ML12310A497

IR 05000382-12-008, July 16, 2012 - September 24, 2012, Waterford 3 Biennial Baseline Inspection of the Identification and Resolution of Problems.

ML12310A497
Person / Time
Site:	Waterford
Issue date:	11/05/2012
From:	Ray Kellar Division of Reactor Safety IV
To:	Jacobs D Entergy Operations
References
EA-12-198 IR-12-008
Download: ML12310A497 (50)

See also: IR 05000382/2012008

Text

November 5, 2012

EA-12-198

Donna Jacobs, Site Vice President, Operations Entergy Operations, Inc.

Waterford Steam Electric Station, Unit 3

17265 River Road

Killona, LA 70057-0751

SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION

REPORT 05000382/2012008 AND NOTICE OF VIOLATION

Dear Ms. Jacobs:

On August 2, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem

Identification and Resolution biennial inspection at

your Waterford Steam Electric Station, Unit 3. The enclosed inspection report documents the inspection results that were discussed on August 2, 2012, with Keith Nichols, Director of Engineering, and other members of your staff. After additional in-office inspection, a final telephonic exit meeting was conducted on September 24, 2012 with Keith Nichols, Director of Engineering, and other members of your staff.

This inspection was an examination of activities conducted under your license as they relate to

problem identification and resolution and compliance with the Commission's rules and regulations and the conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and

interviews with personnel.

Based on the inspection sample, the inspection team concluded that the implementation of the corrective action program and overall performance related to identifying, evaluating, and resolving problems at Waterford Steam Electric Station, Unit 3, were adequate. Licensee

identified problems were entered into the corrective action program at a low threshold.

Problems were generally prioritized and evaluated commensurate with the safety significance of

the problems. Corrective actions were generally implemented in a timely manner commensurate with their importance to safety and addressed the identified causes of problems. Lessons learned from industry operating ex

perience were generally reviewed and applied when appropriate. Audits and self-assessments were effectively used to identify problems and appropriate actions. Finally, the team determined that the station maintains a safety-conscious work environment where employees feel free to raise nuclear safety concerns without fear of retaliation.

Five NRC identified findings of very low safety significance (Green) were identified during this inspection and are documented in the enclosed report. All five of these findings were

determined to involve a violation of NRC requirement

s. The NRC is treating four of the five UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION IV1600 EAST LAMAR BLVDARLINGTON, TEXAS 76011-4511

D. Jacobs - 2 -

violations as non-cited violations (NCVs), consistent with Section 2.3.2 of the Enforcement Policy. Additionally, a licensee-identified violation, which was determined to be of very low safety significance, is listed in this report.

One of the findings that the NRC evaluated under the risk significance determination process as having very low safety significance (Green) did not meet the criteria to be treated as a non-cited violation. The violation associated with this issue was evaluated in accordance with the NRC Enforcement Policy. The current version of this Policy is available on the NRC website at

(http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html). This violation is cited in the enclosed Notice of Violation (Notice), and the circumstances surrounding it are described in detail in the subject inspection report. The violation is being cited in the Notice in accordance

with Section 2.3.2 of the Enforcement Policy because you failed to restore compliance in a reasonable period of time after the violation was previously identified as a non-cited violation.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. This reply should be clearly marked as a

"Reply to a Notice of Violation; EA-12-198" and should specifically include a firm commitment as

to when you will establish a design basis to determine the river level at which flood control measures were to be initiated for closing the water tight doors as required in Procedure OP-901-521, "Severe Weather and Flooding." If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The

NRC review of your response to the Notice w

ill also determine whether further enforcement

action is necessary to ensure compliance with regulatory requirements."

If you contest these non-cited violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to: (1) the Regional Administrator, Region

IV; (2) the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and (3) NRC Resident

Inspector Office at Waterford Steam Electric Station, Unit 3.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your

disagreement, to the Regional Administrator, Re

gion IV; and the NRC Resident Inspector at

Waterford Steam Electric Station, Unit 3

.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response will be available ele

ctronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agency wide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic

Reading Room).

Sincerely,

/RA/

Ray Kellar, P.E., Chief Technical Support Branch Division of Reactor Safety

D. Jacobs - 3 -

Docket No.: 50-382 License No: NPF-38

Enclosures: 1. Notice of Violation EA-12-198

2. Inspection Report 05000382/2012008 w/Attachments: 1. Supplemental Information

2. Information Request

cc w/enclosures: Electronic Distribution for Waterford 3

ML12310A497

SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials RLS Publicly Avail. Yes No Sensitive Yes No Sens. Type Initials

TL/SRI:DRP/C RI:DRP/E PE:DRP/C RI:DRS/EB1 ACES BC:DRP/E RSmith DOverland RKumana MYoung HGepford DAllen -e- -e- /RA/ /RA/ /RA/ /RA/ 10/23/2012 10/23/2012 10/13/2012 10/23/2012 10/26/2012 10/30/12

BC:DRS/TSB

RKellar /RA/ 11/5/2012

- 1 - Enclosure 1

NOTICE OF VIOLATION

Entergy Operations, Inc. Docket No. 50-382 Waterford Steam Electric Station, Unit 2 License No. NPF-38

EA-12-198

During an NRC inspection conducted on July 16

through September 24, 2012, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:

Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion III, "Design

Control," states, in part, that measures shall be established to assure that applicable

regulatory requirements and the design basis, as defined in 10 CFR 50.2, are correctly translated into specifications, procedures, and instructions.

Contrary to the above, from March 10, 2011, to August 2, 2012, the licensee failed to

establish measures to assure that applicable regulatory requirements and the design basis, as defined in 10 CFR 50.2, were correctly translated into specifications, procedures and instructions. Specifically, the licensee had not established a design

basis to determine the river level at which flood control measures were to be initiated for

closing the water tight doors as required in Procedure OP-901-521, "Severe Weather

and Flooding."

This violation is associated with a Green Significance Determination Process finding.

Pursuant to the provisions of 10 CFR 2.201, Entergy Operations is hereby required to submit a

written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document

Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, Region IV, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This

reply should be clearly marked as a "Reply to a Notice of Violation; EA-12-198" and should

include for each violation: (1) the reason for the violation or, if contested, the basis for disputing

the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence if the correspondence adequately addresses the required response. If an adequate reply is not

received within the time specified in this Notice, an Order or a Demand for Information may be

issued as to why the license should not be modified, suspended, or revoked, or why such other

action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear

Regulatory Commission, Washington, DC 20555-0001.

- 2 - Enclosure 1

Because your response will be made available el

ectronically for public

inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), accessible from the

NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be made

available to the public without redaction. If personal privacy or proprietary information is

necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your

response that deletes such information. If you request withholding of such material, you must

specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial

information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

In accordance with 10 CFR 19.11, you may be required to post this Notice within two working

days of receipt.

Dated this 5

th day of November, 2012

- 1 - Enclosure 2

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 50-382 License: NPF-38

Report: 05000382/2012008

Licensee: Entergy Operations, Inc.

Facility: Waterford Steam Electric Station, Unit 3

Location: 17265 River Road Killona, LA 70057-0751

Dates: July 16 through September 24, 2012 Team Leader: R. Smith, Senior Resident Inspector, Grand Gulf

Inspectors:

D. Overland, Resident Inspector, Waterford 3 R. Kumana, Project Engineer

M. Young, Reactor Inspector

Approved By: Ray Kellar, P.E., Chief Technical Support Branch

Division of Reactor Safety

- 2 - Enclosure 2 SUMMARY OF FINDINGS

IR 05000382/2012008; July 16, 2012 -September 24, 2012; Waterford 3 "Biennial Baseline Inspection of the Identification and Resolution of Problems."

The team inspection was performed by one senior resident inspector, one resident inspector,

one reactor inspector, and one project engineer. One cited violation and four non-cited

violations of very low safety significance (Green) were identified during this inspection. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609, "Significance Determination Process". Findings for which the significance determination process does not apply may be Green or be assigned a severity level

after NRC management review. The NRC's program for overseeing the safe operation of

commercial nuclear power reactors is described in NUREG 1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Identification and Resolution of Problems

The team reviewed approximately 350 condition reports, work orders, engineering evaluations, root and apparent cause evaluations, and other supporting documentation to determine if problems were being properly identified, characterized, and entered into the corrective action program for evaluation and resolution. The team reviewed a sample of system health reports, self-assessments, audits, trending reports and metrics, and various other documents related to the corrective action program.

Based on these reviews, the team concluded that the licensee's corrective action program and its other processes to identify and correct nuclear safety problems were adequate to support nuclear safety. However, the team noted at times the licensee staff did not always use the corrective action program for problems that we

re perceived as minor. The team also noted several challenges in correcting adverse conditions in a timely manner. Further, the licensee

had several long-standing issues, which had been in the corrective action process for over a year without resolution.

The licensee appropriately evaluated industry operating experience for relevance to the facility and entered applicable items in the corrective action program. However, there was one

example where the licensee failed to enter an information notice into their corrective action

program for evaluation of a condition adverse to quality. The licensee used industry operating

experience when performing root cause and apparent cause evaluations. The licensee performed effective quality assurance audits and self-assessments, as demonstrated by self-identification of poor corrective action program performance and identification of ineffective

corrective actions.

Finally, the team determined that the station continued to maintain a safety-conscious work environment. Employees felt free to raise nuclear safety concerns to the attention of management without fear of retaliation.

- 3 - Enclosure 2 A. NRC-Identified and Self-Revealing Findings

Cornerstone: Initiating Events

• Green. The team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for a failure to follow

Procedure EN-OP-115, "Conduct of Operations". Specifically, the licensee failed to ensure that control room operators knew the status of equipment at all times.

While interviewing the person responsible for tracking plant deficiencies, the

inspectors discovered that the licensee had two separate governing procedures.

These two instructions had different definitions for categories of plant deficiencies and different databases for tracking them. The inspectors then interviewed the on-shift operators in the control room and reviewed both databases. The

inspectors identified several issues, including lack of knowledge by the control

room operators about which procedure to use, failure to track deficiencies in both

databases, and inadequate classification of deficiencies. The inspectors determined that in March 2010, the licensee changed their process for tracking deficiencies to be consistent with their fleet reporting process. However, the

licensee did not revise the procedure and did not train all affected personnel on

the new process. As a result, control room operators did not have a complete

and accurate knowledge of all plant deficiencies. This finding was entered into the licensee's corrective action program as Condition Report CR-WF3-2012-

03732. The failure to ensure that operators were aware of the status of all plant

equipment was a performance deficiency. The performance deficiency was more

than minor because it was associated with the procedure quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety

functions during shutdown as well as power operations. Specifically, the licensee

failed to implement a procedure designed to ensure operators were aware of

deficiencies in the instrumentation, controls, and operation of nuclear plant systems. In accordance with NRC Inspection Manual Chapter 0609, Attachment 4, "Initial Characterization of Findings," the issue was determined to

affect the Initiating Events Cornerstone. In accordance with NRC Inspection

Manual Chapter 0609, Appendix A, "The Significance Determination Process

(SDP) for Findings at Power," the issue was determined to have very low safety significance (Green) because it did not cause a reactor trip and did not cause the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. This finding had a cross-cutting aspect in

the human performance area, work practices component, in that the licensee

failed to define and effectively communicate expectations regarding procedural

compliance, and personnel did not follow procedures H.4.b] (Section 4OA2.5.d).

