IR 05000382/2018002

NRC Integrated Inspection Report 05000382/2018002

ML18199A643
Person / Time
Site:	Waterford
Issue date:	07/18/2018
From:	Geoffrey Miller NRC/RGN-IV/DRP/RPB-D
To:	Dinelli J Entergy Operations
References
IR 2018002
Download: ML18199A643 (26)

Text

uly 18, 2018

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED INSPECTION REPORT 05000382/2018002

Dear Mr. Dinelli:

On June 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford Steam Electric Station, Unit 3. On July 12, 2018, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. Further the inspectors documented a licensee-identified violation which was determined to be of very low safety significance. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the 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; and the NRC resident inspector at the Waterford Steam Electric Station, Unit 3.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the 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 Waterford Steam Electric Station, Unit 3. 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/

Geoffrey B. Miller, Chief Project Branch D Division of Reactor Projects Docket No. 50-382 License No. NPF-38 Enclosure:

Inspection Report 05000382/2018002 w/ Attachment: Documents Reviewed

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number(s): 05000382 License Number(s): NPF-38 Report Number(s): 05000382/2018002 Enterprise Identifier: I-2018-002-0002 Licensee: Entergy Operations, Inc.

Facility: Waterford Steam Electric Station, Unit 3 Location: Killona, Louisiana Inspection Dates: April 1, 2018 to June 30, 2018 Inspectors: F. Ramírez, Senior Resident Inspector C. Speer, Resident Inspector C. Henderson, Senior Resident Inspector, Arkansas Nuclear One W. Sifre, Senior Reactor Inspector C. Smith, Reactor Inspector E. Uribe, Reactor Inspector Approved By: G. Miller Chief, Project Branch D Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated 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. A self-revealed violation and additional items are summarized in the tables below. A licensee-identified non-cited violation is documented in report Section 71153.

List of Findings and Violations Failure to Ensure Appropriate Chemistry Controls on the Component Cooling Water Heat Exchangers Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Green [H.12] - Human 71111.07 Systems NCV 05000382/2018002-01 Performance,

Closed Avoid Complacency The inspectors reviewed a self-revealed, Green non-cited violation of 10 CFR Part 50,

Appendix B, Criterion V, Instructions, Procedures, and Drawings, which occurred because the licensee did not prescribe procedures for preventing fouling of the component cooling water heat exchangers that were appropriate to the circumstances. Specifically, the licensee did not require in its instructions for adding biocide to the auxiliary component cooling water system that additions be coupled with running the associated auxiliary component cooling water pump or other means of ensuring that the biocide would be sufficiently circulated through the system. As a result, on February 8, 2018, component cooling water heat exchanger B failed a performance test and therefore would not maintain required design basis temperatures under all accident conditions due to biological fouling.

Additional Tracking Items Type Issue number Title Report Status Section URI 05000382/2018002-02 10 CFR 50.59 Evaluation 71111.17T Open Associated with Emergency Feedwater Logic Modification LER 05000382/2018-001-00 Failure to Enter Limiting 71153 Closed Condition of Operation Action Statement due to Lack of Procedure Guidance Results in a Condition Prohibited by Technical Specifications

PLANT STATUS

The plant operated at or near rated thermal power for the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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.

71111.01 - Adverse Weather Protection Summer Readiness

On April 30, 2018, the inspectors evaluated summer readiness of offsite and alternate alternating current (AC) power systems and walked down:

(1) Transformer yard

(2) Switchyard

Seasonal Extreme Weather (1 Sample)

On May 7, 2018, the inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of hurricane season and walked down:

(1) Main steam isolation valve areas

(2) Dry cooling tower areas

(3) Wet cooling tower areas

71111.04 - Equipment Alignment Partial Walkdown

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Auxiliary component cooling water train B with train A out of service for maintenance on April 2, 2018

(2) Emergency feedwater system train B with train A out of service for maintenance on May 2, 2018

(3) Component cooling water train A with train B out of service for maintenance on

May 23, 2018 Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of the containment spray system on May 16, 2018.

71111.05Fire Protection Quarterly Inspection

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) +21 vestibule, Fire Area RAB 3A-003, on April 27, 2018

(2) Component cooling water pump A, Fire Area RAB 19, on April 27, 2018

(3) Condensate polisher building upper levels, Fire Area NS-CP-002, on May 9, 2018

(4) Fire water pump house, Fire Area FWPH-001, on May 16, 2018

(5) Battery Room 3A, Fire Area RAB 12, on June 12, 2018

(6) Cable vault, Fire Area RAB 1E, on June 12, 2018

71111.06Flood Protection Measures Internal Flooding

The inspectors evaluated internal flooding mitigation protections in the component cooling water pump rooms on April 4, 2018.

