IR 05000382/2014002

IR 05000382-14-002, 01/01/2014 - 03/31/2014, Waterford, Unit 3, Integrated Inspection of Equipment Alignment, Maintenance Effectiveness, Operability Determinations and Functionality Assessments, and Problem Identification and Resolution

ML14128A528
Person / Time
Site:	Waterford
Issue date:	05/08/2014
From:	Greg Werner NRC/RGN-IV/DRP/RPB-E
To:	Chisum M Entergy Operations
Werner G
References
Download: ML14128A528 (49)

Text

UNITED STATES May 8, 2014

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED INSPECTION REPORT 05000382/2014002

Dear Mr. Chisum:

On March 31, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Waterford Steam Electric Station, Unit 3 facility. On April 1, 2014, the NRC inspectors discussed the results of this inspection with Mr. Carl Rich, Jr., Director, Regulatory and Performance Improvement, and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.

NRC inspectors documented four findings of very low safety significance (Green) in this report.

All of these findings involved violations of NRC requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the NRC Enforcement Policy.

If you contest the violations or significance of these NCVs, 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, Region IV; the Director, Office of Enforcement, U.S.

Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspectors at the Waterford Steam Electric Station, Unit 3 facility.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV; and the NRC resident inspectors at the Waterford Steam Electric Station, Unit 3. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Gregory E. Werner, Chief Project Branch E Division of Reactor Projects Docket No.: 50-382 License No.: NPF-38

Enclosure:

Inspection Report 05000382/2014002 w/ Attachment: Supplemental Information

REGION IV==

Docket: 05000382 License: NPF-38 Report: 05000382/2014002 Licensee: Energy Operations, Inc.

Facility: Waterford Steam Electric Station, Unit 3 Location: 17265 River Road Killona, LA 70057 Dates: January 1 through March 31, 2014 Inspectors: M. Davis, Senior Resident Inspector C. Speer, Resident Inspector S. Hedger, Operations Inspector R. Latta, Senior Reactor Inspector P. Elkmann, Senior Emergency Preparedness Inspector L. Brandt, Project Engineer (NSPDP)

Approved Gregory E. Werner, Chief By: Project Branch E Division of Reactor Projects-1- Enclosure

SUMMARY

IR 05000382/2014002; 01/01/2014 - 03/31/2014; Waterford Steam Electric Station, Unit 3;

Equipment Alignment, Maintenance Effectiveness, Operability Determinations and Functionality Assessments, and Problem Identification and Resolution.

The inspection activities described in this report were performed between January 1 and March 31, 2014, by the resident inspectors at the Waterford Steam Electric Station, Unit 3, and inspectors from the NRCs Region IV office. Four findings of very low safety significance (Green) are documented in this report. All of these findings involved violations of NRC requirements. The significance of inspection findings is indicated by their color (Green, White,

Yellow, or Red), which is determined using Inspection Manual Chapter 0609, Significance Determination Process. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, Aspects Within Cross-Cutting Areas. Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a non-cited violation of Technical Specification 6.8.1.a because the licensee did not establish written procedures to fill the diesel fuel oil storage tanks for their emergency onsite power sources. Specifically, the licensee did not establish procedures to fill the fuel oil storage tanks for the emergency diesel generators using the credited safety-related, seismic category 1 emergency fill line. The licensee entered this condition into their corrective action program as Condition Report CR-WF3-2014-00636.

The immediate corrective action taken to restore compliance was to develop procedures to fill the emergency diesel generator fuel oil storage tanks using the safety-related, seismic category 1 emergency fill line and evaluate other alternative methods.

The inspectors concluded that the failure to establish procedures to fill the fuel oil storage tanks for the emergency onsite power sources was a performance deficiency. The performance deficiency was more than minor because it was associated with the procedure quality attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, it reduced the licensees reliability and capability to fill the fuel oil storage tanks for the onsite power sources following a loss of offsite power or extreme weather event (e.g., a seismic or flooding event) that may last longer than seven days. The inspectors performed the initial significance determination for this issue. The inspectors used NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, to evaluate the issue.

The initial screening directed the inspectors to use Inspector Manual Chapter 0609,

Appendix A, The Significance Determination Process for Findings At-Power, Exhibit 2,

Section A, to determine the significance of the issue. The finding required a detailed risk evaluation because the performance deficiency could have resulted in a loss of safety function (onsite ac power) because the system may not have remained operable for its 30-day design basis accident mission time. Therefore, a Region IV senior reactor analyst performed a detailed risk evaluation for this issue. The analyst determined that the finding was of very low safety significance (Green) because the diesel generators would have remained functional for the 24-hour probabilistic risk assessment mission time. This detailed risk evaluation used the shorter mission time because after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the NRC assumed that the licensee had substantially more resources available to help mitigate the accident.

The dominant core damage sequences included longer-term loss of offsite power events and the common cause failure of the diesel generators due to potential problems to refill the diesel fuel oil storage tanks after seven days. The relatively long period prior to ultimate diesel generator failure helped to minimize the risk. Additionally, the finding was not a significant contributor to the large early release frequency. The inspectors concluded that the finding reflected current licensee performance and involved an avoiding complacency cross-cutting aspect of the human performance area in that the licensee did not recognize and plan for the possibility of mistakes, latent issues and inherent risk, even while expecting successful outcomes [H.12] (Section 1R04).

Green.

A self-revealing, non-cited violation of Technical Specification 6.8.1.a. occurred because the licensee did not develop a preventative maintenance schedule to inspect or replace an item that has a specific lifetime. Specifically, the licensee did not develop a preventative maintenance schedule to inspect or replace the essential chiller oil pump motors prior to exceeding their duty life. As a result, the essential chiller oil pump B motor failed in-service. The licensee entered this condition into their corrective action program as Condition Report CR-WF3-2014-0095. The immediate corrective action taken to restore compliance was to issue an action request to establish the periodic replacement of the essential chiller oil pumps prior to the end of their vendor recommended service life.

The inspectors concluded that the failure to develop a preventative maintenance schedule to inspect or replace the essential chiller oil pump motors prior to the end of the vendor provided duty life was a performance deficiency. The performance deficiency was more than minor because it was associated with the equipment performance attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, it affected the availability and reliability of the essential chillers to provide a heat sink for the removal of process and operating heat from selected safety-related equipment during design basis accidents. The initial screening directed the inspectors to use Inspector Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, Exhibit 2, Section A, to determine the significance of the finding. The inspectors categorized the finding as having very low safety significance (Green) because the finding did not affect the design or qualification of the system; it did not represent a loss of the system or function; and, the loss of the essential chiller was less than the technical specification allowed outage time. The inspectors also concluded that the finding did not have a cross-cutting aspect because the most significant contributor to the performance deficiency occurred more than 3 years ago, and did not reflect current licensee performance (Section 1R12).