• Green. The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Actions," because the licensee failed to determine the cause of a significant condition adverse to quality and take

- 4 - Enclosure 2 corrective actions to preclude repetition. Specifically, the licensee failed to assure that the cause of the condition was determined and corrective action

taken to preclude repetition related to a contractor's non-compliance with site procedural requirements. The corrective actions include developing additional training and provisions to provide additional contractor oversight. This finding

was entered into the licensee's corrective action program as Condition Reports

CR-WF3-2012-03769 and CR-WF3-2012-03772.

The failure to determine the cause of a significant condition adverse to quality and take corrective action to preclude repetition was a performance deficiency. The performance deficiency was more than minor because if left uncorrected, it

could lead to more significant consequences; therefore, it is a finding.

Specifically, failure to determine the cause of a significant condition adverse to quality and take corrective action to prevent recurrence can result in recurrence of the condition. In accordance with NRC Inspection Manual Chapter 0609, Attachment 4, "Initial Characterization of Findings," the issue was determined to

affect the Initiating Events Cornerstone. In accordance with NRC Inspection

Manual Chapter 0609, Appendix A, "The Significance Determination Process

(SDP) for Findings at Power," the issue was determined to have very low safety significance (Green) because the finding did not cause a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the

trip to a stable shutdown condition. This finding had a cross-cutting aspect in the

human performance, work practice component, in that the licensee failed to

follow guidance in the root cause evaluation procedure when developing

appropriate corrective actions to prevent repetition H.4(b) (Section 4OA2.5.e).

Cornerstone: Mitigating Systems

• Green. The team identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for a failure to follow the Operability Determination Process. Specifically, the licensee failed to

determine the operability of the emergency diesel generators immediately upon discovery without delay and in a controlled manner using the best information available in response to NRC Information Notice 2010-04. The licensee

completed an evaluation of the information notice that indicated that Waterford 3

was vulnerable and susceptible to the issue, but the licensee failed to issue a

condition report as required by their procedure. The failure to initiate a condition

report resulted in the licensee's failure to perform an operability determination of the emergency diesel generators as required by, EN-OP-104," Operability Determination Process," Revision 6. In the evaluation, the licensee considered

the fact that they had an "Action Request" in their system to add routine

thermography inspections within the voltage regulator cabinets to their

preventative maintenance program as being adequate. The action request was not completed when the inspection team reviewed the issue. The inspectors questioned whether there was an operability concern for the emergency diesel

generators. The licensee recognized their failure to perform an operability

determination. They performed a prompt operability determination based on no

- 5 - Enclosure 2 observed degradation in performance and declared the emergency diesel generators operable. In addition, they plan to conduct the thermography

inspections during the next scheduled emergency diesel generator surveillance. This finding was entered into the licensee's corrective action program as Condition Report CR-WF3-2012-03761.

The failure to promptly perform an operability determination of the emergency

diesel generators in response to NRC Information Notice 2010-04 was a

performance deficiency. The performance deficiency was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure

the availability, reliability, and capability of systems that respond to initiating

events to prevent undesirable consequences. Specifically, the licensee failed to

promptly determine the operability of the diesel generators after obtaining information of a potential condition adverse to quality. In accordance with NRC Inspection Manual Chapter 0609, Attachment 4, "Initial Characterization of

Findings," the issue was determined to affect the Mitigating Systems

Cornerstone. In accordance with NRC Inspection Manual Chapter 0609,

Appendix A, "The Significance Determination Process (SDP) for Findings at Power," the issue was determined to have very low safety significance (Green) because it was not a deficiency affecting the design or qualification of the

system, it did not represent a loss of system or function, and it was a Technical Specification system, but did not represent an actual loss of function of a single

train for greater than it allowed outage time. Specifically, the licensee performed

an operability determination in response to the inspectors' questions and determined the emergency diesel generators were operable based on a review of surveillance data and maintenance records. This finding had a cross-cutting

aspect in the problem identification and resolution area, operating experience

component, in that the licensee failed to systematically collect, evaluate, and

communicate to affected internal stakeholders in a timely manner relevant internal and external operating experience P.2.a] (Section 4OA2.5.a).

• Green. The team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," for the failure to take timely corrective action for a condition adverse to quality. Specifically, from May 2011, through

August 2012, the licensee failed to restore a degraded condition, which included

a corrective action to perform a new design analysis for the emergency

feedwater pump AB after the removal of heat trace circuit 1-8C, despite having a reasonable amount of time to complete it. Currently, plant operators are required once per shift to perform temperature verifications of the heat trace to ensure

condensation does not form in the steam supply pipe to the turbine driven pump and to maintain emergency feedwater pump AB in an operable but degraded

status until the design analysis is complete. This finding was entered into the licensee's corrective action program as Condition Report CR-WF3-2012-03754.

The team determined that the failure to complete the corrective action of

performing a new design analysis to determine if emergency feedwater pump AB

- 6 - Enclosure 2 required a design modification based on the analysis in a timely manner was a performance deficiency. The performance deficiency was more than minor

because it affected the equipment performance attribute of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failure to implement this corrective action could

result in reduced reliability of the emergency feedwater pump AB. In accordance

with NRC Inspection Manual Chapter 0609, Attachment 4, "Initial

Characterization of Findings," the issue was determined to affect the Mitigating Systems Cornerstone. In accordance with NRC Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process (SDP) for Findings

at Power," the issue was determined to have very low safety significance (Green)

because it affected the design or qualification of mitigating systems, structures,

and components; however, the systems, structures, and components maintained operability. This finding had a cross-cutting aspect in the human performance area, resources component, in that the licensee failed to minimize a long-

standing equipment issue adequately to assure nuclear safety H.2(a) (Section

4OA2.5.b).

• Green. The team identified a cited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control", for the failure to establish measures to assure that applicable regulatory requirements and the design basis as defined in 10 CFR 50.2 are correctly translated into procedures. Specifically, the licensee

has not determined a basis for the level at which flood control measures are

initiated, two years after receiving a non-cited violation for the same deficiency.

As an interim compensatory measure for a previous violation of inadequate

technical specifications, the licensee modified their flooding procedure to include an action to start shutting flood control doors at a river level of 24 feet instead of 27 feet. The licensee recognized the need to establish a basis for initiating these

actions at 24 feet, and issued a corrective action to track completion. The

licensee extended the due date several times and had not completed it by the

arrival of the inspection team. The inspection team questioned why the licensee had not completed the calculation to justify their basis for their compensatory measures, noting that it had been over two years since the original violation was identified. The inspectors verified through walk-downs, procedure reviews, and

historical data that the licensee's use of 24 feet did not represent an immediate

operability concern, and that the current river level was sufficiently low to allow

time for the licensee to correct the deficiency. This finding was entered into the licensee's corrective action program as condition report CR-WF3-2012-03752.

The failure to complete the corrective action to establish a basis for flood control

measures in a timely manner was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection from external events attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of

systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to verify through calculations or analysis that the

- 7 - Enclosure 2 actions taken to secure flood doors could be completed in time to protect safety-related equipment from flooding due to a levee failure. In accordance with

NRC Inspection Manual Chapter 0609, Attachment 4, "Initial Characterization of Findings," the issue was determined to affect the Mitigating Systems

Cornerstone. In accordance with NRC Inspection Manual Chapter 0609,

Appendix A, "The Significance Determination Process (SDP) for Findings at

Power", the issue was determined to have very low safety significance (Green)

because it did not involve the loss or degradation of equipment or function

specifically designed to mitigate a seismic, flooding, or severe weather initiating event. Specifically, the inspectors confirmed that the licensee could reasonably ensure the flood control doors could perform their safety function. This finding

had a cross-cutting aspect in the human performance area, resources

component in that the licensee failed to

maintain long term plant safety by maintenance of design margins and ensuring engineering backlogs low enough to support safety. H.2.a] (Section 4OA2.5.c).

B. Licensee-Identified Violations

A violation of very low safety significance, which was identified by the licensee, has been reviewed by the inspectors. Corrective actions taken by the licensee have been entered into the licensee's corrective action program. This violation and associated corrective

action tracking numbers are listed in Section 4OA7 of this report.

- 8 - Enclosure 2 REPORT DETAILS

4. OTHER ACTIVITIES (OA)

4OA2 Problem Identification and Resolution (71152)

The team based the following conclusions on the sample of corrective action documents that were initiated in the assessment period, which ranged from May 1, 2010, to the end

of the on-site portion of this inspection on August 2, 2012.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The team reviewed approximately 350 corrective action documents, including associated root cause, apparent cause, and direct cause evaluations, out of

approximately 17,000 corrective action documents that were issued between

May 1, 2010, and August 2, 2012, to determine if problems were being properly identified, characterized, and entered into the corrective action program for evaluation and resolution. The team reviewed a sample of system health reports, operability determinations, self-assessments, trending reports and

metrics, and various other documents related to the corrective action program.

The team evaluated the licensee's efforts in establishing the scope of problems

by reviewing selected logs, work requests, self-assessments results, audits,

system health reports, action plans, and results from surveillance tests and preventive maintenance tasks. The team reviewed work requests and attended the licensee's daily Condition Review Group, (which is the management review committee meeting to assess the reporting threshold, prioritization efforts, and

significance determination process), as well as observing the interfaces with the

operability assessment and work control processes when applicable. The team's review included verifying the licensee considered the full extent of cause and extent of condition for problems, as well as how the licensee assessed generic

implications and previous occurrences. The team assessed the timeliness and

effectiveness of corrective actions, completed or planned, and looked for

additional examples of similar problems.

The team conducted interviews with plant personnel to identify other processes that may exist where problems may be identified and addressed outside the corrective action program.

The team also reviewed corrective action documents that addressed past

NRC-identified violations to ensure that t

he corrective action addressed the issues as described in the inspection reports. The inspectors reviewed a sample of corrective actions closed to other corrective action documents to ensure that corrective actions were still appropriate and timely.

The team considered risk insights from both the NRC's and Waterford Steam

Electric Station, Unit 3's risk assessments to focus the sample selection and plant tours on risk significant systems and components. The team selected the

- 9 - Enclosure 2 component cooling water and auxiliary component cooling water systems as risk significant systems to review. The samples reviewed by the team focused on,

but were not limited to, these systems. The team also expanded their review to include five years of evaluations involv

ing the emergency feedwater system to determine whether problems were being effectively addressed. The team

conducted a walk-down of these systems to assess whether problems were

identified and entered into the corrective action program.

b. Assessments

1. Assessment - Effectiveness of Problem Identification

The team concluded in most cases that the licensee identified issues and

adverse conditions and entered them into the corrective action program in accordance with the licensee's corrective action program guidance and NRC

requirements. The team determined that the licensee generally was identifying problems at a low threshold and entering them into the corrective action program.