71111.07Heat Sink Performance Heat Sink

The inspectors evaluated component cooling water heat exchanger performance on June 11, 2018.

71111.11Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification

The inspectors observed and evaluated licensed operator performance in the simulator during an emergency exercise on June 20, 2018.

Operator Performance (1 Sample)

The inspectors observed and evaluated the control room during engineered safety features actuation system subgroup relay test on train B on June 25, 2018.

71111.12Maintenance Effectiveness Routine Maintenance Effectiveness

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Containment spray system on May 8, 2018

(2) Reactor cutback system on June 26, 2018

(3) Startup transformers on June 28, 2018

71111.13Maintenance Risk Assessments and Emergent Work Control

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Risk assessment for planned Yellow risk due to emergency feedwater system train A work window on May 2, 2018

(2) Risk assessment for planned work on switchgear ventilation on May 14, 2018

(3) Emergent work on emergency diesel generator A1 fuel oil storage tank on June 1, 2018

(4) Emergent Yellow risk due to severe weather on June 11, 2018

(5) Emergent work on essential chiller B on June 13, 2018

(6) Emergent work on static uninterruptible power supply A on June 19, 2018

71111.15Operability Determinations and Functionality Assessments

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Letdown inside containment isolation valve packing leak on April 18, 2018

(2) Control room envelope during pressure boundary repairs on April 26, 2018

(3) Containment spray riser level indication on May 8, 2018

(4) Switchgear auxiliary air handling unit outlet damper on May 15, 2018

(5) Letdown heat exchanger temperature control valve on June 27, 2018

71111.17TEvaluations of Changes, Tests, and Experiments

The inspectors evaluated the following from April 1, 2018, to April 6, 2018:

10 CFR 50.59 Evaluations

(1) 15-02 - Fukushima Emergency Preparedness Communications - Engineering Change (EC) 47846 and licensing basis document change request (LBDCR)15-019

(2) 15-03 - EC 58901, Evaluate RC 1T0125-1 for Use as CPC Input

(3) 15-05 - EC 61746, Temporary Modification for Control Element Drive Mechanism Control System Position Switches

(4) 16-02 - EC 65610, Technical Requirements Manual 3.3.4 Turbine Valve Testing One Time Extension

(5) 17-03 - EC 62939 - Update Specifications 1564.467 and 1564.468 to accept Drillco Maxi-Bolt undercut anchors, add Regulatory Guide (RG) 1.199 to Updated Final Safety Analysis Report (UFSAR) Chapter 1.8, add a description of how to use code ACI 349-01, Appendix B, to UFSAR Chapter 3.8, and issue Calculation ECC17-001

(6) 17-04 - EC 64801 Emergency Feedwater Logic Modification

(7) 17-07 - EC 62976 Enable Trip for Open Phase Detection Systems

(8) 17-08 - CR-WF3-2017-5763 Compensatory Measure: Addition to OP-500-003 for Manual Action to Restart Essential Chiller for Design Basis Events without LOOP 10 CFR 50.59 Screening/Applicability Determinations

(1) PAD-EC-0000061092 - Revise Combustible Loading Calculation ECF91-024 for RAB 22 and ECF91-030 for RAB 30

(2) PAD-MM-006-207 - WMVAAA184A and B (M),(M1), (N) and (N1) valve replacement

(3) PAD-UNT-006-033 - Surveillance Frequency Extensions for Selected Population of Molded Case Circuit Breakers (Technical Specification Surveillance Requirement 4.8.4.1.B)

(4) 0000044904 - Main Steam Isolation Valve Low Low Nitrogen Pressure Alarm Setpoint Change

(5) 0000054158 - Dry Cooling Tower Missile Shield Panel Closure Plate - Train A Ultimate Heat Sink Margin Restoration Project Phase 1

(6) 0000054159 - Dry Cooling Tower Missile Shield Covering - Train B Ultimate Heat Sink Margin Restoration Project

(7) 0000059101 - Dry Cooling Tower Tube Sleeving

(8) 0000062125 - RCP 2A Speed Input to CPC B Degraded Voltage Enhancement

(9) 0000064156 - Engineering Evaluation of Pressurizer Heater Welds CR-WF3-2015-8163

(10) 0000064246 - Evaluation of Crack Between Fire Areas RAB-33 AND RAB-30

(11) 0000067163 - Evaluate 6W12CM10 Using the Ultimate Strength Design Method

(12) 0000068045 - Update PAD SUPS A / B Move from Phase III to Phase II

(13) 0000069189 - Temporary Power for the Supplementary Chiller B Chilled Water Common Circuits in PDP-386A

