IR 05000382/2017008
| ML17362A424 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/28/2017 |
| From: | Thomas Farnholtz Region 4 Engineering Branch 1 |
| To: | Dinelli J Entergy Operations |
| References | |
| IR 2017008 | |
| Download: ML17362A424 (33) | |
Text
December 28, 2017
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC DESIGN BASES
ASSURANCE INSPECTION REPORT 05000382/2017008
Dear Mr. Dinelli:
On November 16, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford Steam Electric Station, Unit 3 and discussed the preliminary results of this inspection with you and other members of your staff. On December 14, 2017, the inspectors discussed the final results of this inspection with Mr. D. Brenton, General Manager-Plant Operations, and other members of your staff. The results of this inspection are documented in the enclosed report.
Nuclear Regulatory Commission inspectors documented two findings of very low safety significance (Green). 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 Enforcement Policy.
Additionally, the inspectors documented one Severity Level IV traditional enforcement violation associated with impacting the ability of the NRC to perform its regulatory oversight function.
The NRC is treating this violation as non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
From December 2016 to December 2017, the NRC issued four Severity Level IV traditional enforcement violations associated with impacting the ability of the NRC to perform its regulatory oversight function. As a result of the four Severity Level IV traditional enforcement violations, the NRC determined that the additional inspection was not warranted because the cause of the most recent violation occurred in 2006 and 2014 and current Waterford procedures and practices should prevent recurrence. Therefore, the NRC will not conduct Inspection Procedure 92723, Follow up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period.
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; and the NRC resident inspector at the Grand Gulf Nuclear Station. 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Grand Gulf Nuclear Station.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Thomas R. Farnholtz, Chief Engineering Branch 1 Division of Reactor Safety
Docket No. 50-382 License No. NPF-38
Enclosure:
Inspection Report 05000382/2017008 w/Attachments:
1. Supplemental Information 2. Additional Information Request
cc w/enclosure: Electronic Distribution
Enclosure U.S. NUCLEAR REGULATORY COMMISSION
INSPECTION REPORT
Docket:
05000382 License:
NPF-38 Report Nos.:
05000382/2017008 Enterprise Identifier:
I-2017-008-0023 Licensee:
Entergy Operations, Inc.
Facility:
Waterford Steam Electric Station, Unit 3 Location:
17265 River Road Killona, LA 70057 On-site Dates:
October 23 through November 16, 2017 Exit Date:
December 14, 2017 Team Leader:
G. George, Senior Reactor Inspector, Engineering Branch 1 Inspectors:
J. Braisted, Reactor Inspector, Engineering Branch 1 N. Okonkwo, Reactor Inspector, Engineering Branch 2 G. Callaway, Senior Reactor Technology Instructor, Technical Training Center Accompanying Personnel:
A. Athar, Reactor Operations Engineer, ROP Assessment Branch, Nuclear Reactor Regulation C. Baron, Contractor, Beckman and Associates S. Gardner, Contractor, Beckman and Associates Approved By:
Thomas R. Farnholtz Branch Chief, Engineering Branch 1 Division of Reactor Safety
SUMMARY
The NRC continued monitoring licensees performance by conducting an Inspection
Procedure 71111.21M, Design Bases Assurance (Teams), inspection at Waterford Steam Electric Station, Unit 3, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC and self-revealed findings, violations, and additional items are summarized in the table below.
List of Findings and Violations
Three examples of Failure to Establish and Maintain Preventive Maintenance Procedures for Safety-Related Electrical Equipment Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000382/2017008-01 Closed Not Applicable 71111.21M The team identified three examples of a Green non-cited violation of Waterford Steam Electric Station, Unit 3, Technical Specification 6.8.1.a, for failure to establish, implement, and maintain written procedures for activities referenced in Appendix A of Regulatory Guide 1.33,
Revision 2, dated February 1978. Specifically, prior to November 16, 2017, the licensee failed to establish and maintain procedures covered in Regulatory Guide 1.33, Appendix A,
Section 9, Procedures for Performing Maintenance, to implement maintenance for safety-related 1600 A, 600 V non-segregated metal-enclosed bus ducts, safety-related 4.16 kV G.E. Magne-Blast circuit breakers, and safety-related 480 V G.E. switchgear AKR breakers.
Failure to Meet RG 1.9 Emergency Diesel Testing Requirements during Surveillance Test Results in Missed Surveillance Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000382/2017008-02 Closed H.11 - Human Performance,
Challenge the Unknown 71111.21M The team identified a Green non-cited violation of Waterford Steam Electric Station, Unit 3,
Technical Specification Limiting Condition for Operation 3.8.1.1 for failure to maintain operability of two separate independent diesel generators. Specifically, on May 23, 2017, the licensee failed to verify that the train A emergency diesel generator energized all auto-connected shutdown loads through the load sequencer and operated for greater than or equal to five minutes in accordance with Technical Specification Surveillance Requirement 4.8.1.1.2.
Two Examples of Failure to Submit and Receive Prior Authorization of Alternatives to ASME OM Code Leak Testing Requirements Cornerstone Significance Cross-cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000382/2017008-03 Closed Not Applicable 71111.21M The team identified two examples of a Severity Level IV, non-cited violation of 10 CFR 50.55a(z), for failure to submit and obtain authorization prior to implementation of multiple alternatives to leak testing requirements of the American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) of Nuclear Power Plants Code.
Specifically, prior to November 16, 2017, the licensee did not submit and receive prior authorization to alternative leak testing requirements for safety injection valves SI-512A and SI-602B.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000382/2017008-
Potential Failure to Obtain a License Amendment for Changes to Diesel Generator Surveillance Test Interval 71111.21M Open
TABLE OF CONTENTS
INSPECTION SCOPES
...............5
REACTOR SAFETY
..................................................................................................................
INSPECTION RESULTS
..............................................................................................................
EXIT MEETINGS AND DEBRIEFS
............................................................................................ 16 LIST OF
DOCUMENTS REVIEWED
...................................................................................... A1-1
ADDITIONAL REQUESTS..................................................................................................... A2-1
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures in effect
at the beginning of the inspection unless otherwise noted. Currently approved inspection
procedures with their attached revision histories are located on the public Web site at
http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.
Samples were declared complete when the inspection procedure requirements most
appropriate to the inspection activity were met consistent with Inspection Manual Chapter 2515,
Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed
selected procedures and records, observed activities, and interviewed personnel to assess
licensee performance and compliance with Commission rules and regulations, license
conditions, site procedures, and standards.
REACTOR SAFETY
Inspection Procedure 71111.21M - Design Bases Assurance (Team) Inspection
From October 23, 2017, to November 16, 2017, the team inspected the following
components and listed applicable attributes, permanent modifications, operating experience,
and operator actions.
Components - 71111.21M (5 Samples)
(1) Emergency feedwater turbine steam supply valves, MSMVAAA401A and 401B:
a) Component maintenance history and corrective action program reports to verify the
monitoring of potential degradation.
b) Calculations for valve thrust and torque to verify the capability of the valve to perform
its required function under the most limiting conditions.
c) Evaluation of the electric heat tracing installed downstream of the motor-operated
valves to verify excessive condensate will not be generated in the event of a cold
start of the emergency feedwater turbine.
d) Procedures for testing the bypass of motor-operated valve thermal overloads under
accident conditions to verify operability of valve.
(2) 125 VDC Bus 3AB-DC-S
a) Component maintenance history and corrective action program reports to verify the
monitoring of potential degradation.
b) Calculations for electrical distribution, system load flow/voltage drop, short-circuit,
and electrical protection to verify that bus capacity and voltages remained within
minimum acceptable limits.
c) The protective device settings and circuit breaker ratings to ensure adequate
selective protection coordination of connected equipment during worst-case short
circuit conditions.
d) Procedures for circuit breaker preventive maintenance, inspection, and testing to
compare maintenance practices against industry and vendor guidance.
