IR 05000382/2011301

NRC Examination Report 05000382-11-301

ML111330742
Person / Time
Site:	Waterford
Issue date:	05/13/2011
From:	Mark Haire Operations Branch IV
To:	Kowalewski J Entergy Operations
References
50-382/11-301
Download: ML111330742 (11)

Text

UNITED STATES NUC LE AR RE G UL AT O RY C O M M I S S I O N May 13, 2011

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC EXAMINATION REPORT 05000382/2011301

Dear Mr. Kowalewski:

On March 25, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an initial operator license examination at Waterford Steam Electric Station, Unit 3. The enclosed report documents the examination results and licensing decisions. The preliminary examination results were discussed on March 25, 2011 with Mr. Charles Arnone, General Plant Manager, and other members of your staff. A telephonic exit meeting was conducted on April 7, 2011, with Mr. John Signorelli, Operations Instructor, and Mr. Mike Mason, Senior Licensing Specialist, who were provided the NRC licensing decisions.

The examination included the evaluation of five applicants for reactor operator licenses, four applicants for instant senior reactor operator licenses, and two applicants for upgrade senior reactor operator licenses. The license examiners determined that ten of the eleven applicants satisfied the requirements of 10 CFR Part 55, and the appropriate licenses have been issued.

There were no post examination comments submitted by your staff. The enclosure contains details of this report.

During the examination, a self-revealing finding was identified and evaluated under the Significance Determination Process as having very low safety significance (Green). The NRC has also determined that a violation is associated with the finding. Consistent with Section 2.3.2 of the Enforcement Policy, the violation is being treated as a noncited violation because it has been entered into your corrective action program. The violation is described in the subject inspection report. If you contest the violation or its significance, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 612 E. Lamar Blvd., Suite 400, Arlington, Texas 76011; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington DC 20555-0001; and the NRC Resident Inspector at the Waterford Steam Electric Station, Unit 3. In addition, if you disagree with the characterization of the finding 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

Entergy Operations, Inc -2-Regional Administrator, Region IV, and the NRC Resident Inspector at the Waterford Steam Electric Station, Unit 3. The information you provide will be considered in accordance with Inspection Manual Chapter 0305.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document 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/

Mark S. Haire, Chief Operations Branch Division of Reactor Safety Docket: 50-382 License: NPF-38

Enclosure:

NRC Examination Report 05000382/2011301

REGION IV==

Docket: 50-382 License: NPF-38 Report: 05000382/2011301 Licensee: Entergy Operations, Inc Facility: Waterford Steam Electric Station, Unit 3 Location: Hwy. 18 Killona, Louisiana Dates: March 21 - April 7, 2011 Inspectors: Chris Steely, Chief Examiner, Senior Operations Engineer Brian Larson, Senior Operations Engineer Clyde Osterholtz, Senior Operations Engineer Approved By: Mark S. Haire, Chief Operations Branch Division of Reactor Safety 1 Enclosure 1

SUMMARY OF FINDINGS

ER 05000382/2011301; March 21 - April 7, 2011; Waterford Steam Electric Station, Unit 3;

Initial Operator Licensing Examination Report.

NRC examiners evaluated the competency of five applicants for reactor operator licenses, four applicants for instant senior reactor operator licenses and two applicants for upgrade senior reactor operator licenses at Waterford Steam Electric Station, Unit 3.

The licensee developed the examinations using NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 9, Supplement 1. The written examination was administered by the licensee on March 29, 2011. NRC examiners administered the operating tests on March 21-25, 2011.

The examiners determined that ten of the eleven applicants satisfied the requirements of 10 CFR Part 55, and the appropriate licenses have been issued. One self-revealing Green non-cited finding was identified. The significance of this finding is indicated by its color (Green,

White, Yellow, Red) using Inspection Manual Chapter (IMC) 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 NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Cornerstone: Mitigating Systems

Green.