The team identified one condition adverse to quality that was not placed in the corrective action program. The licensee wrote approximately 17,000 condition reports during the two-year period of review. The team noted that this high rate of condition report generation is generally a sign of a healthy corrective action

program. The following issues were noted by the team:

• Through the review of NRC information notices over the assessment period, the team identified that the licensee failed to enter one information notice applicable to Waterford Steam Electric Station, Unit 3's emergency

diesel generator voltage regulators into their corrective action program. The team documented this as a Green non-cited violation in Section 4OA2.5.a of this report.

• The team identified that some main control room deficiencies, although identified by white identification tags, had not been entered into the licensee's corrective action program. The team documented this as a

Green non-cited violation in Section 4OA2.5.d of this report.

• The licensee self-identified a failure to initiate condition reports that resulted in missed operability assessments on two occasions when the emergency feedwater pump AB heat trace fell below the required

temperature per the operating instruction. The team documented this as

a licensee identified violation in Section 4OA7 of this report.

2. Assessment - Effectiveness of Prioritization and Evaluation of Issues

The team concluded that generally the licensee effectively prioritized and evaluated conditions adverse to quality. The team found that even with the high

number of condition reports initiated on a daily basis, the licensee's daily action

review committee pre-screening and the management review committees

- 10 - Enclosure 2 effectively assessed each condition adverse to quality. The following are issues

the team identified or reviewed during the inspection:

• The licensee's extent of condition review for an incorrect preventive maintenance classification of a limit switch identified additional incorrect classifications. However, the team identified that the licensee failed to initiate a separate condition report to document these additional errors

and, therefore, failed to ensure the testing requirements for each of the

newly identified components were met until challenged by the team. This

was documented in Condition Report CR-WF3-2012-03557.

• The team identified that the licensee performed an inadequate apparent cause evaluation of a failure of the security diesel generator. The evaluation identified one cause as being an incorrect maintenance

classification. When the licensee found the component was properly

classified in its preventative maintenance optimization program, the licensee did not revise their apparent cause. Instead, they determined

other corrective actions to address security equipment issues.

• The team identified that the apparent cause evaluation for inservice testing failures of the main feed isolation valves was determined to be incorrect. The licensee first determined that the failure was the result of

moisture intrusion in the hydraulic fluid. However, additional failures and

a subsequent root cause analysis showed that the failure mechanism

was actually interior varnishing. This was identified by review of external operating experience that was available, but missed during the initial apparent cause evaluation.

• The team identified a minor violation of 10 CFR Part 50, Appendix B, Criterion V, that is not subject to enforcement action in accordance with

the NRC's Enforcement Policy. The licensee downgraded a Category A

condition report to Category B without obtaining approval of the condition

review group as required by Procedure EN-L1-102, "Corrective Action Program." This was documented in Condition Report CR-WF3-2012-

03325. * The team reviewed roll up Condition Report CR-WF3-2011-07610, which identified that the quality of six previous causal analyses was inadequate.

• The team identified that the licensee categorized many conditions adverse to quality on the diesel fire pump as Category D. Although their process allowed this, they could have identified and corrected non-conforming trends in the diesel fire pumps more effectively with a higher prioritization. This was documented in Condition Report CR-WF3-2012-

03747.

- 11 - Enclosure 2

• The team determined that the licensee categorized a problem with the steam generator feedwater pump B requiring manual operation as an "Operator Burden" when it could have met the definition of an "Operator

Workaround," which carried a higher level of prioritization in the licensee

work planning process.

• The team reviewed a licensee failure to frequently and regularly review a degraded and nonconforming condition associated with the reactor coolant pump N-9000 stage seals as required by Procedure EN-OP-104,

"Operability Determination Process". This is an example of the licensee

not thoroughly evaluating problems, such that the resolutions address

causes and extent of conditions, as necessary. This was documented in

NRC Inspection Report 05000382

/2011002 as a Green non-cited

violation.

The team reviewed a number of condition reports that involved operability reviews to assess the quality, timeliness, and prioritization of operability

assessments. In general, both immediate and prompt operability assessments

reviewed were adequately completed in a timely manner.

3. Assessment - Effectiveness of Corrective Actions

Overall, the team concluded that the licensee generally developed appropriate corrective actions to address problems. However, the team identified a number of corrective actions associated with conditions adverse to quality that were not completed in a timely manner:

• The team identified that the licensee failed to take timely corrective actions to correct a design basis analysis for the emergency feedwater pump AB after the removal of required heat trace on the steam supply

piping. The team documented this as a Green non-cited violation in

Section 4OA2.5.b of this report.

• The team identified that the licensee failed to take timely corrective actions to establish a basis through analysis for the initiation of flood control measures at a river level of 24 feet. The team documented this as

a Green cited violation in Section 4OA2.5.c of this report.

• The team identified that the licensee failed to have a GMPO/Director approve a due date extension on a long-term corrective action from CR-WF3-2011-00887 (Corrective Action 13), which is not permitted by Procedure EN-LI-102, "Corrective Action Program". This resulted in a

minor violation of 10 CFR Part 50, Appendix B, Criterion V, that is not

subject to enforcement action in accordance with NRC's Enforcement

Policy. The corrective action was to complete an engineering analysis to

determine the scope of modifications needed for the steam driven

- 12 - Enclosure 2 emergency feedwater turbine steam supply piping. This was documented in Condition Report CR-WF3-2012-03461.

• The team identified a failure to complete a corrective action to validate data for work hours for security personnel. This resulted in a minor violation of 10 CFR 26.205.e that is not subject to enforcement action in accordance with the NRC's Enforcement Policy. This was documented in

Condition Report CR-WF3-2012-03729.

• The team reviewed a licensee failure to take or perform effective corrective actions for boric acid leaks for the past seven years. This is an example of the licensee's failure to effectively correct identified boric acid leaks in a timely manner. This was documented in NRC Inspection Report 05000382/2010006 as a Green non-cited violation.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope The team examined the licensee's program for reviewing industry operating

experience, including reviewing the governing procedure and self-assessments.

The team reviewed a sample of 10 condition reports examining operating experience documents that had been issued during the assessment period to determine whether the licensee had appropriately evaluated the notification for relevance to the facility. The team then examined whether the licensee had entered those items into their corrective action program and assigned actions to

address the issues. The team reviewed a sample of root cause evaluations and

corrective action documents to verify whether the licensee had appropriately

included industry-operating experience.

b. Assessment

Overall, the team determined that the licensee was adequately evaluating industry operating experience for relevance

to the facility, based on reviewing a sample of 10 condition reports examining industry operating experience. The licensee entered all but one applicable item in the corrective action program in

accordance with station procedures. The team concluded that the licensee was

evaluating industry operating experience when performing root cause and

apparent cause evaluations. Both internal and external operating experiences

were being incorporated into lessons learned for training and pre-job briefs. The following are issues the team identified or reviewed during the inspection:

• The team identified through the review of NRC information notices over the assessment period that the licensee had failed to enter one information notice applicable to Waterford 3 emergency diesel generator

voltage regulators into their corrective action program. In response, the

licensee did a complete audit of all NRC information notices issued during

- 13 - Enclosure 2 the assessment period and found no other discrepancies. The team documented this as a Green non-cited violation in Section 4OA2.5.a

of this report.

• The team reviewed three examples from this assessment period of the licensee's failure in the use of operating experience, resulting in the licensee not implementing and institutionalizing operating experience

through changes to station processes, procedures, equipment, and

training programs.

o The team reviewed a licensee failur

e to implement a preventative maintenance activity to replace dry cooling tower process analog control cards based on internal and industry-wide operating

experience that documented previous failures of process analog

control cards due to age-related degradation after 15 years. This

was documented in NRC Inspection Report 05000382/2011004 as a Green non-cited violation.

o The team reviewed a licensee failure to identify that varnish deposits were causing the main feedwater isolation valve to fail its

inservice testing. This resulted from the licensee's failure to use relevant external operating experience to identify that other sites experienced similar failures of feedwater isolation valves due to varnish deposits on the interior surfaces. This was documented in

NRC Inspection Report 05000382/2011005 as a Green non-cited

violation.

o The team reviewed a licensee failure to evaluate the internal condition of the condensate and refueling water storage pool

structures through performance of appropriate preventative

maintenance after previous documented industry-wide operating

experience of concrete degradation due to boric acid. This was documented in Inspection Report 05000382/2011003 as a Green non-cited violation.

.3 Assessment of Self-Assessments and Audits a. Inspection Scope The team reviewed a sample size of 22

licensee self-assessments, surveillances, and audits to assess whether the licensee was regularly identifying performance trends and effectively addressing them. The team reviewed audit reports to assess the effectiveness of assessments in specific areas. The team evaluated the use of self- and third party assessments, the role of the quality assurance department, and the role of the performance improvement group related to

licensee performance. The specific self-assessment documents reviewed are listed in the Attachment.

- 14 - Enclosure 2 b. Assessment

The team concluded that the licensee had an effective self-assessment process. Licensee management was involved with developing tactical self-assessments. The team determined that self-assessments were self-critical and thorough

enough to identify deficiencies. The following are issues the team reviewed

during the inspection:

• The team reviewed a licensee self-assessment of plant status and configuration control performed in March 2012. This self-assessment was an opportunity for the site to identify and address the issues associated with control room deficiencies documented in Section 4OA2.5.d of this report, but the assessment did not discuss them.

• The team reviewed the licensee's failure to perform an adequate risk assessment associated with the maintenance window for the turbine

driven emergency feedwater pump. This is an example of the licensee's failure to use independent and self-assessments because the licensee performed a probabilistic risk assessment model update in April 2009, but failed to identify an assumption crediting operator actions that were not in

procedures. This was documented in NRC Inspection

Report 05000382/2011007 as a Green non-cited violation.

.4 Assessment of Safety-Conscious Work Environment

a. Inspection Scope

The inspection team conducted individual interviews with over 30 individuals from a cross-section of functional organizations: engineering, operations, maintenance, quality assurance, radiation protec

tion, chemistry, security officers, and contract personnel. Both supervisory and non-supervisory personnel were

included in these interviews. The team conducted these interviews to assess

whether conditions existed that would challenge the establishment of a safety-

conscious work environment (SCWE) at Waterford 3. The team also interviewed the Waterford 3 employee concerns program manager and reviewed the last two safety culture self-assessment documents.

b. Assessment

Overall, the team concluded that a safety-conscious work environment exists at Waterford Steam Electric Station, Unit 3. Employees demonstrated familiarity with the various avenues available to raise safety concerns. They appeared

comfortable with submitting all nuclear safety issues.