(3) High pressure safety injection pump B:
a) Component maintenance history and corrective action program reports to verify the
monitoring of potential degradation.
b) Calculations for system flow, system flow balance, net positive suction head,
surveillance test acceptance criteria minimum flow, and runout flow.
c) The impact of minimum and maximum allowable electrical power supply frequency
on pump performance and net positive suction head.
d) Procedures for operation of the high pressure safety injection system under accident
conditions.
e) Routing of pump motor cables.
f) Corrective action documents issued in the past five years.
g) Procedures for preventive maintenance, inspection, and testing to compare
maintenance practices against industry and vendor guidance.
h) Motor sizing calculations to verify input assumptions and design loading to ensure
adequate design for pumping capacity. The team put special emphasis on pump
motor testing methodology, the values assigned to acceptance criteria, and whether
the values supported design parameters and assumptions.
(4) Safety injection sump outlet motor-operated valve, SI-602A:
a) Component maintenance history and corrective action program reports to verify the
monitoring of potential degradation.
b) Calculations for the determination of allowable leakage, target torque values for
stroke testing, maximum rim-pull force, and torque switch settings to ensure valve
functionality.
c) Procedures for valve and operator preventive maintenance, inspection, and testing to
compare maintenance practices against industry and vendor guidance.
d) Site specific commitments to NRC Generic Letter 89-10, Safety-Related
Motor-Operated Valve Testing and Surveillance.
(5) 480 VAC Class 1E switchgear, Bus 3B31S:
a) System health reports, component maintenance history, and corrective action
program reports to verify the monitoring and correction of potential degradation.
b) Calculations for electrical distribution, system load flow/voltage drop, short-circuit,
and electrical protection to verify that bus capacity and voltages remained within the
minimum acceptable limits.
c) The protective device settings and feeder circuit breaker ratings to ensure adequate
selective protection coordination of connected equipment during worst-case short
circuit conditions.
d) Procedures for preventive maintenance, inspection, and testing to compare
maintenance practices against industry and vendor guidance; including the cable
aging management program.
e) Results of completed preventative maintenance on switchgear and breakers,
including breaker tracking.
Large Early Release Frequency Containment Related Structures, Systems, or
Components - 71111.21M (1 Sample)
(1) Containment isolation actuation system:
a) Pressurizer low pressure and containment high pressure transmitter environmental
qualification files and replacement history to maintain pressure transmitters
environmental qualification.
b) Calculations for measurement loop uncertainty and response time test acceptance
criteria.
c) Surveillance test procedures for emergency safety features relay testing and plant
protection system channel testing.
Modifications to Mitigation Structures, Systems, or Components - 71111.21M (6 Samples)
(1) Engineering Change 530, Ultimate Heat Sink Water Replenishment for Tornado Event
(2) Engineering Change 40828, Evaluation of Replacement Bushings for Unit Auxiliary
Transformer
(3) Engineering Change 46556, CC ISV0807A Solenoid Preventative Maintenance
Equivalency
(4) Engineering Change 44782, Emergency Diesel Generator Governor Upgrade
(5) Engineering Change 55752, Replace SI-512B with a Swing Check Valve
(6) Engineering Change 63801, Emergency Feedwater Circuitry Modification
Operating Experience - 71111.21M (3 Samples)
(1) NRC Generic Letter 1988-03, Resolution of Generic Safety Issue 93, Steam Binding of
Auxiliary Feedwater Pumps
(2) NRC Information Notice 2013-05, Battery Expected Life and its Potential Impact on
Surveillance Requirements
(3) NRC Information Notice 2014-03, Turbine-Driven Auxiliary Feedwater Pump Overspeed
Trip Mechanism Issues
Evaluation of Inspection Sample Related Operator Procedures and Actions
(1) Control room operator actions resulting from a simulated small break loss-of-coolant
accident followed by a post reactor trip loss-of-offsite power with a single failure of
component cooling water pump B.
a) Control room crew expected to enter procedures for standard post trip actions and
loss of coolant accident recovery.
b) Following the component cooling water pump B trip, the crew was expected to
restore cooling to emergency diesel generator B, using component cooling water
pump AB, and prior to emergency diesel generator failure.
INSPECTION RESULTS
Three examples of Failure to Establish and Maintain Preventive Maintenance Procedures for
Safety-Related Electrical Equipment
Cornerstone
Significance
Cross-cutting
Aspect
Report
Section
Mitigating
Systems
Green
Closed
Not Applicable
The team identified three examples of a Green non-cited violation of Waterford Steam Electric
Station, Unit 3, Technical Specification 6.8.1.a, for failure to establish, implement, and maintain
written procedures for activities referenced in Appendix A of Regulatory Guide 1.33,
Revision 2, dated February 1978. Specifically, prior to November 16, 2017, the licensee failed
to establish and maintain procedures covered in Regulatory Guide 1.33, Appendix A,
Section 9, Procedures for Performing Maintenance, to implement maintenance for
safety-related 1600 A, 600 V non-segregated metal-enclosed bus ducts, safety-related 4.16 kV
- G.E. Magne-Blast circuit breakers, and safety-related 480 V G.E. switchgear AKR breakers.
Description:
Example 1: The team identified that the licensee failed to establish a procedure to perform
maintenance and inspection of safety-related 1600 A, 600 V non-segregated metal enclosed
bus ducts as recommended by the vendor. The vendor manual, TD-G080.0735, General
Electric Important Instructions for Armor-Clad Indoor Feeder Busway, GEH-2636, included
recommendations for cleaning dust and dirt on the busway, checking for signs of overheating,
megger checks, visually check for loose bolts at the joints, proper spring tension, excessive
wear, arc spatter, and sooty deposits. No procedure for performing maintenance or plans for
performing maintenance were established for the safety-related metal-enclosed bus ducts.
This represented a failure to establish procedures for activities covered by Regulatory
Guide 1.33, Appendix A, Section 9, Procedures for Performing Maintenance.
Example 2: The team identified that the licensee failed to revise safety-related 4.16 kV G.E.
Magne-Blast circuit breaker preventive maintenance procedures to include auxiliary switch
contact resistance and functional tests. Entergy maintenance procedures are written to
include requirements set forth in the Entergy preventive maintenance templates. The Entergy
preventive maintenance templates for circuit breakers include vendor recommendations and
industry best practices, such as EPRI Technical Report 109641, Guidance on Routine
Preventive Maintenance for Magne-Blast Breakers. EPRI Technical Report 109641, Section
7, Preventive Maintenance Tasks, provides guidance on performing auxiliary switch contact
resistance tests and justifies the tests inclusion using industry operating experience. The
Task Content section of the Preventive Maintenance Template, EN-Switchgear - Medium
Voltage - 1KV-7KV, Revision 3, requires during inspections, cleaning and testing, and
breaker overhauls to Perform contact resistance test. The teams review of maintenance
Procedure ME-003-327, 4.16 KV
- G.E Magne Blast Breaker, Revision 18, identified that the
procedure did not include the performance of auxiliary switch contact resistance tests as
required by the preventive maintenance template. This represented a failure to maintain
procedures for activities covered by Regulatory Guide 1.33, Appendix A, Section 9,
Procedures for Performing Maintenance.
Example 3: The team identified that the licensee failed to revise 480 V G.E. AKR circuit
breakers preventive maintenance procedures to include reduced control voltage tests. Entergy
maintenance procedures are written to include requirements set forth in the Entergy preventive
maintenance templates. The Entergy preventive maintenance templates for circuit breakers
include vendor recommendations and industry best practices, such as EPRI Technical
Report 112938, Routine Preventive Maintenance Guidance for AK and AKR Type Circuit
Breakers. EPRI Technical Report 112938 provides guidance on performing reduced control
voltage tests. In September 2008, Preventive Maintenance Template, EN-Switchgear - Low
Voltage, was changed to include a required reduced control voltage test in the visual
inspection task for low voltage circuit breakers. However, as of September 12, 2017,
Maintenance Procedure ME-003-330, 480 V
- G.E Switchgear Breakers, Revision 310 did not
include the performance of reduced control voltage tests required by the preventive
maintenance template. This represented a failure to maintain procedures for activities covered
by Regulatory Guide 1.33, Appendix A, Section 9, Procedures for Performing Maintenance.
