IR 05000382/2009003

IR 05000382-09-003; 4/7/09 - 7/7/09; Waterford Steam Electric Station, Unit 3; Problem Identification and Resolution: Exercise Evaluation, Identification and Resolution of Problems the Report Covered a 3-month Period of Inspection by Reside

ML092240471
Person / Time
Site:	Waterford
Issue date:	08/12/2009
From:	Clark J A NRC/RGN-IV/DRP/RPB-E
To:	Kowalewski J Entergy Operations
References
IR-09-003
Download: ML092240471 (43)

Text

August 12, 2009

Joseph Kowalewski, Vice President, Operations Entergy Operations, Inc.

Waterford Steam Electric Station, Unit 3 17265 River Road Killona, LA 70057-3093 Subject: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED INSPECTION REPORT 05000382/2009-003

Dear Mr. Kowalewski:

On July 7, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford Steam Electric Station, Unit 3. The enclosed integrated inspection report documents the inspection findings, which were discussed on August 11, 2009 , with you and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. This report documents three NRC identified findings of very low safety significance (Green). All of these findings involved violations of NRC requirements. However, because of the very low safety significance and because they are entered into your corrective action program, the NRC is treating these findings as noncited violations, consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest the violations or the significance of the noncited violations, 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, D.C. 20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 612 E. Lamar Blvd, Suite 400, Arlington, Texas, 76011-4125; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspector at the Waterford Steam Electric Station, Unit 3 facility. In addition, if you disagree with the characterization of any 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 Regional Administrator, Region IV, and the NRC Resident Inspector at Waterford Steam Electric Station, Unit 3. The information you provide will be considered in accordance with Inspection Manual Chapter 0305. Entergy Operations, Inc. - 2 -

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 component of NRC's 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/ Jeffrey A. Clark, P.E. Project Branch E Division of Reactor Projects Docket: 50-382 License: NPF-38

Enclosure:

NRC Inspection Report 05000382/2009003

w/Attachment:

Supplemental Information

cc: w/Enclosure Senior Vice President Entergy Nuclear Operations P. O. Box 31995 Jackson, MS 39286-1995 Senior Vice President and Chief Operating Officer Entergy Operations, Inc.

P. O. Box 31995 Jackson, MS 39286-1995 Vice President, Operations Support Entergy Services, Inc.

P. O. Box 31995 Jackson, MS 39286-1995 Senior Manager, Nuclear Safety and Licensing Entergy Services, Inc. P. O. Box 31995 Jackson, MS 39286-1995 Site Vice President Waterford Steam Electric Station, Unit 3 Entergy Operations, Inc. 17265 River Road Killona, LA 70057-0751 Director Nuclear Safety Assurance Entergy Operations, Inc. 17265 River Road Killona, LA 70057-0751 General Manager, Plant Operations Waterford 3 SES Entergy Operations, Inc.

17265 River Road Killona, LA 70057-0751 Manager, Licensing Entergy Operations, Inc. 17265 River Road Killona, LA 70057-3093

Chairman Louisiana Public Service Commission P. O. Box 91154 Baton Rouge, LA 70821-9154

Entergy Operations, Inc. - 3 -

Parish President Council St. Charles Parish P. O. Box 302 Hahnville, LA 70057 Director, Nuclear Safety & Licensing Entergy, Operations, Inc. 440 Hamilton Avenue White Plains, NY 10601 Louisiana Department of Environmental Quality, Radiological Emergency Planning and Response Division P. O. Box 4312 Baton Rouge, LA 70821-4312

Chief, Technological Hazards Branch FEMA Region VI 800 North Loop 288 Federal Regional Center Denton, TX 76209 Chairperson, Radiological Assistance Committee Region VI Federal Emergency Management Agency Department of Homeland Security 800 North Loop 288 Federal Regional Center Denton, TX 76201-3698

Entergy Operations, Inc. - 4 -

Electronic distribution by RIV: Regional Administrator (Elmo.Collins@nrc.gov) Deputy Regional Administrator (Chuck.Casto@nrc.gov)

DRP Director (Dwight.Chamberlain@nrc.gov) DRP Deputy Director (Anton.Vegel@nrc.gov) DRS Director (Roy.Caniano@nrc.gov) DRS Deputy Director (Troy.Pruett@nrc.gov) Senior Resident Inspector (Ray.Azua@nrc.gov)

Resident Inspector (Dean.Overland@nrc.gov) Branch Chief, DRP/E (Jeff.Clark@nrc.gov) Senior Project Engineer, DRP/E (George.Replogle@nrc.gov) WAT Site Secretary (Linda.Dufrene@nrc.gov) Public Affairs Officer (Victor.Dricks@nrc.gov) Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov) RITS Coordinator (Marisa.Herrera@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov) Congressional Affairs Officer (Jenny.Weil@nrc.gov) OEMail Resource Regional State Liaison Officer (Bill.Maier@nrc.gov) NSIR/DPR/EP (Steve.LaVie@nrc.gov)

Only inspection reports to the following: DRS STA (Dale.Powers@nrc.gov) OEDO RIV Coordinator (Leigh.Trocine@nrc.gov) ROPreports

File located: R:\_REACTORS\_WAT\2009\WAT 2009003 RP-DHOAdams.doc ML092240471 SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials GDR Publicly Avail Yes No Sensitive Yes No Sens. Type Initials GDR RIV:SRI:DRP/E SPE/DRP/E C:DRS/EB1 C:DRS/EB2 C:DRs/OB DHOverland GDReplogle TRFarnholtz NFOKeefe RELantz

/RA/-E /RA/ /RA/ /RA/ /RA/ 8/4/09 8/5/09 8/5/09 8/5/09 8/5/09 C:DRS/PSB C:DRS/OSB2 C:DRP/E MPShannon GEWerner JAClark

/RA/ /RA/ /RA/

8/ /09 8/8/09 8/11/09 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 05000382 License: NFP-38 Report: 05000382/2009003 Licensee: Entergy Operations, Inc. Facility: Waterford Steam Electric Station, Unit 3 Location: Hwy. 18 Killona, LA Dates: April 7 through July 7, 2009 Inspectors: D. Overland, Senior Resident Inspector Paul J. Elkmann, Senior Emergency Preparedness Inspector Gilbert L. Guerra, CHP, Emergency Preparedness Inspector Approved By: Jeff Clark, Chief, Project Branch E Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000382/2009003; 4/7/09 - 7/7/09; Waterford Steam Electric Station, Unit 3; Problem Identification and Resolution: Exercise Evaluation, Identification and Resolution of Problems The report covered a 3-month period of inspection by resident inspectors and an announced baseline inspection by regional based inspectors. Three Green noncited violations of significance were identified. The significance of most findings is indicated by their color (Green, White, Yellow, or 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.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion VXI (Corrective Actions), because the licensee failed to identify the cause for a significant condition adverse to quality. The Train B 125 Vdc battery bank failed to pass a technical specification surveillance requirement discharge test during a Spring 2008 outage. The root cause procedure required that the licensee sequester the battery in a controlled area so that vital information related to the failure could be obtained. However, the licensee disposed of the battery instead. When questions arose concerning the specified failure cause (impurities in the battery materials), the licensee was unable to provide objective evidence to support the conclusion. Had the licensee obtained objective evidence to support their conclusion that impurities caused the battery failure, a 10 CFR Part 21 report may have been required. The licensee replaced the battery and planned to replace similar batteries in the other two trains during the next refueling outage. The licensee entered this finding in their corrective action program as Condition Report CR-WF3-2009-2846. The finding was more than minor because, if left uncorrected, it could lead to a more significant safety concern. Specifically, since the cause of the battery failure was not definitively found, the licensee may not have taken corrective actions to prevent other battery failures. Using the Inspection Manual Chapter 0609, "Significance Determination Process," Phase 1 Screening Worksheet, the finding was of very low risk significance because it did not actually cause the loss of operability or functionality of another 125 Vdc battery at the time of the inspection. This finding had a crosscutting aspect in the area of Problem Identification and Resolution (Corrective Action Program Component) because the licensee failed to thoroughly evaluate the need to keep the battery prior to disposal P.1(c) (Section 4OA2).

