August 1999 Forwards LER 99-009-00 Re Discovery of Condition of Noncompliance with App R Involving Inadequate Separation of Essential Cables Routed in Fire Area RAB-30 in Rab. Compensatory Measures Were Established Immediately 05000382/LER-1999-010, Forwards LER 99-010-00,providing Details of Inadequate Pumping Capacity in Dry Cooling Tower Area.All Commitments Contained in Submittal Are Identified on Attached Commitment Identification Voluntary Enhancement Form1999-08-26026 August 1999 Forwards LER 99-010-00,providing Details of Inadequate Pumping Capacity in Dry Cooling Tower Area.All Commitments Contained in Submittal Are Identified on Attached Commitment Identification Voluntary Enhancement Form ML20211F5421999-08-24024 August 1999 Forwards Proposed marked-up TS Page Xviii, Index Administrative Controls, Correcting Page Number Re TS Change Request NPF-38-220.Editorial Changes for TS Change NPF-38-221 Discussed ML20211F3561999-08-24024 August 1999 Forwards CTS Pages & TS Proposed marked-up Pages for Insertion Into TS Change Request NPF-38-207 Re Efas, Originally Submitted on 980702.Original NSHC Determination Continues to Be Applicable ML20211F4611999-08-24024 August 1999 Informs That NRC Reviewed Ltr & Encl Objectives for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Exercise Objectives Appropriate to Meet Emergency Plan Requirements ML20211G1731999-08-23023 August 1999 Informs That Info Submitted in ,B&W Rept 51-1234900-00,will Be Withheld from Public Disclosure,Per 10CFR2.790 ML20211C5101999-08-19019 August 1999 Forwards Certified Copies of Liability Insurance Policy Endorsements Issued in First Half of 1999 for Each Entergy Operations,Inc Nuclear Unit,Per 10CFR140.15 ML20210T9791999-08-18018 August 1999 Discusses Which Responded to Reconsideration of Violation Denial (EA 98-022) Enforcement Action Detailed in .Concludes That Violation Occurred as Stated ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210S0561999-08-12012 August 1999 Submits Voluntary Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for NRC Fys 2000 & 2001 for Waterford 3 ML20210Q6161999-08-12012 August 1999 Forwards Corrected Copy of Monthly Operating Rept for July 1999 for Waterford 3.Original Rept,Submitted with ,Contained Typos ML20217F2661999-08-12012 August 1999 Forwards Copy of 1999 Waterford 3 Biennial Exercise Package to Be Performed Using Waterford 3 CR Simulator ML20210R9231999-08-11011 August 1999 Forwards Insp Rept 50-382/99-10 on 990719-23.Violations Noted.Nrc Has Determined That One Severity Level IV Violation of NRC Requirements Occurred ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams 05000382/LER-1999-008, Forwards LER 99-008-00,re Failure to Perform Testing of ESF Filtration Units Per TS Srs.Commitments Made by Util Also Encl1999-07-29029 July 1999 Forwards LER 99-008-00,re Failure to Perform Testing of ESF Filtration Units Per TS Srs.Commitments Made by Util Also Encl ML20210H4291999-07-29029 July 1999 Forwards Response to NRC Rai,Associated with TS Change Request NPF-38-208,proposing to Replace Ref to Supplement 1 with Ref to Supplement 2 of Calculative Methods for CE Small Break LOCA Evaluation Model, in ACs Section of TSs ML20210F9451999-07-27027 July 1999 Forwards Proprietary & non-proprietary Version of Rev 29 to EPIP EP-002-100, Technical Support Ctr Activation,Operation & Deactivation. Proprietary Info Withheld,Per 10CFR2.790 ML20210D3171999-07-23023 July 1999 Submits Proposal for Final Resolution of Reracking Spent Fuel Pool at Plant,Per License Amend 144,issued by NRC in .No New Commitments Are Contained in Ltr 05000382/LER-1999-007, Forwards LER 99-007-00,providing Details of Operation Outside Tornado Missile Protection Licensing Basis for turbine-driven Emergency Feedwater Pump Exhaust Stack & Steam Supply Piping.All Commitments Identified on Attached1999-07-23023 July 1999 Forwards LER 99-007-00,providing Details of Operation Outside Tornado Missile Protection Licensing Basis for turbine-driven Emergency Feedwater Pump Exhaust Stack & Steam Supply Piping.All Commitments