A self-revealing non-cited violation of 10 CFR Part 50, Appendix B,

Criterion V, Instructions, Procedures, and Drawings, for failure of the licensee to ensure emergency operating procedures were adequate to ensure important activities could be satisfactorily accomplished. Specifically, the procedural inadequacy contributed to one crew out of three deciding to prematurely secure RCPs because the verbiage in OP-902-006, Loss of Main Feedwater Recovery,

Step 7 did not adequately translate its basis. In particular, Step 7 directs the Operators: If Main Feedwater is lost for greater than 30 minutes AND ONE Motor driven Emergency Feedwater Pump is the only Emergency Feedwater Pump available, then stop ALL RCPs, but the step should instead tie the 30 minute timer to loss of adequate feed rather than strictly the loss of Main Feedwater. The licensee has entered this issue into their corrective action program as CR-WF3-2011-01619.

The failure of the licensee to ensure proper emergency operating procedure adequacy was a performance deficiency. The performance deficiency is more than minor, and therefore a finding, because it adversely impacted the procedure quality attribute of the Mitigating Systems cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using the Inspection Manual Chapter 0609, Significance Determination Process, Phase 1 Worksheets, the inspectors determined that the finding had very low safety significance (Green) because it was not a design issue resulting in loss of function, did not represent an actual loss of a system safety function, did not result in exceeding a Technical Specification allowed outage time, and did not affect external event mitigation.

There is no crosscutting area assigned to the performance deficiency because the inadequacy in the procedure is not indicative of current plant performance (Section 4OA2).

Licensee-Identified Violations

None.

REPORT DETAILS

4OA2 Identification and Resolution of Problems

a. Examination Scope

The examiners observed procedure implementation and operator performance during the initial license examination validation with licensed operators and during the initial license examination administration with applicants.

b. Findings

Introduction.

A self-revealing non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for failure of the licensee to ensure emergency operating procedures were adequate to ensure important activities could be satisfactorily accomplished. Specifically, the procedural inadequacy contributed to one crew out of three deciding to prematurely secure RCPs because the verbiage in OP-902-006, Loss of Main Feedwater Recovery, Step 7 did not adequately translate its basis. In particular, Step 7 directs the Operators: If Main Feedwater is lost for greater than 30 minutes AND ONE Motor driven Emergency Feedwater Pump is the only Emergency Feedwater Pump available, then stop ALL RCPs, but the step should instead tie the 30 minute timer to loss of adequate feed rather than strictly the loss of Main Feedwater.

Description.

During the scenario portion of the examination, crews were given a scenario with a Loss of Main Feedwater Pump B and a failure of Emergency Feedwater Pump A to run. Earlier in the scenario, Main Feedwater Pump A had tripped. Upon the loss of Main Feedwater Pump B, the crew was in a Loss of Main Feedwater event, which is addressed by OP-902-006. At this point, the scenario leaves the crew with no Main Feedwater Pump and only Emergency Feedwater Pump AB available. Step 7 of OP-902-006 directs the crew: If Main Feedwater is lost for greater than 30 minutes AND ONE Motor driven Emergency Feedwater Pump is the only Emergency Feedwater Pump available, then stop ALL RCPs. This verbiage tells the operators to secure all RCPs when two criteria are met: 1) loss of Main Feedwater for 30 minutes, and 2) only one Motor Driven Emeregency Feedwater Pump is available. Since a single Motor Driven Emergency Feedwater Pump may not be sufficient to meet the feedwater needs, the basis of this step is to give the crew a 30 minute window to either restore adequate feedwater or secure the RCPs - which removes a significant heat load from the primary system. However, the way the step is worded, it inappropriately ties the 30 minute clock to the loss of Main Feedwater which, by itself, does not create an inadequate feedwater condition warranting shedding of the heat load created by the RCPs. The wording of Step 7 of OP-902-006 was based on an assumption that the loss of all Main Feedwater directly and immediately resulted in inadequate feedwater; however, the exam scenario established conditions where Emergency Feedwater Pump AB continued to fully supply feedwater needs for a period of time after the loss of Main Feedwater, and it therefore would have been inappropriate in that circumstance to start the 30 minute timer for securing RCPs until later in the scenario when Emergency Feedwater Pump AB was lost and feedwater supply was not adequate. Starting the timer, as directed by Step 7 of OP-902-006, at the loss of all Main Feedwater when there was still adequate feed from the Emergency Feedwater Pump AB results in premature securing of the RCPs.

The basis of the action was not adequately translated into the verbiage of the procedure, which created confusion for one of the three crews and resulted in their prematurely securing RCPs.

Analysis.