Green.

The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI (Corrective Action), for the failure to promptly correct conditions adverse to quality. The licensee had documented several conditions adverse to quality and then transferred the concerns to other condition reports. Then, the licensee closed those condition reports without addressing the concerns. Identified conditions included (1) the Train B 125 Vac discharge test data indicated a loose battery connection but the battery was permitted to pass the test anyway; (2) the root cause determination for the failed battery was focused on the statements of one person and failed to address other information; (3) the root cause determination failed to address conflicting information; and (4) the root cause determination failed to properly address other potential causes for the inoperable battery, such as tampering. Plant personnel had failed to accurately translate the issues when transferring information from one condition report to another. The licensee entered this finding into their corrective action program as Condition Report CR-WF3-2009-1177. The finding was more than minor because, if left uncorrected, it would become a more significant safety concern. For example, the failure to include acceptance criteria in the battery discharge test (intended to identify and correct loose battery connections) could result in another inoperable 125 Vdc battery for an extended period. The inspectors evaluated the finding using Inspection Manual Chapter 609, Significance Determination Process, Phase 1 Screening Worksheet and determined that the finding was of very low risk significance because it did not result in another battery becoming inoperable or nonfunctional. This finding had a crosscutting aspect in the area of Human Performance (Work Practices Component) because plant personnel failed to effectively use human error prevention techniques, such as self and peer checking, when transferring concerns between condition reports H.4(a) (Section 4OA2).

Cornerstone: Emergency Preparedness

Green.

The inspectors identified a noncited violation of 10 CFR 50.47(b)(10) for the licensee's failure to develop and have in place guidelines for the choice of protective actions during an emergency that were consistent with federal guidance. Specifically, the licensee's guidelines for extending existing protective action recommendations into additional geographical areas of the emergency planning zone under conditions of changing wind vectors were not consistent with the guidance of EPA-400-R-92-001, AManual of Protective Action Guides and Protective Actions for Nuclear Incidents.

@ The licensee's practices resulted in unnecessary recommendations for protective actions in areas where valid dose projections show federal protective action guides are not exceeded, and may expose members of the public to unjustified risks. The licensee has entered this issue into their corrective action system as Condition Report CR-WF3-2009-03256.

This finding was more than minor because it was not similar to the examples of Manual Chapter 0612, Appendix E, and affected the emergency preparedness cornerstone objective because unnecessary protective actions may expose members of the public to an unjustified risk. The finding was associated with the emergency response organization attributes of 50.47(b) planning standards and training. This finding was of very low safety significance because it was not a risk significant planning standard functional failure or degraded function because licensee protective action recommendations would be issued in accordance with federal guidance for all areas of the emergency planning zone where Protective Action Guides are exceeded. This finding was evaluated as not having a crosscutting aspect because the finding was not indicative of current licensee performance (Section 1EP1).

B. Licensee-Identified Violations

None

REPORT DETAILS

Summary of Plant Status

The plant began the inspection period on April 7, 2009, at 100 percent power and remained at approximately 100 percent power for the rest of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness

1R01 Adverse Weather Protection

.1 Summer Readiness for Offsite and Alternate-ac Power

a. Inspection Scope

The inspectors performed a review of the licensee's preparations for summer weather for selected systems, including conditions that could lead to loss-of-offsite power and conditions that could result from high temperatures. The inspectors reviewed the licensee's procedures affecting these areas and the communications protocols between the transmission system operator and the plant to verify that the appropriate information was being exchanged when issues arose that could affect the offsite power system. Examples of aspects considered in the inspectors' review included:

• The coordination between the transmission system operator and the plant during off-normal or emergency events

• The explanations for the events

• The estimates of when the offsite power system would be returned to a normal state

• The notifications from the transmission system operator to the plant when the offsite power system was returned to normal During the inspection, the inspectors focused on plant-specific design features and the licensee's procedures used to mitigate or respond to adverse weather conditions.

Additionally, the inspectors reviewed the Final Safety Analysis Report and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant-specific procedures. Specific documents reviewed during this inspection are listed in the attachment. The inspectors also reviewed corrective action program items to verify that the licensee was identifying adverse weather issues at an appropriate threshold and entering them into their corrective action program in accordance with station corrective action procedures. The inspectors' reviews focused specifically on the following plant systems:

• Emergency diesel generators

• Station startup transformers

• Uninterruptible power supplies These activities constitute completion of one readiness for summer weather affect on offsite and alternate ac power sample as defined in Inspection Procedure 71111.01-05.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignments

.1 Partial Walkdown

a. Inspection Scope

The inspectors a performed partial system walkdown of the following risk-significant system:

• May 11, 2009, partial system walkdown of emergency diesel generator Train B The inspectors selected this system based on its risk significance relative to the reactor safety cornerstones at the time it was inspected. The inspectors attempted to identify any discrepancies that could affect the function of the system and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, Final Safety Analysis Report, technical specification requirements, administrative technical specifications, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the system incapable of performing their intended functions. The inspectors also walked down accessible portions of the system to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one partial system walkdown sample as defined in Inspection Procedure 71111.04-05.

b. Findings

No findings of significance were identified.

.2 Complete Walkdown

a. Inspection Scope

On June 3, 2009, the inspectors performed a complete system alignment inspection of the containment spray system Train B to verify the functional capability of the system. The inspectors selected this system because it was considered both safety-significant and risk-significant in the licensee's probabilistic risk assessment. The inspectors walked down the system to review mechanical and electrical equipment line ups, electrical power availability, system pressure and temperature indications, as appropriate, component labeling, component lubrication, component and equipment cooling, hangers and supports, operability of support systems, and to ensure that ancillary equipment or debris did not interfere with equipment operation. The inspectors reviewed a sample of past and outstanding work orders to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the corrective action program database to ensure that system equipment-alignment problems were being identified and appropriately resolved. Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of one complete system walkdown sample as defined in Inspection Procedure 71111.04-05

b. Findings

No findings of significance were identified.

1R05 Fire Protection

.1 Quarterly Fire Inspection Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns that were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:

• April 28, 2009, reactor auxiliary building fire Zones 33, 35, and 36

• May 11, 2009, reactor auxiliary building fire Zones 2, 15, 16, and 23

• May 27, 2009, reactor auxiliary building fire Zones 17, 18, and 19

• May 27, 2009, reactor auxiliary building fire Zones 20, and 21 The inspectors reviewed areas to assess if licensee personnel had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant; effectively maintained fire detection and suppression capability; maintained passive fire protection features in good material condition; and had implemented adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features, in accordance with the licensee's fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plant's Individual Plant Examination of External Events with later additional insights, their potential to affect equipment that could initiate or mitigate a plant transient, or their impact on the plant's ability to respond to a security event. Using the documents listed in the attachment, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed, that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensee's corrective action program. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of four quarterly fire-protection inspection samples as defined in Inspection Procedure 71111.05-05.

b. Findings

No findings of significance were identified.

1R06 Flood Protection Measures

a. Inspection Scope

The inspectors reviewed the Final Safety Analysis Report, the flooding analysis, and plant procedures to assess susceptibilities involving internal flooding; reviewed the corrective action program to determine if licensee personnel identified and corrected flooding problems; inspected underground bunkers/manholes to verify the adequacy of sump pumps, level alarm circuits, cable splices subject to submergence, and drainage for bunkers/manholes; and verified that operator actions for coping with flooding can reasonably achieve the desired outcomes. The inspectors also walked down the area listed below to verify the adequacy of equipment seals located below the flood line, floor and wall penetration seals, watertight door seals, common drain lines and sumps, sump pumps, level alarms, and control circuits, and temporary or removable flood barriers. Specific documents reviewed during this inspection are listed in the attachment.