Green.

The inspectors identified a non-cited violation of License Condition 2.C.9 because the licensee did not implement Procedure EN-DC-161, Control of Combustibles, which requires, in part, that a transient combustible evaluation shall be processed or compensatory actions shall be established if a flammable liquid exceeds one pint in an approved container. Specifically, the licensee did not implement Section 5.6 of Procedure EN-DC-161 after a fuel oil leak from the standby fuel oil pump for the train B emergency diesel generator exceeded one pint in an approved container which eventually failed to hold the fuel oil while in service. The licensee entered this condition into their corrective action program as Condition Reports CR-WF3-2013-6020 and CR-WF3-2013-06123. The immediate corrective actions taken to restore compliance was to remove the leaking fuel oil from around the emergency diesel generator, implement an hourly fire watch, and repair the standby fuel oil pump leak and returned the emergency diesel generator to an operable status on January 3, 2014.

The inspectors concluded that the failure to implement a fire protection program procedure was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection against external factors (i.e., fire) attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to perform a transient combustible evaluation when a flammable liquid above one pint in an approved container was present in the B emergency diesel generator room prevented the licensee from implementing required compensatory measures in response to the presence of transient combustibles surrounding and on the B emergency diesel generator. In addition, similar to NRC Inspection Manual Chapter 0612, Appendix E, Section 4, Example k, of a more than minor violation, the failure of the leak collection device resulting in fuel oil around the B emergency diesel generator represented a credible fire scenario involving transient combustibles that could affect equipment important to safety. The inspectors used NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, to evaluate this issue. Since this finding was related to controls for transient combustible materials, the initial screening directed the inspectors to use Appendix F, Fire Protection Significance Determination Process, to determine the significance of the finding. The inspectors categorized the finding under Task 1.4.1, Fire Prevention and Administrative Controls, and qualitatively screened it as very low safety significance (Green) because the impact of the fire finding was limited to no more than one train of equipment important to safety. The inspectors concluded that the finding reflected current licensee performance and involved a conservative bias cross-cutting aspect in the human performance area in that the licensee did not use decision making practices that emphasized prudent choices over those that are simply allowable [H.14] (Section 1R15).

Green.

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

Criterion III, Design Control, occurred because the licensee did not establish design control measures for the selection and review for the suitability of application of a molded case circuit breaker that was essential to the safety-related function of a shutdown cooling heat exchanger fan cooler. Specifically, the licensee did not select and review for the suitability of the correct safety-related circuit breaker for the application to provide circuit fault protection to the train B shutdown cooling heat exchanger air handling unit fan motor. The licensee entered this condition into their corrective action program as Condition Reports CR-WF3-2013-02316 and CR-WF3-2013-04644. The immediate corrective action taken to restore compliance included the replacement of the breaker with a breaker more suitable for the application to protect the air handling unit fan motor. The planned corrective actions included an extent of condition review for other installed breakers and the revision of work order instructions to eliminate the practice of substituting and using the factory acceptance testing for pre-installation and post-maintenance tests, respectively.

The inspectors concluded that the failure to establish design control measures for the selection and review for suitability of application for the correct safety-related circuit breaker was a performance deficiency. The performance deficiency was more than minor because it was associated with the design control attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

Specifically, the incorrect breaker affected the availability, reliability, and capability of the shutdown cooling heat exchanger fan coolers to remove heat from the shutdown cooling heat exchanger areas following a design basis accident. The inspectors performed the initial significance determination. The inspectors used the NRC Inspection Manual 0609,

Attachment 4, Initial Screening and Characterization of Findings. The initial screening directed the inspectors to use Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Section A, to determine the significance of the finding. The finding required a detailed risk evaluation because it involved a potential loss of one train of safety-related equipment for longer than the technical specification allowed outage time. The total exposure period was 23 days.

The allowed outage time was 7 days. A Region IV senior reactor analyst performed the detailed risk evaluation and determined that the change to the core damage frequency was 5E-13/year (Green). The dominant core damage sequences included loss of offsite power events, failure of both trains of containment spray, and the failure of a pressurizer safety relief valve to remain closed. The equipment that helped mitigate the risk included the emergency diesel generators and the essential feedwater systems.

The inspectors concluded that the finding reflected current licensee performance and involved a cross-cutting aspect of avoiding complacency in the human performance area because the licensee did not recognize and plan for the possibility of mistakes, latent issues, and inherent risk on relying on 21 year old vendor information and installing a breaker without pre-installation and adequate post-maintenance testing [H.12] (Section 4OA2.2).

PLANT STATUS

The Waterford Steam Electric Station, Unit 3 facility, began the inspection period at 100 percent power. The unit remained at 100 percent power for the duration of the inspection period.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

On January 6, 2014, the inspectors completed an inspection of the stations readiness for seasonal extreme weather conditions. The inspectors reviewed the licensees adverse weather procedures for freeze protection and temperature maintenance for anticipated low temperatures with seasonal extreme cold weather and evaluated the licensees implementation of these procedures. The inspectors verified that prior to the onset of seasonal extreme cold weather the licensee had corrected weather-related equipment deficiencies identified during the previous cold season.

The inspectors selected two risk-significant systems that were required to be protected from cold conditions:

Fire protection system for the motor and diesel driven fire pumps Alternate direct current system The inspectors reviewed the licensees procedures and design information to ensure the systems would remain functional when challenged by seasonal extreme cold weather.

The inspectors verified that operator actions described in the licensees procedures were adequate to maintain readiness of these systems. The inspectors walked down portions of these systems to verify the physical condition of the seasonal extreme cold weather protection features.

These activities constituted one sample of readiness for seasonal adverse weather, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial Walkdown

a. Inspection Scope

The inspectors performed partial system walk-downs of the following risk-significant systems:

On January 2, 2014, temporary emergency diesel generators with emergency diesel generator B out of service for maintenance On February 12, 2014, auxiliary component cooling water train A with train B out of service for maintenance On February 24, 2014, emergency feedwater trains A and B with the steam driven emergency feedwater pump AB out of service for maintenance The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems were correctly aligned for the existing plant configuration.

These activities constituted three partial system walk-down samples as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

.2 Complete Walkdown

a. Inspection Scope

On January 6, 2014, the inspectors performed a complete system walk-down inspection of the train B emergency diesel generator fuel oil storage and transfer system. The inspectors reviewed the licensees procedures and system design information to determine the correct system lineup for the existing plant configuration. The inspectors also reviewed outstanding work orders, open condition reports, in-process design changes, temporary modifications, and other open items tracked by the licensees operations and engineering departments. The inspectors then visually verified that the system was correctly aligned for the existing plant configuration.