(14) 0000073256 - Installation of Suppression Diode for 152X Relay in the Fast Bus Transfer Circuit

71111.18Plant Modifications

The inspectors evaluated the following permanent modification:

(1) Permanent modification to raise component cooling water flow to containment spray pump bearing and seals on May 9, 2018

71111.19Post Maintenance Testing

The inspectors evaluated the following post maintenance tests:

(1) Auxiliary component cooling water header A component cooling water heat exchanger outlet temperature control valve following maintenance on April 3, 2018

(2) Chemical volume control pump B following maintenance on April 17, 2018

(3) Emergency feedwater header B to steam generator 2 primary flow control valve following maintenance on April 25, 2018

(4) Containment spray train B following maintenance on May 23, 2018

(5) Control room envelope following repairs on May 31, 2018

71111.22Surveillance Testing The inspectors evaluated the following surveillance tests: In-service

(1) Auxiliary component cooling water pump B on May 18, 2018

(2) Component cooling water pump B on May 24, 2018

(3) Containment spray pump B on June 12, 2018

Reactor Coolant System Leak Detection (1 Sample)

(1) Reactor coolant system unidentified leakage calculation on April 19, 2018

71114.06Drill Evaluation Emergency Planning Drill

The inspectors evaluated an emergency planning training drill on June 20,

OTHER ACTIVITIES - BASELINE

===71151Performance Indicator Verification The inspectors verified licensee performance indicator submittals listed below:

MS05: Safety System Functional Failures (SSFFs) ===

(1) Unit 3 (April 1, 2017, through March 31, 2018)

MS06: Emergency AC Power Systems (1 Sample)

(1) Unit 3 (April 1, 2017, through March 31, 2018)

MS07: High Pressure Injection Systems (1 Sample)

(1) Unit 3 (April 1, 2017, through March 31, 2018)

71152Problem Identification and Resolution Semiannual Trend Review

The inspectors reviewed the licensees corrective action program for potential adverse trends that might be indicative of a more significant safety issue. The inspectors identified an observation related to the evaluation of non-adverse conditions in the Maintenance Rule Program that is documented in the Inspections Results section below.

Annual Follow-up of Selected Issues (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Potential preconditioning of safety-related valves on May 15, 2018

(2) Corrective Actions to NCV 05000382/2017002-04 and CR-WF3-2017-06754

71153Follow-up of Events and Notices of Enforcement Discretion Licensee Event Reports

The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) Licensee Event Report (LER) 05000382/2018-001-00, Failure to Enter Limiting Condition of Operation Action Statement due to Lack of Procedure Guidance Results in a Condition Prohibited by Technical Specifications (ADAMS Accession No. ML18051B502), on February 20, 2018. A licensee-identified violation associated with this LER is documented in the Inspections Results section below.

INSPECTION RESULTS

Failure to Ensure Appropriate Chemistry Controls on the Component Cooling Water Heat Exchangers Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Systems Green [H.12] - Human 71111.07 NCV 05000382/2018002-01 Performance, Closed Avoid Complacency The inspectors reviewed a self-revealed, Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, which occurred because the licensee did not prescribe procedures for preventing fouling of the component cooling water heat exchangers that were appropriate to the circumstances. Specifically, the licensee did not require in its instructions for adding biocide to the auxiliary component cooling water system that additions be coupled with running the associated auxiliary component cooling water pump or other means of ensuring that the biocide would be sufficiently circulated through the system. As a result, on February 8, 2018, component cooling water heat exchanger B failed a performance test and therefore would not maintain required design basis temperatures under all accident conditions due to biological fouling.

Description:

On February 8, 2018, while analyzing the results of Procedure PE-004-021, Component Cooling Water Heat Exchanger Performance Test, Revision 5, the licensee discovered that component cooling water heat exchanger B could not maintain its required outlet temperature. The outlet temperature of the heat exchanger is required to be maintained at less than 115 degrees Fahrenheit (F) under design basis accident conditions and the acceptance criterion for Procedure PE-004-021 is an outlet temperature of less than 114 degrees F. Testing showed that under design basis accident conditions, component cooling water heat exchanger B outlet temperatures could exceed 120 degrees F.

In reviewing the event, the licensee determined that biological fouling was the most likely cause of the degraded condition. The component cooling water heat exchanger carries component cooling water in its tube side. Biological buildup on the shell side of the heat exchanger degraded its ability to transfer heat to the auxiliary component cooling water such that it could not meet its design basis requirements. This condition has potentially existed since the summer of 2015.