• July 1, 2009, review of Operating Experience Smart Sample OpESS FY2007-02, "Flooding Vulnerabilities Due to Inadequate Design and Conduit / Hydrostatic Seal Barrier Concerns," in the switchgear Train B room These activities constitute completion of one flood protection measure inspection sample as defined in Inspection Procedure 71111.06-05.

b. Findings

No findings of significance were identified.

R11 Licensed Operator Requalification Program

a. Inspection Scope

On May 28, 2009, the inspectors observed a crew of licensed operators in the plant's simulator to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

• Licensed operator performance

• Crew's clarity and formality of communications

• Crew's ability to take timely actions in the conservative direction

• Crew's prioritization, interpretation, and verification of annunciator alarms

• Crew's correct use and implementation of abnormal and emergency procedures

• Control board manipulations

• Oversight and direction from supervisors

• Crew's ability to identify and implement appropriate technical specification actions and emergency plan actions and notifications The inspectors compared the crew's performance in these areas to pre-stablished operator action expectations and successful critical task completion requirements. Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of one quarterly licensed-operator requalification program sample as defined in Inspection Procedure 71111.11.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk significant systems:

• June 2, 2009, emergency lighting system

• June 29, 2009, review of Operating Experience Smart Sample OpESS FY2008-01, "Negative trend and Recurring Events Involving Emergency Diesel Generators"

The inspectors reviewed events such as where ineffective equipment maintenance has resulted in valid or invalid automatic actuations of engineered safeguards systems and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

• Implementing appropriate work practices

• Identifying and addressing common cause failures

• Scoping of systems in accordance with 10 CFR 50.65(b)

• Characterizing system reliability issues for performance

• Charging unavailability for performance

• Trending key parameters for condition monitoring

• Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or (a)(2)

• Verifying appropriate performance criteria for structures, systems, and components classified as having an adequate demonstration of performance through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as requiring the establishment of appropriate and adequate goals and corrective actions for systems classified as not having adequate performance, as described in 10 CFR 50.65(a)(1) The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of two quarterly maintenance effectiveness samples as defined in Inspection Procedure 71111.12-05.

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed licensee personnel's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:

• April 17, 2009, replacement and calibration of power Supply 37-H for PPS Channel B

• April 21, 2009, planned maintenance outage of Train B emergency core cooling systems

• May 6, 2009, scheduled maintenance outage of high pressure safety injection Train A

• June 17, 2009, corrective maintenance to replace station Battery 3AB-S Cell 31 due to low individual cell voltage The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When licensee personnel performed emergent work, the inspectors verified that the licensee personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of four maintenance risk assessments and emergent work control inspection samples as defined in Inspection Procedure 71111.13-05.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed the following issues:

• May 12, 2009, voiding discovered at low pressure safety injection Pump A discharge to reactor coolant Loop 2B vent

• May 13, 2009, multiple trips of control room emergency filtration unit Train A

• May 13, 2009, failure of emergency diesel generator Train A to achieve 110 percent design basis load during scheduled surveillance run The inspectors selected these potential operability issues based on the risk-significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and Final Safety Analysis Report to the licensee's evaluations, to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors also reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three operability evaluations inspection sample(s) as defined in Inspection Procedure 71111.15-05

b. Findings

No findings of significance were identified.

1R19 Postmaintenance Testing

a. Inspection Scope

The inspectors reviewed the following postmaintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:

• April 20, 2009, replacement and calibration of power Supply 37-H for PPS Channel B

• April 22, 2009, replacement of diesel generator sequencer Relay EG EREL2392-N following Part 21 recall

• May 7, 2009, breaker and motor maintenance and relay replacement on high pressure safety injection Pump A

• May 13, 2009, leak test and adjustment for control room outside air intake Valve HVC-102 following multiple trips of control room emergency filtration unit Train A

• May 15, 2009, replacement of a motor-operated potentiometer and adjustment of the mechanical governor following a failed emergency diesel generator Train A surveillance run

• June 5, 2009, motor maintenance and oil leak repair for containment spray Pump A

• June 12, 2009, corrective maintenance to replace pump plungers and packing to correct leaking seals on charging Pump AB in an attempt to reduce reactor coolant system leakage

• June 16, 2009, corrective maintenance to replace pump plungers and packing to correct leaking seals on charging Pump B in an attempt to reduce reactor coolant system leakage The inspectors selected these activities based upon the structure, system, or component's ability to affect risk. The inspectors evaluated these activities for the following (as applicable):

• The effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed

• Acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate The inspectors evaluated the activities against the technical specifications, the Final Safety Analysis Report, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with postmaintenance tests to determine whether the licensee was identifying problems and entering them in the corrective action program and that the problems were being corrected commensurate with their importance to safety. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of eight postmaintenance testing inspection samples as defined in Inspection Procedure 71111.19-05.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the Final Safety Analysis Report, procedure requirements, and technical specifications to ensure that the five surveillance activities listed below demonstrated that the systems, structures, and/or components tested were capable of performing their intended safety functions. The inspectors either witnessed or reviewed test data to verify that the significant surveillance test attributes were adequate to address the following:

• Preconditioning

• Evaluation of testing impact on the plant

• Acceptance criteria

• Test equipment

• Procedures

• Jumper/lifted lead controls

• Test data

• Testing frequency and method demonstrated technical specification operability

• Test equipment removal

• Restoration of plant systems

• Fulfillment of ASME Code requirements

• Updating of performance indicator data

• Engineering evaluations, root causes, and bases for returning tested systems, structures, and components not meeting the test acceptance criteria were correct

• Reference setting data

• Annunciators and alarms setpoints The inspectors also verified that licensee personnel identified and implemented any needed corrective actions associated with the surveillance testing.

• April 23, 2009, low pressure safety injection Pump B operability check

• April 27, 2009, component cooling water in-service valve testing

• May 8, 2009, emergency feedwater Pump A operability check

• May 26, 2009, emergency diesel generator Train A

• June 15, 2009, reactor coolant system leakage detection Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five surveillance testing inspection sample(s) as defined in Inspection Procedure 71111.22-05.

b. Findings

No findings of significance were identified.

Cornerstone:

Emergency Preparedness

1EP1 Exercise Evaluation

a. Inspection Scope

The inspectors reviewed the objectives and scenario for the 2009 biennial emergency plan exercise to determine if the exercise would acceptably test major elements of the emergency plan. The scenario simulated a tornado touchdown on site that damaged the turbine building, a failure of a liquid radiological waste tank, a main generator trip leading to damage in the station switchyard causing a loss of offsite power, failures of both emergency diesel generators leading to station blackout conditions, a large reactor coolant system break inside containment, fission product barrier failures, core damage from fuel overheating, a filtered and monitored radiological release to the environment via a containment penetration failure and annulus ventilation, and a change in the direction of the radiological release to demonstrate the licensee emergency response organization's capability to implement their emergency plan.

The inspectors evaluated exercise performance by focusing on the risk-significant activities of event classification, offsite notification, recognition of offsite dose consequences, and development of protective action recommendations, in the control room simulator and the following dedicated emergency response facilities:

• Technical Support Center

• Operations Support Center

• Emergency Operations Facility The inspectors also assessed recognition of, and response to, abnormal and emergency plant conditions, the transfer of decision making authority and emergency function responsibilities between facilities, onsite and offsite communications, protection of emergency workers, emergency repair evaluation and capability, and the overall implementation of the emergency plan to protect public health and safety and the environment. The inspectors reviewed the current revision of the facility emergency plan, emergency plan implementing procedures associated with operation of the licensee's emergency response facilities, procedures for the performance of associated emergency functions, and other documents as listed in the attachment to this report.