These activities constituted one complete system walk-down sample, as defined in Inspection Procedure 71111.04.

b. Findings

Introduction.

The inspectors identified a Green, non-cited violation of Technical Specification 6.8.1.a because the licensee did not establish written procedures to fill the diesel fuel oil storage tanks for their emergency onsite power sources. Specifically, the licensee did not establish procedures to fill the fuel oil storage tanks for the emergency diesel generators using the credited safety-related, seismic category 1 emergency fill line following any design basis event and loss of offsite power.

Description.

On January 6, 2014, the inspectors started a review and complete system walkdown of the train B emergency diesel generator fuel oil storage and transfer system.

As a part of the review, the inspectors questioned the licensee about the use and testing of the safety-related alternate emergency fill connection, which the licensee can use to fill the diesel fuel oil storage tanks following a loss of offsite power lasting greater than seven days. The inspectors noted that the alternate emergency fill connection was the only safety-related, seismic category 1 fill line credited for use in the licensees Final Safety Analysis Report. Additionally, based on the review of the licensees safety evaluation and updated final safety analysis reports, this line is the only fill connection for the emergency diesel generators that is assumed to be available for use following an extreme weather event (e.g., seismic, tornado, or flooding).

The licensee initiated Condition Report CR-WF3-2014-00636 because the licensee could not identify any procedures for how to use the safety-related alternate emergency fill connection. The only procedural guidance for using this line was a note at the top of operating Procedure OP-003-009, Fuel Oil Receipt and Transfer. Specifically, Section 6.1 of OP-003-009 contained a note stating that the alternate emergency fill connection is available in the event of damage to the normal fill line. The normal fill line is a non-safety-related and non-seismic fill connection used to fill the diesel fuel oil storage tanks during normal operation. The inspectors determined that an extreme weather event could damage or render the normal fill line unavailable. Based on this information, the inspectors concluded that no specific written procedural guidance existed for the use of the safety-related alternate emergency fill connection in order to fill the emergency diesel generator fuel oil storage tanks following an extreme weather and design basis event with a loss of offsite power.

Additionally, the inspectors noted that the licensee had previous opportunities to identify this issue. In 2011, the licensee modified the fuel oil transfer line near the alternate emergency fill connection as part of a modification to the fuel oil storage tanks.

However, the licensee did not review any procedures to determine if this modification would affect the safety-related fill connection. Such a review may have revealed that procedures did not exist to fill the diesel fuel oil storage tanks using the alternate emergency fill connection. The inspectors also determined that opportunities to identify this issue existed when the licensee prepared for hurricanes and other extreme weather events. However, the licensee did not know that the alternate emergency fill connection was the credited safety-related fill connection identified in design basis documents. The licensee entered this condition into their corrective action program as Condition Report CR-WF3-2014-00636. The immediate corrective action taken to restore compliance was to develop procedures to fill the emergency diesel generator fuel oil storage tanks using the alternate emergency fill line and to evaluate other alternative methods.

Analysis.

The failure to establish procedures to fill the fuel oil storage tanks for the emergency onsite power sources was a performance deficiency. The inspectors determined that this deficiency was reasonably within the licensees ability to foresee and correct. The performance deficiency was more than minor because it was associated with the procedure quality attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, it reduced the licensees reliability and capability to fill the fuel oil storage tanks for the onsite power sources following a loss of offsite power or extreme weather event (e.g., a seismic or flooding event) that may last longer than seven days. The inspectors used NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, to evaluate this issue. The initial screening directed the inspectors to use Inspection Manual chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, Exhibit 2, Section A, to determine the significance of the issue. The finding required a detailed risk evaluation because the performance deficiency could have resulted in a loss of safety function (onsite ac power)because the system may not have remained operable for its 30-day design basis accident mission time. Therefore, a Region IV senior reactor analyst performed a detailed risk evaluation for this issue. The analyst determined that the finding was of very low safety significance (Green) because the diesel generators would have remained functional for their 24-hour probabilistic risk assessment mission time. The senior reactor analyst used the shorter mission time for the detailed risk evaluations because after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the NRC assumes that the licensee has substantially more resources available to help mitigate the accident. The dominant core damage sequences included the longer-term loss of offsite power events and the common cause failure of the diesel generators because of potential problems refilling the diesel fuel oil storage tanks. The relatively long period prior to ultimate diesel generator failure helped to minimize the risk.

To address the contribution to conditional large early release frequency, the analyst used NRC Inspection Manual Chapter 0609, Appendix H, Containment Integrity Significance Determination Process. Since the performance deficiency would not result in a large early (less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) release of fission products to the environment, this finding was not significant to the large early release frequency.

The inspectors concluded that the finding reflected current licensee performance and involved an avoiding complacency cross-cutting aspect of the human performance area in that the licensee did not recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes [H.12].

Enforcement.

Technical Specification 6.8.1.a, requires, in part, that procedures shall be established, implemented and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2. Section 3.s.(2)(a) of Regulatory Guide 1.33, Revision 2, Appendix A, recommends, in part, that instructions for filling should be prepared for the onsite diesel generators. Contrary to the above, prior to January 6, 2014, the licensee did not prepare instructions for filling the onsite power sources as recommended in Regulatory Guide 1.33, Revision 2, Appendix A.

Specifically, the licensee did not establish procedures to fill the fuel oil storage tanks for the emergency diesel generators using the credited safety-related, seismic category 1 alternate emergency fill line following any design basis accident and loss of offsite power. The licensee entered this condition into their corrective action program as Condition Report CR-WF3-2014-00636.

Because this violation was of very low safety significance and the licensee entered the issue into their corrective action program, this violation was treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy: NCV 05000382/2014002-01, Failure to Establish Procedures for Using the Alternate Emergency Fuel Oil Storage Tank Fill Line.

1R05 Fire Protection

.1 Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on six plant areas important to safety:

On January 14, 2014, fire area CT4-001, wet cooling tower train B On January 14, 2014, fire area CT2-001, dry cooling tower train B On February 4, 2014, fire area reactor auxiliary building 18, component cooling water heat exchanger A On February 4, 2014, fire area reactor auxiliary building 37, motor driven emergency feed pump room A On March 10, 2014, fire area reactor auxiliary building 39, -35 reactor auxiliary building general area On March 10, 2014, fire area NS-TB-002, +15 turbine generator building west For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.

These activities constituted six quarterly inspection samples, as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

a. Inspection Scope

On February 13, 2014, the inspectors completed an inspection of the stations ability to mitigate flooding due to internal causes. After reviewing the licensees flooding analysis, the inspectors chose one plant area containing risk-significant structures, systems, and components that were susceptible to flooding:

Flooding analysis zone 35, Wing Area The inspectors reviewed plant design features and licensee procedures for coping with internal flooding. The inspectors walked down the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether operator actions credited for flood mitigation could be successfully accomplished.