Identified on Attached ML20210D8701999-07-23023 July 1999 Forwards Safety Evaluation Re First 10-yr Interval Inservice Insp Plan Requests for Relief ISI-018 Through ISI-020 for Entergy Operations,Inc,Unit 3 ML20210B1521999-07-15015 July 1999 Forwards Insp Rept 50-382/99-13 on 990523-0703.Three Violations Being Treated as Noncited Violations ML20209G9771999-07-13013 July 1999 Forwards Objectives & Guidelines for Waterford 3 Emergency Preparedness Exercise Scheduled for 991013.List of Objectives cross-referenced Where Applicable to Relevant Sections of NUREG-0654 IR 05000382/19990081999-07-12012 July 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/99-08 Issued on 990503 ML20209E5231999-07-0909 July 1999 Informs That as Result of NRC Review of Util Responses to GL-92-01,rev 1 & Suppl 1,staff Revised Info in Reactor Vessel Integrity Database & Releasing Database as Rvid Version 2.This Closes Staff Efforts Re TAC MA0583 ML20209D4051999-07-0707 July 1999 Forwards Revised TS Pages to Replace Attachment C,Entirely in Original TS Change Request NPF-38-207,per 990519 Discussion with C Patel of Nrc.Changes to Action 20 Delete Word Requirement & Revise Word Modes to Mode 1999-09-09
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20217L0421999-10-21021 October 1999 Forwards Insp Rept 50-382/99-20 on 990815-0925 & Notice of Violation.Two Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20217N2111999-10-19019 October 1999 Forwards Insp Rept 50-382/99-14 on 990913-17 & 1004-08.No Violations Noted.Licensed Operator Requalification Program, Effective,Utilized Systems Approach to Training & Showed Continued Improvements Over Previous Insp Findings ML20217C6251999-10-0505 October 1999 Informs That NRC Reviewed Util Ltr & Encl Exercise Scenario Package for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Based on Review,Nrc Determined That Exercise Appropriate to Meet Objectives ML20212J6921999-09-29029 September 1999 Forwards Insp Rept 50-382/99-18 on 990830-0902.One Noncited Violation Identified Re Failure to Follow Procedural Instructions to Ensure That Members on Fire Brigade Shift Were Qualified ML20216G2441999-09-27027 September 1999 Forwards Insp Rept 50-382/99-19 on 990830-0903.No Violations Noted IR 05000382/19993011999-09-21021 September 1999 Informs That NRC License Exam Previously Associated with NRC Insp Rept 50-382/99-301 Will Be Incorporated Into NRC Insp Rept 50-382/99-14 ML20212D8761999-09-16016 September 1999 Informs That on 990818,NRC Staff Completed Midcycle PPR of Waterford 3.During Assessment Period,Number of Personnel Errors Occurred,Which Demonstrated Lack of Attention to Detail by Plant Personnel.Historical Listing of Issues,Encl ML20212C5881999-09-14014 September 1999 Forwards Insp Rept 50-382/99-15 on 990719-23 with Continuing in Ofc Insp Until 0819.No Violations Noted ML20211Q4421999-09-0909 September 1999 Forwards Insp Rept 50-382/99-07 on 990601-11.Three Violations Being Treated as Noncited Violations ML20211K9741999-09-0101 September 1999 Forwards Insp Rept 50-382/99-16 on 990704-0814.Two Severity Level IV Violations Identified & Being Treated as Noncited Violations,Consistent with App C of Enforcement Policy ML20211G5751999-08-27027 August 1999 Forwards RAI Re IPEEE Submittal.Please Provide RAI within 60 Days of Receipt of Ltr,Per Util Response to GL 88-20,suppl 4 ML20211F4611999-08-24024 August 1999 Informs That NRC Reviewed Ltr & Encl Objectives for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Exercise Objectives Appropriate to Meet Emergency Plan Requirements ML20211G1731999-08-23023 August 1999 Informs That Info Submitted in ,B&W Rept 51-1234900-00,will Be Withheld from Public Disclosure,Per 10CFR2.790 ML20210T9791999-08-18018 August 1999 Discusses Which Responded to Reconsideration of Violation Denial (EA 98-022) Enforcement Action Detailed in .Concludes That Violation Occurred as Stated ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210R9231999-08-11011 August 1999 Forwards Insp Rept 50-382/99-10 on 990719-23.Violations Noted.Nrc Has Determined