The licensee uses Procedure CE-002-003, Maintaining Auxiliary Component Cooling Water Chemistry, Revision 304, to address potential biological fouling in the auxiliary component cooling water system, including the shell side of the component cooling water heat exchanger. Procedure CE-002-003 only required biocide to be added on an as needed basis based on periodic chemistry sampling. However, because the biological fouling adhered tightly to the component cooling water heat exchanger surfaces, the chemistry sampling of auxiliary component cooling water did not show increased biological levels despite biological fouling being present. Additionally, although it included instructions for adding biocide to reduce biological fouling, revisions of Procedure CE-002-003 in use prior to the February 8, 2018, failed test did not include specific instructions to ensure that the biocide additions were dispersed through the auxiliary component cooling water system. Notably, Procedure CE-002-003 did not include a requirement to couple additions with operation of the auxiliary component cooling water pumps or for alternating biocide types to address biological resistance.

The licensee completed an engineering evaluation and determined that the heat exchanger could have performed its safety function despite the degraded condition. Although potentially unable to maintain its required outlet temperature given design basis ambient air temperatures, the licensee found that given the actual ambient air temperatures over the previous 3 years, the heat exchanger would have maintained the required outlet temperatures.

Corrective Actions: The licensee performed cleaning and biocide additions to reduce fouling in the component cooling water heat exchangers A and B. Additionally, the licensee revised Procedure CE-002-003 to include detailed guidance on adding biocide to address biological fouling, including requiring additions to coincide with auxiliary component cooling water pump operation, requiring routine monthly additions rather than basing additions solely on chemistry sampling, and directions for changing biocide types to address biological resistance.

Corrective Action References: CR-WF3-2018-00785, CR-WF3-2018-00951, CR-WF3-2018-01001

Performance Assessment:

Performance Deficiency: The failure to provide procedures to address biological fouling of the component cooling water heat exchangers that were appropriate to the circumstances was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it adversely affected the equipment performance attribute of the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee did not address biological fouling to ensure the component cooling water heat exchangers could maintain the required temperatures under all design basis accident conditions.

Significance: Using Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green) because it involved the design or qualification of a mitigating structure system or component but maintained its operability.

Cross-cutting Aspect: The finding had a cross-cutting aspect in the area of human performance associated with avoiding complacency because individuals did not recognize and plan for the possibility of mistakes, latent issues, and inherent risk even while expecting successful outcomes. Specifically, the licensee did not recognize and plan for the possibility of latent issues associated with their approach to controlling biological fouling in the auxiliary component cooling water system.

Enforcement:

Violation: As required by Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances.

Contrary to the above, prior to February 8, 2018, the licensees procedure for maintaining auxiliary component cooling water chemistry, an activity affecting quality, was not appropriate to the circumstances. Specifically, Procedure CE-002-003, Maintaining Auxiliary Component Cooling Water Chemistry, did not include appropriate instructions for adding biocide to the auxiliary component cooling water system to ensure adequate dispersal. As a result, the train B component cooling water heat exchanger was unable to meet its design basis requirements due to biological fouling.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Unresolved Item 10 CFR 50.59 Evaluation Associated with Emergency 71111.17T (Open) Feedwater Logic Modification URI 05000382/2018002-02

Description:

The licensee changed the emergency feedwater logic, as described in the Updated Final Safety Analysis Report (UFSAR), Section 7.3.1.1.6, from flow control mode to level control mode during a safety injection actuation signal. To accomplish this change, the licensee had to modify the following logic system signals and setpoints: steam generator critical level, steam generator lo level, steam generator lo-lo level, safety injection actuation, control board manual control, and the steam generator lo-lo level annunciator. The NRC team questioned whether the emergency feedwater modification required additional information to determine if the 10 CFR 50.59 evaluation was adequate, or if NRC approval was needed for the change. Specifically, the NRC team questioned if the emergency feedwater logic change:

• used a method of evaluation other than what was described in the UFSAR (e.g. the use of the TRANFLOW program) or

• would result in a more than minimal increase in the likelihood of occurrence of a malfunction of a system important to safety. Specifically, because the emergency feedwater logic change introduced the potential to overcool the reactor, and substituted a previous automatic action for manual operator action, the NRC team questioned if the change and associated 50.59 evaluation addressed these concerns.

Planned Closure Actions: The NRC and the licensee are working to gather more information related to the Final Safety Analysis Report-described methods for steam generator analyses and if the change resulted in a more-than-minimal increase in risk. Specifically, the licensee plans to provide an analysis that demonstrates the emergency feedwater logic change would not result in a more than minimal increase in the likelihood of an overcooling accident.

Licensee Actions: The licensee has implemented a compensatory measure to take manual control of the emergency feedwater system during a safety injection signal such that an overcooling event will be prevented.