These activities constitute completion of one flood protection measures sample as defined in Inspection Procedure 71111.06.

b. Findings

No findings were identified.

1R07 Heat Sink Performance

a. Inspection Scope

The inspectors reviewed licensee programs to verify heat exchanger performance and operability for the following heat exchangers:

On February 10, 2014, high pressure safety injection pump seal and bearing cooler (SI-MPMP-002B)

On February 10, 2014, component cooling water heat exchanger (CC-MHX-0001A)

On February 10, 2014, emergency feedwater pump room air handling unit (HVR-MAHU-00038B)

The inspectors verified whether testing, inspection, maintenance, and chemistry control programs are adequate to ensure proper heat transfer. The inspectors verified that the periodic testing and monitoring methods, as outlined in commitments to NRC Generic Letter 89-13, utilized proper industry heat exchanger guidance. Additionally, the inspectors verified that the licensees chemistry program ensured that biological fouling was properly controlled between tests. The inspectors reviewed previous maintenance records of the heat exchangers to verify that the licensees heat exchanger inspections adequately addressed structural integrity and cleanliness of their tubes. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three triennial heat sink inspection samples as defined in Inspection Procedure 71111.07.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On January 27, 2014, the inspectors observed an evaluated simulator scenario performed by an operating crew. The inspectors assessed the performance of the operators and the evaluators critique of their performance. The inspectors also assessed the modeling and performance of the simulator during the requalification activities.

These activities constitute completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

On February 7, 2014, the inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened activity due to an unexpected alarm. The inspectors observed the operators performance of the following activities:

Alarm response Procedural compliance In addition, the inspectors assessed the operators adherence to plant procedures that included the conduct of operations procedure and other operations department policies.

These activities constitute completion of one quarterly licensed operator performance sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed three instances of degraded performance or condition of safety-related structures, systems, and components (SSCs):

On February 25, 2014, emergency feedwater to steam generator number 2 backup isolation valve (EFW-229B) dissimilar metal issue On March 17, 2014, essential chiller oil pump B failure On March 18, 2014, shutdown cooling heat exchanger fan motor molded case circuit breaker failure (HVREBK313B-4D)

The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensees characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.

These activities constituted completion of three maintenance effectiveness samples, as defined in Inspection Procedure 71111.12.

b. Findings

Introduction.

A self-revealing Green, non-cited violation of Technical Specification 6.8.1.a occurred because the licensee did not develop a preventative maintenance schedule to inspect or replace an item that has a specific lifetime. Specifically, the licensee did not develop a preventative maintenance schedule to inspect or replace the essential chiller oil pump motors prior to the end of their vendor provided service life.

Description.

On January 8, 2014, the essential chiller oil pump B tripped while in service. The licensee took action to place essential chiller AB in service in place of essential chiller B while performing troubleshooting. During the troubleshooting effort, the licensee identified that at least one thermal overload on the breaker tripped. The troubleshooting also revealed that the pumps running amps exceeded the time over current trip threshold. The licensee noted that this indicated that the pump motor drew excessive amperage. Based on the above information, the licensee determined that wear in the drive gear assembly for the pump motor was the most likely cause of the excessive amperage draw. The licensee initiated Condition Report CR-WF3-2014-00095 and took action to replace the oil pump for essential chiller B.

The inspectors reviewed the apparent cause evaluation and the preventative maintenance template for the motors. The inspectors noted that during the licensee apparent cause evaluation, the evaluation revealed that the duty life for the pump motor based on the vendor technical manual was 15 years of equivalent continuous duty operation. Based on the operating time and the run hour monitoring of the motor, the licensee determined that the pump motor had an equivalent run time of over 24 years, which was in excess of its maximum duty life. The inspectors noted that the licensee classified the essential chiller oil pumps as high critical components. However, the licensee treated the pumps as run-to-failure because the licensee did not have a preventative maintenance schedule to replace the pump periodically prior to the end of the motors duty life. Additionally, the inspectors noted that there were no inspections or monitoring in place to establish trending to allow the licensee to predict the end of life for the oil pump motor.

The inspectors also reviewed past failures of the essential chillers and their evaluations under the maintenance rule. A review of past work orders showed that the oil pump for essential chiller A failed during maintenance and the licensee replaced the oil pump on March 18, 2004. The essential chiller A pump was in service for approximately 22 years prior to it failing to function. At that time, the licensee did not recognize that the pump had exceeded its duty life of 15 years. The inspectors determined that was a missed opportunity to change the preventative maintenance template. The immediate corrective action taken to restore compliance was to issue an action request to establish the periodic replacement of the essential chiller oil pumps prior to the end of their vendor recommended service life.

Analysis.

The failure to develop a preventative maintenance schedule to inspect or replace the essential chiller oil pumps prior to exceeding the vendor provided duty life was a performance deficiency. The inspectors determined that this deficiency was reasonably within the licensees ability to foresee and correct. The performance deficiency was more than minor because it was associated with the equipment performance attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, it affected the availability and reliability of the essential chiller to provide a heat sink for the removal of process and operating heat from selected safety-related equipment during design basis accidents. The inspectors used NRC Inspection Manual Chapter 0609, 4, Initial Characterization of Findings, to evaluate this issue. The initial screening directed the inspectors to use Inspector Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, Exhibit 2, Section A, to determine the significance of the finding. The inspectors categorized the finding as having very low safety significance (Green) because the finding did not affect the design or qualification of the system; it did not represent a loss of the system or function; and, the loss of the essential chiller was less than the technical specification allowed outage time. The inspectors concluded that the finding did not have a cross-cutting aspect because the most significant contributor to the performance deficiency occurred more than 3 years ago, and did not reflect current licensee performance.

Enforcement.

Technical Specification 6.8.1.a requires, in part, that procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2.

Section 9.b. of Regulatory Guide 1.33, Revision 2, Appendix A, recommends, in part, that preventative maintenance schedules should be developed to specify lubrication schedules, inspection of equipment, and inspection or replacement of parts that have a specific lifetime. Contrary to the above, prior to January 8, 2014, the licensee failed to develop, preventative maintenance schedules to specify inspection or replacement of parts that have a specific lifetime as recommended in Regulatory Guide 1.33, Revision 2, Appendix A. Specifically, the licensee failed to develop a preventative maintenance schedule to inspect or replace the oil pumps associated with the essential chillers prior to exceeding the vendor recommended service life. The licensee entered this condition into their corrective action program as Condition Report CR-WF3-2014-0095.