This represented a failure to establish procedures for activities covered by Regulatory
Guide 1.33, Appendix A, Section 9, Procedures for Performing Maintenance.
Corrective Action(s): In response to this issue, the licensee created corrective actions to
evaluate the appropriateness and scheduling for each preventive maintenance task. This
finding does not represent an immediate safety concern.
Corrective Action Reference(s): Condition Reports CR-WF3-2017-08574,
CR-WF3-2017-08611, CR-WF3 2017-08632, CR-WF3-2017-08635, and CR-WF3-2017-08737
Performance Assessment:
Performance Deficiency: The team determined that the failure to establish and maintain
maintenance procedures for activities covered by Regulatory Guide 1.33, Appendix A,
Section 9, Procedures for Performing Maintenance, was a performance deficiency.
Screening: This performance deficiency was more than minor, and therefore a finding,
because it was associated with the procedure quality attribute of the Mitigating Systems
Cornerstone and adversely affected the cornerstone objective to ensure the availability,
reliability, and capability of systems to respond to initiating events to prevent undesirable
consequences. Specifically, the failure to incorporate the testing, and inspection requirements
into preventive maintenance procedures could cause unacceptable conditions to go
undetected.
Significance: In accordance with Inspection Manual Chapter 0609, Appendix A, The
Significance Determination Process (SDP) for Findings At Power, dated July 19, 2012, the
finding screened as having very low safety significance (Green) because it was a design or
qualification deficiency that did not represent a loss of operability or functionality; did not
represent an actual loss of safety function of the system or train; did not result in the loss of
one or more trains of non-technical specification equipment; and did not screen as potentially
risk-significant due to seismic, flooding, or severe weather.
Cross Cutting Aspect: The team determined that this finding did not have a cross-cutting
aspect because the most significant contributor did not reflect current licensee performance.
Enforcement:
Violation: Waterford Steam Electric Station, Unit 3, Technical Specification 6.8.1.a, requires
that written procedures shall be established, implemented, and maintained to cover the
applicable procedures recommended in Appendix A of Regulatory Guide RG 1.33, Revision 2,
dated February 1978. Appendix A, Section 9, Procedures for Performing Maintenance
recommends in part that, Maintenance that can affect the performance of a safety-related
equipment should be properly pre-planned and performed in accordance with written
procedures, documented instructions, or drawings appropriate to the circumstance.
Contrary to the above, prior to November 16, 2017, the licensee failed to establish and
maintain written procedures for performing maintenance that can affect the performance of
safety-related equipment. Specifically, the licensee failed to establish and maintain
procedures covered in Regulatory Guide 1.33, Appendix A, Section 9, Procedures for
Performing Maintenance, to implement maintenance for safety-related 1600 A,
600 V non-segregated metal-enclosed bus ducts, safety-related 4.16 kV G.E. Magne-Blast
circuit breakers, and safety-related 480 V G.E. Switchgear AKR Breakers.
Enforcement Action(s): This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Failure to Meet RG 1.9 Emergency Diesel Testing Requirements during Surveillance Test
Results in Missed Surveillance
Cornerstone
Significance
Cross-cutting
Aspect
Report
Section
Mitigating
Systems
Green
Closed
H.11 - Human
Performance,
Challenge the
Unknown
The team identified a Green non-cited violation of Waterford Steam Electric Station, Unit 3,
Technical Specification Limiting Condition for Operation 3.8.1.1 for failure to maintain
operability of two separate independent diesel generators. Specifically, on May 23, 2017, the
licensee failed to verify that the train A emergency diesel generator energized all auto-
connected shutdown loads through the load sequencer and operated for greater than or equal
to five minutes in accordance with Technical Specification Surveillance Requirement 4.8.1.1.2
Description:
Technical Specification Surveillance Requirement 4.8.1.1.2 requires the licensee to
demonstrate each diesel generators operability by verification, for a simulated loss-of-offsite
power and simulated loss-of-offsite power in conjunction with safety injection actuation system
test signal, that the following is met:
Verifying the diesel starts on the auto-start signal, energizes the emergency busses and the
permanently connected loads within 10 seconds after the auto-start signal, energizes the auto-
connected shutdown loads through the load sequencer and operates for greater than or equal
to 5 minutes while its generator is loaded with the shutdown loads. After energization, the
steady-state voltage and frequency of the emergency busses shall be maintained at
4160 +420, -240 volts and 60 +1.2, -0.3 Hz during this test.
The surveillance requirement for demonstrating operability is consistent with the
recommendations of Regulatory Guide 1.9, Selection of Diesel Generator Set Capacity for
Standby Power Supplies, Revision 4, March 2007. The licensee performs Operating
Procedure OP-903-115, Integrated Emergency Diesel Generator/Emergency Safety Features
Test - Train A, Revision 39, to accomplish this Surveillance Requirement.
Procedure OP-903-115 contains Component List(s) which identifies all the emergency safety
features loads required to auto-connect on the emergency diesel generator bus for both the
simulated loss-of-offsite power and the simulated loss-of-offsite power concurrent with a safety
injection actuation signal. In various steps, Procedure OP-903-115 directs the operators to
verify all components listed on the Component List are energized while performing the
various tests.
On May 23, 2017, Procedure OP-903-115 was performed without verifying all components on
the Component List were energized. Specifically, the surveillance test was performed
without verifying that the listed safety components, boric acid makeup pump B and dry cooling
tower fan 6A, auto-connected and were energized. In the test results, as documented in Work Order 52685292, the licensee acknowledged the components were not available because of
equipment issues and determined the test was satisfactory. On May 24, 2017, the licensee
initiated Condition Report CR-WF3-2017-04435 for the unavailable components, further
determining that the train A emergency diesel generator was operable because the addition of
the loads was within the capacity of the diesel generator.
Regulatory Guide 1.9, Revision 4, Section 2.2.5, LOOP Test, states that the loss-of-offsite
power test must demonstrate that the emergency diesel generator energizes all
auto-connected shutdown loads through the load sequencer. It further states, If the required
loads are not available, one or more equivalent load(s) may be used. Based on Regulatory
Guide 1.9, the inspectors determined that the licensee failed to perform a satisfactory
surveillance test, in accordance with Surveillance Requirement 4.8.1.1.2, because all auto-
connected loads were not energized and equivalent loads were not energized on the safety
bus when the licensee determined the components were not available. This resulted in a
missed surveillance, in accordance with Surveillance Requirement 4.0.3, and a failure to meet
Technical Specification Limiting Condition for Operation 3.8.1.1 when reactor startup
commenced on June 1, 2017.
Corrective Action(s): The licensee entered these issues into the corrective action program,
initiated the Surveillance Requirement 4.0.3 risk evaluation, and scheduled the performance of
Surveillance Requirement 4.8.1.1.2 at the first opportunity.
Corrective Action Reference(s): Condition Reports CR-WF3-2017-09106 and
Performance Assessment:
Performance Deficiency: The team determined that the failure to perform the emergency
diesel generator surveillance test in accordance with written test procedures was a
performance deficiency.
Screening: This performance deficiency was more than minor, and therefore a finding,
because it was associated with the equipment performance attribute of the Mitigating Systems
Cornerstone and adversely affected the cornerstone objective to ensure the availability,
reliability, and capability of systems to respond to initiating events to prevent undesirable
consequences. Specifically, the failure to ensure all components would auto-connect did not
ensure that the emergency diesel generator and sequencer would be capable of carrying
required loads during an event.
