IR 05000382/2019003

Integrated Inspection Report 05000382/2019003

ML19310G722
Person / Time
Site:	Waterford
Issue date:	11/05/2019
From:	John Dixon NRC/RGN-IV/DRP
To:	Vazquez S Entergy Operations
References
IR 2019003
Download: ML19310G722 (37)

Text

{{#Wiki_filter:ber 5, 2019

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 - INTEGRATED INSPECTION REPORT 05000382/2019003

Dear Mr. Vazquez:

On September 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Waterford Steam Electric Station, Unit 3. On October 10, 2019, 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.

Two findings of very low safety significance (Green) are documented in this report. One of these findings involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

A licensee-identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as an NCV consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or significance or severity of the violation documented in this inspection report, 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 Waterford.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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 Waterford Steam Electric 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/ John L. Dixon, Jr., Chief Reactor Projects Branch D Division of Reactor Projects Docket No. 05000382 License No. NPF-38

Enclosure:

As stated

Inspection Report

Docket Number: 05000382 License Number: NPF-38 Report Number: 05000382/2019003 Enterprise Identifier: I-2019-003-0002 Licensee: Entergy Operations, Inc.

Facility: Waterford Steam Electric Station, Unit 3 Location: Killona, LA 70057 Inspection Dates: July 1, 2019 to September 30, 2019 Inspectors: B. Baca, Health Physicist L. Carson, Senior Health Physicist K. Clayton, Senior Operations Engineer M. Doyle, Operations Engineer N. Greene, Senior Health Physicist S. Makor, Reactor Inspector J. O'Donnell, Health Physicist F. Ramirez Munoz, Senior Resident Inspector C. Speer, Resident Inspector J. Vera, Resident Inspector Approved By: John L. Dixon, Jr., Chief Reactor Projects 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 licensee-identified non-cited violation is documented in report section: 71153.

List of Findings and Violations Failure to Periodically Calibrate Radiation Monitoring Equipment Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.3] - Change 71124.05 Radiation Safety NCV 05000382/2019003-01 Management Open/Closed The inspectors identified a Green non-cited violation (NCV) of 10 CFR 20.1501(c) for failure to periodically calibrate area radiation monitoring equipment used to perform dose rate measurements. Specifically, on or around January 18, 2012, the licensee began changing the periodic calibrations of area radiation monitors without verifying the instruments were in calibration.

Failure to Implement Procedures for Main Generator Exciter Maintenance Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.5] - Work 71153 FIN 05000382/2019003-03 Management Open The inspectors reviewed a self-revealed Green finding because the licensee did not follow procedure requirements when performing periodic maintenance on the main generator exciter. Specifically, the licensee did not implement the preventative maintenance steps required by Procedure ME-004-003, Main Exciter, Revisions 300 through 303, to perform inspection, cleaning, and testing of the main exciter during refueling outages.

Additional Tracking Items Type Issue Number Title Report Status Section URI 05000382/2019003-02 Quantity of Radioactive 71124.08 Open Material Shipment Error LER 05000382/2019-004-00 Boron Dilution Alarm 71153 Closed (Startup Channel High Neutron Flux) Inoperable Resulting in Operation or Condition Prohibited by Technical Specifications.

LER 05000382/2019-005-00 Automatic Reactor SCRAM 71153 Discussed due to Steam Generator 1 High Level Resulting from a

Main Turbine Trip and Subsequent Reactor Power Cutback due to Failed Diode Modules within the Main Exciter

PLANT STATUS

The Waterford Steam Electric Station, Unit 3, began the inspection period at 100 percent power.