The team noted a potential vulnerability in the licensee's safety-conscious work environment from discussions with plant personnel. There was a perception among some members of the plant staff that management may use the condition

- 15 - Enclosure 2 report process to discipline workers when personnel errors were documented in the condition reports. Additionally, some personnel stated that they did not write

condition reports, but rather they passed the comments along to supervisors who would enter them into the corrective action program.

Overall, most individuals were familiar with the employee concerns program and

its location on site. There was visibility of the program throughout the site. Many

of the individuals interviewed had knowledge of the employee concerns

manager; however, no one interviewed indicated having direct interactions with the employee concerns manger during the inspection period. Personnel understood and were confident in the confidentiality of the program.

Site personnel have received initial and annual refresher training, which provided

instruction on safety-conscious work environment policies. Many of the individuals interviewed were familiar with this training and with the overall message in the training. However, not everyone was familiar with the details of

the policy. None of the individuals in

terviewed cited any examples of harassment, intimidation, retaliation or discrimination, or any negative reactions from management when individuals raised nuclear safety concerns. Finally, individuals indicated that if they were to believe unsafe conditions existed, they would feel comfortable stopping work without fear of retaliation, even if such

actions would prolong an outage or extend a planned schedule.

.5 Specific Issues Identified During This Inspection

a. Failure to Promptly Determine the Operability of the Emergency Diesel Generators

Introduction. The team identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for a

failure to follow

Procedure EN-OP-104, "Operability Determination Process." Specifically, the licensee failed to determine the operability of the emergency diesel generators immediately upon discovery without delay and in a controlled manner using the best information available

in response to NRC Information Notice 2010-04.

Description. The team reviewed the licensee's corrective actions taken in response to an NRC Information Notice. On February 26, 2010, the NRC issued Information Notice 2010-04, "Diesel Generator Voltage Regulation System Component [Failure] Due to Latent Manufacturing Defect." This information notice describes the failure of a linear

power reactor in an emergency diesel generator voltage regulation system at a plant where the licensee's preventive maintenance program did not address the emergency diesel generator excitation system magnetic components.

The licensee completed an evaluation of the information notice per Procedure EN-OE-100, "Operating Experience Program," on July 1, 2010. This evaluation indicated that Waterford 3 was vulnerable and susceptible to the issue, but the licensee failed to

issue a condition report as required by their procedure. The failure to initiate a condition

report resulted in the licensee's failure to perform an operability determination of the

- 16 - Enclosure 2 emergency diesel generators as required by Procedure EN-OP-104,"

Operability Determination Process," Revision 6.

In the evaluation, the licensee considered the fact that they had an "Action Request" in their system that addressed a similar concern to be an acceptable response to this information notice. Action Request 079684 was initiated on December 10, 2009, to

address recommendations from an INPO assistance visit in 2007 and it included an

action to add routine thermography inspections within the voltage regulator cabinets to

their preventative maintenance program. The Entergy Nuclear Corporate Operating Experience group also reviewed this information notice on March 4, 2010. In response, they issued a specific action through their operating experience database to evaluate the information notice to each Entergy site. However, they failed to issue one to

Waterford 3.

The licensee started routing Action Request 079684 for approval, but they stopped on March 15, 2010. The licensee attributed this to an incomplete turnover by departing personnel. No other approval actions were taken until April 16, 2012, when the request

was routed to the next person in the approval process. Again, no further action was

taken, and the action request was not completed when the inspection team reviewed the issue.

The inspectors questioned why there was no condition report generated and why the

action request had not been completed more than two years after issuance. In

particular, the inspectors questioned whether there was an operability concern for the

emergency diesel generators. The licensee recognized their failure to issue a condition report and perform an operability determination. They performed a prompt operability determination based on operating data, work history, and no observed degradation in

performance, and declared the emergency diesel generators operable. In addition, they plan to conduct the thermography during the next scheduled emergency diesel

generator surveillance.

The licensee initiated CR-WF3-2012-00596 and CR-WF3-2012-03761 to address the

issue. They also initiated CR-HQN-2012-00857 to address the failure of the corporate

organization to include Waterford 3 in their site-specific requests.

Analysis. The failure to promptly perform an operability determination of the emergency diesel generators in response to NRC Information Notice 2010-04 was a performance deficiency. The performance deficiency was more than minor because it was associated

with the equipment performance attribute of the Mitigating Systems Cornerstone and

affected the cornerstone objective to ensure the availability, reliability, and capability of

systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to promptly determine the operability of the diesel generators after obtaining information of a potential condition adverse to quality. In

accordance with NRC Inspection Manual Chapter 0609, Attachment 4, "Initial

Characterization of Findings," the issue was determined to affect the Mitigating Systems

Cornerstone. In accordance with NRC Inspection Manual Chapter 0609, Appendix A,

"The Significance Determination Process (SDP) for Findings at Power," the issue was

- 17 - Enclosure 2 determined to have very low safety significance (Green) because it was not a deficiency affecting the design or qualification of the system, it did not represent a loss of system or function, and it was a Technical Specification system but did not represent an actual loss of function of a single train for greater than it allowed outage time. Specifically, the licensee performed an operability determination in response to the inspectors' questions

and determined the emergency diesel generators were operable based on a review of

surveillance data and maintenance records. This finding had a cross-cutting aspect in

the problem identification and resolution area, operating experience component, in that

the licensee failed to systematically collect, evaluate, and communicate to affected internal stakeholders in a timely manner relevant internal and external operating

experience P.2.a].

Enforcement. Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in

accordance with these instructions, procedures, or drawings. Licensee Procedure

EN-OP-104, "Operability Determination Process," Revision 6, Section 5.1 step 13

required that an operability should be determined immediately upon discovery without delay and in a controlled manner using the best information available. Contrary to this requirement, from July 1, 2010, to July 25, 2012, the licensee failed to accomplish an activity affecting quality prescribed by documented instructions. Specifically, the

licensee failed to determine the operability of the emergency diesel generators as

required by Licensee Procedure EN-OP-104 in response to NRC Information

Notice 2010-04. The licensee immediately determined the operability of the emergency diesel generators based on operating data and work history, and they established a reasonable basis for operability. This violation is being treated as an NCV, consistent

with Section 2.3.2 of the Enforcement Policy, because it was of very low safety

significance (Green) with no actual or potential safety consequences and was entered

into the licensee's corrective action program as Condition Report CR-WF3-2012-03761 to address recurrence. (NCV 05000382/2012008-01, "Failure to Promptly Determine the

Operability of the Emergency Diesel Generators")

b. Failure to Take Corrective Action Associated with the Emergency Feedwater Pump AB

Introduction. The team identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," for the failure to take timely corrective action for a condition adverse to quality. Specifically, the licensee failed to restore a

degraded condition, which included a corrective action to perform a new design analysis

for the emergency feedwater pump AB after the removal of heat trace circuit 1-8C

despite having a reasonable amount of time to complete it.

Description. The team performed an in-depth review of corrective actions associated

with the emergency feedwater system.

The turbine driven emergency feedwater pump AB has steam piping that is maintained at a high temperature with a heat trace to

prevent excessive condensation from developing, which could reduce the reliability of

the pump to perform its design function. The licensee removed heat trace circuit 1-8C

- 18 - Enclosure 2 from a horizontal section of steam piping because the heat trace was not maintaining the piping above the required setpoint. In May 2011, the licensee determined that

emergency feedwater pump AB was operable but degraded. A corrective action was initiated to perform a design analysis using RELAP to determine what modifications needed to be performed on the system to return the system to a fully operable status.

The team identified that the licensee extended the due date twice for the corrective

action, first from February 23 to June 15, 2012, and then from June 15 until

October 12, 2012. The last extension was approved due to lack of engineering resources resulting from other activities placed at a higher priority by Waterford 3 management. The team determined that from May 2011 to August 2012, a corrective

action to perform a design analysis for the long-standing equipment issue of determining

whether or not a plant modification is needed to maintain the system operable had not been performed in a timely manner. Currently, plant operators are required once per shift to perform temperature verifications of the heat trace to ensure condensation does

not form in the steam supply pipe to the turbine driven pump and maintain emergency feedwater pump AB in an operable, but degraded, status until the design analysis is

complete. The licensee has entered the concern into their corrective action program as

Condition Report CR-WF3-2012-03754.

Analysis. The team determined that the failure to complete the corrective action of performing a new design analysis to determine if emergency feedwater pump AB required a design modification based on the analysis in a timely manner was a

performance deficiency. The performance deficiency was more than minor because it

affected the equipment performance attribute of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failure to implement this corrective action could result in reduced reliability of the emergency feedwater pump

AB. In accordance with NRC Inspection Manual Chapter 0609, Attachment 4, "Initial

Characterization of Findings," the issue was determined to affect the Mitigating Systems Cornerstone. In accordance with NRC Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process (SDP) for Findings at Power," the issue was

determined to have very low safety significance (Green) because it affected the design or qualification of mitigating systems, structures, and components; however, the systems, structures, and components maintained operability. This finding had a cross-cutting aspect in the human performance area, resources component, in that the licensee failed to minimize a long-standing equipment issue adequately to assure nuclear safety H.2(a).

Enforcement. Title 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," states, in part, that measures be established to assure that conditions adverse to quality, such as failures, malfunction, deficiencies, deviations and non-conformances are promptly identified and corrected. Contrary to this requirement, from May 2011 through August 2012, the licensee failed to assure that measures were established to assure

that a condition adverse to quality was promptly corrected. Specifically, the licensee failed to take prompt corrective action to restore a degraded condition by not performing

- 19 - Enclosure 2 a design analysis for emergency feedwater pump AB after heat trace circuit 1-8C was removed. Consequently, plant operators are required once per shift to perform

temperature verifications of the heat trace to ensure condensation does not form in the steam supply pipe to the turbine driven pump and maintain emergency feedwater pump AB in an operable, but degraded, status until the design analysis is complete. This

violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement

Policy because it was of very low safety significance (Green) with no actual or potential

safety consequence and was entered into the licensee's corrective action program as CR-WF3-2012-03754 to address recurrence. (NCV 05000382/2012008-02, "Failure to Take Corrective Action Associated with Emergency Feedwater Pump AB")

c. Failure to Take Timely Corrective Action to Establish a Basis for Flood Control Measures

Introduction. The team identified a Green cited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control", for the failure to establish measures to assure that applicable regulatory requirements and the design basis as defined in 10 CFR 50.2 are

correctly translated into procedures. Specifically, the licensee has not determined a

basis for the level at which flood control measures are initiated, two years after receiving a non-cited violation for the same deficiency.