Significance: In accordance with Inspection Manual Chapter 0609, Appendix A, The
Significance Determination Process (SDP) for Findings At Power, dated July 19, 2012, the
finding screened as having very low safety significance (Green) because it was a design or
qualification deficiency that did not represent a loss of operability or functionality; did not
represent an actual loss of safety function of the system or train; did not result in the loss of
one or more trains of non-technical specification equipment; and did not screen as potentially
risk-significant due to seismic, flooding, or severe weather.
Cross Cutting Aspect: This finding had a human performance cross-cutting aspect, associated
with challenge the unknown, because the licensee failed to stop when faced with uncertain
conditions. Specifically, individuals failed to stop work when it was determined that the
surveillance test procedure could not be performed as written [H.11].
Enforcement:
Violation: Waterford Steam Electric Station, Unit 3, Technical Specification 3/4.8.1, A.C.
Sources, Limiting Condition for Operation 3.8.1.1 which requires that two separate and
independent diesel generators shall be operable in Modes 1, 2, 3, and 4.
Contrary to the above, from June 1, 2017, to November 16, 2017, the licensee failed to
maintain two separate and independent diesel generators operable in Modes 1, 2, 3, and 4.
Specifically, the licensee failed to perform a satisfactory surveillance test on train A emergency
diesel generator, in accordance with Surveillance Requirement 4.8.1.1.2, because all auto-
connected loads were not energized and equivalent loads were not energized on the safety
bus when the licensee determined the components were not available.
Enforcement Action(s): This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Two Examples of Failure to Submit and Receive Prior Authorization of Alternatives to ASME
OM Code Leak Testing Requirements
Cornerstone
Significance
Cross-cutting
Aspect
Report
Section
Not Applicable
Closed
Not Applicable
The team identified two examples of a Severity Level IV, non-cited violation of
CFR 50.55a(z), for failure to submit and obtain authorization prior to implementation of
multiple alternatives to leak testing requirements of the American Society of Mechanical
Engineers (ASME) Operation and Maintenance (OM) of Nuclear Power Plants Code.
Description:
Example 1: Reactor coolant loop 2 hot leg injection check valve, SI-512B, is an ASME Code
Class 1, 3-inch swing check valve that is inservice testing Categories A and C with an active
safety function. During the teams inspection of Engineering Change 55752, Replace SI-512B
with a Swing Check Valve, the team reviewed completed work orders associated with leak
rate testing. ASME OM Code required leak rate testing for SI-512B is performed using
Procedure OP-903-008, Reactor Coolant System Isolation Leakage Test. The team noted
that the licensee had modified the procedure based on an evaluation performed in Engineering
Change 47766, Safety Injection Check Valve Leak Test Method, approved on January 8,
2014. The changes to the test methodology involved measuring the pressure rise downstream
of the valve and correlating that rise to a leak rate. If the pressure rise was less than
pounds per square inch, gauge, over a 30-minute period, the test result was considered
satisfactory and recorded as less than the acceptance criteria of 1 gallon per minute. If
pressure were to rise above 30 pounds per square inch, gauge, a leak rate would be obtained
by another test.
The team determined that this test did not conform to the leak testing requirements of the
ASME OM Code, Subsection ISTC, Inservice Testing of Valves, Paragraph ISTC-3630,
Leakage Rate for Other Than Containment Isolation Valves, and the licensee did not obtain
prior authorization for this alternative test. The team also observed that the alternative test did
not guarantee a valid leak rate result because it assumed another downstream check valve,
SI-510B, was leak tight and that the piping system downstream of SI-512B was water solid,
without the test verifying those assumptions. These observations called into question whether
or not the alternative test, as written, would have obtained a valid result.
Example 2: Safety injection sump outlet header A isolation valve, SI-602A, is a 24-inch
butterfly valve that is ASME Code Class 2 and inservice testing Category A with an active
safety function. The team reviewed completed work orders associated with leak rate testing.
Required leak rate testing for valve SI-602A is performed in accordance with
Procedure OP-903-128, Category A Leak Test. The team noted that the procedure allows for
two tests for determining SI-602A valve leakage, depending on whether or not a spool piece is
removed. One of the tests allows the use of a leak detection fluid. If no evidence of leakage
exists (i.e., bubbles), the test result is recorded as satisfactory and no further leak testing is
performed. If evidence of leakage exists, a leak rate is then obtained by another test.
The team determined that this test does not conform to the leak testing requirements of the
ASME OM Code, Subsection ISTC, Inservice Testing of Valves, Paragraph ISTC-3630,
Leakage Rate for Other Than Containment Isolation Valves, and the licensee did not obtain
prior authorization for this alternative test. Although the use of leak detection fluid is not
complicated, the team observed that the test did not provide specific instructions, for example,
as to how much fluid to use, how long to wait, or where to apply the fluid. These observations
called into question whether or not the alternative test, as written, would have obtained a valid
result.
Corrective Action(s): For SI-512B, the licensee performed an operability determination which
concluded that SI-512B met technical specification leakage rate acceptance criteria of
gallon per minute or less based on a review of the reactor coolant system leak rate program.
For SI-602A, an initial review conducted by the licensee identified that the last time the use of
leak detection fluid alone for the leakage rate test of SI-602A occurred in 2006. All other tests
since 2006 obtained leak rates by tests in compliance with the ASME OM Code and were less
than the specified leakage rate limit.
Corrective Action Reference(s): Condition Report CR-WF3-2017-09143 and
Performance Assessment:
The team determined that the failure to submit and receive prior authorization for alternatives
to leak testing requirements for safety injection valves SI-512B and SI-602A was a violation of
CFR 50.55a(z).
Screening: The team determined this violation was associated with a minor performance
deficiency.
Significance: The team determined the violation to be a Severity Level IV violation similar to
violation example 6.1.d.2 in the NRC Enforcement Policy.
Enforcement:
Severity: Because this violation affected the NRCs ability to perform its regulatory function,
the inspectors evaluated this violation using the traditional enforcement process in accordance
with the NRC Enforcement Policy, dated November 1, 2016. This violation was more than
minor because there was a reasonable likelihood the change would require NRC review and
approval prior to implementation, similar to violations assessed in Section 2.1.3 of the NRC
Enforcement Manual. The team determined the violation to be a Severity Level IV violation
similar to violation example 6.1.d.2 in the NRC Enforcement Policy.
Violation: 10 CFR 50.55a(z), Alternatives to codes and standards requirements, requires, in
part, Alternatives to the requirements of paragraphs (b) through (h) of this section or portions
thereof may be used when authorized by the Director, Office of Nuclear Reactor Regulation, or
Director, Office of New Reactors, as appropriate. A proposed alternative must be submitted
and authorized prior to implementation.
Paragraph (f) of 10 CFR 50.55a, Inservice testing requirements, requires, in part, Systems
and components of boiling and pressurized water cooled nuclear power reactors must meet
the requirements of the ASME BPV Code and ASME OM Code as specified in this paragraph.
Paragraph (4) of 10 CFR 50.55a(f), Inservice testing standards requirement for operating
plants, requires, in part, that Throughout the service life of a boiling or pressurized water-
cooled nuclear power facility, pumps and valves that are classified as ASME Code Class 1,
Class 2, and Class 3 must meet the inservice test requirements (except design and access
provisions) set forth in the ASME OM Code and addenda that become effective subsequent to
editions and addenda specified in paragraphs (f)(2) and (3) of this section and that are
incorporated by reference in paragraph (a)(1)(iv) of this section, to the extent practical within
the limitations of design, geometry, and materials of construction of the components.