On July 31, 2019, operators shutdown the reactor in accordance with Technical Specification 3.0.3 due to excessive leakage in the chemical and volume control system, due to a crack in a drain line weld. On August 7, 2019, operators restarted the reactor. The unit achieved full power on August 8, 2019, and maintained full power for the remainder of the 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 External Flooding Sample (IP Section 03.04)

(1) The inspectors evaluated readiness to cope with external flooding for the following areas on July 11, 2019:

• Dry cooling towers
• Reactor auxiliary building
• Turbine building

71111.04Q - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)

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

(1) Auxiliary feedwater during a period of increased risk significance due to plant shutdown lineup on August 2, 2019

(2) Emergency feedwater train B with train A inoperable for maintenance on August 3, 2019

(3) Auxiliary component cooling water train A with train B inoperable for maintenance on August 22, 2019

(4) Emergency diesel generator train A with train B inoperable for maintenance on September 16, 2019

71111.05A - Fire Protection (Annual) Annual Inspection (IP Section 03.02)

(1) The inspectors evaluated fire brigade performance during an unannounced drill on September 4, 2019

71111.05Q - Fire Protection Quarterly Inspection (IP Section 03.01)

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

(1) Fire area RAB 8C, switchgear room AB, on July 30, 2019

(2) Fire area ROOF W, main steam isolation valve A room, on July 30, 2019

(3) Fire area RAB 8B, switchgear room B, on August 23, 2019

(4) Fire area RAB 13, battery room 3A, on September 3, 2019

(5) Fire area RAB 1A, B, C, D, control room, on September 30, 2019

71111.06 - Flood Protection Measures Inspection Activities - Internal Flooding (IP Section 02.02a.)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Flood zone 14, +46 heating, ventilation and air conditioning (HVAC) and chiller room, on July 25, 2019

71111.07A - Heat Sink Performance Annual Review (IP Section 02.01)

The inspectors evaluated readiness and performance of:

(1) Component cooling water heat exchanger A on September 9, 2019

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Requalification Program (IP Section 03.04)

(1) Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examinations.

Annual Requalification Operating Tests The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.

Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.

Requalification Examination Security The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.

Remedial Training and Re-examinations The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.

Operator License Conditions The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.

Control Room Simulator The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant and for meeting the requirements contained in 10 CFR 55.46.

Problem Identification and Resolution The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1) The inspectors observed and evaluated licensed operator performance in the control room during a period of heightened activity due to an unplanned plant shutdown and cooldown in accordance with Technical Specification 3.0.3 due to excessive leakage in the chemical and volume control system, due to a crack in a drain line weld on July 31, 2019.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the simulator during an evaluated examination on August 20, 2019.

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness Inspection (IP Section 02.01)

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

(1) Main generator and 25 kV distribution system on September 18, 2019

(2) Essential chillers on September 30, 2019

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

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

(1) Emergent work review associated with control element assembly 43 control system failure on July 17, 2019

(2) Risk assessment associated with planned yellow risk due to emergency feedwater pump B maintenance on July 29, 2019

(3) Emergent work review associated with elevated leakage in the chemical and volume control system on July 31, 2019

(4) Risk assessment and emergent work review associated with control element drive motor control system undervoltage relay failure on August 21, 2019

(5) Emergent work review associated with the failure of the auxiliary component cooling water header A component cooling water heat exchanger outlet temperature control valve on September 6, 2019

71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 02.02)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Operability determination associated with the flow path to the charging pump suction header due to a leak near the volume control tank outlet header drain to the equipment drain tank sump valve on July 10, 2019

(2) Operability determination associated with main generator lockout relays not actuating following a manual turbine trip on August 6, 2019

(3) Operability determination associated with the essential chiller B hot gas bypass valve failing to open on September 27, 2019

==71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample) The inspectors evaluated the following temporary or permanent modifications:

(1) Auxiliary component cooling water wet tower basin level setpoint change on July 17, 2019

71111.19 - Post-Maintenance Testing Post-Maintenance Test Sample (IP Section 03.01)

[[IP sample::=

=IP 71111.18|count=5}}

The inspectors evaluated the following post maintenance tests:

(1) Control element assembly subgroup 10 following the replacement of associated control element drive system electrical components on July 22, 2019

(2) Emergency feedwater header A to steam generator 1 backup flow control valve, following valve repacking, on August 4, 2019

(3) Control element drive mechanism control system cabinet 3 undervoltage relay following relay replacement on August 22, 2019

(4) Safety related switchgear 31A following undervoltage relay calibration on September 11, 2019

(5) Emergency diesel generator B following a system maintenance outage on September 23, 2019