Description. The team reviewed the licensee's corrective actions taken in response to a non-cited violation from 2010 documented as NCV 2010006-02, "Non-conservative

Technical Specification 3.7.5 Action Statement." The licensee entered this violation into

their corrective action program under CR-WF3-2010-03232 on May 24, 2010. The

licensee determined that Technical Specification 3.7.5 "Flood Protection" was not required to be included in their technical specifications and submitted an amendment to move it to the Technical Requirements Manual. As an interim compensatory measure,

the licensee modified their Procedure OP-901-521, "Severe Weather and Flooding" to

include an action to start shutting flood control doors at a river level of 24 feet instead of

27 feet. The required actions included verifying that all flood control penetrations below a level of 30 feet were shut within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> before the river was projected to reach 27 feet. There

are seven flood control doors of varying sizes that are required to be shut and two valves

that are required to be locked shut. Five of these doors and both valves are normally shut during power operations, but may be open during outages. Most of them require

entry into the Radiologically Controlled Area and one requires entry into a locked room for access.

The licensee recognized the need to establish a basis for initiating these actions at

24 feet, and issued Corrective Action 18 (CA-18) in CR-WF3-2010-03232 on March 10, 2011, to formally evaluate and document whether 24 feet was an acceptable river level elevation at which to initiate flood control measures. The CA-18 due date was

extended twice and on February 24, 2012, they

determined that the methodology they intended to use was not acceptable. CA-18 was closed to Corrective Action 23 (CA-23)

which directed the licensee to issue an engineering change using the methodology used

- 20 - Enclosure 2 in Waterford 3 UFSAR Section 2.4.3.7. The due date for CA-23 was itself extended to September 30, 2012.

The inspection team questioned why the licensee had not completed the calculation to justify their basis for their compensatory measures, noting that it had been over

two years since the original violation was identified. The licensee initiated

CR-WF3-2012-03752 to address this concern. The inspectors verified through

walk-downs, procedure reviews, and historical data that the licensee's use of 24 feet did not represent an immediate operability concern and that the current river level was sufficiently low to allow time for the licensee to correct the deficiency.

Analysis. The failure to complete the corrective action to establish a basis for flood control measures in a timely manner was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection from external events attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that

respond to initiating events to prevent undesirable consequences. Specifically, the

licensee failed to verify through calculations or analysis that the actions taken to secure

flood doors could be completed in time to protect safety-related equipment from flooding due to a levee failure. In accordance with NRC Inspection Manual Chapter 0609, Attachment 4, "Initial Characterization of Findings," the issue was determined to affect

the Mitigating Systems Cornerstone. In

accordance with NRC Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process (SDP) for Findings

at Power", the issue was determined to have very low safety significance (Green)

because it did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event. Specifically, the inspectors confirmed that the licensee could reasonably ensure the flood control

doors could perform their safety function. This finding had a cross-cutting aspect in the

human performance area, resources component in that the licensee failed to maintain

long term plant safety by maintenance of design margins and ensuring engineering backlogs low enough to support safety H.2.a].

Enforcement. Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion III, "Design Control," states, in part, that measures shall be established to

assure that applicable regulatory requirements and the design basis, as defined in

10 CFR 50.2, are correctly translated into specifications, procedures and instructions. Contrary to the above, from March 10, 2011, to August 2, 2012, the licensee failed to establish measures to assure that applicable regulatory requirements and the design

basis, as defined in 10 CFR 50.2, were correctly translated into specifications,

procedures and instructions. Specifically, the licensee had not established a design

basis to determine the river level at which flood control measures were to be initiated for closing the water tight doors, as required in Procedure OP-901-521, "Severe Weather and Flooding." The licensee demonstrated sufficient safety margin based on historical

data and current river levels to provide assurance that this is not an immediate safety

concern. Due to the licensee's failure to restore compliance within a reasonable time

- 21 - Enclosure 2 following previous NCV 05000382/2010006-02, this violation is being cited as a Notice of Violation consistent with Section 2.3.2 of the NRC Enforcement Policy. This is a

violation of 10 CFR 50, Appendix B, Criterion III. A Notice of Violation is attached. (VIO 05000382/2012008-03, "Failure to Take Timely Corrective Action to Establish a Basis for Flood Control Measures")

d. Failure to Ensure Operator Knowledge of Equipment Status

Introduction. The team identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for a

failure to follow

Procedure EN-OP-115, "Conduct of Operations". Specifically, the licensee failed to ensure that control room operators knew the status of equipment at all times.

Description. The team reviewed how the licensee was addressing deficiencies in plant instrumentation, controls, and equipment that impacted the ability of operators to properly operate the plant. This included a review of the licensee's program to identify,

compensate for, and correct these plant deficiencies and a walk-down of the control

room.

While interviewing the person responsible for tracking plant deficiencies, the inspectors discovered that the licensee had two separate governing procedures. The licensee used

the Entergy Fleet Administrative Procedure EN-FAP-OP-006, "Operator Aggregate

Impact Index Performance Indicator," to track several categories of plant deficiencies in a standardized spreadsheet. The licensee also had the local departmental Operating Instruction OI-002-000, "Annunciator, Control Room Instrumentation and Workarounds Status Control". This instruction had different definitions for categories of plant deficiencies and directed the use of a different database.

The inspectors then interviewed the on shift operators in the control room and reviewed

both databases. The inspectors identified several issues:

• The person responsible for tracking plant deficiencies was only using the fleet administrative procedure and was unaware of the operating instruction.

• On one shift, the shift technical advisor believed the fleet administrative procedure was being used and was not aware of the operating instruction, while the control room supervisor believed the operating instruction was being used and was not aware of the fleet administrative procedure.

• The database required by the operating instruction had not been maintained

for two years.

• The operating instruction did not have a category for "Operator Burdens"; however, the shift crew differentiated between "Operator Workarounds" and

"Operator Burdens". In most cases, they chose the less conservative

designation of "Operator Burden".

- 22 - Enclosure 2 * The fleet administrative procedure was intended for fleet performance reporting, not plant deficiency control. It does not direct any actions to

address and correct plant deficiencies.

• The operating instruction subcategorizes "Workarounds" by scheduling of resources rather than by risk significance or impact to operators. The fleet

administrative procedure does not subc

ategorize "Operator Workarounds" or "Operator Burdens", but the licensee carried over this practice to the fleet

administrative procedure spreadsheet. This could lead to improper prioritization of corrective actions.

• The operating instruction directs identification of plant deficiencies through a review of work requests, but it does not require a review of condition reports.

• Some plant deficiencies were not entered into either database.

• Operators were using the same tags for "Control Room Deficiencies" and informal operator notes. These notes are not controlled by either procedure.

• A list of plant deficiencies was not immediately available to control room operators.

The inspectors determined that when the fleet administrative procedure was issued in March 2010, the licensee changed their process for tracking deficiencies. The licensee

Procedure W2.109, "Procedure Development, Review & Approval," is safety-related and

requires implementation and maintenance of procedures and departmental instructions. This procedure prescribes a process for approving and revising procedures and

instructions and conducting necessary training. When the licensee began tracking plant

deficiencies per the fleet administrative procedure, the licensee did not revise the

operating instruction to conform to the new process, and the licensee did not train all affected personnel on the new process. As a result, the operators did not maintain a consistent accurate list and were not aware of all plant deficiencies, and therefore were

not aware of the status of all plant equipment. This was not in accordance with

Procedure EN-OP-115, "Conduct of Operations," Revision 9, Section 5.13 step 1, which states that the status of plant equipment is known at all times by plant operators.

The licensee initiated CR-WF3-2012-03732 to address the issue. The licensee will revise the operating instruction to address the process issues and make the intended

changes.

Analysis. The failure to ensure that operators were aware of the status of all plant equipment was a performance deficiency. The performance deficiency was more than minor because it was associated with the procedure quality attribute of the Initiating

Events Cornerstone and affected the cornerstone objective to limit the likelihood of those

events that upset plant stability and challenge critical safety functions during shutdown

as well as power operations. Specifically, the licensee failed to implement a procedure

designed to ensure operators were aware of deficiencies in the instrumentation, controls,

- 23 - Enclosure 2 and operation of nuclear plant systems. In accordance with NRC Inspection Manual Chapter 0609, Attachment 4, "Initial Characterization of Findings," the issue was

determined to affect the Initiating Events Cornerstone. In accordance with NRC Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process (SDP) for Findings at Power," the issue was determined to have very low safety significance (Green) because it did not cause a reactor trip and the loss of mitigation

equipment relied upon to transition the plant from the onset of the trip to a stable

shutdown condition. This finding had a cross-cutting aspect in the human performance

area, work practices component, in that the licensee failed to define and effectively communicate expectations regarding procedural compliance, and personnel did not follow procedures H.4.b].

Enforcement. Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstance and shall be accomplished in accordance with these instructions, procedures, or drawings. Procedure EN-OP-115,

"Conduct of Operations," Revision 9, Section 5.13, step 1, states that the status of plant

equipment is known at all times by plant operator

s. Contrary to this requirement, from March 2, 2010, to August 1, 2012, the licensee failed to accomplish an activity affecting quality in accordance with the documented instructions appropriate to the circumstance.

Specifically, the licensee failed to ensure operators knew the status of plant equipment

at all times in accordance with Licensee Procedure EN-OP-115, "Conduct of

Operations." The licensee has a corrective action to revise their operating instruction for

tracking plant deficiencies, and none of the current plant deficiencies represents an immediate safety concern. This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy, because it was of very low safety significance

(Green) with no actual or potential safety consequences and was entered into the

licensee's corrective action program as CR-WF3-2012-03732 to address recurrence.

(NCV 05000382/2012008-04, "Failure to Ensure Operator Knowledge of Equipment

Status") e. Failure to Develop Effective Corrective Actions to Preclude Repetition

Introduction. The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Actions," because the licensee failed to determine the cause of a significant condition adverse to quality and take corrective actions to prevent recurrence. Specifically, the licensee failed to assure that the cause of the

condition was determined and corrective action taken to preclude repetition associated with a contractor's non-compliance with site procedural requirements.

Description. During refuel outage 16 in 2009, contract instrumentation and control technicians performed a functional test on a feedwater heater level switch according to

work order instructions. Following restoration, a plant transient occurred because a

valve was out of position (CR-WF3-2009-7420). The licensee determined that the event constituted a significant condition adverse to quality in accordance with guidance from

Procedure EN-LI-102, "Corrective Action Process." During the valve manipulation, the

- 24 - Enclosure 2 work instructions called for concurrent verification. However the licensee's root cause analysis determined that the contract workers failed to perform concurrent verification as

required by the procedure (NCV 2011003-04). The contract workers knew the procedural requirement, but they behaved inappropriately when they chose not to follow the instructions. The licensee's root cause analysis did not determine why the contract

workers chose not to follow the procedure. The licensee's corrective action to preclude

repetition (CAPR) of this significant condition adverse to quality (SCAQ) was to release the contract workers for not following the procedure and prohibit them from future work

at Entergy sites. No actions to preclude repetition that addressed the underlying cause of the failure to perform concurrent verification were taken. The team identified that despite guidance provided in Procedure EN-LI-118, Attachment 9.9, "Root Cause

Evaluation Process," which states that discipline of individuals is not an appropriate

CAPR, disciplinary action was the only CAPR identified in the root cause for

CR-WF3-2009-07420 performed on January 7, 2010.

