ML18348B003

(Waterford 3) - Reply to a Notice of Violation; NRC Inspection Report 05000382/2018008

ML18348B003
Person / Time
Site:	Waterford
Issue date:	12/14/2018
From:	Signorelli J V Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation, NRC Region 4
References
IR 2018008, W3F1-2018-0073
Download: ML18348B003 (5)

See also: see also:IR 05000382/2018008

Text

Entergy Operations, Inc. 17265 River Road Killona, LA 70057-3093 Tel 504-739-6032 John V. Signorelli

Manager, Regulatory Assurance

(Acting) W3F1-2018-0073 December 14, 2018 U.S. Nuclear Regulatory Commission

ATTN: Document Contro

l Desk Washington, DC 20555-0001 Reference: NRC Letter to 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)

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. The Enclosure provides Entergy's response to the Notice of Violation. This information is provided in accordance with the provisions of 10 CFR 2.201. This letter contains no new regulatory commitments. Should you have any questions regarding this letter, please contact the Acting Regulatory Assurance Manager, John V. Signorelli, at (504) 739-6032.

Respectfully, John V. Signorelli

JVS/mmz Subject: Reply to a Notice of Violation; NRC Inspection Report 05000382/2018008 Waterford Steam Electric Station, Unit 3 (Waterford 3) NRC Docket No. 50-382 Facility Operating License No. NPF-38

W3F1-2018-0073

Page 2 of 2 cc: NRC Region IV Regional Administrator NRC Senior Resident Inspector - Waterford Steam Electric Station, Unit 3 NRR Project Manager

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

ENCLOSURE

W3F1-2018-0073 Entergy Operations, Inc. Reply to Notice of Violation, NRC Inspection Report 05000382/2018008

W3F1-2018-0073 Enclosure

Page 1 of 2 Entergy Operations, Inc. Reply to Notice of Violation, NRC Inspection Report 05000382/2018008 In U.S. Nuclear Regulatory Commission (NRC) letter to Entergy Operations, Inc. "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 Entergy Operations' 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 enclosure 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.

W3F1-2018-0073 Enclosure

Page 2 of 2 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. Corrective Steps That Will Be Taken The corrective action plan includes the performance of validation testing to correct the non-conforming condition and ensure that the affected basic components conform to quality requirements. Validation test parameters will be in accordance with approved Commercial Grade Dedication plans. The following actions will be completed:Action 1: Obtain appropriate test specimens. Action 2: Develop validation testing plans for each of the different Electroswitch switch and relay family types installed at Waterford 3. Action 3: Perform validation testing.

Action 4: Determine appropriate disposition of results. Document in an approved Engineering Change evaluation. Action 5: Complete an Adverse Condition Anal

ysis (ACA) to determine cause and identify actions required to correct the condition. This ACA will include 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 will be added to the corrective action plan.

Date When Full Compliance Will Be Achieved Entergy will be in full compliance by June 21, 2019.