71111.20 - Refueling and Other Outage Activities Refueling/Other Outage Sample (IP Section 03.01)

(1) The inspectors evaluated the licensee's performance during a forced outage to repair failed piping in the chemical and volume control system from July 31 to August 8, 2019

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Surveillance Tests (other) (IP Section 03.01)

(1) Auxiliary component cooling water pump A Baker test on July 11, 2019

(2) Shutdown cooling heat exchanger A temperature loop calibration on July 18, 2019

(3) Essential chillers A and B component cooling water common header inlet and outlet isolation valves on August 19, 2019

(4) High pressure safety injection pump AB testing on September 17, 2019

Inservice Testing (IP Section 03.01) (1 Sample)

(1) Condensate makeup train A quarterly valve testing on July 16, 2019

71114.06 - Drill Evaluation Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

(1) The inspectors evaluated an emergency preparedness drill on September 25,

71124.05 - Radiation Monitoring Instrumentation Walk Downs and Observations (IP Section 02.01)

The inspectors evaluated radiation monitoring instrumentation during plant walkdowns.

(1) The inspectors reviewed the following:

Portable Survey Instruments

• AMP 100 (CHP-ARM014)
• AMS-4 (CHP-RD-261)
• LM-177 (CHP-CR-148, CHP-CR-186, CHP-CR-195)
• Ludlum 9-3 (CHP-DR-286, HP-DR-562, CHP-DR-661)
• RO-20 (CHP-DR-119)
• SAC-4 (HP-DS-066)
• Wide range telepole (CHP-TEL034, CHP-TEL039, CHP-TEL138)

Source Check Demonstration

• AMS4 (CHP-AMSD-0214)
• ARGOS 5AB (1410-186)
• Cronos 4 (1011-061)
• MGP Small Tool Monitor (89-0527)
• PM7 (394, 395)

Area Radiation Monitors and Continuous Air Monitors

• Area Radiation Monitors: ARMIR5103, ARMIR5014, ARMIR5015, ARMIR5018, ARMIR5208
• Fuel Handling Building Normal Ventilation Radiation Monitor Loop
• Containment Particulate, Iodine, and Gaseous Monitor Personnel Contamination Monitors, Portal Monitors and Small Article Monitors
• ARGOS 5AB (1410-86, 1412-364)
• Cronos 4 (1011-061, 1412-364)
• Fastscan (Dosimetry Office, West Side Access)
• GEM 5 (HP-DS-080, HP-DS-095)
• PM7 (394, 395)

Calibration and Testing Program (IP Section 02.02) (1 Sample)

The inspectors evaluated the calibration and testing program implementation.

(1) The inspectors reviewed the following:

Alarm Setpoint and Calibration Method Check of Personnel Contamination Monitors, Portal Monitors and Small Article Monitors

• ARGOS 5AB (1410-186)
• Cronos4 (1011-061)
• MGP Small Tool Monitor (89-0527)
• PM7 (394, 395)

Failure to Meet Calibration or Source Check Acceptance Criteria

• GEM 5 (1410-190)
• Ludlum 9-3 (HP-DR-559, HP-DR-562)
• RO20 (CHP-DR-163)
• Telepole (CHP-TEL126, CHP-TEL135, CHP-TEL137)

71124.06 - Radioactive Gaseous and Liquid Effluent Treatment Walk Downs and Observations (IP Section 02.01)

The inspectors walked down the following gaseous and liquid radioactive effluent monitoring and filtered ventilation systems to assess the material condition and verify proper alignment according to plant design:

   (1)

• Fuel Handling Building Exhaust Gaseous Radiation Monitor (RE-5107)
• Plant Stack RAB Ventilation Gaseous Radiation Monitor (RE-0100)
• Dry Cooling Tower Sump 1 Liquid Radiation Monitor (RE-6665)
• Turbine Building Industrial Waste Tank Liquid Radiation Monitor (RE-6778)
• Component Cooling Water Liquid Radiation Monitor (RE-7050)
• Circwater Discharge Liquid Radiation Monitor (RE-1900)
• Control Room Emergency Filtration Unit
• Controlled Ventilation Areas Filter Unit Calibration and Testing Program (Process & Effluent Monitors) (IP Section 02.02) (1 Sample)