Corrective Action References: CR-WF3-2017-06067, CR-WF3-2017-05882, CR-WF3-2017-05173 Observation 71152 The inspectors identified a trend involving deficient Maintenance Rule functional failure screenings. Specifically, the inspectors identified that for condition reports that were classified as non-adverse in accordance with Licensee Procedure EN-LI-102, Corrective Action Program, the Maintenance Rule evaluation stated: This condition report has been classified as non-adverse by CRG [condition review group]. Based on this non-adverse classification this CR [condition report] has been auto classified not to impact any system maintenance rule function. The condition review group was the management group responsible for condition report review, categorization, and assignment of responsibilities. The same function is now performed by the performance improvement review group. The inspectors identified numerous condition reports with this Maintenance Rule screening, which impacted safety-related systems such as emergency feedwater system, containment spray system, plant protection system, component cooling water system, and 125 Vdc system. The inspectors concluded that the practice of screening condition reports in the Maintenance Rule process based on the condition report classification represented a vulnerability since once the performance improvement review group classified the condition report as non-adverse, the Maintenance Rule database did not provide it to systems engineering or the Maintenance Rule coordinator to fully assess if it constituted a maintenance rule functional failure.

The inspectors discussed this trend with licensee personnel, who captured the issue in Condition Reports CR-WF3-2018-00472 and CR-WF3-2018-02255. The licensees corrective actions included performing a review of the past 2 years in all the safety systems to ensure that condition reports categorized as non-adverse did not include a functional failure. In addition, systems engineering supervisors and the maintenance rule coordinator are now expected to review all condition reports on a daily basis to determine if non-adverse condition reports should be reclassified to adverse to ensure they are evaluated for maintenance rule functional failure.

Licensee-Identified Non-Cited Violation 71153 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Technical Specification 3.6.3, Containment Isolation Valves, requires, in part, that when an isolation valve for containment penetrations associated with an open system are inoperable, the licensee must restore the inoperable valve(s) to operable status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, isolate the affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or be in hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Contrary to the above, between December 8, 2017, and December 11, 2017, with containment isolation valves inoperable, the licensee did not restore the inoperable valves to operable status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, isolate the affected penetrations within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or place the unit in hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The licensee restored the valves to operable status on December 20, 2017, exceeding the Technical Specification 3.6.3 allowed outage time by approximately 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br />.

Significance/Severity Level: The finding was of very low safety significance (Green) because the containment isolation valves were maintained closed during the period and did not represent an actual open pathway in the physical integrity of the reactor containment.

Corrective Action Reference: CR-WF3-2018-00983

EXIT MEETINGS AND DEBRIEFS

The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

On May 17, 2018, the inspector presented the Evaluations of Changes, Tests, and Experiments inspection results to Mr. R. Gilmore, Director, Regulatory Performance Improvement, and other members of the licensee staff.

On July 12, 2018, the inspector presented the quarterly resident inspector inspection results to Mr. J. Dinelli, Site Vice President, and other members of the licensee staff.

THIRD PARTY REVIEWS Inspectors reviewed Institute of Nuclear Power Operations reports that were issued during the inspection period.

DOCUMENTS REVIEWED

71111.01 - Adverse Weather Protection

Miscellaneous Documents

Number Title Revision/Date

Summer 2018 Seasonal Reliability Plan May 1, 2018

ECM13-001 MSIV Area Flooding Analysis 0

ECM99-10 DCT Basin Ponding Analysis 0

MNQ3-5 Flooding Analysis Outside Containment 5

Procedures

Number Title Revision

EN-DC-158 Entergy Nuclear South Unit Seasonal Capability Updating 1

Process

EN-EP-309 Fatigue Management For Hurricane Response Activities 0

EN-FAP-EP-010 Severe Weather Response 6

EN-FAP-EP-012 Severe Weather Recovery 2

EN-FAP-WM-016 Seasonal Reliability 0

ENS-DC-199 Off Site Power Supply Design Requirements Nuclear Plant 9

Interface Requirements

ENS-DC-201 ENS Transmission Grid Monitoring 7

OP-901-314 Degraded Grid Conditions 3

OP-901-521 Severe Weather and Flooding 325

Condition Reports (CRs)

CR-WF3-2017-05724 CR-WF3-2017-08052 CR-WF3-2018-02538

71111.04 - Equipment Alignment

Miscellaneous Documents

Number Title Revision

G-153 Flow Diagram Feedwater, Condensate & Air Evacuation 49

Systems - Sheet 4

G-163 Flow Diagram Containment Spray & Refueling Water 43

Storage Pool

Procedures

Number Title Revision

OP-002-001 Auxiliary Component Cooling Water 311

OP-002-003 Component Cooling Water 317

OP-009-001 Containment Spray 306

OP-009-003 Emergency Feedwater System 309

Condition Reports (CRs)