The inspectors compared the observed exercise performance with the requirements in the facility emergency plan, 10 CFR 50.47(b), 10 CFR Part 50, Appendix E, and with the guidance in the emergency plan implementing procedures and other federal guidance.

The inspectors attended the postexercise critiques in each emergency response facility to evaluate the initial licensee self-assessment of exercise performance. The inspectors also attended a subsequent formal presentation of critique items to plant management. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.01-05.

b. Findings

Introduction.

The inspectors identified a noncited violation of 10 CFR 50.47(b)(10) for the licensee's failure to develop and have in place guidelines for the choice of protective actions during an emergency that were consistent with federal guidance. Specifically, the licensee's guidelines for extending existing protective action recommendations into additional geographical areas of the emergency planning zone under conditions of changing wind vectors were not consistent with the guidance of EPA-400-R-92-001, AManual of Protective Action Guides and Protective Actions for Nuclear Incidents.

@

Description.

The inspectors identified that Procedure EP-2-052, AProtective Action Guidelines,@ Revision 20, allows the licensee to generate evacuation protective action recommendations for members of the general public in areas of the emergency planning zone where radiological protective action guides are not exceeded. Specifically, inspectors determined that, with an existing initial protective action recommendation based on plant conditions, the licensee's practice when changes occur in the wind direction vector were to recommend to offsite authorities in any circumstance additional protective actions to the same downwind distance for every geographical area traversed by the wind as previously recommended. The recommendations would be done without considering in the decision process whether EPA protective action guides were exceeded in the newly-affected areas. The licensee's practices result in unnecessary recommendations for protective actions in areas where valid dose projections show federal protective action guides are not exceeded, and may expose members of the public to unjustified risks.

The inspectors determined the licensee has adopted a prompt protective action scheme based on EPA-400-R-92-001, AManual of Protective Action Guides and Protective Actions for Nuclear Incidents,@ as described by:

• Waterford 3 Steam Electric Station Emergency Plan, Revision 37, Section 6.6.1.2, "Offsite Protective Action Recommendations," states, in part, the set of guidelines, based on dose projections, is consistent with both EPA protective action guidelines and with the protective action guidelines of the State of Louisiana Peacetime Radiological Response Plan, that guidelines will be used to minimize risks for an accident and that, when total effective dose equivalent projected dose is less than 1 rem or to the projected committed dose equivalent thyroid is less than 5 rem, no immediate actions are necessary.

• Procedure EP-2-052, AProtective Action Guidelines,@ Revision 20, states in Section 1.0 the purpose is to provide guidance for protective action decisionmaking with respect to the EPA Protective Action Guidelines, and in Section 5.2.1.3, that if dose projection information is available, then use 7.2 or equivalent computerized methods which assess the projected radiation dose to modify the initial General Emergency protective actions as necessary.

The inspectors reviewed the licensee's Emergency Plan and emergency plan implementing procedure for making protective action recommendations to offsite authorities, and discussed with licensee emergency preparedness staff the licensee's expectations and practices for making protective action recommendations under conditions of changing wind direction and radiological severity. The inspectors were informed by the licensee's emergency preparedness management that their practice with regard to changing wind direction was to always recommend extending existing protective actions to adjacent geographical areas affected by the new wind vector(s) to the same downwind distance as in previously-affected areas. The licensee would make this automatic extension of existing protective action recommendations without considering dose projection results, even when valid dose projections were available that showed protective action guides were not exceeded along the new wind vector(s). The inspectors concluded that the licensee's practice of always recommending to offsite authorities the extension of protective actions to the same downwind distance as existing recommendations was not in accordance with the guidance of EPA-400-R-92-001, because the licensee did not modify initial General Emergency protective actions based on EPA protective action guides when valid dose projection information was available.

The inspectors determined that the licensee performed periodic dose assessments to assess the impact of a radiological release on the emergency planning zone as meteorological and radiological conditions change. The inspectors determined the licensee's practices under conditions of changing wind direction and release severity would always result in appropriate protective action recommendations to offsite authorities for geographical areas in the emergency planning zone where radiological risk to the public exists (that is, where protective action guides are exceeded), but also could result in recommendations to evacuate geographical areas where radiological risk is determined not to exist (that is, where protective guides are not exceeded).

Analysis.

Licensee practices resulting in recommending to offsite authorities protective actions for the public in geographical areas of the emergency planning zone where valid dose assessment has not identified that protective action guides are projected to be exceeded was a performance deficiency, and it was within the licensee's ability to foresee and correct, and could have been prevented. The finding was more than minor because it was not similar to the examples of Manual Chapter 0612, Appendix E, and has the potential to impact public safety because unnecessary protective actions may expose members of the public to an unjustified risk. The finding was associated with the emergency response organization attributes of 50.47(b) planning standards and training. The finding affects the emergency preparedness cornerstone objective because recommendations to offsite authorities to take protective actions in areas where protective action guides were not exceeded affects the offsite authority's ability to protect the health and safety of the public, and may have resulted in unnecessary risk to the public. This finding was evaluated using the emergency preparedness significance determination process and was determined to have very low safety significance (Green) because it was a failure to comply with NRC requirements, was associated with emergency preparedness planning standard 50.47(b)(10), was associated with a risk significant planning standard as defined in Manual Chapter 0609, Appendix B, Section 2.0, and was not a risk significant planning standard functional failure or a risk significant planning standard degraded function because appropriate protective action recommendations would be issued for all geographical areas of the plume phase emergency planning zone where protective action guides are exceeded. The finding was evaluated as not having a crosscutting aspect.

Enforcement.

Title 10 of the Code of Federal Regulations, 50.47(b)(10) states, in part, that guidelines for the licensee's choice of protective actions during an emergency, consistent with federal guidance, are developed and in place.Section IV(B) of Part 50, Appendix E, requires, in part, that a licensee describe the basis for determining when and what type of protective measures should be considered outside the site boundary. Federal guidance for the choice of protective actions during an emergency is described in EPA-400-R-92-001. Section 1.4 of EPA-400-R-92-001 states that protective action guides are the approximate levels at which protective measures are justified. Section 2.3.1 of EPA-400-R-92-001 states that evacuation is seldom justified at projected radiation doses less than one rem of total effective dose equivalent.

Contrary to the above, the licensee did not develop and have in place guidelines for the choice of protective actions during an emergency that were consistent with federal guidance. The licensee's guidelines for extending initial General Emergency protective action recommendations under conditions of changing wind direction vectors were not consistent with EPA-400-R-92-001 guidance. Specifically, the licensee's process of automatically extending existing offsite protective action recommendations without evaluating dose assessment information did not provide justification for recommending protective actions in geographical areas where valid dose projections show federal protective action guides are not exceeded. Because this failure was of very low safety significance and has been entered into the licensee

=s corrective action system (Condition Report CR-WF3-2009-03256), this violation is being treated as a noncited violation, consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000382/2009003-1, "Licensee Practices Result in Protective Action Recommendations for Areas Where Protective Action Guides Are Not Exceeded."

Cornerstone:

Emergency Preparedness

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

The inspector performed an in-office review of Revision 37 to the Waterford 3 Steam Electric Station Emergency Plan submitted May 12, 2009. This revision added security threats to the bases of the four emergency classifications, revised the [offsite] Notification Message Form to characterize radiological releases as being below or above federally-approved operating limits, added detail about the functions of the Reactor Auxiliary Building instrumentation laboratory, increased the number of available voice communications channels from 5 to 23, increased the number of offsite emergency warning sirens from 72 to 73, revised definitions used in the emergency plan, updated station position titles and service vendors, and made minor editorial changes.

This revision was compared to its previous revision, to the criteria of NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, and to the standards in 10 CFR 50.47(b), to determine if the revision adequately implemented the requirements of 10 CFR 50.54(q). This review was not documented in a safety evaluation report and did not constitute approval of the licensee's changes; therefore, this revision is subject to future inspection.