That One Severity Level IV Violation of NRC Requirements Occurred ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20210D8701999-07-23023 July 1999 Forwards Safety Evaluation Re First 10-yr Interval Inservice Insp Plan Requests for Relief ISI-018 Through ISI-020 for Entergy Operations,Inc,Unit 3 ML20210B1521999-07-15015 July 1999 Forwards Insp Rept 50-382/99-13 on 990523-0703.Three Violations Being Treated as Noncited Violations IR 05000382/19990081999-07-12012 July 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/99-08 Issued on 990503 ML20209E5231999-07-0909 July 1999 Informs That as Result of NRC Review of Util Responses to GL-92-01,rev 1 & Suppl 1,staff Revised Info in Reactor Vessel Integrity Database & Releasing Database as Rvid Version 2.This Closes Staff Efforts Re TAC MA0583 ML20196E6931999-06-22022 June 1999 Forwards Corrected Ltr Re Changes to Rev 19 to Emergency Plan.Original Ltr Had Error in Subject Line ML20196E0831999-06-21021 June 1999 Forwards Insp Rept 50-382/99-12 on 990524-27.No Violations Noted.Purpose of Insp Was to Conduct Assessment of Emergency Preparedness Program ML20196D9941999-06-18018 June 1999 Forwards Insp Rept 50-382/99-11 on 990524-28.No Violations Noted ML20195J8091999-06-17017 June 1999 Forwards Safety Evaulation Re First 10-yr Interval Inservice Insp Relief Request for Plant,Unit 3 ML20196C8711999-06-15015 June 1999 Discusses Insp Rept 50-382/99-08 & Forwards Notice of Violation Re Unescorted Access Which Was Mistakenly Granted to Individual Whose Background Investigation Indicated That He Had Failed Prior Drug Screening with Another Employer ML20196F3721999-06-0909 June 1999 Corrected Ltr Forwarding Rev 19 to Emergency Plan ML20195G3711999-06-0909 June 1999 Ack Receipt of Ltr Dtd 981223,which Transmitted Waterford 3 Steam Electric Station Emergency Plan,Rev 24,under Provisions of 10CFR50,App E,Section V.No Violations of 10CFR50.54(q) Identified During Review ML20207E8541999-06-0303 June 1999 Forwards SE Accepting Licensee 990114 Submittal of one-time Request for Relief from ASME B&PV Code IST Requirements for Pressurizer Safety Valves at Plant,Unit 3 ML20207G3441999-06-0303 June 1999 Forwards Insp Rept 50-382/99-09 on 990411-0522 & Notice of Violation.One Violation Identified & Being Treated as Noncited Violation C ML20207D3771999-05-27027 May 1999 Ack Receipt of 990401 & 0504 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/99-01 on 990303 ML20207A5121999-05-24024 May 1999 Refers to Which Responded to NOV & Proposed Imposition of Civil Penalty Sent by .Violations A,B & E Withdrawn & Violations C & D Changed to Severity Level IV ML20206U7851999-05-18018 May 1999 Forwards Insp Rept 50-382/99-06 on 990405-09.Three Violations of NRC Requirements Occurred & Being Treated as non-cited Violations ML20206N6961999-05-11011 May 1999 Informs That NRC Office of Nuclear Reactor Regulation Reorganized Effective 990328.As Part of Reorganization, Division of Licensing Project Management Created ML20206S4411999-05-10010 May 1999 Forwards Insp Rept 50-382/99-05 on 990228-0410.Three Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20206H3841999-05-0707 May 1999 Informs That on 990407,NRC Administered Generic Fundamental Exam Section of Written Operator Licensing Exam.Licensee Facility Did Not Participate in Exam,However Copy of Master Exam,With Answer Key,Encl for Info.Without Encl ML20206K0951999-05-0606 May 1999 Discusses Insp Rept 50-382/99-08 Issued 990503 Without Cover Ltr Documenting EA Number & Subject Line Indicated NOV Which Was Incorrect.Corrected Cover Ltr Encl ML20206F4701999-05-0303 May 1999 Forwards Insp Rept 50-382/99-08 on 990405-07.One Apparent Violation Re Failure to Review & Consider Derogatory Access Authorization Background Info as Required by PSP Identified & Being Considered for Escalated Enforcement Action ML20206K1211999-05-0303 May 1999 Corrected Cover Ltr Forwarding Insp Rept 50-382/99-08 on 990405-07.One Violations Noted & Being Considered for Escalated EA ML20205N7251999-04-13013 April 1999 Forwards Summary of 990408 Meeting