Because this violation was of very low safety significance and the licensee entered the issue into their corrective action program, this violation was treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy: NCV 05000382/2014002-02, Failure to Replace an Essential Chiller Oil Pump prior to the Vendor Service Life.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

The inspectors reviewed three risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:

On January 16, 2014, high pressure safety injection train B outage On January 22, 2014, emergency diesel generator train B outage On February 24, 2014, emergency feedwater train AB outage The inspectors verified that these risk assessment were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments.

The inspectors also observed portions of two emergent work activities that had the potential to cause an initiating event, to affect the functional capability of mitigating systems, or to impact barrier integrity:

On January 8, 2014, activities in response to the unexpected failure of essential chiller B On February 11, 2014, feedwater to emergency feedwater header pressurizing check valves FW-1763A and FW-1763B The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected SSCs.

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

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

The inspectors reviewed five operability determinations that the licensee performed for degraded or nonconforming SSCs:

On January 8, 2014, operability determination of emergency diesel generator train B fuel oil pump On January 27, 2014, operability determination for emergency feed water back up flow control valve EFW-223B On February 3, 2014, operability determination for dry cooling tower train B component cooling water leak On February 10, 2014, operability determination for emergency feedwater pump AB On March 12, 2014, operability determination for emergency diesel generator A and B alternate emergency fill line The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded SSC to be operable, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability of the degraded SSC.

These activities constitute completion of five operability and functionality review samples, as defined in Inspection Procedure 71111.15.

b. Findings

Failure to Perform an Evaluation for Transient Combustibles

Introduction.

The inspectors identified a Green, non-cited violation of License Condition 2.C.9, because the licensee did not implement Procedure EN-DC-161, Control of Combustibles, which requires, in part, that a transient combustible evaluation shall be processed or compensatory actions shall be established if a flammable liquid exceeds one pint in an approved container. Specifically, the licensee did not implement Section 5.6 of Procedure EN-DC-161 after a fuel oil leak from the standby fuel oil pump for the train B emergency diesel generator exceed one pint in an approved container which failed while in service.

Description.

On December 4, 2013, the licensee discovered a fuel oil leak coming from the standby fuel oil pump for emergency diesel generator B. The licensee initiated Condition Report CR-WF3-2013-5962. As a part of the operability evaluation, the licensee quantified the leak at 10 drops per minute (dpm) and put a leak collection device in place to contain the leaking fuel. At this time, the licensee declared the emergency diesel generator B fully operable with no compensatory actions. On December 14, 2013, the fuel oil leak increased from 10 dpm to 45 dpm. The licensee initiated another Condition Report CR-WF3-2013-6020 and concluded that the fuel oil leak although showing degradation did not affect the operability of the emergency diesel generator B. The licensee established a leak of 60 dpm as the limit to take action. The inspectors reviewed the condition reports and operability evaluations, and questioned the licensee about the operability of the emergency diesel generator B and standby fuel oil pump condition. The licensee replied that although Procedure EN-OP-104, Operability Determination Process, recommended that oil leaks from safety-related pumps be classified as operable-degraded/nonconforming, operable-op/evaluation, inoperable, or inoperable-op/evaluation, it was not a requirement.

On December 20, 2013, the inspectors identified that the leak collection device did not adequately contain the leaking fuel oil from the standby fuel oil pump. The inspectors found fuel oil leaking on the floor around the emergency diesel generator B. At that time, the inspectors considered this to represent a credible fire scenario that could affect safety-related equipment and further questioned the categorization of the standby fuel oil pump condition since no transient combustible evaluation or compensatory actions of having a fire watch was in place. The licensee took action to clean the leaking fuel oil, initiated another Condition Report CR-WF3-2013-6123 and determined that Procedure EN-DC-161, Control of Combustibles, required a transient combustible evaluation or compensatory actions. Specifically, the licensee designated the emergency diesel room B as a Level 2 Combustible Control Zone in Attachment 9.8 of the procedure. Section 5.6 of Procedure EN-DC-161, allows only one pint of flammable liquid in approved containers in the area without an evaluation or appropriate compensatory measures. The inspectors noted that the leak collection device could hold up to two gallons, which would exceed the one-pint limit. Following discussions with the inspectors, the licensee promptly established an hourly fire watch and performed the required transient combustible evaluation.

In addition, the licensee revised the operability of the diesel as operable with compensatory measures and established that personnel monitor the leak every six hours. The inspectors determined that if the licensee followed the recommended classification per the operability determination procedure, then the licensee might have recognized that this degraded condition needed a transient combustible evaluation or compensatory measures. The licensee repaired the standby fuel oil pump on January 3, 2014, and returned emergency diesel generator B to a fully operable status.

Analysis.

The failure to implement a fire protection program procedure was a performance deficiency. The inspectors determined that this deficiency was reasonably within the licensees ability to foresee and correct. The performance deficiency was more than minor because it was associated with the protection against external factors (i.e., fire) attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to perform a transient combustible evaluation when a flammable liquid above one pint in an approved container was present in the B emergency diesel room prevented the licensee from implementing required compensatory measures in response to the presence of transient combustibles. In addition, similar to NRC Inspection Manual Chapter 0612, Appendix E, Section 4, Example k, of a more than minor violation, the failure of the leak collection device resulted in fuel oil around the emergency diesel generator B, which represented a credible fire scenario that involve transient combustibles that could potentially affect equipment important to safety. The inspectors used NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, to evaluate this issue. Since this finding was related to controls for transient combustible materials, the initial screening directed the inspectors to use Appendix F, Fire Protection Significance Determination Process, to determine the significance of the finding. The inspectors categorized the finding under Task 1.4.1, Fire Prevention and Administrative Controls, and qualitatively screened it as very low safety significance (Green) because the impact of the fire finding was limited to no more than one train of equipment important to safety. The inspectors concluded that the finding reflected current licensee performance and involved a conservative bias cross-cutting aspect in the human performance area in that the licensee did not use decision making practices that emphasized prudent choices over those that are simply allowable [H.14].

Enforcement.

License Condition 2.C.9, requires, in part, that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report. Final Safety Analysis Report, Section 9.5.1.6.3, specifies Procedure UNT-005-013, Fire Protection Program, which describes responsibilities, controls, and implementing requirements for the Waterford 3 Fire Protection Program. Procedure UNT-005-013, Section 5.4.2, specifies that transient combustibles shall be controlled in accordance with Procedure EN-DC-161, Control of Combustibles. Procedure EN-DC-161, Attachment 9.8, identifies the train B emergency diesel generator room as a Level 2 area and in Section 5.6, states, in part, that a transient combustible evaluation shall be processed for Level 2 Plant Areas combustibles associated exceed one pint in approved containers. Contrary to the above, from December 4 until December 20, 2013, the licensee failed to comply with License Condition 2.C.9 to implement and maintain in effect all provisions of the approved fire protection program as described in the final safety analysis report for the facility and as approved in the Safety Evaluation Report. Specifically, the licensee failed to perform a transient combustible evaluation as required by EN-DC-161 when it was required. The licensee entered this condition into their corrective action program as Condition Reports CR-WF3-2013-6020 and CR-WF3-2013-06123.