Contrary to the above, prior to November 16, 2017, ASME Code Class 1 and 2 valves did not
meet the inservice test requirements of the ASME OM Code and the alternatives were not
submitted and authorized prior to implementation. Specifically, the licensee did not submit and
receive prior authorization to alternative leak testing requirements for safety injection
valves SI-512A and SI 602B, which are ASME Code Class 1 and 2 valves, respectively.
Enforcement Action(s): This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Unresolved Item
(Open)
Potential Failure to Obtain a License Amendment for
Changes to Diesel Generator Surveillance Test Interval
Description:
The team identified an unresolved item for the licensees failure to perform a 10 CFR 50.59
safety evaluation and subsequently obtain a license amendment for changes to the
surveillance testing frequency of the emergency diesel generators.
The licensees process for changing surveillance test intervals is controlled by Technical Specification 6.5.18, Surveillance Frequency Control Program. The licensees changes to
the surveillance test intervals are made in accordance with NEI 04-10, Risk Informed Method
for Control of Surveillance Frequencies, Revision 1, as written in procedure EN-DC-355,
Engineering Evaluation of Proposed Surveillance Test Interval Changes, Revision 2.
The team reviewed the licensees changes to the surveillance test interval, as required by
Technical Specification Surveillance Requirements 4.8.1.1.2.e, for emergency diesel
generators. The licensee changed the surveillance test interval for the train A and B
emergency diesel generators from both emergency diesel generators tested every 18 months
to each emergency diesel generator tested every 36 months. The team determined that
testing the emergency diesel generators once every 36 months was contrary to guidance in
Regulatory Guide 1.9, Application and Testing of Safety-Related Diesel Generators in
Nuclear Power Plants, Revision 4. Specifically, Section 2.3.2.3, Refueling Outage Testing,
requires the capability of the overall emergency diesel generator design should be
demonstrated during every refueling outage not exceeding a period of 24 months.
The team determined that the licensee did not correctly evaluate the change to the
surveillance interval in accordance with surveillance frequency control program change
process. Specifically, the licensee did not correctly evaluate NEI 04-10, step 1, Check for
Prohibitive Commitments, and step 2, Can Commitments be Changed? of the change
process. The team determined that this change would require a 10 CFR 50.59 safety
evaluation and subsequent license amendment because it would result in more than a
minimal increase in likelihood of a malfunction of a component important to safety as
previously described in the final safety analysis report. Specifically, the test interval would no
longer meet the applicable acceptance standard, Regulatory Guide 1.9, to which the licensee
is committed.
Planned Closure Action(s): The NRC inspectors will review the final corrective actions,
pending NRC resolution of applicability of 10 CFR 50.59 to the surveillance frequency control
program.
Licensee Action(s): Prior to this inspection, the licensee identified this 10 CFR 50.59 issue in
the corrective action program because of industry operating experience. At the time of this
inspection, the licensee had not completed the final corrective action and 10 CFR 50.59
activities. These corrective actions will be completed once industry guidance on the NRC
resolution of applicability of 10 CFR 50.59 to the surveillance frequency control program was
available.
Corrective Action Reference(s): Condition Reports CR-WF3-2017-05590 and
NRC Tracking Number: 05000382/2017008-04
EXIT MEETINGS AND DEBRIEFS
The inspection team verified no proprietary information was retained or documented in this
report.
On November 16, 2017, the team presented the preliminary results of the Inspection
Procedure 71111.21M inspection to Mr.
- J. Dinelli, Senior Vice President, and other members
of the licensee staff.
On December 14, 2017, the team presented the final results of the Inspection
Procedure 71111.21M inspection to Mr.
- D. Brenton, General Manager-Plant Operations, and
other members of the licensee staff.
LIST OF DOCUMENTS REVIEWED
Calculations
Number
Title
Revision/Date
ECC99-008
TORMIS ANALYSIS: Tornado Generated Missile Strike at
Waterford 3
ECE89-008
Electrical Design Criteria
ECE90-006
EDG Loading and Fuel Oil Consumption
ECE91-016
Battery 3AB-S Cell Sizing
ECE91-055
AC Short Circuit Calculations
ECE91-056
Relay Settings and Coordination Curves for 6,9KV, 4.16KV
and 480 Volt Buses
ECE91-060
ECE91-195
Load Study for PDP 3AB-DC-S, 346AB, 346AB-1 and 3FDAB 2
ECE91-252
Short Circuit Study for 3AB-S
ECE93-003
Voltage at Motor-Operated Valve
February 12,
1994
ECE9I-050
Degraded Voltage Relay Set-point & Plant Load Study
ECI01-007
Determination of ECCS Measurement Channels Functional
Safety Significance
ECI92-019
Plant Protection System Uncertainty Calculation
ECI93-058
Transmitter Uncertainties
ECI95-011
HPSI Cold Leg Injection Flow Instrumentation Loop
Uncertainty Calculation
ECI99-001
ESF Response Time Acceptance Criteria Basis
ECM00-004
Emergency Feedwater Turbine Steam Supply RELAP Model
ECM05-003
High Pressure Safety Injection System Capacity
ECM07-001
NPSH Analysis of Safety Injection and Containment Spray
Pumps
ECM89-018
SI 602 A&B Pressure Requirements
ECM91-011
NPSH for Safeguard Pumps in Recirculation with
Valve SI-106A(B) Failed Open
ECM92-037
MOV Design Basis Review Calculation No. SI.002
ECM92-042
MOV Design Basis Review Calculation MS-401A&B
ECM97-022
Wet Cooling Tower Makeup requirements
A
Calculations
Number
Title
Revision/Date
ECS04-019
Risk Assessment of Sl-6028 Not Fully Closed
ECS91-016
SI-602 Leakage Study
ECS98-015
Containment P&T Response Analysis
EE2-12-05
4.16KV Switchgears High Resistance Grounding
EE2-16-06
Station Service Transformer Impedance and MCC Bus
Reactor Calculation
HVAC-059
Battery Room Air Flow Required To Limit Hydrogen
Concentration To 1%
HVAC-070
Hydrogen Generation By Station Batteries
IM1024
Piping Stress Qualification for IM1024 due to Replacement of
Valve SI-512B
MN(Q)-6-29
SIS Maximum Operating Suction Pressure
MNQ9-17
Tornado Multiple Missile Protection of Cooling Towers
MNQ93
Heat Removal Capacities of DCT and WCT After LOCA
SQ-MN-352
- 2500# FLOWSERVE Check Valve
SQ-MN-370
Size 3 Class 2500 (CF8M) Swing Check Valve
Drawings
Number
Title
Revision/Date
2-441-0653-3
SMB-00 & 000 STANDARD UNITS WITH: A1 H0BC-
H3BC WORM GEAR ASSEMBLY B1 SEISMIC
SUPPORT BRACKET
February 20,
1987
2B8124
BODY SMB-00-HBC2 ACTUATOR LIMITORQUE -
200 ELECTRIC ACTUATED CONTROL VALVE
B
75B70058, Sh.16 Electrical Diagram 52 Control CKT
75B70058, Sh.17 Electrical Diagram 52 Control CKT
75D700340, Sh.