The inspectors reviewed the following gaseous and liquid effluent monitor instrument calibrations and tests:

(1) Gaseous Effluent Radiation Monitors

• WO 52776602, RE-0002, Main Condenser Evacuation System (MCES),

March 19, 2019

• WO 52798848, RE-0100.1, RAB Ventilation System / Plant Stack A, June 3, 2019
• WO 52730813, RE-0648, Gaseous Waste Management System (GWMS),

July 7, 2018

• WO 52748891, RE-5107A, Fuel Handling Building Ventilation System A, December 3, 2018
• WO 52719287, RE-5107B, Fuel Handling Building Ventilation System B, March 20, 2018 Liquid Effluent Radiation Monitors
• WO 52717425, RE-7050B, Component Cooling Water Blowdown, March 12, 2018
• WO 52734471, RE-6776, Dry Cooling Tower Sump B, June 21, 2018
• WO 52773476, RE-6778, Turbine Building Industrial Waste Sump, May 6, 2019
• WO 52721495, RE-1900, Circulating Water Discharge, April 2, 2018

Sampling and Analysis (IP Section 02.03) (1 Sample)

The inspectors reviewed the following sampling and analysis:

(1) Radioactive Effluent Sampling and Analysis Activities

• Fuel Handling Building Radiation Monitor A and B Filter Changeout, September 17, 2019
• Fuel Handling Building Radiation Monitor B Tritium Sample, September 17, 2019
• Plant Stack RAB Ventilation Filter Changeout, September 17, 2019
• Dry Cooling Tower Sump 2 Liquid Sample, September 18, 2019 Effluent Discharges
• The inspectors were unable to observe any active liquid or gaseous discharge activities, but reviewed numerous permits.

Instrumentation and Equipment (IP Section 02.04) (1 Sample)

The inspectors reviewed the following radioactive effluent discharge system surveillance test results:

   (1)

• WO 52716247, HVC B - Control Room Emergency Filtration Unit Charcoal Sampling, February 14, 2018
• WO 52716248, HVC B - Control Room Emergency Filtration Unit In-Place Charcoal Testing, February 14, 2018
• WO 52714811, CVAS B - Controlled Ventilation Areas Filtration Unit In-Place Charcoal Testing, March 15, 2018
• WO 52728264, SBV A - Shield Building Ventilation Unit Charcoal Sampling, June 4, 2018
• WO 52767953, CVAS A - Controlled Ventilation Areas Filtration Unit In-Place Charcoal Testing, January 11, 2019
• WO 52795776, HVC A - Control Room Emergency Filtration Unit In-Place Charcoal Testing, July 9, 2019

Dose Calculations (IP Section 02.05) (1 Sample)

The inspectors reviewed the following to asses public dose:

(1) Gaseous Discharge Permits

• W3GB2017-151
• W3GB2018-038
• W3GB2019-017
• W3GC2018-063
• W3GC2018-150
• W3GC2019-020 Liquid Discharge Permits
• W3LB2017-269
• W3LB2018-078
• W3LB2019-023
• W3LC2017-267
• W3LC2018-242
• W3LC2019-016 Annual Radiological Effluent Release Reports
• 2017 Annual Radioactive Effluent Release Report
• 2018 Annual Radioactive Effluent Release Report Abnormal Gaseous or Liquid Tank Discharges
• None occurred

71124.07 - Radiological Environmental Monitoring Program Site Inspection (IP Section 02.01)

The inspectors evaluated the radiological environmental monitoring program implementation.

(1) The inspectors reviewed the following:

Walkdowns, Calibrations, and Maintenance Record Review Air Samplers

• APP-1
• APQ-1
• APF-1
• APE-26/30 TLDs
• P-1
• Q-1
• R-1
• E-1
• M-1 Environmental Sample Collections and Preparation Observation
• SWK-1
• SWE-5
• SWP-7 Licensee Actions in Response to Missed Sample, Inoperable Sampler, Lost TLD or Anomalous Measurement
• For both 2017 and 2018, milk was unavailable at the indicator locations, so broadleaf vegetation was collected as a surrogate.
• In July 2019, air sample pump not running at full capacity, so pump was replaced.
• In July 2019, the G-8 and K1 thermoluminescent dosimeters (TLD) were missing and replaced with new TLDs.