The failure to determine the cause of a significant condition adverse to quality and take

corrective action to preclude repetition had no actual consequences on nuclear plant

safety. However, the failure to determine the cause of the condition adverse to quality and take corrective action to preclude repetition from an ineffective CAPR has the ability to lead to more significant safety consequences. The licensee documented this violation in Condition Reports CR-WF3-2012-03769 and CR-WF3-2012-03772. The corrective

actions include developing additional training and provisions to provide additional

contractor oversight.

Analysis. The failure to determine the cause of a significant condition adverse to quality and take corrective action to preclude repetition was a performance deficiency. The performance deficiency was more than minor because if left uncorrected, it could lead to

more significant consequences, therefore it is a finding. Specifically, failure to determine

the cause of a significant condition adverse to qualify and take corrective action to

prevent recurrence can result in recurrence of the condition. In accordance with NRC Inspection Manual Chapter 0609, Attachment 4, "Initial Characterization of Findings," the issue was determined to affect the Initiating Events Cornerstone. In accordance with

NRC Inspection Manual Chapter 0609, Appendix A, "The Significance Determination

Process (SDP) for Findings at Power," the issue was determined to have very low safety

significance (Green) because the finding did not cause a reactor trip and the loss of

mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. This finding had a cross-cutting aspect in the human performance, work practice component, in that the licensee failed to follow guidance in

the root cause evaluation procedure when developing appropriate corrective actions to

prevent repetition H.4(b).

Enforcement. Title 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," states, in part, in the case of significant conditions adverse to quality, the measures shall

assure that the cause of the condition is determined and corrective action taken to

preclude repetition. Contrary to this requirement, on January 7, 2010, for a significant

condition adverse to quality, the licensee failed to take measures to assure that the

cause of the condition was determined and corrective actions taken to preclude

- 25 - Enclosure 2 repetition. Specifically, the licensee did not determine the underlying cause of the failure of the site contract workers to comply with licensee's procedural requirements nor were

corrective actions taken to preclude repetition of the condition. The licensee's corrective actions to address this problem include developing additional training and provisions to provide additional contractor oversight. This violation is being treated as an NCV,

consistent with Section 2.3.2 of the Enforcement Policy because it was of very low safety

significance (Green) with no actual or potential safety consequence and was entered

into the licensee's corrective action program as CR-WF3-2012-03769 and

CR-WF3-2012-03772 to address recurrence. (NCV 05000382/2012008-05, "Failure to Develop Effective Corrective Actions to Preclude Repetition")

4OA6 Meetings

Exit Meeting Summary

On August 2, 2012, the team presented the inspection results to Keith Nichols, Director of

Engineering, and other members of the licensee staff. The licensee acknowledged the issues

presented. The inspector asked the licensee whether any materials examined during the

inspection should be considered proprietary. No proprietary information was identified.

On August 23, 2012, the team exited with the revised characterization of the inspection results

to William McKinney, Acting Director Nuclear Safety and Assurance, and other members of the

licensee staff. The licensee acknowledged the issues presented.

On September 24, 2012, the team exited with the revised characterization of the inspection results to Keith Nichols, Director of Engineering, and other members of the licensee staff. The licensee acknowledged the issues presented.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements, which meets the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as an NCV.

• Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings and shall be

accomplished in accordance with these instructions, procedures, or drawings. Contrary to this requirement, on May 10 and May 12, 2011, the licensee failed to accomplish an activity affecting quality as prescribed by the documented procedure. Specifically, the licensee failed to perform operability reviews when heat trace circuit 1-8C fell below the

operating instruction temperature on the steam supply piping to the emergency

feedwater pump in accordance with Procedure EN-OP-104, "Operability Determination Process". The team determined that this finding was of very low safety significance (Green) because it affected the design or qualification of a mitigating system structure

component; however, the system structure component maintained its operability.

- 26 - Enclosure 2 The emergency feed water pump AB was declared inoperable on May 14, 2011; however, subsequent evaluation declared the pump operable but degraded.

This was documented in the licensee's corrective action program as Condition

Reports CR-WF3-2011-03599 and CR-WF3-2011-03600.

ATTACHMENTS: SUPPLEMENTAL INFORMATION

INFORMATION REQUEST

A1-1 Attachment 1

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

S. Adams, Planning Scheduling and Outage Manger

J. Bourgeois, Acting Chemistry Manager

E. Brauner, Supervision of System Engineering K. Cook, General Manager, Plant Operations

G. Fey, Emergency Planning Manager

S. Fontenot, Acting Corrective Actions and Assessment Manager

R. Gilmore, Engineering and Components Manager

J. Gumnick, Radiation Protection Manager D. Jacobs, Site Vice President, Operations J. Jarrell, Assistant Operations Shift Manager

B. Lanka, Manager, System Engineering Manager

B. Lindsey, Maintenance Manager

M. Mason, Acting Licensing Manager W. McKinney, Acting Director Nuclear Safety and Assurance K. Nichols, Director of Engineering

R. Porter, Design Engineering Manager

D. Rieder, Quality Assurance Supervisor

K. Rockwood, Acting Technical Training Supervisor

T. Sanders, Security Superintendant P. Stanton, Design Engineering Supervisor

NRC Personnel

R. Kumana, Project Engineer

R. Smith, Team Leader/Senior Resident Inspector D. Overland, Resident Inspector M. Young, Reactor Inspector

A1-2 Attachment 1

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened 05000382/2012008-03 VIO Failure to Take Timely Corrective Action to Establish a Basis for

Flood Control Measures (Section 4OA2.5.c)

Opened and Closed

05000382/2012008-01 NCV Failure to Promptly Determine the Operability of the Emergency Diesel Generators (Section 4OA2.5.a)05000382/2012008-02 NCV Failure to Take Corrective Action Associated with Emergency

Feedwater Pump AB (Section 4OA2.5.b)05000382/2012008-04 NCV Failure to Ensure Operator Knowledge of Equipment Status (Section 4OA2.5.d)05000382/2012008-05 NCV Failure to Develop Effective Corrective Actions to Preclude Repetition (Section 4OA2.5.e)

A1-3 Attachment 1 LIST OF DOCUMENTS REVIEWED

PROCEDURES

NUMBER TITLE REVISIONEN-LI-104 Self-Assessment and Benchmark Process 8 EN-LI-102 Corrective Action Process 19

EN-LI-118 Root Cause Evaluation Process 17

EN-LI-119 Apparent Cause Evaluation (ACE) Process 15

EN-OP-104 Operability Determination Process 6

EN-QV-100 Conduct of Nuclear Oversight 7

EN-QV-102 Quality Control Inspection Program 1

EN-QV-108 QA Surveillance Process 9

EN-MA-101 Fundamentals of Maintenance 10

OP-901-310 Loss of Train A Safety Bus 308

OP-903-115 Train A Integrated Emergency Diesel Generator / Engineering Safety Features Test

21 ME-007-005 Time Delay Relay

Setting Check, Adjustment and Functional Test

16 EN-TQ-201 Systematic Approach to Training Process 12 EN-TQ-201 Systematic Approach to Training Process 13

TM-OP-100 Operations Training Manual 16

EN-TQ-114 Licensed Operator Requalification Training Program Description

3 EN-TQ-126 Inprocessing Training Program 6

A1-4 Attachment 1

NUMBER TITLE REVISIONEN-TQ-126 Inprocessing Training Program 8 EN-TQ-107 General Employee Training 7

EN-EC-100 Guidelines For Implementation Of The Employee

Concerns Program

6 EN-MA-133 Control of Scaffolding 8 OP-002-007 Freeze Protection and Temperature Maintenance 18

EN-IS-102 Confined Space Program 8

OP-903-046 Emergency Feed Pump Operability Check 309

EN-NE-G-013 Human Reliability Analysis for PSA Models 1

OP-009-003 Emergency Feedwater 304

EN-FAP-OP-006 Operator Aggregate Impact Index Performance Indicator 0

OI-002-000 Operator Instruction Annunciator, Control Room Instrumentation and Workarounds Status Control

304 EN-OP-137 Licensed Operator Candidate Selection Process 2 EN-LI-125 NRC Cross-Cutting Analysis and Trending 1

EN-OE-100 Operating Experience Program 14

EN-LI-118-06 Common Cause Analysis (CCA) 3

OP-002-007 Freeze Protection and Temperature Maintenance 18

OP-903-053 Fire Protection System Pump Operability Test 17

UNT-005-013 Fire Protection Program 12

EN-FAP-LI-001 Condition Review Group (CRG) 3

A1-5 Attachment 1

NUMBER TITLE REVISIONEN-FAP-LI-003 Corrective Action Review Board (CARB) Process 8 EN-HU-103 Human Performance Error Reviews 7

EN-HU-106 Procedure and Work Instruction Use and Adherence 0

EN-PL-202 Personnel Expectations Related to Fatigue Management 0

EN-TQ-113 Initial Licensed Operator Training Program Description 7

OP-100-014 Technical Specification and Technical Requirements

Compliance

317 OP-901-521 Severe Weather and Flooding 305 EN-OE-100 Operating Experience Program 14

EN-FAP-AD-001 Fleet Administrative Procedure (FAP) Process 0

EN-AD-101-01 NMM Procedure Writer Manual 9

EN-AD-101 Procedure Process 14

EN-PL-155 Entergy Nuclear Change Management 4

W2.109 Procedure Development, Review & Approval 13

EN-NS-102 Fitness For Duty Program 9

EN-NS-117 Fitness For Duty Processes 6

EN-OM-123-02 Working Hour Limits eSOMS Users Guide 1

EN-OM-123 Fatigue Management Program 4

EN-PL-202 Personnel Expectations Related to Fatigue Management 0

EN-OP-115 Conduct of Operations

9

A1-6 Attachment 1 CALCULATIONS

NUMBER TITLE REVISION EC-C97-003 Probabilistic Evaluation of Tornado Missile Strike for

Waterford 3 Nuclear Station

0, Change 1EC-M00-004 Thermal-Hydraulic Calculation for the EFW Steam Supply

Valves (MS-401A(B)) and Lines

0 Calculation No. MNQ3-5 Flooding Analysis Outside Containment 4 EC-M99-010 Minimum Flow for DCT Sump Pump 0-2

134669-G-07 Scour Analysis and Scour Protection Design from a Hypothetical Levee Break

1 DRAWINGS NUMBER TITLE REVISION G-153 Feedwater, Condensate & Air Evacuation Systems G-151 Flow Diagram Main & Extraction Steam System 43 G-924 HVAC - Water Treatment Bldg. & Fire Pump House 6

G1370 Fire Protection Turbine Bldg. 2

OTHER DOCUMENTS

NUMBER TITLE REVISION/ DATE QS-2012-W3-008 QA Follow-up Surveillance of Category A Condition Reports initiated during April 2012