Connection Diagram
75D701437
Indoor AKD-5 Power Master SWGR
B-289, Sh. 110
Power Distribution and Motor Data Panel 3AB-DC-S
B-289, Sh. 110A
Power Distribution and Motor Data Panel 3AB-DC-S
B-289, Sh. 157
Power Distribution and Motor Data 480V SWGR Front
View
Drawings
Number
Title
Revision/Date
B-289, Sh. 16
Power Distribution and Motor Data 4.16KV SWGR 3B3-S
One-line Diagram
B-289, Sh. 16-1
Power Distribution and Motor Data 4.16KV SWGR 3B3-S
One-line Diagram
B-289, Sh. 16A
Power Distribution and Motor Data 4.16KV SWGR 3B3-S
Protective Relay Settings
B-289, Sh. 20
Power Distribution and Motor Data 480V SWGR 3A31-S
One-line Diagram
B-289, Sh. 21
Power Distribution and Motor Data 480V SWGR 3B31-S
One-line Diagram
B-289, Sh. 21-1
Power Distribution and Motor Data 480V SWGR 3B31-S
One-line Diagram
B-289, Sh. 22
Power Distribution and Motor Data 480V SWGR 3AB31-S
One-line Diagram
B-289, Sh. 22-1
Power Distribution and Motor Data 480 SWGR 3AB31-S
One-line Diagram
B-424, Sh. 1535
Emergency FW Pump Turbine Steam Shut-off Valve 611
B-424, Sh. 1541
Emergency FWPT Governor Valve
B-424, Sh. 2389S Control Wiring Diagram, 480V MCC 3B31-S Undervoltage
Relays Sh.1
B-424, Sh. 2390
Control Wiring Diagram, 480V Bus 3B31-S Undervoltage
Relays Sheet 2
B-424, Sh. 2390S Control Wiring Diagram, 480V Bus 3B31-S Undervoltage
Relays Sheet 1
B-424, Sh. 2397S Control Wiring Diagram, Station Services Transformer
3B31-S Feeder
B-424, Sh. 2410S Control Wiring Diagram, 480V Bus 3AB31-S Undervoltage
Relays Sh.1
B-424, Sh. 2506S Control Wiring Diagram, 480V MCC 3B313-S Feeder
B-424, Sh. 2507S Control Wiring Diagram, 480V MCC 3B314-S Feeder
B-424, Sh. 2925
Control Wiring Diagram, Annunciator Display Cabinet D
B-424, Sh. 3016S Control Wiring Diagram - EFAS Test Module Channel A
B-424, Sh. 3017S Control Wiring Diagram - EFAS Test Module Channel A
B-424, Sh. 509
Control Wiring Diagram, High Pressure Safety Injection
Pump B
Drawings
Number
Title
Revision/Date
B-424, Sh. E1535 Control Wiring Diagram - Emergency Feedwater pump
Turbine Shutoff Valve VA 2MS-V611a
B-424, Sh. E509
Control Wiring Diagram, High Pressure Safety Injection
Pump B
G-167, Sh. 1
Safety Injection System Flow Diagram
July 8, 1991
G-167, Sh. 2
Safety Injection System Flow Diagram
July 8, 1991
G-250S07
Reactor Aux. Bldg. El. -35.00 Conduit Details & Sections
G-285
Main One Line Diagram
G-286
1977-1165 MW Installation Key Auxiliary One Line
Diagram
G-287, Sh. 1
25VDC and 120VAC One Line Diagram
G-317-S01
Reactor Aux Bldg. - El. +7.00 Conduit, Trays &
Grounding - Sh.1
G-329
Reactor Aux. BLDG-El-4.00 Conduit, Trays and
Grounding, Sh. 4
G-335-S01
Reactor Auxiliary Building - EL-35.00 Conduit, Tray &
Grounding-Sh. 3
G-344-S01
Electrical Equipment Room SWGR, MCC & Panel Detail
Sh. 1
T025W2000HM, Type O Plus C, IEEE, Condenser Bushing
Procedures
Number
Title
Revision/Date
01-002-000
Annunciator and Control Room Instrumentation Status Control 309
ECT-64802
Emergency Feedwater Control Valves EFWMVMA 224B and
EFWMVAAA223A
ECT-64803
Emergency Feedwater Control Valves EFWMVAAA 224A and
EFWMVAAA223B
NMM Procedure Process
Engineering Change Process
Engineering Change Process
Preventative Maintenance Component Classification
Predictive Maintenance Program
Preventive Maintenance Program
Procedures
Number
Title
Revision/Date
PM Basis Template
Engineering Evaluation of Proposed Surveillance Test Interval
change
CFR 50.59 Evaluations
Corrective Action Program
Conduct of Maintenance
EN-MA-101-
Maintenance Work Preparation Process
EN-MA-119-01 Control, Storage, and Inspection of Lifting Equipment
Operability Determination Process
RAB Train "AB" Thermography Route
June 21,
2011
ME-001-012
Temporary Power from Temporary Diesel for 3A2 and 3B2 4kV
Buses (MODES 1-6)
313
ME-003-210
Performance Test on DC Battery
ME-003-230
Battery Service Test
315
ME-003-240
Performance Test on DC EBATAB Battery
313
ME-003-301
480 VAC Overcurrent Protective Integrated Device Functional
Test
ME-003-327
4.16 kV G.E. Magne-Blast Breaker
ME-003-330
480 Volt GE Switchgear Breakers
310
ME-003-410
Motor-Operated Valve Thermal Overload Channel Calibration
311
ME-004-021
ME-004-061
Unit Auxiliary Transformer
308
ME-004-115
4.16/6.9 kV G.E. Magne-Blast Breaker Overhaul
ME-004-141
Low Voltage Switchgear
2
ME-004-142
480 Volt GE Switchgear AKR Breaker Overhaul
ME-004-161
Low Voltage Power Distribution Panels
ME-004-211
Station Battery Quarterly
ME-007-043
Viper Testing of MOVs
ME-007-047
VOTES Testing of MOVs
Procedures
Number
Title
Revision/Date
ME-007-073
Testing Procedure, Unit Auxiliary Transformer Power Factor
Testing
MI-003-219
Plant Protection System Sensor Bi-stable Response Time
Verification Channel A, B, C, or D
301
MI-003-222
Matrix Response Time Verification for Reactor Protection
System and Engineered Safety Features Actuation System
Channels A, B, C, or D
307
MI-003-302
Containment Pressure (Narrow Range) Loop Check and
Calibration CB IP6701 SMA, SMB, SMC, or SMD
304
MI-003-316
Pressurizer Pressure (Wide Range) Loop Check and
Calibration RC IP0102 A, B, C, or D
2
MI-003-514
Emergency Feedwater Control Loop Check and Calibration
311
MI-003-515
Emergency Feedwater Control Loop Check and Calibration
309
MI-005-204
Calibration of Temperature Instruments
MI-005-464
Plant Protection System Power Supply Calibration
305
MI-005-705
Engineered Safety Features Actuation System Auxiliary Relay
Cabinet 3A or 3B Power Supply and Ground Detector Test
301
MI-013-522
PPS Ground Detection Test
MM-006-053
Check Valve Inspection (Swing)
OP-002-007
Freeze Protection and Temperature Maintenance
OP-006-001
Plant Distribution (7KV, 4KV and SSD) System
26
OP-009-002
341
OP-009-008
Safety Injection System
OP-100-014
Technical Specification and Technical Requirements
Compliance
337, 341
OP-500-004,
Attach. 4.113
480V Bus SB Bkr Trip/Trouble
OP-500-004,
Attach. 4.85
SS Xfmr. 3B31-S Ground/Temp Hi
OP-500-011
Control Room Cabinet M
OP-500-012
Control Room Cabinet N
OP-500-013
Control Room Cabinet SA
OP-500-014
Control Room Cabinet SB
OP-901-521
Severe Weather and Flooding