The failure of the licensee to ensure proper emergency operating procedure adequacy was a performance deficiency. The performance deficiency is more than minor, and therefore a finding, because it adversely impacted the procedure quality attribute of the Mitigating Systems cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Additionally, if left uncorrected, the performance deficiency could have become more significant in that not ensuring activities in the emergency operating procedures could be satisfactorily accomplished could be a precursor to a more significant event. Using the Inspection Manual Chapter 0609, Significance Determination Process, Phase 1 Worksheets, the inspectors determined that the finding had very low safety significance (Green) because it was not a design issue resulting in loss of function, did not represent an actual loss of a system safety function, did not result in exceeding a Technical Specification allowed outage time, and did not affect external event mitigation. There is no crosscutting area assigned to the performance deficiency because the inadequacy in the procedure is not indicative of current plant performance.

Enforcement.

10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires the licensee to ensure emergency operating procedures are adequate to ensure important activities can be completed satisfactorily. OP-902-006 provides procedure steps to address loss of feedwater during emergency conditions.

Contrary to the above, the licensee did not ensure that emergency operating procedures were adequate to ensure response to a loss of feedwater was adequate.

Specifically, the verbiage in OP-902-006, Loss of Main Feedwater Recovery, Step 7 did not adequately translate its basis. In particular, Step 7 directs the Operators: If Main Feedwater is lost for greater than 30 minutes AND ONE Motor driven Emergency Feedwater Pump is the only Emergency Feedwater Pump available, then stop ALL RCPs, but the step should instead tie the 30 minute timer to loss of adequate feed rather than strictly the loss of Main Feedwater. Because this finding is of very low safety significance and was entered into the corrective action program as CR-WF3-2011-01619, this violation is being treated as a non-cited violation, consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000382/2011301-01, Failure to Correctly Implement Emergency Operating Procedures.

4OA5 Other Activities (Initial Operator License Examination)

.1 License Applications

a. Scope

NRC examiners reviewed all license applications submitted to ensure each applicant satisfied relevant license eligibility requirements. Examiners also audited three of the license applications in detail to confirm that they accurately reflected the subject applicants qualifications. This audit focused on the applicants experience and on-the-job training, including control manipulations that provided significant reactivity changes.

b. Findings

No findings were identified.

.2 Examination Development

a. Scope

NRC examiners reviewed integrated examination outlines and draft examinations submitted by the licensee against the requirements of NUREG-1021. The NRC examination team conducted an onsite validation of the operating tests.

b. Findings

No findings were identified.

NRC examiners provided outline, draft examination and post-validation comments to the licensee. The licensee satisfactorily completed comment resolution prior to examination administration.

NRC examiners determined the written examinations and operating tests initially submitted by the licensee were within the range of acceptability expected for a proposed examination.

.3 Operator Knowledge and Performance

a. Scope

On March 29, 2011, the licensee proctored the administration of the written examinations to all eleven applicants. The licensee staff graded the written examinations, analyzed the results, and presented their analysis to the NRC on March 30, 2011.

The NRC examination team administered the various portions of the operating tests to all applicants during the week of March 21, 2011.

b. Findings

No findings were identified.

Ten of the eleven applicants passed all parts of the operating test. All applicants passed the written examination. The final written examinations and post examination analysis may be accessed in the ADAMS system under the accession numbers noted in the attachment. There were no post examination comments as indicated in the licensee submittal.

No generic weaknesses were noted.

.4 Simulation Facility Performance

a. Scope

The NRC examiners observed simulator performance with regard to plant fidelity during examination validation and administration.

b. Findings

No findings were identified.

.5 Examination Security

a. Scope

The NRC examiners reviewed examination security for examination development during both the onsite preparation week and examination administration week for compliance with 10 CFR 55.49 and NUREG-1021. Plans for simulator security and applicant control were reviewed and discussed with licensee personnel.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

The chief examiner presented the preliminary examination results to Messrs. Charles Arnone, General Plant Manager, Kimberly Cook, Operations Manager, and other members of the staff on March 24, 2011. A telephonic exit was conducted on April 7, 2011 between Mr. Chris Steely, Chief Examiner, Mr. John Signorelli, Operations Instructor, and Mr. Mike Mason, Senior Licensing Specialist.

The licensee did not identify any information or materials used during the examination as proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

John Signorelli, Operations Instructor

NRC Personnel

Marlone Davis, Senior Resident Inspector