1 QS-2012-W3-007 QA Follow-up review of EN-QV-126 required issues initiated January, February, and March 2012

1 QS-2011-W3-015 QA Follow-up Surveillance of Category A Condition Reports initiated during September, 2011

July 26, 2011 QS-2011-W3-012 QA Follow-up Surveillance of the 2011 Corrective

Action Program (CAP) Audit

September 12, 2011

A1-7 Attachment 1

NUMBER TITLE REVISION/ DATE QS-2011-W3-009 QA Follow-up Surveillance of Quality Assurance

Finding CR-WF3-2011-3084

1 QS-2011-W3-008 QA Follow-up Surveillance of Category A Condition Reports Initiated During May 2011 June 13, 2011 QS-2011-W3-007 QA Follow-up Surveillance of Category A Condition Reports Initiated During April 2011

1 QS-2011-W3-006 QA Follow-up to Category A Condition Reports for

January and February 2011

1 LO-WLO-2011-

0007 Quality of Causal Analysis Focused Assessment October 13, 2011 LO-WLO-2011-

0053 Maintenance Training Focused Self-Assessment (I&C, Mechanical, Electrical)

July 29, 2011 LO-WLO-2011-

0124 Quality Assurance Self-Assessment Report December 9, 2011 LO-WLO-2012-

0015 Snapshot Assessment / Benchmark On: PME Performance May 23, 2012 LO-WLO-2012-

0030 Snapshot Assessment / Benchmark On: Maintenance - Advanced Qualifications

February 6, 2012

OE34343-20111008 Seismic Monitoring Systems Failed to Actuate

During a Seismic Event September 1, 2011

OE35212-20120211 Extraction Steam System Carbon Steel Reducer found Below Design Minimum Wall due to

Unpredicted Flow-Accelerated Corrosion

November 3, 2011

OE34934-20120107 Nuclear Regulatory Commission Red Finding Root

Cause Analysis Results December 9, 2011 LO-WLO-2010-

00143 Licensed Operator Requal 71111.11 Pre-Inspection Assessment

March 3, 2011 WLO-2011-00018 Evaluate the Effectiveness of Waterford 3 Shift Manager/STA Training Program November 3, 2011

LOR/STAR Biennial Written Exam Worksheet Examination # WWEX-LOR-11046R/S Examination # WEX-LOR-11043R/S

2011

A1-8 Attachment 1

NUMBER TITLE REVISION/ DATE Site Broadcast RCA Drain Limitations February 16, 2012 Waterford 3 - 2010 Employee Concerns Data

Analysis Waterford 3 - 2011 Employee Concerns Data

Analysis FCBT-GET-PATSS Entergy Fleet Specific Plant Access Training 17 Training Review Group Meeting Minutes June 9, 2010

WLP-TRNC-SATR Focused SAT Review 2

2 nd QTR 2010 Instructor Continuing Training Kickoff

LO-WLO-2010-

0059 Waterford 3 Equipment Reliability and Core Business Focused Self Assessment May 27-29, 2010 LO-WLO-2010-

0091 WF3 IST Program Focused Self Assessment August 20-24, 2010 LO-WLO-2011-

0041 Snapshot Assessment/Benchmark on: Relief Valve

Program October 26, 2011 WH-TB-11-5-A2 Evaluation Summary: Evaluation of Downstream Sump Debris Effects in Support of GSI-191 June 14, 2011 TB-11-5 Assessment of WCAP-16406-P-A Abrasive Wear Model and Recommendations

March 1, 2011 WH-TB-10-4-A2 Evaluation Summary: CEDM Upper Pressure

Housing Venting August 17, 2010 TB-10-4 Potential for Stress Corrosion Cracking in Control Element Drive Mechanism Upper Pressure Housing

April 12, 2010 SD-EFW Emergency Feedwater 11 DCP-3506 Auxiliary Steam Test Connection for EFW Pump

A/B March 12, 1997

A1-9 Attachment 1

NUMBER TITLE REVISION/ DATE DCP-3506 Auxiliary Steam Test Connection for EFW Pump

A/B July 24, 1998 DCP-3506 Auxiliary Steam Test Connection for EFW Pump

A/B February 25, 1999 DCP-3506 Auxiliary Steam Test Connection for EFW Pump

A/B May 26, 1999 DC-3526 EFW Heat Trace Reliability Improvements September 3, 1999

EC 37263 Replacement of MCC DCT Cubicle Compartments 0

Operability Assistance Tool

STI-WO-275977 CS117A, Shutdown Cooling Heat Exchanger Discharge Stop Check Valve Leakage Test

0 EC 31375 Clarify Safety Function and Leakage Criteria for CS-

111A(B) and CS-117A(B)

Draft W3-DBD-003 Emergency Feedwater System 301

CRG Report for Tuesday July 31, 2012

CRG Report for Thursday August 2, 2012

Operational Focus July 31, 2012

Operational Focus August 2, 2012

LO-WLO-2010-

00061 Status of the Safety Conscious Work Environment

in Security

July 6, 2010 LO-WLO-2012-

006 Operations Assessment of Plant Status and

Configuration Control

March 1, 2012

A1-10 Attachment 1

NUMBER TITLE REVISION/ DATE LPL-EQA-4.2B Environmental Qualification Assessment on Allis-

Chalmers Form Wound Motors Used in the

Waterford SES Unit No. 3

2 NRC IN 2010-04 Diesel Generator Voltage Regulation System Component Due to Latent Manufacturing Defect

February 26, 2010 NRC-IN-2010-04-

A2-WF3-0002-001 Entergy OE A2 Evaluation Summary July 1, 2010 OP-903-053 V134 Fire Protection System Pump Operability Test January 9, 2008

OP-903-053 V135 Fire Protection System Pump Operability Test June 18, 2009

ER-W3-2002-

0429-000 Diesel Fire Pump Louvers 0 WSES-FSAR-UNIT-3 Updated Final Safety Analysis Report OP-903-053 V136 Fire Protection System Pump Operability Test August 25, 2011

W3-DBD-018 Fire Protection 0

NPF-38 Waterford Operating License

W3-DBD-037 Nuclear Island and Building Design - RCB 1

Ltr from A H Wern Waterford SES Unit No. 3 Levee Stability Analysis December 7, 1972

TS 3.7.5 Flood Protection NA W3F1-2011-0018 License Amendment Request to Relocate Technical Specifications to the Technical Requirements

Manual Waterford Steam Electric Station Unit 3

November 21, 2011 AR079684 Scope Revision to PMID 6718 incorporate EPRI Recommend Pdm December 12, 2009

A1-11 Attachment 1

NUMBER TITLE REVISION/ DATE Annual Work Hour Review & Fatigue Assessment

Summary 2010 Annual Work Hour Review & Fatigue Assessment

Summary 2011 ODMI SI MTRP0001 Auto Vent 0

ODMI LPSI A Gas Accumulation 14

Entergy System

Policies &

Procedures

Workplace Violence and Weapons 1 EN-IS-111 General Industrial Safety Requirements 11 PS-011-102 Personnel Access Control 308

PS-011-103 Vehicle Access Control 303

PS-011-110 Security Owner Controlled Area Vehicle and Personnel Access Control

010 Waterford 3 Accreditation Board Report September 2010

CONDITION REPORTS

CR-WF3-2012-03424 CR-WF3-2012-03461 CR-WF3-2012-03479

CR-WF3-2012-03495 CR-WF3-2012-03557 CR-WF3-2012-03596

CR-WF3-2012-03701 CR-WF3-2012-03729 CR-WF3-2012-03732

CR-WF3-2012-03736 CR-WF3-2012-03744 CR-WF3-2012-03745 CR-WF3-2012-03747 CR-WF3-2012-03752 CR-WF3-2012-03754 CR-WF3-2012-03761 CR-WF3-2012-03657 CR-WF3-2012-03658

CR-WF3-2012-03659 CR-WF3-2012-03660 CR-WF3-2012-03661

CR-WF3-2012-03662 CR-WF3-2012-03663 CR-WF3-2012-03664

CR-WF3-2012-03665 CR-WF3-2012-03666 CR-WF3-2012-03667 CR-WF3-2012-03668 CR-WF3-2012-03669 CR-WF3-2012-03670 CR-WF3-2012-03671 CR-WF3-2012-03672 CR-WF3-2012-03736

CR-WF3-2012-03709 CR-WF3-2012-03710 CR-WF3-2012-03711

CR-WF3-2012-03712 CR-WF3-2012-03713 CR-WF3-2012-03714

A1-12 Attachment 1 CONDITION REPORTS

CR-WF3-2012-03715 CR-WF3-2012-03716 CR-WF3-2012-03717 CR-WF3-2012-03718 CR-WF3-2012-03719 CR-WF3-2012-03720 CR-WF3-2012-03721 CR-WF3-2012-03722 CR-WF3-2012-03723

CR-WF3-2012-03724 CR-WF3-2012-03725 CR-WF3-2012-03726

CR-WF3-2012-03727 CR-WF3-2012-03728 CR-WF3-2012-03729

CR-WF3-2012-03730 CR-WF3-2012-03731 CR-WF3-2012-03732

CR-WF3-2012-03733 CR-WF3-2012-03734 CR-WF3-2012-03735 CR-WF3-2012-03736 CR-WF3-2012-03737 CR-WF3-2012-03738 CR-WF3-2012-03739 CR-WF3-2012-03740 CR-WF3-2012-03741

CR-WF3-2012-03742 CR-WF3-2010-03235 CR-WF3-2011-07469

CR-WF3-2009-07420 CR-WF3-2010-01166 CR-WF3-2010-03660

CR-WF3-2010-07223 CR-WF3-2010-06219 CR-WF3-2010-02721 CR-WF3-2011-06832 CR-WF3-2011-00679 CR-WF3-2011-01927 CR-WF3-2011-03163 CR-WF3-2011-07602 CR-WF3-2011-03636

CR-WF3-2011-03190 CR-WF3-2011-06205 CR-WF3-2011-04481

CR-WF3-2011-01356 CR-WF3-2011-07605 CR-WF3-2011-02005

CR-WF3-2011-07606 CR-WF3-2011-06254 CR-WF3-2011-07610 CR-WF3-2011-02927 CR-WF3-2011-03084 CR-WF3-2011-00458 CR-WF3-2011-01737 CR-WF3-2012-01048 CR-WF3-2012-00015

CR-WF3-2012-00351 CR-WF3-2012-06832 CR-WF3-2012-01419

CR-WF3-2012-03496 CR-WF3-2010-02940 CR-HQN-2006-00605

CR-WF3-2011-07845 CR-WF3-2011-03522 CR-WF3-2011-03523

CR-WF3-2011-03525 CR-WF3-2011-03526 CR-WF3-2011-03527 CR-WF3-2011-08044 CR-WF3-2011-08045 CR-WF3-2011-08046 CR-WF3-2011-08048 CR-WF3-2011-08049 CR-WF3-2011-08050