Because this violation was of very low safety significance and the licensee entered the issue into their corrective action program, this violation was treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy: NCV 05000382/2014002-03, Failure Implement a Fire Protection Program Procedure to Perform an Evaluation for Transient Combustibles.

1R18 Plant Modifications

.1 Permanent Modifications

a. Inspection Scope

On January 21, 2014, the inspectors reviewed a permanent plant modifications related to the fuel oil return line on emergency diesel generator B that affected risk-significant SSCs:

The inspectors reviewed the design and implementation of the modification. The inspectors verified that work activities involved in implementing the modification did not adversely impact operator actions that may be required in response to an emergency or other unplanned event. The inspectors verified that post-modification testing was adequate to establish the operability of the SSC as modified.

These activities constitute completion of one sample of permanent modifications, as defined in Inspection Procedure 71111.18.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed six post-maintenance testing activities that affected risk-SSCs:

On January 23, 2014, emergency diesel generator B following significant maintenance On February 14, 2014, auxiliary component cooling water pump B following significant maintenance On February 20, 2014, shutdown cooling heat exchanger breaker train B On February 21, 2014, replaced essential chiller pump B On February 26, 2014, emergency feedwater pump AB On March 11, 2014, emergency feedwater valve EFW-223A The inspectors reviewed licensing- and design-basis documents for the SSCs and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs.

These activities constitute completion of six post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed six risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the SSCs were capable of performing their safety functions:

In-service tests:

On January 16, 2014, essential chilled water pump A operability test On February 10, 2014, refueling water storage pool isolation valves FS-404 and FS-423 Reactor coolant system leak detection tests:

On February 18, 2014, reactor coolant system leak detection and inventory balance Other surveillance tests:

On January 13, 2014, emergency diesel generator train A operability test On January 17, 2014, emergency feedwater pump A operability test On February 28, 2014, ultimate heat sink thermal performance test train A The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing.

These activities constitute completion of six surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

The inspector performed an in-office review of Procedure EP-002-010, Notifications and Communications, Revision 309. This revision added information for evaluating the accuracy of notifications and made minor administrative changes to the emergency notification form.

The 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)(3) and 50.54(q)(4). The inspector verified that the revision did not reduce the effectiveness of the emergency plan. This review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection.

These activities constitute completion of one emergency action level and emergency plan change sample as defined in Inspection Procedure 71114.04.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors observed an emergency preparedness drill on February 19, 2014, to verify the adequacy and capability of the licensees assessment of drill performance.

The inspectors reviewed the drill scenario, observed the drill from the Technical Support Center, Operations Support Center and simulator, and attended the post-drill critique.

The inspectors verified that the licensees emergency classifications, off-site notifications, and protective action recommendations were appropriate and timely. The inspectors verified that any emergency preparedness weaknesses were appropriately identified by the licensee in the post-drill critique and entered into the corrective action program for resolution.

These activities constitute completion of one emergency preparedness drill observation samples, as defined in Inspection Procedure 71114.06-05.

b. Findings

No findings were identified.

OTHER ACTIVITIES

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

4OA1 Performance Indicator Verification

.1 Unplanned Scrams per 7000 Critical Hours (IE01)

a. Inspection Scope

On March 7, 2014, the inspectors reviewed licensee event reports (LERs) for the period of January 1, 2013, through December 31, 2013, to determine the number of scrams that occurred. The inspectors compared the number of scrams reported in these LERs to the number reported for the performance indicator. Additionally, the inspectors sampled monthly operating logs to verify the number of critical hours during the period.

The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the data reported.

These activities constituted verification of the Unplanned Scrams per 7000 Critical Hours performance indicator for Waterford Steam Electric Station, Unit 3, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.2 Unplanned Power Changes per 7000 Critical Hours (IE03)

a. Inspection Scope

On March 10, 2014, the inspectors reviewed operating logs, corrective action program records, and monthly operating reports for the period of January 1, 2013, through December 31, 2013, to determine the number of unplanned power changes that occurred. The inspectors compared the number of unplanned power changes documented to the number reported for the performance indicator. Additionally, the inspectors sampled monthly operating logs to verify the number of critical hours during the period. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the data reported.

These activities constituted verification of the Unplanned Power Outages per 7000 Critical Hours performance indicator for Waterford Steam Electric Station, Unit 3, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.3 Unplanned Scrams with Complications (IE04)

a. Inspection Scope

On March 11, 2014, the inspectors reviewed the licensees basis for including or excluding in this performance indicator each scram that occurred between January 1, 2013, and December 31, 2013. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the data reported.

These activities constituted verification of the unplanned scrams with complications performance indicator for Waterford Steam Electric Station, Unit 3, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.

b. Findings

No findings were identified.

.2 Annual Follow-up of Selected Issues

a. Inspection Scope

The inspectors selected two issues for an in-depth follow-up:

On January 14, 2014, public address system issue, malfunction during an evaluated exercise On February 20, 2014, shutdown cooling heat exchanger room B air handling unit fan motor breaker trip The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition.

The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition.

These activities constitute completion of two annual follow-up samples as defined in Inspection Procedure 71152.

.1 Failure to Establish Adequate Design Control Measures for the Selection and Review for

the Suitability of Application of Molded Case Circuit Breakers

Introduction.

A self-revealing, Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, occurred because the licensee did not establish design control measures for the selection and review for the suitability of application of a molded case circuit breaker that was essential to the safety-related function of a shutdown cooling heat exchanger fan cooler. Specifically, the licensee did not select and review the suitability of the correct safety-related circuit breaker for the application to provide circuit fault protection for the train B shutdown cooling heat exchanger air handling unit fan motor.

Description.

On April 18, 2013, during a preventive maintenance task for an installed molded case circuit breaker, the train B shutdown cooling heat exchanger fan motor breaker (HVREBKR313B-4D) failed to function. The failed breaker was a Gould 10-amp breaker with an instantaneous rating of 58 amps. The licensee did not have a like-for-like breaker replacement due to obsolescence. At that time, the licensee generated Engineering Change Request 15610 to install a Westinghouse 7-amp breaker with an instantaneous rating of 56 amps. The licensee selected the breaker based on design drawing B289, sheets 2 and 80, which contain generic motor data for motor control center breaker settings.