CR-WF3-2018-00938 CR-WF3-2018-01550 CR-WF3-2018-01628

71111.05Fire Protection Quarterly

Miscellaneous Documents

Number Title Revision

FWPH-001 Waterford-3 S.E.S 3

Prefire Strategy

Fire Water Pump House

NS-CP-002 Waterford-3 S.E.S 2

Prefire Strategy

Condensate Polisher Building - Upper Levels

RAB1E-001 Waterford-3 S.E.S 10

Prefire Strategy

Elev. +35.00 RAB

Cable Vault

RAB3A-003 Waterford-3 S.E.S 3

Prefire Strategy

Elev. +21.00

Vestibule

RAB13-001 Waterford-3 S.E.S 7

Prefire Strategy

Elev. +21.00 RAB

Battery Room 3A

RAB19-001 Waterford-3 S.E.S 7

Prefire Strategy

Elev. +21.00 RAB (RCA)

Component Cooling Water Pump A

Condition Reports (CRs)

CR-WF3-2018-00923 CR-WF3-2018-02168 CR-WF3-2018-02526

71111.06Flood Protection Measures

Miscellaneous Documents

Number Title Revision

EC 72874 Incorporate Seismic Leakage Criteria Into Design Basis For 0

CCW

ECM05-004 Required Isolation Time to Prevent Depletion of CCW Surge 0

Tank Due to SSE

ECM97-006 Design Basis for CCW Makeup 0

ECM97-042 Design Basis Review for CCW Pumps Header Isolation 0

Valves CC-114A, CC-114B, CC-115A, CC-115B, CC-126A,

CC-126B, CC-127A, and CC-127B

ECM98-009 CCW Makeup Design Basis 1

ER-W3-2005- Stroke Times for CCW Isolation Valves 0

0430-000

MNQ3-5 Flooding Analysis Outside Containment 0

MNQ9-2 Component Cooling Water System 2

Procedures

Number Title Revision

OP-903-118 Primary Auxiliaries Quarterly IST Valves Test 44

STI-0063 CCW Non-Seismic Loop Isolation Valve Leakage Test 0

Condition Reports (CRs)

CR-WF3-2014-03301 CR-WF3-2015-00828 CR-WF3-2015-05751 CR-WF3-2016-00260

CR-WF3-2018-00983

71111.07Heat Sink Performance

Miscellaneous Documents

Number Title Revision

457000087 Component Cooling Water Heat Exchangers 65

Chemistry General Guidelines on Cooling Water Chemical Additions 0

Standing

Instruction 57

Procedures

Number Title Revision

CE-002-003 Maintaining Auxiliary Component Cooling Water Chemistry 5

CE-002-003 Maintaining Auxiliary Component Cooling Water Chemistry 305

CE-002-003 Maintaining Auxiliary Component Cooling Water Chemistry 304

Condition Reports (CRs)

CR-WF3-2018-00785 CR-WF3-2018-00951 CR-WF3-2018-01001 CR-WF3-2018-01302

CR-WF3-2018-02829

71111.11Licensed Operator Requalification Program and Licensed Operator Performance

Procedures

Number Title Revision

OP-100-010 Equipment Out of Service 315

OP-100-010 Equipment Out of Service 316

OP-100-014 Technical Specification and Technical Requirements 344

Compliance

OP-100-017 Emergency Operating Procedure Implementation Guide 5

OP-901-524 Fire In Areas Affecting Safe Shutdown 16

OP-902-000 Standard Post Trip Actions 16

OP-902-007 Steam Generator Tube Rupture Recovery Procedure 17

OP-902-008 Functional Recovery 27

OP-903-094 ESFAS Subgroup Relay Test 31

Condition Reports (CRs)

CR-WF3-2018-03667

71111.12Maintenance Effectiveness

Procedures

Number Title Revision

EN-DC-203 Maintenance Rule Program 4

EN-DC-204 Maintenance Rule Scope and Basis 4

EN-DC-205 Maintenance Rule Monitoring 6

EN-DC-206 Maintenance Rule (A)(1) Process 3

Condition Reports (CRs)

CR-WF3-2016-06499 CR-WF3-2016-07340 CR-WF3-2016-07536 CW-WF3-2017-03529

CR-WF3-2017-04589 CR-WF3-2017-04983 CR-WF3-2017-05842 CR-WF3-2017-06078

CR-WF3-2017-06386 CR-WF3-2017-06622 CR-WF3-2017-07110 CR-WF3-2017-07644

CR-WF3-2017-09550 CR-WF3-2018-00196

Work Orders

00480584 00480585

71111.13Maintenance Risk Assessments and Emergent Work Control

Miscellaneous Documents

Number Title Revision

B-424 Letdown Containment Isolation Control and Wiring Diagram 13

Procedures

Number Title Revision

EN-FAP-WM-107 Emergent Issues Process 1

EN-MA-125 Troubleshooting and Control of Maintenance Activities 22

EN-WM-104 On Line Risk Assessment 16

OI-037-000 Operations Risk Assessment Guideline 313

Condition Reports (CRs)