These activities constitute completion of one sample as defined in Inspection Procedure 71114.04-05.

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator Verification

.1 Data Submission Issue

a. Inspection Scope

The inspectors performed a review of the data submitted by the licensee for the first quarter 2009 performance indicators for any obvious inconsistencies prior to its public release in accordance with Inspection Manual Chapter 0608, "Performance Indicator Program." This review was performed as part of the inspectors' normal plant status activities and, as such, did not constitute a separate inspection sample.

b. Findings

No findings of significance were identified.

.2 Safety System Functional Failures

a. Inspection Scope

The inspectors sampled licensee submittals for the safety system functional failures performance indicator for the period from the first quarter 2008 through the first quarter 2009. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, and NUREG-1022, "Event Reporting Guidelines 10 CFR 50.72 and 50.73," definitions and guidance were used. The inspectors reviewed the licensee's operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, issue reports, event reports, and NRC integrated inspection reports for the period of March 2008 through March 2009 to validate the accuracy of the submittals. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.

These activities constitute completion of one safety system functional failures sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings of significance were identified.

.3 Mitigating Systems Performance Index - Emergency ac Power System

a. Inspection Scope

The inspectors sampled licensee submittals for the mitigating systems performance index - emergency ac power system performance indicator for the period from the first quarter 2008 through the first quarter 2009. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, was used. The inspectors reviewed the licensee's operator narrative logs, mitigating systems performance index derivation reports, issue reports, event reports, and NRC integrated inspection reports for the period of March 2008 through March 2009 to validate the accuracy of the submittals. The inspectors reviewed the mitigating systems performance index component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.

These activities constitute completion of one safety system functional failures sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings of significance were identified.

.4 Mitigating Systems Performance Index - High Pressure Injection Systems

a. Inspection Scope

The inspectors sampled licensee submittals for the mitigating systems performance index - high pressure injection systems performance indicator for the period from the first quarter 2008 through the first quarter 2009. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, was used. The inspectors reviewed the licensee's operator narrative logs, issue reports, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports for the period of March 2008 through March 2009 to validate the accuracy of the submittals. The inspectors reviewed the mitigating systems performance index component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.

These activities constitute completion of one safety system functional failures sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings of significance were identified.

.5 Drill/Exercise Performance (EP01)

a. Inspection Scope

The inspectors sampled licensee submittals for the Drill and Exercise Performance, performance indicator for the period from July 2008 through March 2009. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, was used. The inspectors reviewed the licensee's records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the Nuclear Energy Institute guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the performance indicator; assessments of performance indicator opportunities during predesignated control room simulator training sessions, performance during the 2007 biennial exercise, and performance during other drills. Specific documents reviewed are described in the attachment to this report.

These activities constitute completion of the drill/exercise performance sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings of significance were identified.

.6 Emergency Response Organization Drill Participation (EP02)

a. Inspection Scope

The inspectors sampled licensee submittals for the Emergency Response Organization Drill Participation performance indicator for the period from July 2008 through March 2009. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, was used. The inspectors reviewed the licensee's records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the Nuclear Energy Institute guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the performance indicator, rosters of personnel assigned to key emergency response organization positions, twelve selected emergency responder training records, and a sample of eight exercise participation records. Specific documents reviewed are described in the attachment to this report.

These activities constitute completion of the emergency response organization drill participation sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings of significance were identified.

.7 Alert and Notification System (EP03)

a. Inspection Scope

The inspectors sampled licensee submittals for the Alert and Notification System performance indicator for the period from July 2008 through March 2009

. To determine the accuracy of the performance indicator data reported during those periods, performance indicator definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, was used. The inspectors reviewed the licensee's records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the Nuclear Energy Institute guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the performance indicator and the results of bimonthly alert notification system operability tests. Specific documents reviewed are described in the attachment to this report.

These activities constitute completion of the alert and notification system sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical Protection

.1 Routine Review of Identification and Resolution of Problems

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensee's corrective action program at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. The inspectors reviewed attributes that included: the complete and accurate identification of the problem; the timely correction, commensurate with the safety significance; the evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews; and the classification, prioritization, focus, and timeliness of corrective. Minor issues entered into the licensee's corrective action program because of the inspectors' observations are included in the attached list of documents reviewed.

These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure, they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.

b. Findings

No findings of significance were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensee's corrective action program. The inspectors accomplished this through review of the station's daily corrective action documents.

The inspectors performed these daily reviews as part of their daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings of significance were identified.

.3 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a review of the licensee's corrective action program and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors focused their review on repetitive equipment issues, but also considered the results of daily corrective action item screening discussed in Section 4OA2.2, above, licensee trending efforts, and licensee human performance results. The inspectors nominally considered the period from October 2008 through June 2009, although some examples expanded beyond those dates where the scope of the trend warranted.

The inspectors also included issues documented outside the normal corrective action program in major equipment problem lists, repetitive and/or rework maintenance lists, departmental problem/challenges lists, system health reports, quality assurance audit/surveillance reports, self-assessment reports, and maintenance rule assessments. The inspectors compared and contrasted their results with the results contained in the licensee's corrective action program trending reports. Corrective actions associated with a sample of the issues identified in the licensee's trending reports were reviewed for adequacy.

These activities constitute completion of one single semi-annual trend inspection sample as defined in Inspection Procedure 71152-05.

b. Findings

Introduction.

The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI (Corrective Action), for the failure to promptly correct conditions adverse to quality. The licensee had documented several conditions adverse to quality and then transferred the concerns to other condition reports. Then, the licensee closed those condition reports without addressing the concerns. Identified conditions included

(1) the Train B 125 Vac discharge test data indicated a loose battery connection but the battery was permitted to pass the test anyway;

(2) the root cause determination for the failed battery was focused on the statements of one person and failed to address other information;

(3) the root cause determination failed to address conflicting information; and

(4) the root cause determination failed to properly address other potential causes for the inoperable battery, such as tampering.

Description.

On December 17, 2008, the NRC described to the licensee several concerns with a root cause analysis for a significant condition adverse to quality (Train B 125 Vdc battery failure identified on September 2, 2008). Specifically, the inspectors identified that

(1) the root cause determination for the failed battery was focused on the statements of one person and failed to address other information;

(2) the root cause determination failed to address conflicting information from different individuals; and

(3) the root cause determination failed to properly address other potential causes for the inoperable battery, such as tampering. These concerns were entered into the corrective action process as Condition Report CR-WF3-2008-5852. This condition report was closed out to Condition Report CR-WF3-2009-4179, Corrective Action CA-54, which was intended to correct the conditions. However, this condition report was subsequently closed without addressing the concerns.

On January 6, 2009, the licensee identified that the Train B 125 Vac discharge test data (May 27, 2008) indicated a loose battery connection but the battery was permitted to pass the test anyway. Several months later, the licensee found that the loose connection had rendered the battery inoperable. That condition was documented in Condition Report CR-WF3-2009-0069. This condition report was subsequently closed out to Condition Report CR-WF3-2009-4179, Corrective Action CA-55, which was intended to address the condition. However, the corrective action was closed without addressing the concern.

NOTE: Additional NRC followup to the failed station battery will be documented in NRC Inspection Report 05000382/2009008.

On February 9, 2009, the inspectors identified that the licensee had closed Condition Report CR-WF3-2008-4179 but had not corrected the conditions that were transferred to the document from Condition Reports CR-WF3-2008-5852 and CR-WF3-2009-0069. The licensee entered this new finding into their corrective action process as Condition Report CR-WF3-2009-0697.

To determine the extent of condition, the licensee reviewed the corrective actions for Condition Report CR-WF3-2008-4179 and determined that an additional seven corrective actions had been closed out without fully being answered. These additional examples were entered into the licensee's corrective action program as Condition Report CR-WF3-2009-1177. The licensee characterized the problem as a significant condition adverse to quality. Subsequently, the licensee's extent of condition review identified an additional 30 examples where corrective actions were inappropriately closed without correcting the identified conditions in the past 14 months.