with EOI in Jackson, Mississippi Re EOI Annual Performance Assessment of Facilities & Other Issues of Mutual Interest.List of Meeting Attendees & Licensee Presentation Slides Encl ML20205M0561999-04-0909 April 1999 Forwards Insp Rept 50-382/99-04 on 990301-19.One Violation of NRC Requirements Occurred & Being Treated as Noncited Violation,Consistent with App C of Enforcement Policy ML20205J8781999-04-0505 April 1999 Forwards Insp Rept 50-382/99-02 on 990117-0227.No Violations Noted.Inspectors Determined That Six Violations Occurred & Being Treated as Noncited Violations Consistent with App C of Enforcement Policy ML20205J0901999-04-0202 April 1999 Informs That Info Submitted by & 970313 Affidavit Will Be Withheld from Public Disclosure,Per 10CFR2.790(b) (5) ML20205A4681999-03-26026 March 1999 Forwards Insp Rept 50-382/99-03 on 990308-12.Two Violations of Radiation Protection Requirements Occurred & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20205A6141999-03-25025 March 1999 Forwards SE Accepting Request to Use Mechanical Nozzle Seal Assemblies (Mnsas) as an Alternative Repair Method,Per 10CFR50.55a(a)(3)(i) for Reactor Coolant Sys Application at Plant,Unit 3 ML20205F3311999-03-19019 March 1999 Advises of Planned Insp Effort Resulting from Plant,Unit 3 PPR Review,Which Was Completed on 990211.Performance at Plant,Unit 3 Was Acceptable ML20204E4941999-03-17017 March 1999 Discusses TSs Bases Change Re 3/4.4.1,3/4.6.1.7,3/4.6.3, 3/4.7.12 & 3/4.8.4.Forwards Affected Bases Pp B 3/4 4-1, B 3/4 6-3,B 3/4 6-4,B 3/4 7-7 & B 3/4 8-3 ML20207F1251999-03-0303 March 1999 Forwards Insp Rept 50-382/99-01 on 990125-29 & 0208-12 & Notice of Violations ML20203H8501999-02-17017 February 1999 Forwards SE Accepting Licensee 970701 Submittal of Second Ten Year ISI Program & Associated Relief Request for Plant, Unit 3.Nine Relief Requests Had Been Authorized Previously & Proposed Alternatives Remain Authorized ML20203D7211999-02-11011 February 1999 Forwards Request for Addl Info Re Licensee 970317 & 990111 Responses to GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves. Response Should Be Provided within 60 Days 1999-09-09
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- ARLINGTON. TEXAS 76011 8064
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December 3,1997
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Charles M. Dugger, Vice President .
Operations - Waterford 3 Entergy Operations, Inc.
- P.O. Box B Killona, Louisiana 70066 a SUBJECT: NRC INSPECTION REPORT 50-382/9717
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Dear Mr. Dugger:
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Thank you for your letter of November 24; 1997, in response to our letter and Notice of Vi >Iation dated October 23,1997, We have reviewed your reply and find it responsive to our concern about emergency operating procedures raised in our Notice of Violation. We wili review the implementation of your ccrrective actions during a future inspection to determine that full r
compliance has been achieved and will be maintained.
Sincerely, hGJohn L. Pellet, Chief Operations Branch Division of Reactor Safety Docket'No.: 50-382 /
License No.: NPF 38 l
cc:
Executive Vice President and Chief Operating Officer /
Entergy Operations. Inc.
P.O. Box 31995 Jackson. Mississi.o pi 39286 1995 9712050023 971203 7 PDR ADOCK 05000302 0 pg .
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Entergy Operationsiinc. - 2- ,
L Vice President [ Operations Support -
Entergy Operations, Inc.
P.O. Box 31995 Jackson, Mississippi 39286-1995- -
t Wise, Carter, Child & Caraway P.O. Box 651 Jackson, Mississippi 39205 General Manager, Plant Operations . -
Waterford 3 SES Entergy Operations, Inc.
P.O. Box B Killona, Louisiana 70066 Manager Licensing Manager '
Waterford 3 SES Entergy Operations, Inc.
P.O. Box B Killona, Louisiana 70066
, Chairman Louisiana Public Service Commission
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One American Place, Suite 1630 Baton Rouge, Louisiana 70825-1697 Director, Nuctsar Safety & ..