CR-WF3-2018-03380 CR-WF3-2018-03492

Work Orders

00379330 00379590 00395470 52689943 52689944

2747600

71111.15Operability Determinations and Functionality Assessments

Drawings

Number Title Revision

G153 Feedwater, Condensate & Air Evacuation Systems, Sheet 4 49

G160 Component Closed Cooling Water System, Sheet 1 49

Drawings

Number Title Revision

G160 Component Closed Cooling Water System, Sheet 4 17

Procedures

Number Title Revision

EN-OP-104 Operability Determination Process 15

Condition Reports (CRs)

CR-WF3-2017-06534 CR-WF3-2018-00785 CR-WF3-2018-00951 CR-WF3-2018-01829

CR-WF3-2018-02171 CR-WF3-2018-02242 CR-WF3-2018-02281 CR-WF3-2018-02298

CR-WF3-2018-02781 CR-WF3-2018-03587 CR-WF3-2018-03509

71111.17T - Evaluations of Changes, Tests and Experiments

Miscellaneous Documents

Number Title Revision

1501532 ASME Code,Section III Qualification of Pressurizer Heater 1

Sheath to Heater Sleeve Fillet Weld

CN-NCE-08-44 Waterford 3 Replacement Steam Generator TRANFLOW 1

Analysis: Emergency and Faulted Transients to Support

Emergency Feedwater System Modifications

EC-8427 Evaluation of Train B Dry Cooling Tower Air Recirculation 0

with Temporary Work Platform

EC-61746 Temporary Modification for CEA 66 RSPT 2 Temporary 0

Signal from RSPT Substitution Box

EC-64801 Emergency Feedwater (EFW) Circuitry Modification 0

(Parent)

EC-65610 Technical Requirements Manual 3.3.4 Turbine Valve Testing 0

One Time Extension

EC-67163 Common Mat Stress Analysis - Cooling Tower Area 2

EC-67815 TRM Update to Address Equipment Dependency on HVAC 0

EC-69180 Tube Clamp Installation for DCT Tube Bundle 1B at Tube 0

Location 5F

EC-70422 Incorporate LPI CALC LA170375-LR-001 into Design Basis 0

CALC A13073-C-001

Miscellaneous Documents

Number Title Revision

EC-71946 Document PAD for Design Change EC 69180 for DCT 0

Bundle NO. 1/5 F Tube Support Clamp per EN-OP-104

EC-72083 Mark Up Drawings G802C & G802F to Reflect Approval to 0

Have Less Than 1" Gap Between Grating and Containment

Wall

EC-73298 Determine Leakage Criteria for Essential Chiller Select 0

Valves

ECM10-006 Dry Cooling Tower B Airflow Reduction Limits to support 0

Steam Generator Replacement

EN-ME-SOO1-W Tube Sleeve Installations for Dry Cooling Towers 2

G707 Tornado Missile Protection Dry Cooling Towers, Sh.1 3

W3-DBD-37 Essential Chilled Water System 301

W3-DBD-38 Safety Related HVAC-Control Room 301

WF3-ME-15- Tube Sleeve Qualification for Dry Cooling Towers 0

00004

Procedures

Number Title Revision

EN-LI-100 Process Applicability Determination 21

EN-LI-101 10 CFR 50.59 Evaluations 15

OP-002-004 Chilled Water System 314

OP-500-003 Control Room Cabinet C 31

OP-901-502 Evacuation of Control Room and Subsequent Plant 34

Shutdown

Condition Reports (CRs)

CR-WF3-2017-05173 CR-WF3-2017-05761 CR-WF3-2017-05763 CR-WF3-2017-05882

CR-WF3-2017-06067 CR-WF3-2017-09164 CR-WF3-2018-01612 CR-WF3-2018-01841

71111.18Plant Modifications

Miscellaneous Documents

Number Title Revision

EC 68240 Increase Containment Spray Pump Bearing Seal Cooling by 0

CCW

Miscellaneous Documents

Number Title Revision

EC 68489 Chile EC for CC IFIS7651B Alarm Setpoint Change 0

EC-M97-028 Bearing Frame Cooling Water Flow Requirements 0

Condition Reports (CRs)