Analysis.

The failure to correct conditions adverse to quality was a performance deficiency. The finding was more than minor because, if left uncorrected, it would become a more significant safety concern. For example, the failure to include acceptance criteria in the battery discharge test (intended to identify and correct loose battery connections) could result in another inoperable 125 Vdc battery for an extended period. The inspectors evaluated the finding using Inspection Manual Chapter 0609, Significance Determination Process, Phase 1 Screening Worksheet and determined that the finding was of very low risk significance because it did not result in another battery becoming inoperable or nonfunctional. This finding had a crosscutting aspect in the area of Human Performance (Work Practices Component) because plant personnel failed to effectively use human error prevention techniques, such as self and peer checking, when transferring concerns between condition reports H.4(a).

Enforcement.

In accordance with 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part, that measures be established to assure that conditions adverse to quality are promptly identified and corrected. On December 17, 2008, and on January 6, 2009, four conditions adverse to quality were identified by the inspectors and the licensee, as noted in the body of this report. Contrary to the above, the licensee failed to correct the conditions adverse to quality, in that the concerns were transferred to another condition report and then closed without action. Because this violation was of very low safety significance and was entered in the corrective action program as Condition Report CR-WF3-2009-0697, this violation is being treated as a noncited violation, consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000382/2009002-02, "Failure to Correct Several Conditions Adverse to Quality."

.4 Selected Issue Follow-up Inspection

a. Inspection Scope

During a review of items entered in the licensee's corrective action program, the inspectors reviewed operator workarounds and burdens and conducted a review of conditions surrounding the premature failure of the Train B 125 Vdc station battery. The inspectors considered the following during the review of the licensee's actions:

(1) complete and accurate identification of problems in a timely manner;

(2) evaluation and disposition of operability/reportability issues;

(3) consideration of extent of condition, generic implications, common cause, and previous occurrences;

(4) classification and prioritization of the resolution of the problem;

(5) identification of root and contributing causes of the problem;

(6) identification of corrective actions; and

(7) completion of corrective actions in a timely manner.

These activities constitute completion of two in-depth problem identification and resolution samples as defined in Inspection Procedure 71152-05.

b. Findings

Introduction.

The inspectors identified a green noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI (Corrective Actions), because the licensee failed to identify the cause for a significant condition adverse to quality. The Train B 125 Vdc battery bank failed to pass a technical specification surveillance required discharge test during a Spring 2008 outage. The root cause procedure required that the licensee sequester the battery in a controlled area so that vital information related to the failure could be obtained. However, the licensee disposed of the battery instead. When questions arose concerning the specified failure cause (impurities in the battery materials), the licensee was unable to provide objective evidence to support the conclusion. Had the licensee obtained objective evidence to support their conclusion that impurities caused the battery failure, a 10 CFR Part 21 report may have been required. The licensee replaced the battery and planned to replace similar batteries in the other two trains during the next refueling outage.

Description.

On May 16, 2008, during a refueling outage, the licensee conducted a technical specification required performance test of the safety-related Train B, 125 Vdc station battery. The licensee determined that the battery capacity was 86.25 percent from this test. This was an unexpected result, as the licensee had predicted a capacity near 100 percent.

The licensee consulted with the battery vendor (C&D). The vendor advised the licensee that the licensee's testing method may be inappropriate and suggested changes. The licensee performed a second test of the battery on May 22 and noted that the capacity was 71.6 percent. Technical Specification Surveillance Requirement 4.8.2.1.d required that the battery capacity be verified to be at least 80 percent of the manufacturers rating every 60 months, when subjected to a discharge test. The failure to pass the technical specification surveillance requirement rendered the battery inoperable. The battery had a vendor specified 20- year service life but had only lasted a little more than 15 years. The licensee promptly procured a new battery and replaced the failed Train B battery.

The only extent of condition review that the licensee performed was to verify that the other station batteries were from different manufacturing lots. At the time of the surveillance failure, the plant was in an outage and was relying on the other station batteries to meet the requirements for the technical specification required minimum equipment.

In response to the battery failure, the licensee performed a root cause analysis, as documented in Condition Report WF3-2008-02431, dated August 12, 2008. The licensee considered the battery failure a "significant condition adverse to quality." The licensee concluded that the battery had most likely failed the test because of impurities introduced during manufacturing. The licensee reached this conclusion based on the elimination of other potential causes that they had considered. The inspectors determined that the licensee did not obtain vendor assistance or input. The licensee did not perform testing to verify that impurities were actually present in the battery. Then, the licensee disposed of the battery. No cells from the defective battery train were returned to the vendor for analysis.

On July 30, 2009, licensee senior management decided to reassess the root cause because they no longer believed that it involved a manufacturing defect. The inspectors identified that the licensee had failed to meet the requirements of 10 CFR Part 50, Appendix B, Criterion XVI (Corrective Actions), for the battery failure. This requirement specifies, in part, that the cause of significant conditions adverse to quality be determined and corrective actions taken to preclude repetition. In this instance, since the licensee disposed of the battery prior to performing a thorough analysis of the failed components, the licensee could not adequately determine the cause.

The inspectors also noted that the licensee had failed to follow their root cause procedure concerning analysis of failed components. Corporate Procedure EN-LI-118, "Root Cause Analysis Process," Revision 7, discusses actions to be performed during the course of performing a root cause analysis. Section 5, step [3](a)(3) required the licensee to "initiate physical evidence collection" and "move items to a controlled area to prevent tampering or loss." For the failed battery, the licensee did not complete these actions.

Additionally, had the licensee conclusively determined that battery failure was caused by impurities introduced during the manufacturing process, a 10 CFR Part 21, "Reporting of Defects and Noncompliance," may have been required. This regulation requires licensees and vendors to notify the NRC of defects in safety-related components that could involve a substatial safety hazard. If the failure did involve a defect, the inspectors believed that a subsafety hazard would exist due to the rapid degradation that occurred within a single surveillane interval making the failure undetectable. The NRC would then notify licensees that could be affected by the condition so that they could take appropriate corrective measures. In this instance, however, since the cause of the failure was not actually known, the NRC could not evaluate the condition or further consider a generic communication.

Analysis.

The failure to identify the cause for a significant condition adverse to quality was a performance deficiency. The finding was more than minor because, if left uncorrected, it could lead to a more significant safety concern. Specifically, since the cause of the battery failure was not definitively found, the licensee may not have taken corrective actions to prevent other battery failures. Using the Inspection Manual Chapter 0609, "Significance Determination Process," Phase 1 Screening Worksheet, the finding was of very low risk significance because it did not actually cause the loss of operability or functionality of another 125 Vdc battery at the time of the inspection. This finding had a crosscutting aspect in the area of Problem Identification and Resolution (Corrective Action Program Component) because the licensee failed to thoroughly evaluate the need to keep the battery prior to disposal P.1(c).

Enforcement.

Title 10 CFR Part 50, Appendix B, Criterion XVI (Corrective Actions), requires, in part, that "Measures shall be established to assure that conditions adverse to quality . . . are promptly identified and corrected. 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 the above, as of July 7, 2009, the licensee had identified a significant condition adverse to quality (125 Vdc battery train failure on May 22, 2008) but had not determined the cause of the condition and therefore could not specify actions to preclude repetition. Because this violation was of very low safety significance and was entered in the corrective action program as Condition Report CR-WF3-2009-2846, this violation is being treated as a noncited violation, consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000382/2009003-03, "Failure to Determine the Cause of a 125 Vdc Battery Failure."

4OA5 Other Activities

.1 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period, the inspectors performed observations of security force personnel and activities to ensure that the activities were consistent with Waterford Steam Electric Station security procedures and regulatory requirements relating to nuclear plant security. These observations took place during both normal and off-normal plant working hours.