Sampling Program for the Potential of Licensed Material Entering Groundwater

• Condensate Storage Tank
• Old Steam Generator Storage Facility
• Spent Fuel Pool Groundwater Protection Initiative (GPI) Implementation (IP Section 02.02) (1 Sample)

(1) The inspectors evaluated the licensees voluntary groundwater protection initiative.

No additional observations were identified.

71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation Radioactive Material Storage (IP Section 02.01)

The inspectors evaluated radioactive material storage.

(1) The inspectors toured the following areas:

• Spent Fuel Pool
• Cask Storage Pit
• Low Level Waste Storage Facility
• Old Steam Generator Mausoleum The inspectors performed a container check (e.g., swelling, leakage and deformation)on the following containers:
• Radwaste and Radioactive Material Containers in the Low Level Waste Storage Facility
• Spent Fuel Pool Container Inventory
• Cask Storage Pit Container Inventory Radioactive Waste System Walkdown (IP Section 02.02) (1 Sample)

The inspectors evaluated the following radioactive waste processing systems [and processes] during plant walkdowns:

(1) Liquid or Solid Radioactive Waste Processing Systems

• Spent Fuel Pool
• Cask Storage Pit
• Low Level Waste Storage Facility
• Old Steam Generator Mausoleum Radioactive Waste Resin and/or Sludge Discharges Processes
• There were no current or resin and sludge discharge processes being conducted this inspection.

Waste Characterization and Classification (IP Section 02.03) (1 Sample) The inspectors evaluated the radioactive waste characterization and classification for the following waste streams:

  (1)

• Spent Fuel Pool Operations
• Storage of Spent Tri-Nuclear Filters
• Dry Active Waste
• Spent Resin Transfers

Shipment Preparation (IP Section 02.04) (2 Samples)

The inspectors evaluated [and observed] the following radioactive material shipment preparation processes:

(1) There were no shipments being prepared for transit during this inspection period. However, the details and content of the following spent resin shipment to the licensees waste processor were reviewed:

• 18-1013, Rx Drain Tank Sludge to Bear Creek
• 18-1020, RWM Resin to Bear Creek
• 19-1015, RWM Resin LSA to Bear Creek
• 19-1019, LWM Resin LSA to Bear Creek

Shipping Records (IP Section 02.05) (1 Sample)

The inspectors evaluated the following non-excepted package shipment records:

  (1)

• ACME Shipment to UniTech Services ORSC
• 18-3002, Detector ARM RD

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below: MS08: Heat Removal Systems (IP Section 02.07) ===

(1) July 1, 2018, through June 30, 2019 MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)

(1) July 1, 2018, through June 30, 2019 MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)

(1) July 1, 2018, through June 30, 2019

71152 - Problem Identification and Resolution Semiannual Trend Review (IP Section 02.02)

(1) 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 and associated minor violation related to the licensees treatment of repetitive issues with subgroup 10 of the control element drive mechanism control system documented in the Inspection Results section of this report.

71153 - Follow-up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000382/2019-004-00, Boron Dilution Alarm (Startup Channel High Neutron Flux) Inoperable Resulting in Operation or Condition Prohibited by Technical Specifications (ADAMS Accession: ML19129A439). The inspectors documented a licensee identified violation associated with this LER in the inspection results section of this report.

(2) LER 05000382/2019-005-00, Automatic Reactor Scram due to Steam Generator 1 High Level Resulting from a Main Turbine Trip and Subsequent Reactor Power Cutback due to Failed Diode Modules within the Main Exciter (ADAMS Accession:

ML19196A346). The circumstances surrounding this LER are documented in the Inspection Results section of this report.