On May 8, 2013, the licensee received an annunciator alarm in the control room that indicated a loss of power to shutdown cooling heat exchanger room B air handling unit (HVRAHU0032-B). The licensee initiated troubleshooting and attempted to start the air handling unit fan motor. However, the 7-amp breaker tripped and the air handling unit failed to start on demand. The licensee attempted to start the unit once more but the breaker tripped again. The licensee entered an unplanned 7-day shutdown limiting condition of operation since this affected the operability of the train B containment spray system. Additionally, the licensee initiated an apparent cause evaluation Condition Report CR-WF3-2013-2316.

As a follow-up to this issue, the inspectors reviewed the apparent cause evaluation report, preventive maintenance tasks for the breaker, work orders, operator logs, design documents, and post-maintenance tests. The inspectors determined that the licensee installed the incorrect circuit breaker following the replacement of the obsolescent Gould 10-amp breaker when the licensee could not locate a like-for-like replacement.

The inspectors noted that as a part of the engineering change request conducted by the licensee, the licensee identified the incorrect breaker and established the wrong instantaneous setting of 56 amps. The inspectors noted that the design documents used for the selection of the 7-amp replacement breaker did not account for the shutdown cooling heat exchanger room B air handling unit motor locked rotor current because it was unknown at the time of the selection. The inspectors also noted that the licensee did not set the instantaneous setting to twice the locked rotor current as described in the design drawing for breaker settings and the final safety analysis report, as updated. The inspectors mentioned to the licensee that the locked rotor current information should be contained on the nameplate rating for the fan motor. The licensee was able to obtain the fan motors nameplate rating on drawing 1564-8954. Based on the locked rotor current information, the licensee generated another engineering change request to install a 15-amp breaker with an instantaneous setting of 75 amps.

Additionally, the inspectors identified that the licensee had the wrong instantaneous setting for the shutdown cooling heat exchanger room A breaker because it was not set to twice the locked rotor current as described in design documentation. The licensee entered this condition into their corrective action program as Condition Report CR-WF3-2013-04644 and conducted an extent of condition review.

In addition to the design control issues, the inspectors identified that the licensee did not perform pre-installation and post-maintenance tests of molded case circuit breakers if the vendor had already conducted factory acceptance tests. The inspectors noted that work order instructions allowed the licensee to substitute factory acceptance test for the pre-installation and post-maintenance tests, respectively. The inspectors noted that the factory acceptance tests were at times more than 21 years old. The immediate corrective actions taken to restore compliance included the replacement of the breaker with a breaker more suitable for the application to protect the air handling unit fan motor.

The planned corrective action included an extent of condition review for other installed breakers and the revision of work order instructions to eliminate the practice of substituting and using the factory acceptance testing for pre-installation and post-maintenance tests, respectively.

Analysis.

The failure to establish design control measures for the selection and review for suitability of application for the correct safety-related circuit breaker was a performance deficiency. The performance deficiency was more than minor because it was associated with the design control attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the incorrect breaker affected the availability, reliability, and capability of the shutdown cooling heat exchanger fan coolers to remove heat from the shutdown cooling heat exchanger areas following a design basis accident. The inspectors performed the initial significance determination. The inspectors used the NRC Inspection Manual 0609, Attachment 4, Initial Screening and Characterization of Findings. The initial screening directed the inspectors to use Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Section A. The finding required a detailed risk evaluation because it involved a potential loss of one train of safety-related equipment for longer than the technical specification allowed outage time. The total exposure period was 23 days.

The allowed outage time was 7 days.

A Region IV senior reactor analyst performed the detailed risk evaluation. The analyst noted that the containment spray pumps affected both the mitigating systems and barrier integrity cornerstone objectives. However, NRC Inspection Manual Chapter 0609, Appendix H, Containment Integrity Significance Determination Process, dated May 6, 2004, Table 4.1, Containment-Related Structures, Systems and Components Considered for Large Early Release Frequency (LERF) Implications, specified that containment sprays are important to late containment failure and source term but not LERF - the unmitigated releases from containment in a time frame prior to the effective evacuation of the close-in population. While containment failure was possible, it would not occur before the licensee and local emergency preparedness personnel would evacuate the close-in population. Therefore, the analyst only considered the impact to internal events.

The analysts performed simplified calculations to determine the change to the core damage frequency (delta-CDF) for the containment spray pump failure. The analyst used the Waterford-3 Standardized Plant Analysis Risk model, Revision 8.16, with a truncation limit of E-20. This truncation limit was needed because most of the sequences where the containment spray pump failed were truncated when the analyst used an E-11 truncation limit. The containment spray system as only modeled in the loss of offsite power event tree. Therefore, the analyst solved only the loss of offsite power sequences.

The following definitions are important to this analysis:

Nominal case - this is the baseline risk for the developed sequences. This case does not include equipment failures associated with the performance deficiency.

Current case - this case includes the equipment failures associated with the performance deficiency.

For the nominal and current cases, the analyst set the basic event for alternate room cooling to 1.0. The NRC had a prior finding where inspectors determined that the alternate room cooling would not function because the licensee did not have a safety-related power source for the fans, did not have procedures to direct the action, and did not train operators on the action (see NRC Inspection Report 05000382/2011007).

For the current case, the analyst also set the basic event for the train B containment spray pump (failure to start) to 1.0. This was consistent with a condition were the common cause failure of both containment spray pumps was ruled out.

The dominant core damage sequences included loss of offsite power events, failure of both trains of containment spray, and failure of a pressurizer safety relief valve to remain closed. Equipment that helped mitigated the risk included emergency diesel generators and the essential feedwater system. To isolate the cutsets of interest, the analyst used the slice function to identify cutsets that included the failed containment spray pump.

The conditional core damage probability was 8E-12. This represented a full year of exposure. To determine the delta-CDF, the analyst factored in the 23-day mission time.

The delta-CDF was 5E-13/year. Therefore, the finding was of very low safety significance (Green).

The inspectors concluded that the finding reflected current licensee performance and involved a cross-cutting aspect of avoiding complacency in the human performance area because the licensee did not recognize and plan for the possibility of mistakes, latent issues, and inherent risk on relying on 21 year old vendor information and installing a breaker without pre-installation and adequate post-maintenance testing [H.12].

Enforcement.

Title 10 of CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that design control measures shall also be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems and components. Contrary to the above, prior to May 2013, the licensee did not establish design control measures for the selection and review for the suitability of application of a molded case circuit breaker that was essential to the safety-related function of a shutdown cooling heat exchanger fan cooler. Specifically, the licensee did not select and review the suitability of the correct safety-related circuit breaker for the application to provide circuit fault protection for the train B shutdown cooling heat exchanger air handling unit fan motor. As a result, with the incorrect breaker installed this affected the availability, reliability, and capability of the shutdown cooling heat exchanger fan coolers to remove heat from the shutdown cooling heat exchanger areas that rendered one train of containment spray inoperable greater than its allowed outage time. The licensee entered this condition into their corrective action program as Condition Reports CR-WF3-2013-02316 and CR-WF3-2013-04644.