Regulatory Affairs Waterford 3 SES Entergy Operations, Inc.
P.O. Box B Killona, Louisiana 70066 William H.-Spell, Administrator lo 'isiana Radiation Protection Division P.O. Box 82135 '
Baton Rouge, Louisiana 70884-2135 Parish President St Charles Parish-P.O. Box 302 -
Hahnville; Louisiana --70057
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Entergy Operations, Inc, .
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- Mr. William A. Cross -
. Bethesda Licensing Office-
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- Bethesda, Maryland 20814 - -
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-Winston & Strawn - ;
- .1400 L Street, N.W.
- . Washington, D.C. 20005-3502 - ,
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Entergy Operations, Inc. -4-E-Mail report to T. Frye (TJF) -
E-Mail report to T. Hiltz (TGH)-
E-Mail report to NRR Event Tracking System (IPAS) .
E Mail report to Document Control Desk (DOCDESK)
bec to DCD ('E01)(IE42)
bec distrib. by RIV:
Regional Administrator Resident inspector
DRS Director DRS Deputy Director DRP Director DRS-PSB
, - Branch Chief (DRP/D) MIS System i Project Engineer (DRP/D) RIV File Branch Chief (DRP/TSS) i
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4 DOCUMENT NAME: R:\_WAT\WT717ak.jlp To receive copy of document. Indicate in box:"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy
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12/$/97 '
, OFFICIAL RECORD COPY
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Entergy Operations, Inc. -4-E-Mai! report to T. Frye (TJF)
E Mail report to T. Hiltz (TGH)
E-Mail report to NRR Event Tracking System (IPAS)
E-Mail report to Document Control Desk (DOCDESK)
bec to DCD (IE21)(ik2)-
L bec distrib, by RIV:
Regional Administrator Resident inspector DRS Director DRS Deputy Director DRP Director DRS-PSB Branch Chief (DRP/D) MIS System Project Engineer (DRP/D) RIV File Branch Chief (DPP/TSS)
DOCUMENT NAME: R:\_WAT\WT717ak.jlp To receive copy of document, indicate in box:"C" = Copy without enclosures "E" a Copy wdh enclosures "N" = No copy
C:OB 0, l l JLPELLET Q}/
12/$/97
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OFF!CIAL RECORD COPY
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Ec-01-of 18:40 'Fros:ENTERGY QPERATICNS 5047396t90 T-350 P.02/0 JoH l4
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W3F1-97-0260 A4.05 PR l
November 24,1997 U.S. Nuclear Regulatory Commission ,
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ATTN: Document Control Desk Washington, D.C. 20555 Subject: Waterford 3 SES Docket No. 50-382 ,
License No. NPF-38 NRC Inspection Report 50-382/97-17 Reply to Notice of Violation Gentlemen-In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submns in Attachment 1 the response to the violatica identified in Enclosure 1 of the sut' ject inspection Report.
if you have any questions concoming this response, please contact me at (504) 739-8242 or T.J. Gaudet at (504) 739-6666.
Very truly yours,
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E.C. Ewing Director, Nuclear Safety & Regulatory Affairs ECE/OPPlasf
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Attachment
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cc: E.W. Merschoff (NRC Region IV), C.P. Patel (NRC-NRR),
J. Smith, N.B. Reynoide, NRC Restdont Ins.pectors Office
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DEC-01-Ifc13:40 - Fros:tRTERGY GPERAT40Mt 50478tC680 T458 P.03/05 Job-ll4 '
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NRC Inspection Report 97-17 RepW to Notice of Violation W3F197 0260 l
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l Novemoor 24,1997 oc: Mail:- : D.C. Hintz : (M-ECH46) ,
J.W Yelverton (M-ECH45) ~ l
! (W.G88-300)
T.R. Leonard (W-MSB4-300)
F.J. Drummond (W G85-305) ;
A..l. Wrape (W-GSB-315) .
G.D. Pierce - (W-ADM-686)-
R.E. Allen (W-G88-102)
B.E. Meyers (W-ADM-565)
J.J. Zabritski . (W4M-567) ,
J.G. Hoffpauir (W-MSB4-336)
J.G. Dewease (M-ECH46) - .