INSPECTION RESULTS

Failure to Periodically Calibrate Radiation Monitoring Equipment Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.3] - Change 71124.05 Radiation Safety NCV 05000382/2019003-01 Management Open/Closed The inspectors identified a Green NCV of 10 CFR 20.1501(c) for failure to periodically calibrate area radiation monitoring equipment used to perform dose rate measurements.

Specifically, on or around January 18, 2012, the licensee began changing the periodic calibrations of area radiation monitors without verifying the instruments were in calibration.

Description:

During a review of calibration records for four area radiation monitors (ARMIR5013, ARMIR5014, ARMIR5015 and ARMIR5018), the inspectors identified the monitors last had a detector calibration on November 18, 2009, November 13, 2009, October 28, 2009, and November 19, 2009, respectively. Upon further review, the inspectors identified that on January 18, 2012, the licensee initiated an Action Request (AR 133414) to increase the radiation detector calibration frequency for these area radiation monitors from 2R (three years) to 4R (six years), where R represents a refueling cycle of 18 months. The licensee again extended the calibration frequency of the radiation detectors another time from 4R to 6R (nine years): AR 195165 dated November 18, 2014, for ARMIR5013 and ARMIR5014; AR 213067, dated March 24, 2015, for ARMIR5015; and AR 267979, dated February 6, 2017, for ARMIR5018. For each of the frequency extensions, the licensee did not calibrate nor verify the calibration was acceptable before extending the calibration frequency.

These four area radiation monitors are listed in the licensees Final Safety Analysis Report (FSAR), Chapter 12, Table 12.3-2, and are used, in part, to

(1) measure ambient gamma radiation and to indicate to operations personnel the ambient gamma radiation in specific areas of the plant;

(2) annunciate and warn of abnormal radiation levels in specific areas of the plant;

(3) provide base data in controlling access of personnel to radiation areas;

(4) warn of uncontrolled or inadvertent movement of radioactive material in the plant;

(5) provide local indication and alarms at key points where a substantial change in radiation levels might be of immediate importance to personnel frequenting the area; and

(6) furnish information for making radiation surveys. Additionally, a specific note for these monitors in Table 12.3-2 of the FSAR points out these monitors are used by Radiation Protection during shutdown for personnel protection.

The inspectors determined the preventative maintenance program, as described in licensee Procedure EN-DC-324, Preventative Maintenance Program, Revision 22, does not prescriptively include the involvement of radiation protection within its program or process. By not including a member from the Radiation Protection organization during the calibration frequency change process for these four area radiation monitors, the licensee personnel implementing the changes failed to fully understand the area radiation monitor functions, as described in the FSAR, and how they related to Title 10 of the Code of Federal Regulations (10 CFR) Part 20, Standards for Protection Against Radiation, Subpart F, Surveys and Monitoring.

Corrective Actions: The licensee entered the issue in the corrective action program to re-evaluate and document an adequate basis for the calibration frequency change of monitors ARMIR5013, ARMIR5014, ARMIR5015, and ARMIR5018.

Corrective Action References: Condition Report CR-WF3-2019-07366

Performance Assessment:

Performance Deficiency: The failure to periodically calibrate area radiation monitoring instruments used to evaluate dose rate measurements as required by 10 CFR Part 20 was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the plant facilities/equipment and instrumentation attribute of the Occupational Radiation Safety Cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation.

Specifically, the licensee failed to calibrate or verify the calibration of four area radiation monitors prior to extending their calibration frequency. As a result, the failure to calibrate or verify the calibration of the four area radiation monitors impacts the licensees ability to ensure accurate radiation measurements.

Significance: The inspectors assessed the significance of the finding using Appendix C, Occupational Radiation Safety SDP. The finding was:

(1) not related to as low as is reasonably achievable planning,

(2) did not involve an overexposure or

(3) did not involve a substantial potential for overexposure, and

(4) the ability to assess dose was not compromised. Therefore, the inspectors determined the finding to be of very low safety significance (Green).

Cross-Cutting Aspect: H.3 - Change Management: Leaders use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority.