These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors' normal plant status review and inspection activities.

b. Findings

No findings of significance were identified.

4OA6 Meetings

Exit Meeting Summary

On May 27, 2009, the inspector conducted a telephonic exit meeting to present the results of the in-office inspection of changes to the licensee's emergency plan to Mr. J. Lewis, Manager, Emergency Preparedness, and other members of the licensee's staff. The licensee acknowledged the issues presented.

On June 26, 2009, the inspectors presented the results of the inspection of the onsite emergency preparedness exercise to Mr. J. Kowalewski, Site Vice President, and other members of the licensee's staff. The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary or sensitive. All identified proprietary or sensitive information examined during the inspection had been returned to the licensee.

On June 30 and July 1, 2009, the inspectors discussed the technical and regulatory aspects of the identified emergency preparedness noncited violation with Mr. J. Lewis, Manager, Emergency Preparedness.

On July 20, 2009, the inspectors presented the inspection results to Mr. Joe Kowalewski, Site Vice-President, and other members of the licensee staff. A followup telephonic exit was conducted on August 10 with Mr. Joe Kowalewski 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.

A-1 Attachment

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

M. Adams, Supervisor, System Engineering

S. Anders, Manager, Plant Security

B. Briner, Technical Specialist IV, Componet Engineering

K. Christian, Director, Nuclear Safety Assurance

K. Cook, Manager, Operations

C. Fugate, Assistant Manager, Operations

M. Haydel, Supervisor, Programs and Components

J. Kowalewski, Vice President of Operations

J. Lewis, Manager, Emergency Preparedness

B. Lindsey, Manager, Maintenance

M. Mason, Senior Licensing Specialist, Licensing

W. McKinney, Manager, Corrective Action and Assessments

R. Murillo, Manager, Licensing

K. Nicholas, Director, Engineering

R. Putnam, Manager, Programs and Components

J. Williams, Senior Licensing Specialist, Licensing

LIST OF ITEMS

OPENED AND CLOSED

Opened and Closed

05000382/2009003-01 NCV Licensee Practices Result in Protective Action Recommendations for Areas Where Protective Action Guides are Not Exceeded.(Section 1EP1)

05000382/2009003-02 NCV Failure to Correct Several Conditions Adverse to Quality (Section 4OA2)

05000382/2009003-03 NCV Failure to Determine the Cause of a 125 Vdc Battery Failure (Section 4OA2)

Section 1R01: Adverse Weather Protection

CONDITION REPORTS

CR-WF3-2009-2229

CR-WF3-2009-2305

CR-WF3-2009-2306

CR-WF3-2009-2961

CR-WF3-2009-2413

CR-WF3-2009-2767

CR-WF3-2009-2307

CR-WF3-2009-2118

CR-WF3-2009-2414

CR-WF3-2009-2938

CR-WF3-2009-2326

CR-WF3-2009-0687

CR-WF3-2009-2415

CR-WF3-2009-2651

CR-WF3-2009-2343

CR-WF3-2009-0155

CR-WF3-2009-2440

Attachment

WORK ORDERS

51798176

51701184

194505

51088942

51697577

51680597

167665

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

ENS-PL-159 Summer Reliability

OP-009-002 Emergency Diesel Generator 310

OP-006-001 Plant Distribution 305

OP-006-008 Transformer Operation 301

OP-006-009 Electrical Bus Outages 4

OP-006-005 Inverters and Distribution 302

OP-902-003 Loss of Offsite Power 6

Section 1R04: Equipment Alignment

WORK ORDERS

2021780 34838

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

OP-009-002 Emergency Diesel Generator 308

OP-903-121 Safety Systems Quarterly IST Valve Tests 9

OP-009-001 Containment Spray 301

1R05:

Fire Protection

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

UNT-005-013 Fire Protection Program 10

OP-009-004 Fire Protecton 305

MM-004-424 Building fire Hose Station Inspection and Hose Replacement

MM-007-010 Fire Extinguisher Inspection and Extinguisher Replacement

2

FP-001-014 Duties of a Fire Watch 14

Attachment

FP-001-015 Fire Protection Impairments 302

DBD-018 Appendix R/fire Protection

Section 1R06: Flood Protection Measures

NUMBER TITLE REVISION

OP-901-521 Severe Weather and Flooding 4

OP-902-008 Functional Recovery Procedure 15 FSAR Section 3.6A.6 Flooding Analysis 14-A FSAR Section 3.6A.6.4.1 Reactor Auxiliary Building - High Energy Pipe Breaik 14-A DWG - G173 Sheet 2 Sump Pump System - Reactor Auxiliary Bldg. 5 FSAR Figure 9.3-5 Reactor Auxiliary Building Drainage Sys. 4

Section 1R11: Licensed Operator Requalification Program

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION E-68 Simulator Scenario 3

OP-901-202 Steam Generator Tube Leakage or High Activity 9

OP-901-212 Rapid Plant Power Reduction 3

OP-902-000 Standard Post Trip Actions 10

OP-902-008 Safety Function Recovery Procedure 15

Section 1R12: Maintenance Effectiveness

CONDITION REPORTS

CR-WF3-2009-2662

CR-WF3-2009-2245

CR-WF3-2009-1284

CR-WF3-2008-5905

CR-WF3-2008-3106

CR-WF3-2008-2467

CR-WF3-2007-0762

CR-WF3-2007-0935

CR-WF3-2007-1666

CR-WF3-2007-2469

CR-WF3-2007-4448

CR-WF3-2009-2384

CR-WF3-2009-2223

CR-WF3-2009-0205

CR-WF3-2008-5669

CR-WF3-2008-2957

CR-WF3-2008-1315

CR-WF3-2008-0037

CR-WF3-2008-2352

CR-WF3-2008-5115

CR-WF3-2008-5258

CR-WF3-2007-4280

CR-WF3-2009-2356

CR-WF3-2009-2092

CR-WF3-2009-0017

CR-WF3-2008-4215

CR-WF3-2008-2833

CR-WF3-2008-0676

CR-WF3-2008-5786

CR-WF3-2009-0785

CR-WF3-2009-1972

CR-WF3-2009-2306

CR-WF3-2007-4281

CR-WF3-2009-2355

CR-WF3-2009-1356

CR-WF3-2009-0016

CR-WF3-2008-3210

CR-WF3-2008-2756

CR-WF3-2008-0613

CR-WF3-2009-2321

CR-WF3-2009-2337

CR-WF3-2009-2343

CR-WF3-2009-2861

CR-WF3-2007-2610

Attachment WORK ORDERS

117089

155100

172152

51562560

94701 94702

113371

132935

00085241

00140811 95498

51097820 PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

DC-121 Maintenance Rule 1 NUMARC 93-01 Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants

Section 1R13: Maintenance Risk Assessment and Emergency Work Controls

CONDITION REPORTS

CR-WF3-2009-1706

CR-WF3-2009-1718

CR-WF3-2009-3023

CR-WF3-2009-2807 WORK ORDERS

00190937

186508

173008

197692

186497

185547

136785

160282

185560

116977

51657973

184949

197599 PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

EN-WEM-101 On-Line Work Management Process 1

OI-037-000 Operations Risk Assessment Guideline 2

OP-006-003 125 Vdc Electric Distribution 301

ME-007-002 Molded Case Circuit Breakers 15

ME-007-008 Motor-Operated Valves 16

ME-007-045 Motor-Operated Valve Motor Power Monitor 2

UNT-001-015 Equipment QAualification Program 7

ME-004-809 Low/Medium voltage Power & Control Cable/Conductor Terminations and splices