Because this violation of is of very low safety significance and the licensee entered it into their corrective action program, it is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy:

NCV 05000382/2014002-04, Failure to Establish Adequate Design Control Measures for the Selection and Review for the Suitability of Application of Molded Case Circuit Breakers.

4OA3 Follow-up of Events and Notices of Enforcement Discretion

(Closed) Licensee Event Report 05000382/2012-003-00 Cracked Instrument Line Affects Fire Protection Safe Shutdown Analysis On April 4, 2012, the licensee discovered a steam leak on an instrument line associated with the steam supply to emergency feedwater pump AB. The steam leak was due to a crack on the instrument line. The licensee isolated the leak when operators closed the upstream instrument lines root valve. The licensee determined that this condition created an unanalyzed condition because it could have affected the fire protection safe shutdown manual actions for the emergency feedwater pump AB. In the review of this event, no findings or violations of NRC requirements were identified.

(Closed) Licensee Event Report 05000382/2012-005-02 Valve Degradation Causes Inoperability of Safety-related System On several occasions, the licensee declared auxiliary component cooling water train A inoperable due to excessive seat leakage on an air operated temperature control valve (ACC-126A). The licensee attributed the causes of the leakage to a calibration drift of the valve operator and degraded valve internals. The inspectors reviewed previous revisions of this event and identified a Non-Cited Violation 05000382/2012004-02, Failure to Identify and Correct Degraded Conditions Associated with the Auxiliary Component Cooling Water Heat Exchanger Temperature Outlet Control Valve. The inspectors documented this violation in Section 1R12 of the NRC Inspection Report 05000382/2012004 prior to the final revision of this licensee event report being issued.

(Closed) Licensee Event Report 05000382/2013-005-01 Emergency Diesel Generator Inoperable Due to Room Exhaust Fan Failure On May 20, 2013, during an operational surveillance run, the emergency diesel generator room temperature reached 118°F in less than one hour. The rise in room temperature was due to a failed exhaust fan. The exhaust fan failed because the fan hub assembly separated from the hub sleeve, which effectively separated the fan from the fan motor. The licensee identified that the train B emergency diesel generator exhaust fan blades were not rotating while the fan motor was operating. This condition made the emergency diesel generator inoperable since the purpose of the emergency diesel generator ventilation system is to remove the heat associated with diesel operation from the emergency diesel generator B room. As a part of the review of this event, the inspectors identified an apparent violation 05000382/2013008-01, Failure to Establish an Adequate Test Program to Demonstrate that the Train B Emergency Diesel Generator Exhaust Fan Would Perform Satisfactorily In-Service. The inspectors documented this violation in Section 1R22 of the NRC Inspection Report 05000382/2013008.

(Closed) Licensee Event Report 05000382/2014-001-00 Room Cooler Breaker Inoperability Causes Past Inoperability of Containment Spray System Train On May 8, 2013, a safety-related circuit breaker tripped open on two consecutive start attempts of the shutdown cooling heat exchanger room B air handling unit by operation personnel. The breaker tripped because the licensee installed the wrong breaker during and engineering change request to replace the original breaker. As a part of the review of this event, the inspectors identified a Non-Cited Violation 05000382/2014002-04, Failure to Establish Adequate Design Control Measures for the Selection and Review for the Suitability of Application of Molded Case Circuit Breakers. The inspectors documented this violation in Section 4OA2 of this report.

These activities constitute completion of four event follow-up samples, as defined in Inspection Procedure 71153.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On February 14, 2014, the inspectors presented the inspection results for the triennial heat sink inspection to Mr. M. Chisum, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues and observations presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

On March 21, 2014, the inspector conducted a telephonic exit meeting to present the results of the in-office inspection of changes to the licensees emergency plan and implementing procedures to Mr. E. Brauner, Manager, Emergency Preparedness. The licensee acknowledged the issues presented.

On April 1, 2014, the inspectors presented the inspection results to Mr. C. Rich Jr.,

Director, Regulatory and Performance Improvement, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

M. Chisum, Site Vice President, Operations

E. Brauner, Manager, Emergency Preparedness

K. Cook, General Manager, Plant Operations

B. Pellegrin, Senior Manager, Production

M. Chaisson, Supervisor, Radiation Protection

J. Briggs, Superintendent, Electrical Maintenance

K. Crissman, Senior Manager, Maintenance

D. Frey, Manager, Radiation Protection

R. Gilmore, Manager, Systems and Components

L. Milster, Licensing Specialist, Licensing

A. James, Manager, Security

B. Lanka, Director, Engineering

N. Lawless Manager, Chemistry

B. Lindsey, Senior Manager, Operations

J. Pollock, Licensing Specialist, Licensing

M. Mills, Manager, Nuclear Oversight

W. McKinney Manager, Performance Improvement

S.W. Meiklejohn, Superintendent, I & C Maintenance

J. Jarrell, Manager, Regulatory Assurance

G. Pierce, Manager, Training

R. Porter, Manager, Design & Program Engineering

D. Reider, Supervisor, Quality Assurance

C. Rich, Jr., Director, Regulatory & Performance Improvement

M. Richey, Acting General Manager, Plant Operations

J. Signorelli, Superintendent, Simulator & Training Support

R. Simpson, Superintendent, Operator Training

P. Stanton, Supervisor, Design Engineering

J. Toth, Mechanical Superintendent, Maintenance

J. Williams, Senior Licensing Specialist

NRC Personnel

M. Davis, Senior Resident Inspector

C. Speer, Resident Inspector

Attachment

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000382-2014002-01 NCV Failure to Establish Procedures for Using the Alternate Emergency Fuel Oil Storage Tank Fill Line (Section 1R04)

05000382-2014002-02 NCV Failure to Replace an Essential Chiller Oil Pump prior to the Vendor Service Life (Section 1R12)

05000382-2014002-03 NCV Failure Implement a Fire Protection Program Procedure to Perform an Evaluation for Transient Combustibles (Section 1R15)

05000382-2014002-04 NCV Failure to Establish Adequate Design Control Measures for the Selection and Review for the Suitability of Application of Molded Case Circuit Breakers (Section 4OA2.2)

Closed

05000382-2012-003-00 LER Cracked Instrument Line Affects Fire Protection Safe Shutdown Analysis (Section 4OA3)

05000382-2012-005-02 LER Valve Degradation Causes Inoperability of Safety-related System (Section 4OA3)

05000382-2013-005-01 LER Emergency Diesel Generator Inoperable Due to Room Exhaust Fan Failure (Section 4OA3)

05000382-2014-001-00 LER Room Cooler Breaker Inoperability Causes Past Inoperability of Containment Spray System Train (Section 4OA3)