CR-WF3-2016-06113 CR-WF3-2016-06499

71111.19Post Maintenance Testing

Procedures

Number Title Revision

EN-DC-177 Control Room Habitability Program 4

OP-903-035 Containment Spray Pump Operability Check 29

OP-903-118 Primary Auxiliaries Quarterly IST Valves Test 44

OP-903-121 Safety Systems Quarterly IST Valve Tests 28

Condition Reports (CRs)

CR-WF3-2018-01857 CR-WF3-2018-02281 CR-WF3-2018-03120

Work Orders

454900 485093 500167-07 52764205 52785365

71111.22Surveillance Testing

Procedures

Number Title Revision

OI-040-000 Reactor Coolant System Leakage Monitoring 15

OP-903-006 Reactor Trip Circuit Breaker Test 13

OP-903-035 Containment Spray Pump Operability Check 29

OP-903-050 Component Cooling Water and Auxiliary Component 41

Cooling Water Pump and Valve Operability Test

Condition Reports (CRs)

CR-WF3-2018-01823 CR-WF3-2018-01845 CR-WF3-2018-02338 CR-WF3-2018-02473

CR-WF3-2018-04237

Work Orders

2807736

71114.06Drill Evaluation

Miscellaneous Documents

Number Title Date

Emergency Preparedness Drill Scenario June 20,

2018

71151Performance Indicator Verification

Miscellaneous Documents

Number Title Date

W3F1-2017- NRC Performance Indicator (PI) Data - 2nd Quarter 2017 Jul 13, 2017

0058 ROP Data

W3F1-2017- NRC Performance Indicator (PI) Data - 3rd Quarter 2017 Oct 6, 2017

0076 ROP Data

W3F1-2018- NRC Performance Indicator (PI) Data - 4th Quarter 2017 Jan 9, 2018

0004 ROP Data

W3F1-2018- NRC Performance Indicator (PI) Data - 1st Quarter 2018 Apr 12, 2018

24 ROP Data

Procedures

Number Title Revision

EN-LI-114 Regulatory Performance Indicator Process 11

71152Problem Identification and Resolution

Miscellaneous Documents

Number Title Revision/Date

EC 77747 Engineering Analysis Required by CEP-IST-4 for 0

CR-WF3-2018-02496

EC 78126 CR-WF3-2018-03279 Containment Spray Start Time 0

ECI99-001 ESF Response Time Acceptance Criteria Basis 2

ECS10-001 Waterford 3 Cycle 22 Reload Analysis Groundrules 5

ER-W3-97-0174- CCW & ACCW Flow Balance Test Acceptance Criteria May 26, 1997

00-00

UNT-006-033 Technical Specification Surveillance Frequency List 1

Procedures

Number Title Revision

CEP-IST-4 Standard on In-service Testing 308

EN-TQ-129 Planner Training Program 1

EN-TQ-129 Planner Training Program 2

OP-100-014 Technical Specification and Technical Requirements 344

Compliance

PE-004-024 CCW/ACCW System Flow Balance 306

SEP-WF3-IST-1 WF3 Inservice Testing Bases Document 7

SEP-WF3-IST-2 WF3 Inservice Testing Plan 7

Condition Reports (CRs)

CR-WF3-2017-01977 CR-WF3-2017-04390 CR-WF3-2017-05507 CR-WF3-2017-06754

CR-WF3-2017-07110 CR-WF3-2018-00472 CR-WF3-2018-02255 CR-WF3-2018-02496

CR-WF3-2018-03279 CR-WF3-2018-03308 CR-WF3-2018-03604

71153Follow-up of Events and Notices of Enforcement Discretion

Miscellaneous Documents

Number Title Date

LER 2018-001- Failure to Enter Limiting Condition of Operation Action February 20,

Statement due to Lack of Procedure Guidance Results in a 2018

Condition Prohibited by Technical Specifications

Condition Reports (CRs)

CR-WF3-2018-00983

ML18199A643

SUNSI Review ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: GMiller Yes No Publicly Available Sensitive NRC-002

OFFICE SRI:DRP/D RI:DRP/D BC:DRS/EB1 BC:DRS/EB2 BC:DRS/PSB2 BC:DRS/OB

NAME FRamirez CSpeer TFarnholtz JDrake HGepford VGaddy

SIGNATURE /RA/ GBM for /RA/ /RA/ /RA/ /RA/ /RA/ JCK for

DATE 7/17/18 7/17/18 07/17/2018 7/17/18 7/17/18 7/17/18

OFFICE TL:DRS/IPAT SPE:DRP/D BC:DRP/D

NAME GGeorge JDixon GMiller

SIGNATURE /RA/ /RA/ /RA/

DATE 7/18/18 7/17/18 7/18/18