25
Procedures
Number
Title
Revision/Date
OP-902-002
Loss of Coolant Accident Recovery
OP-903-008
Reactor Coolant System Isolation Leakage Test
OP-903-011
High Safety Injection Pump Operability Check
OP-903-029
Safety Injection Actuation Signal Test
OP-903-030
Safety Injection Pump Operability Verification
OP-903-033
Cold Shutdown IST Valve Tests
OP-903-066
Electrical Breaker Alignment Check
2
OP-903-094
ESFAS Subgroup Relay Test - Operating
OP-903-095
ESFAS Subgroup Relay Test - Shutdown
OP-903-100
MOV Overload Bypass Test
310
OP-903-107
Plant Protection System Channel A B C D Function Test
310
OP-903-108
SI Flow Balance Test
OP-903-108,
Att. 10.3
Completed Flow Balance for HPSI Pump B
OP-903-115
Integrated Emergency Diesel Generator/Emergency Safety
Features Test - Train A
OP-903-116
Train B Integrated Emergency Diesel Generator/ Engineering
Safety Features Test
OP-903-128
Category A Leak Test
SEP-ISI-104
ASME SECTION XI, DIVISION I INSERVICE INSPECTION
PROGRAM
SEP-WF3-
IST-1
WF3 INSERVICE TESTING BASES DOCUMENT
SEP-WF3-
IST-2
WF3 INSERVICE TESTING PLAN
SEP-WF3-
IST-3
WF3 INSERVICE TESTING CROSS REFERENCE
DOCUMENT
UNT-006-033
Technical Specifications Surveillance Frequency List
W2.109
Procedure Development, Review and Approval
Engineering Changes
Number
Title
Revision/Date
Documentation of Waterford 3's Response to NRC Generic
Letter No. 96-01 "Testing of Safety-Related Logic Circuits"
Evaluation of Replacement Bushing for UAT
Emergency Diesel Generator Governor Upgrade
April 23, 2014
Safety Injection Check Valve Leak Test Method OP-903-008
Issue Markup to ECC99-008 For EDG Lines (Tormis) not
Protected for Tornado Missiles
Leak Repair of EDG Fuel Oil Feed Tank Vent Pipes
Replace SI-512B with a Swing Check Valve
Child EC For SI-512B Hard Seat Option
EDG Day Tank Vent Lines Installation Clarification
Emergency Feedwater Circuitry Modification
Environmental Qualification Documents
Number
Title
Revision
Mark-up of LPLEQA8.1D LPLEQA8.1C
Mark-up of EQMI-8.1 LPLEQA8.1D
Mark-up of EQMI-8.1
LPL-EQA08.01C Rosemount 1153 Series D Transmitters
LPL-EQA-8.01D
Rosemount Model 1154 Series H Transmitters
LPL-EQA-8.01D
Rosemount Model 1154 Series H Transmitters
LPL-EQA-8.0I
Rosemount Model 3154N Transmitters
LPL-EQMI-08.01 Rosemount Model 1153 Series A, B &D, 1154 &1154
Series H Transmitters and 1159 Remote Seals
LPL-EQMI-8.01B Rosemount Model 3152N, 3153N, and 3154N Series
Transmitters and 3159 Remote Seals
Vendor Documents
Number
Title
Revision/Date
15-111494-001
SWING CHECK VALVE STAINLESS STEEL. NOREM
TRIM BUTT WELD ENDS. SIZE: 3 CLASS: 2500
Form 2432
Instruction Manual Type 9200 T-Ring Butterfly Valve
Bodies
March 1974
Vendor Documents
Number
Title
Revision/Date
GEK-721
Instructions for Type AKD-6 Low voltage
August 1977
Letter-C&D
Technologies
Battery Cover Crack
May 15, 2013
Lou-1564.261-B
Ebasco Purchase Specification for Metal-Enclosed
600Volt Class Draw-out type Class 1E Buses 3A31-S,
3B31-S, 3AB31-S, Transformer 3A315-S, 3B315-S & Non-
Class 1E Buses 3A32, 3B32
RAL-21146
Design and Seismic Analysis Report (Size 3 Class 2500
(CF8M) Swing Check Valve Drawing 15-111494-001)
Standby Battery Vented Cell Installation and Operating
Instruction
TD-A1800.0095
Allis-Chalmers Installation Operation Maintenance
Instruction Induction Motors/Generators Horizontal 500,
580, 30 Frames M3514-02
October 31,
1996
TD-F994.0085
Swing check Valve, Size 3 Class 2500 Operation and
Maintenance Manual
TD-G080,0735
General Electric Important Instructions for Armor-Clad
Indoor Feeder Busway, GEH-2636
TD-G080.0625
General Electric Station Service Ventilated Dry
Transformer
TD-G080-0095
General Electric Switchgear Magne-Blast Breaker
TD-G080-0145
GE Low Voltage Switchgear Tech Manual
TD-L200.0055
LIMITORQUE VALVE CONTROLS TYPE SB-1 AND SMB
AND 00 FOR OPERATING AT HIGH TEMPERATURE
TD-S440.0015
Struthers Dunn Type A112 & 112 Relays
July 31, 1997
TD-W120.3115
Westinghouse MCCB AB De-ion breaker
TD-W120.3135
TD-W120.3145
Westinghouse Tri-Pac Breaker
April 1976
W290.0055
2301A Load Sharing and Speed Control
W290.0065
Digital Reference Unit
W290.0075
EDG Proportional Governor/Actuator
Design Basis Documents
Number
Title
Revision
W3-DBD-001
Safety Injection System
305
Design Basis Documents
Number
Title
Revision
W3-DBD-002
Emergency Diesel Generator & Automatic Load
Sequencer
305
W3-DBD-003
2
W3-DBD-006
Main Steam System
W3-DBD-008
Electrical Distribution (DC Portion)
W3-DBD-009
Reactor Coolant System & Steam Generator Blowdown
System
304
W3-DBD-011
Electrical Distribution (AC Portion)
W3-DBD-012
Plant Protection System Design Basis Document
W3-DBD-014
Safety Related, Air Operated Valves
303
W3-DBD-026
Containment Isolation and Leakage Rate Testing
Quality Assurance Audit Reports
Number
Title
Date
QA-4-2016-W3-1 Engineering (Design Control)
April 14, 2016
QA-8-2017-W3-1 Engineering Programs
March 13, 2017
QA-8-2017-W3-2 Engineering Programs
April 25, 2017
Miscellaneous
Number
Title
Revision/Date
CN7C7244
Connection To Auxiliary Transformer
System Health Report, 125VDC Distribution
Q2-2017
EG
System Health Report, Emergency Diesel Generator
Q2-2017
EN-Motor
EN-Motor-Medium Voltage (>600V/<15KV)
ER-W3-2004-
0575-001
Reclassify SI-602 A & B as IST Category A
LO-WLO-2017-
00011
2017 Pre NRC DBAI Focus Self-Assessment
October 10, 2017
Procurement
Eval. 00155992
Switch, Temperature Hot Spot, Indicating
---
SD-CC
Component Cooling Water System Description
SD-SI
Safety Injection
Miscellaneous
Number
Title
Revision/Date
SPEC-15-00002-
W
Reactor Coolant Hot Leg Injection Check Valve SI
MVAAA512 B Replacement
SSD
SSD - 480V Station Service Distribution
Q2-2017
STI 17-001
Integrated EDG/ESF Test
WLP-OPS-DG00 Emergency Diesel Generator Training
Condition Reports
CR-WF3-
2014-05582
CR-WF3-
2014-05662
CR-WF3-
2014-05690
CR-WF3-
2014-05131
CR-WF3-
2016-01754
CR-WF3-
2017-01231
CR-WF3-
2017-04865
CR-WF3-
2017-07888
CR-WF3-
2017-08621
CR-WF3-
2017-08618
CR-WF3-
2017-08589
CR-WF3-
2017-08448
CR-WF3-
2015-05792
CR-WF3-
2016-05473
CR-WF3-
2017-02670
CR-WF3-
2017-07682
CR-WF3-