2

ME-007-047 VOTES Testing of Motor-Operated Valves 5

OP-009-008 Safety Injection System 25

OP-009-001 Containment spray 301

MI-005-464 Plant Protection System Power Supply Calibration 303

OP-009-007 Plant Protection System 9

ME-007-005 Time Delay Relay Setting Check Adjustment 13

Attachment

ME-004-330 4KV Induction Motor Maintenance 300

ME-004-211 Station Battery (Quarterly) 7

ME-002-210 Station Battery Bank & Charger (Quarterly) 14

Section 1R15: Operability Evaluations

CONDITION REPORTS

CR-WF3-2009-2189

CR-WF3-2008-5867

CR-WF3-2008-5618

CR-WF3-2009-2253

CR-WF3-2009-2212

CR-WF3-2009-2226

CR-WF3-2009-2229

CR-WF3-2009-2253 WORK ORDERS

51646383

51695212

194110

52033543

164712

194505

51701184 PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

OP-903-026 Emergency Core Cooling System Valve Lineup Verification

OP-009-008 Safety Injection 25

MM-007-038 Valves

HVC-101 and

HVC-102 Leak Test 300

OP-009-002 Emergency Diesel Generator 308

OP-903-068 Emergency Diesel Generator Operability and Subgroup Relay Operability Verification

2

OP-903-15 Train A Integrated Emergency Diesel Generator / Engineering Safety Features Test

Section 1R19: Postmaintenance Testing

CONDITION REPORTS

CR-WF3-2009-1706

CR-WF3-2008-4304 CR-WF3-2009-2212

CR-WF3-2009-1718

CR-WF3-2008-4304 CR-WF3-2009-2226

CR-WF3-2008-5786

CR-WF3-2008-4765 CR-WF3-2009-2229

CR-WF3-2008-4765

CR-WF3-2009-2253 CR-WF3-2009-225

WORK ORDERS

00190937

173009

185560

2030855

164712 34838

194505

197180

180143

516557973

184946

2022009

51701184

170228

2034706 46961

186508

173008

51646383

51695212

52033835

2031652

168290

185547

52022649

194110

52033543

52036094

191225

Attachment PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

MI-005-464 Plant Protection System Power Supply Calibration 303

OP-009-007 Plant Protection System 9

MI-013-522 PPS Ground Detection Test 5

MI-005-293 Retest Procedure for Power Supplies 2

OP-903-107 Plant Protection System Channel A&B&C&D Functional Test

303

ME-007-005 Time Delay Relay Setting Check Adjustment 13

OP-009-008 Safety Injection System 25

OP-903-030 Safety Injection Pump Operability Verification 15

OP-009-008 Safety Injection System 25

ME-007-002 Molded Case Circuit Breakers 15

ME-007-005 Time Delay Relay Setting Check Adjustment 13

ME-007-008 Motor Operated Valves 16

ME-007-045 Motor-Operated Valve Motor Power Monitor 2

ME-004-809 Low/Medium Voltage Power & Control Cable/Conductor Terminations and Splices

2

ME-007-057 MCE/EMAX Data Acquisition 4

ME-004-330 4KV Induction Motor Maintenance 300

MM-007-038 Valves

HVC-101 and

HVC-102 Leak Test 300

OP-009-002 Emergency Diesel Generator 308

OP-903-068 Emergency Diesel Generator Operability and Subgroup Relay Operability Verification

2

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

OP-100-002 Leak Reduction 300

OP-903-003 Charging Pump Operability Check 301

OP-002-005 Chemical and Volume Control 28

OP-903-035 Containment Spray Pump Operability Check 13

OP-009-001 Containment Spray 301

MM-006-021 Charging Pump Maintenance 9

Attachment

Section 1R22: Surveillance Testing

WORK ORDERS

2033543

51795535

51794147

52034706

51797247

52031652

51695212 PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

OP-903-030 Safety Injection Pump Operability Verification 15

OP-009-008 Safety Injection System 25

OP-903-118 Primary Auxiliaries Quarterly IST Valve Test 16

OP-002-003 Component Cooling Water System 305

OP-009-003 Emergency Feedwater 301

OP-903-046 Emergency Feed Pump Operability Check 304

OP-002-005 Chemical and Volume Control 28

OP-100-002 Leak Reduction 300

OP-009-002 Emergency Diesel Generator 308

OP-903-068 Emergency Diesel Generator Operability and Subgroup Relay Operability Verification

2

OP-903-115 Train A Integrated Emergency Diesel Generator / Engineering Safety Features Test, 10

Section 1EP1: Exercise Evaluation

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION / DATE

EP-1-001 Recognition and Classification of Emergencies 22

EP-1-020 Actions for Alert 301

EP-1-030 Actions for Site Emergency 25-2

EP-1-040 Actions for General Emergency 26-2

EP-2-010 Notifications and Communications 303

EP-2-015 Emergency Responder Activation 8-1

EP-2-030 Emergency Radiation Exposure Guidelines and Controls 9

EP-2-031 In-Plant Radiation Control during Emergencies 7-2

EP-2-033 KI Administration 301

EP-2-034 Onsite Surveys during Emergencies 5-1

EP-2-050 Offsite Dose Assessment 303

Attachment NUMBER TITLE REVISION / DATE

EP-2-052 Protective Action Guidelines 20

EP-2-071 Site Protective Measures 18-2

EP-2-100 TSC Activation, Operation, and Deactivation 33

EP-2-101 OSC Activation, Operation, and Deactivation 302

EP-2-102 EOF Activation, Operation, and Deactivation 301

EP-2-130 Emergency Team Assignments 22 2007-03 2007 Green Team Site Drill

February 18, 2008 2007-04 2007 Green Team Biennial Exercise

March 10, 2008 2008-01 2008 Red Team Site Drill

August 3, 2008 2008-03 2008 Blue Team Site Drill

January 8, 2009 2008-04 2008 Orange Team Site Drill

March 29, 2009 2009-01 2009 Green Team Site Drill

June 19, 2009 2009-02 2009 Blue Team Site Drill

June 21, 2009

WLP-EP-EDIR Emergency Preparedness Lesson Plan: Emergency Director 7

WLP-EP-EC Emergency Preparedness Lesson Plan: Emergency Coordinator

WLP-EP-RPC Emergency Preparedness Lesson Plan: Radiation Protection Coordinator

WLP-OPS-EP02 Operations Lesson Plan: Emergency Plan Training for Control Room Personnel, Training Personnel, and Operations Coordinators

CORRECTIVE ACTION DOCUMENTS

2009-01101 2009-01184

Section 4OA1: Performance Indicator Verification

NUMBER TITLE REVISION

NEI 99-02 Regulatory Assessment Performance Indicator Guideline

PROCEDURES

NUMBER TITLE REVISION

EP-1-001 Recognition and Classification of Emergencies 22

EP-2-010 Notifications and Communications 303

EP-2-052 Protective Action Guidelines 20

Attachment

EP-3-070 Emergency Communications Systems Routine Testing 301

EN-EP-201 Emergency Planning Performance Indicators 8

EN-LI-114 Perofrmance Indicator Process 4

EPP-422 Siren and Helicopter Warning System Maintenance 4

EPP-424 Siren Testing and Siren Administrative Controls 12

MISCELLANEOUS DOCUMENTS

TITLE REVISION Water3 Steam Electric Station Emergency Plan 37

Section 4OA2: Identification and Resolution of Problems

PROCEDURES

NUMBER TITLE REVISION

OI-002-000 Annunciator, Control Room Instrumentation and Workaround Status Control

301

OI-034-000 Work Management Center 18

EN-LI-102 Corrective Action Process 11

ME-003-240 Battery Performance Test 13

EN-LI-118 Root Cause Analysis Process 7 CONDITION REPORTS

CR-WF3-2009-0069

CR-WF3-2008-2431

CR-WF3-2009-1177

CR-WF3-2008-2515

CR-WF3-2009-0697

CR-WF3-2008-5852

CR-WF3-2008-4179

CR-WF3-2009-2846 WORK ORDERS

155714

156715

169263

148345

168928

152819 157646