CR-WF3-2010-07466 CR-WF3-2011-00553 CR-WF3-2011-06203

CR-WF3-2011-07610 CR-WF3-2011-06204

CR-WF3-2011-08150

CR-WF3-2011-03550

CR-WF3-2011-05841

CR-WF3-2011-07603

CR-WF3-2011-06852

CR-WF3-2011-03350

CR-WF3-2011-05841

CR-WF3-2011-06850

CR-WF3-2012-00013

CR-WF3-2012-00021

CR-WF3-2012-00014

CR-WF3-2012-00818

CR-WF3-2012-01477

CR-WF3-2007-01955

CR-WF3-2012-00837

CR-WF3-2012-01476

CR-WF3-2010-06760

CR-WF3-2011-00217

CR-WF3-2010-02278

CR-WF3-2011-06653

CR-WF3-2012-00024

CR-WF3-2010-01330

CR-WF3-2010-03660

CR-WF3-2010-03050

CR-WF3-2011-03636

CR-WF3-2009-00655

CR-WF3-2009-1276

CR-WF3-2008-04000

CR-WF3-2011-00415

CR-WF3-2011-04935

CR-WF3-2012-00530 CR-WF3-2000-01334

CR-WF3-2012-01334 CR-WF3-2012-03495 CR-WF3-2012-00632 CR-WF3-2011-01737 CR-WF3-2010-07223 CR-WF3-2010-06219 CR-WF3-2011-00458 CR-WF3-2011-00836 CR-WF3-2012-02902 CR-WF3-2012-03190 CR-WF3-2010-04364

CR-WF3-2012-03736 CR-WF3-2012-03461 CR-WF3-2010-03235

CR-WF3-2010-03564 CR-WF3-2010-00686 CR-WF3-2010-02857

CR-WF3-2009-00802 CR-WF3-2010-00341 CR-WF3-2010-02584

CR-WF3-2012-01576 CR-WF3-2012-01581 CR-WF3-2012-00569

A1-13 Attachment 1 CONDITION REPORTS

CR-WF3-2012-02314 CR-WF3-2011-03807 CR-WF3-2012-03424 CR-WF3-2011-00544 CR-WF3-2011-08043

CR-WF3-2010-04199 CR-WF3-2011-00934 CR-WF3-2011-08047

CR-WF3-2011-01168 CR-WF3-2011-04562 CR-WF3-2011-01965

CR-WF3-2011-00987 CR-WF3-2011-08140 CR-WF3-2011-02546

CR-WF3-2010-05595 CR-WF3-2011-03811 CR-WF3-2012-01044

CR-WF3-1999-00708

CR-WF3-2011-00836

CR-WF3-2011-07603 CR-WF3-2012-00659 CR-WF3-2012-01045

CR-WF3-2011-06573 CR-WF3-2011-06254 CR-WF3-2010-02672

CR-WF3-2011-06870 CR-WF3-2012-01380 CR-HQN-2010-00503

CR-WF3-2012-00507 CR-WF3-2012-03067 CR-WF3-2011-03524

CR-WF3-2012-00507 CR-WF3-2009-04155 CR-WF3-2010-02135 CR-WF3-2010-00213 CR-WF3-2010-00036 CR-HQN-2012-00857 CR-WF3-2006-03416 CR-WF3-2007-04464 CR-WF3-2009-02487 CR-WF3-2009-03499 CR-WF3-2009-04155

CR-WF3-2010-00812 CR-WF3-2010-00890 CR-WF3-2010-02302

CR-WF3-2010-02721 CR-WF3-2010-02927 CR-WF3-2010-03099

CR-WF3-2010-03565 CR-WF3-2010-03588 CR-WF3-2010-03595 CR-WF3-2010-04344 CR-WF3-2010-04352 CR-WF3-2010-04634 CR-WF3-2010-04641 CR-WF3-2010-04659 CR-WF3-2010-04785

CR-WF3-2010-05141 CR-WF3-2010-05927 CR-WF3-2010-05929

CR-WF3-2010-07232 CR-WF3-2010-07276 CR-WF3-2010-07362

CR-WF3-2010-07552 CR-WF3-2011-00030 CR-WF3-2011-00553

CR-WF3-2011-00786 CR-WF3-2011-01897 CR-WF3-2011-01965 CR-WF3-2011-02546 CR-WF3-2011-03350 CR-WF3-2011-03465 CR-WF3-2011-03618 CR-WF3-2011-04230 CR-WF3-2011-05320

CR-WF3-2011-05779 CR-WF3-2011-05840 CR-WF3-2011-06166

CR-WF3-2011-06303 CR-WF3-2011-06573 CR-WF3-2011-06701

CR-WF3-2011-07443 CR-WF3-2011-07462 CR-WF3-2011-08055 CR-WF3-2011-08060 CR-WF3-2011-08081 CR-WF3-2011-08150 CR-WF3-2012-00315 CR-WF3-2012-00632 CR-WF3-2012-00659

CR-WF3-2012-00772 CR-WF3-2012-00797 CR-WF3-2012-00891

CR-WF3-2012-01139 CR-WF3-2012-01173 CR-WF3-2012-01503

CR-WF3-2012-01581 CR-WF3-2012-01605 CR-WF3-2012-01660

CR-WF3-2012-02046 CR-WF3-2012-02315 CR-WF3-2012-03232 CR-WF3-2012-03479 CR-WF3-2012-03596 CR-WF3-2012-03701 CR-WF3-2012-03732 CR-WF3-2012-03747 CR-WF3-2012-03752

CR-WF3-2012-03764 CR-WF3-2011-02519 CR-WF3-2012-01956

CR-WF3-2009-02172 CR-WF3-2011-03582 CR-WF3-2012-03325

CR-WF3-2009-05353 CR-WF3-2011-05625 CR-WF3-2012-03729 CR-WF3-2010-02672 CR-WF3-2011-06203 CR-WF3-2012-03761 CR-WF3-2010-03232 CR-WF3-2011-07415 CR-ANO-C-2011-00441

CR-WF3-2010-03809 CR-WF3-2011-08059 CR-WF3-2010-07466

CR-WF3-2010-04638 CR-WF3-2011-08308 CR-WF3-2011-00594

CR-WF3-2010-05046 CR-WF3-2012-00746 CR-WF3-2012-01507

CR-WF3-2010-06531 CR-WF3-2012-01014

A1-14 Attachment 1

WORK ORDERS

248856 52230980 289449 275977 196828 262164

283919 256250 64753

205779 296253 303342

296271 305641 52340992

52356683 52371026 52376231 52389001 254348 257755 246482 254493 263585

286950 261413 279127

298743 28810 287883

245561 52382399 52351187 254203

A2-1 Attachment 2

Information Request

June 11, 2012

Biennial Problem Identification and Resolution Inspection - Waterford 3 Nuclear

Generating Station Inspection Report 2012008

This inspection will cover the period from May 1, 2010, to June 1, 2012. All requested

information should be limited to this period unless otherwise specified. To the extent possible,

the requested information should be provided electronically in Adobe PDF or Microsoft Office format. Lists of documents should be provided in Microsoft Excel or a similar sortable format.

A supplemental information request will likely be sent during the week of July 9, 2012.

Please provide the following no later than June 30, 2012:

1. Document Lists

Note: for these summary lists, please include the document/reference number, the

document title or a description of the issue, initiation date, and current status. Please

include long text descriptions of the issues.

a. Summary list of all corrective action documents related to significant conditions adverse to quality that were opened, closed, or evaluated during the period

b. Summary list of all corrective action documents related to conditions adverse to quality that were opened or closed during the period

c. Summary lists of all corrective action documents which were upgraded or downgraded in priority/significance during the period

d. Summary list of all corrective action documents that subsume or "roll up" one or more smaller issues for the period

e. Summary lists of operator workarounds, engineering review requests and/or operability evaluations, temporary modifications, and control room and safety

system deficiencies opened, closed, or evaluated during the period

f. Summary list of plant safety issues raised or addressed by the Employee Concerns Program (or equivalent)

g. Summary list of all Apparent Cause Evaluations completed during the period

h. Summary list of all Root Cause Evaluations planned or in progress, but not complete at the end of the period

2. Full Documents, with Attachments

a. Root Cause Evaluations completed during the period

A2-2 Attachment 2 b. Quality assurance audits performed during the period

c. All audits/surveillances performed during the period of the Corrective Action Program, of individual corrective actions, and of cause evaluations

d. Corrective action activity reports, functional area self-assessments, and non-NRC third party assessments completed during the period (do not include INPO assessments)

e. Corrective action documents generated during the period for the following:

i. NCV's and Violations issued to Waterford 3

ii. LER's issued by Waterford 3

f. Corrective action documents generated for the following, if they were determined to be applicable to Waterford 3 (for those that were evaluated, but determined

not to be applicable, provide a summary list):

i. NRC Information Notices, Bulletins, and Generic Letters issued or evaluated during the period

ii. Part 21 reports issued or evaluated during the period

iii. Vendor safet

iv. y information letters (or equivalent) issued or evaluated during the period

v. Other external events and/or

Operating Experience evaluated for applicability during the period

g. Corrective action documents generated for the following:

i. Emergency planning drills and tabletop exercises performed during the

period ii. Maintenance preventable functional failures which occurred or were evaluated during the period

iii. Adverse trends in equipment, processes, procedures, or programs which were evaluated during the period

iv. Action items generated or addressed

by plant safety review committees during the period

A2-3 Attachment 2 3. Logs and Reports

a. Corrective action performance trending/tracking information generated during the period and broken down by functional organization

b. Corrective action effectiveness review reports generated during the period

c. Current system health reports or similar information

d. Radiation protection event logs during the period

e. Security event logs and security incidents during the period (sensitive information can be provided by hard copy during first week on site)

f. Employee Concern Program (or equivalent) logs (sensitive information can be provided by hard copy during first week on site)

g. List of training deficiencies, requests for training improvements, and simulator deficiencies for the period

4. Procedures

a. Corrective action program procedures, to include initiation and evaluation procedures, operability determination procedures, apparent and root cause

evaluation/determination procedures, and any other procedures which implement the corrective action program at Waterford 3

b. Quality Assurance program procedures

c. Employee Concerns Program (or equivalent) procedures

d. Procedures which implement/maintain a Safety-Conscious Work Environment

5. Other a. List of risk significant components and systems

b. Organization charts for plant staff and long-term/permanent contractors

A2-4 Attachment 2 Note: "Corrective action documents" refers to condition reports, notifications, action requests, cause evaluations, and/or other similar documents, as applicable to Waterford 3.

As it becomes available, but no later than June 30, 2012, this information should be uploaded on the Certrec IMS website. When thes

e documents have been compiled (and by June 30, 2012), please download these documents onto a CD or DVD and sent it via overnight carrier to:

Richard L. Smith

U.S. NRC Resident Inspector Office 7003 Bald Hill Road Port Gibson, MS 39150

Please note that the NRC is not able to accept

electronic documents on thumb drives or other similar digital media. However, CDs and DVDs are acceptable.