2015-06557
CR-WF3-
2016-05478
CR-WF3-
2017-02727
CR-WF3-
2017-06067
CR-WF3-
2015-07737
CR-WF3-
2017-02633
CR-WF3-
2017-04436
OE-NOE-
2005-00338
CR-WF3-
2017-06067
CR-WF3-
2014-05529
CR-WF3-
2014-05341
CR-WF3-
2014-05413
CR-WF3-
2014-05690
CR-WF3-
2017-07223
CR-WF3-
2014-05131
CR-WF3-
2004-02847
CR-WF3-
1998-00516
CR-WF3-
2015-04850
CR-WF3-
2008-05183
CR-WF3-
2017-07462
CR-WF3-
2015-04850
CR-WF3-
2008-05183
CR-WF3-
2017-05602
CR-WF3-
2017-5590
CR-WF3-
2017-04435
CR-WF3-
2017-0572
CR-WF3-
2017-7462
CR-WF3-
2017-03768
CR-WF3-
2016-07647
CR-WF3-
2016-07921
CR-WF3-
2016-04038
CR-WF3-
2016-04038
CR-WF3-
2015-07975
CR-WF3-
2015-05346
CR-WF3-
2015-07907
CR-WF3-
2015-06950
CR-WF3-
2009-05400
CR-WF3-
2014-05458
CR-WF3-
2017-01148
CR-WF3-
2017-01055
CR-WF3-
2017-01045
CR-WF3-
2017-01046
CR-WF3-
2017-01047
CR-WF3-
2014-05369
CR-WF3-
2014-05131
CR-WF3-
2014-05841
Condition Reports Generated During this Inspection
CR-HQN-
2017-01724
CR-HQN-
2017-01906
CR-WF3-
2017-07462
CR-WF3-
2017-08432
CR-WF3-
2017-08448
CR-WF3-
2017-08511
CR-WF3-
2017-08518
CR-WF3-
2017-08519
CR-WF3-
2017-08521
CR-WF3-
2017-08559
CR-WF3-
2017-08568
CR-WF3-
2017-08572
Condition Reports Generated During this Inspection
CR-WF3-
2017-08574
CR-WF3-
2017-08580
CR-WF3-
2017-08582
CR-WF3-
2017-08583
CR-WF3-
2017-08585
CR-WF3-
2017-08589
CR-WF3-
2017-08606
CR-WF3-
2017-08611
CR-WF3-
2017-08616
CR-WF3-
2017-08618
CR-WF3-
2017-08621
CR-WF3-
2017-08627
CR-WF3-
2017-08632
CR-WF3-
2017-08634
CR-WF3-
2017-08635
CR-WF3-
2017-08678
CR-WF3-
2017-08680
CR-WF3-
2017-08689
CR-WF3-
2017-08737
CR-WF3-
2017-08757
CR-WF3-
2017-08940
CR-WF3-
2017-08962
CR-WF3-
2017-08982
CR-WF3-
2017-08983
CR-WF3-
2017-09093
CR-WF3-
2017-09106
CR-WF3-
2017-09107
CR-WF3-
2017-09108
CR-WF3-
2017-09125
CR-WF3-
2017-09132
CR-WF3-
2017-09140
CR-WF3-
2017-09143
CR-WF3-
2017-09144
CR-WF3-
2017-09164
CR-WF3-
2017-09165
CR-WF3-
2017-09185
CR-WF3-
2017-09201
Work Orders
2694
15069
27321 01
44570 01
48893 01
53699
57714 01
24211 01
25122 01
27292
153521 01
154929 01
183024 01
183173 01
2639 01
263714
263714
309077
357372
395966
396915
411850
411921
50010020
51523197 01
51523197 04
51523197 06
51655055 01
51663303 01
51663303 01
2320766 01
2333000 01
2369790
2369908 01
2433042
2442300
2475662
2475662
2485562 01
2496264 01
2504349 01
2505058 01
2507904 01
2507904 02
2514258 01
2523350 01
2534002
2550025
2570374 01
2577433
2581739 01
2591365 01
2610648
2610648
2628265
2645751
2647626
2655753 01
2679221 01
2680941
2683228
2683228
2685151
2737542 01
ADDITIONAL REQUESTS
Paperwork Reduction Act Statement
This letter does not contain new or amended information collection requirements subject
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information
collection requirements were approved by the Office of Management and Budget, control
number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to
respond to, a request for information or an information collection requirement unless the
requesting document displays a currently valid Office of Management and Budget control
number.
Modification Selections
Number
Title
System Inspector
40828
EVALUATION OF REPLACEMENT BUSHINGS FOR UAT
N Okonkwo
44782
EDG GOVERNOR UPGRADE (BASE EC)
EG
S Gardner
46556
CC ISV0807A SOLENOID PREVENTATIVE
MAINTENANCE EQUIVALENCY
J Braisted
55752
REPLACE SI-512B WITH A SWING CHECK VALVE
J Braisted
63801
Emergency Feedwater Circuitry Modification
C Baron
LBDCR Change to OP-100-014 Revision 337, Ultimate Heat
Sink
C Baron
Ultimate Heat Sink Water Replenishment for Tornado Event
C Baron
Component Selections
No. Component
Inspector
Turbine Emergency Feedwater Steam Supply Valves, MSMVAAA401A
AND 401B, (DC valves)
C Baron
25V dc Bus 3AB-DC-S
S Gardner
High Pressure Safety Injection Pump B and Motor
C Baron
Sump Outlet Motor-Operated Valve Safety Injection SI-602A
J Braisted
480 Vac Class 1E switchgear, Bus 3B31S
N Okonkwo
Containment isolation System/Actuation System
G George
Operating Experience
Number
Title
Inspector
Battery Expected Life and its Potential Impact
on Surveillance Requirements
S Gardner
Turbine-Driven Auxiliary Feedwater Pump
Overspeed Trip Mechanism Issues
A Athar
Resolution of Generic Safety Issue 93, "Steam
Binding of Auxiliary Feedwater Pumps"
A Athar
Problem Identification CRs
CR
Subject
Inspector
Diesel generator day tank degradation
Jon Braisted
3B31 issue
Additional Requests
1. Please create an item (link) in Certrec for each component listed.
2. Provide the following documents for each component, in addition to Section II of the RFI:
a. Preventive maintenance, surveillance, and test procedures; and
normal/abnormal/emergency operating procedures.
b. Frequency of preventive maintenance.
c. A List with brief description of corrective action documents for previous 3 years.
Provide an additional list of operability evaluations which discuss degraded or
nonconforming conditions.
d. Vendor Manuals.
3. Please the following program procedures in one certrec item:
a. Corrective Action Program
c. Engineering Change
d. Procedure Change
e. 50.59 Procedures
f.
Preventive Maintenance Programs
4. Please provide electronic copies of the following CRs and corrective actions in one
certrec item:
2014-5162
2014-5375
2014-5414
2014-5446
2014-5662
2014-5173
2014-5377
2014-5417
2014-5448
2014-5670
2014-5175
2014-5384
2014-5419
2014-5450
2014-5690
2014-5212
2014-5385
2014-5420
2014-5452
2014-5704
2014-5213
2014-5388
2014-5421
2014-5458
2014-5708
2014-5224
2014-5390
2014-5422
2014-5497
2014-5714
2014-5304
2014-5392
2014-5423
2014-5520
2014-5720
2014-5341
2014-5407
2014-5429
2014-5529
2014-5725
2014-5343
2014-5412
2014-5441
2014-5582
2014-5730
2014-5374
2014-5413
2014-5445
2014-5584
2014-5732
SUNSI Review
ADAMS:
Non-Publicly Available
Non-Sensitive
Keyword:
By: GGeorge
Yes No
Publicly Available
Sensitive
OFFICE
SRI:EB1
RI:EB1
RI:EB2
SRTI:TTC
ROE:NRR/IPAB
C:PBD
NAME
GGeorge
JBraisted
NOkonkwo
GCallaway
AAthar
GMiller
SIGNATURE
/RA/
/RA/
/RA/
/RA/
/RA/
/RA/
DATE
2/26/17
2/21/17
2/26/17
2/20/17
2/27/17
2/27/17
OFFICE
C:EB1
NAME
TFarnholtz
SIGNATURE
/RA/
DATE
2/28/17