L.F. Daughtery (GGNS - ADMILIC)
S.J. Bethey -
C.A. Bottomiller
. T.W. Gates T.J. Goudet K. Godfrey C. Gunn
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W.K.Hughey 4 IEA f R.J. King D.N. Lorfing J.M. Manzella D.C. Mims (ANO)
R. Thomas bec: SRC Secretary - (W-GSB-102)
T.J. Sibley _ (W-GSB-318)
Waterford 3 Records Center (W-G08-100) ,
NRC Inspootion Report 97-17 Licensing Green Folder File c
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DEC-01*S? 13:40 Froa: ENTER 1Y QPERA? IONS 504?396698 T-358 P.04/05 h b-!$4
N5F15E5550 Page 1 of 2
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ATTACHMENT 1 ENTERGY OPERATIONS. INC. RESPONS'i TO THE VIOLATION IDENTIFIED IN EMCLOSURE 1 OF INSPECTION REPORT 50-382/97-17 VIOt.ATION NO. 9717-01 Technical Specification 6.8.1.a states, in part that written procedures shall be established, implemented, and maintained covering emergency operating procedures.
Subprocedure V, " Containment Isolation,' of the licensee's Emergency Operating Procedure OP 902-008, Revision 10, contair,ed instructions necessary to satisfy the success path for the containment isolation safety function.
The licensee had completed recent moditications to the plant, which pxmitted overriding a containment spray permissive signal to allow the operators to cicse Containment Spray Valves CS-125A(B) in order to isolate the containment and satisfy the safety function success path.
Contrary to the above, written procedures were not maintained for en)ergency operating procedures in that the Itcenses failed to revise the Emergency Operating Procedure OP-902-008 following valve modifications to provide the operators with adequate instruction for closing Containment Spray Valves CS125A(B) to isolate the Containment.
This is a Severity Level IV vielation (Supplement I) (50-382/9717-01).
RESPONSE
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(1) Reason for the Violation Entergy attributes the violation to a combination of the inefficient location of procedural guidance and to the lack of clearly defined management expectations for Operations in this area. Entercy a0rees that appropriately located procedural guidance is needed to ensure the proper and appropriate operation of Containment Spray Valves (CS-125A(B)). The location of the procedural guidanca in an Emergency Planning Procedure (EP-002-100, Revision 25, Attachment 7.12) versus in an 5mergency Operating Procedure (OP-902-008) was a conscious decision, which had been reached after much deliberation. Waterford 3 is committed to meeting the strategies for Emergency Operating Procedures outlined in CEN-162, CE Emergency Operating Procedure Guidelines. The NRC approved the use of the strategies in CEN-152 Revisions 03 and 04. The strategies that CE recommends in the guidelines do not include specific steps to iriate containment in the case of equipment failure (e.g. a Containe.< ' Jpray Pump
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not running).7 The Safety Function Success Path for containment isolation in -
the Fundlunal Recovery Guideline (CEN-152) states to ensure an isolation
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valve is clossd for each containment penetration required to be closed. The
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1 Waterford 3 Safety Function Recovery Procedura (OP-902 008) states that et least one containment isolation valve must be closed for sech containment
penetration not in usec The EOPs are written assuming that safety-equipreent s is operable and will perform its intended function. - To assume safety-related !
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equipment failures in developing EOPs would drastically increase the volume -
c - of information necessary in the body of the E0Ps, thus potentially increasing -
operator complication ar'd response time. Based on the above considerations, we have assessed that the procedural guidance would more appropriately ba located in a standard appendices to the EOPs rather than in ;
- the body of the EOPs.
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It should be noted that the NRC is currently evakating Entergy's position on the Containment Spray Containment isolation Vatves presentad at the Enforcement Conference held in Ariington, Texas on July 29,1997. Final
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resolution tan that issue la pending. Waterford 3 will address the results accordingly. .
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(2) Corrective Stans That Have Baan Takan and the Resulta Achieved
! Operating crews have been briefed on the violation scenario in various
- Operations Department meetings and are awere of the current location of the subject procedural guidance and management's expectations in that regard.
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(3) Corrar*ive Bi= = Which Will Be Taken to Avoid Further Violations ;
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. Waterford 3 has plans to develop a standard appendices to the EOPs l wherein guidance will be included to provide dinction to the operators for i closing Containment Spray Valves CS 125A(B) with Containment Spray l Pumps not running. The Operator imining program will include training for l
. the Operators on the new standard appendices. l
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(4) Date When Full Compliance Will Be Achieved The EOP standard appendices will be completed by June 30,1996.
l Operations Training inclusion of the appendices in the treining program will l
be completed by August 31,'1998. ,
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