The finding had a cross-cutting aspect in the area of human performance associated with change management because the licensees change process did not identify that the instrument calibration requirements of 10 CFR Part 20 were applicable to area radiation monitors. Specifically, the change process did not involve an adequate systematic process to include members of the radiation protection organization to ensure compliance of 10 CFR Part 20 were maintained. Although these changes were made effective in 2012, there were recent opportunities for the licensee to evaluate the changes and/or ensure the affected monitors were appropriately calibrated due to multiple condition reports reviewed relative to the performance of these monitors.

Enforcement:

Violation: Title 10 CFR 20.1501(c) requires, in part, the licensee ensure that instruments used for quantitative radiation measurements (e.g., dose rate and effluent monitoring) are calibrated periodically for the radiation measured.

Contrary to the above, on or around January 18, 2012, the licensee failed to ensure that instruments used for quantitative radiation measurements (e.g., dose rate and effluent monitoring) are calibrated periodically for the radiation measured. Specifically, the licensee began changing the periodic calibrations of area radiation monitors without verifying the instruments were currently calibrated and may be adequately used for dose rate measurements of plant areas.

Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.

Quantity of Radioactive Material Shipment Error Unresolved Item Unresolved Item 71124.08 (Open) URI 05000382/2019003-02

Description:

While reviewing the circumstances associated with a solid radwaste/radioactive material (SRW/RAM) transportation event that was identified on May 1, 2019, the inspectors identified several issues of concern related to compliance with certain regulatory requirements, such as, 10 CFR Part 37 and 10 CFR 71.5. The inspectors identified that during a period from April 2-17, 2019, the licensee unknowingly mischaracterized, relocated, prepared, and shipped offsite Category 2 radioactive material quantities of concern (RAMQC). On April 17, 2019, the licensee sent a radioactive waste shipment (19-1015) to a waste processor in Tennessee. The shipment left the site with inaccurate information relative to the total weight and radioactivity amounts on the waste manifest shipping papers. The waste manifest (NRC Forms 540 and 541) accompanying the shipment indicated that shipment 19-1015 contained a total of 8.32 Curies; however, it actually contained 79.2 Curies.

The licensee became aware of the problem with this shipment because their waste processor questioned the net weight of the shipment upon its arrival at their facility. On May 1, 2019, Energy Solutions, located in Oak Ridge, Tennessee, received a shipment of spent resin from Waterford, Unit 3, for processing. The weight of the container was determined to be significantly different from the weight listed on the manifest. Specifically, the manifest indicated the container weighed approximately 742 lbs. When Energy Solutions weighed the container upon receipt, it weighed 6,550 lbs. Waterford, Unit 3, was notified of the inaccuracy of the weight in the manifest, and after revising the weight-based calculated activities for the radionuclides, the licensee provided a revised manifest to Energy Solutions. The original manifest indicated a total package activity of 8.2 Ci, of which 2.1 Ci was Co-60. The revised and corrected manifest specified a total package activity of 72.9 Ci, including 18.7 Ci of Co-60. This radioactivity amount exceeded the Category 2 limits (8.2 Ci) for security concerns under 10 CFR Part 37. Additionally, the licensee had stored, prepared, and shipped offsite RAMQC into the public domain which appeared to be in non-compliance with 10 CFR 71.5 in the implementation of DOT regulations 49 CFR 172.203(d)(3), Subpart C and 49 CFR 172.800 and 802, Subpart I.

These issues of concern require additional information and review to determine whether the preparation and shipment of RAMQC constituted violations of NRC requirements.

Consequently, we are considering this matter as an Unresolved Item (URI).

Planned Closure Actions: The NRC inspectors plan to continue their review of documents provided by the licensee, as they are made available. This review will be a comprehensive assessment of all associated violations and/or findings related to this shipping occurrence of incorrectly calculating the weighted-activities of radionuclides and improperly characterizing the shipment.

Licensee Actions: The licensee placed this matter into their corrective action program for review. The inspectors did not perceive any immediate safety or security concerns.

Corrective Action References: CR-WF3-2019-04477, CR-WF3-2019-07307, CR-WF3-2019-07312 Observation: Semi-Annual Trend Review Associated with the Control Element 71152 Drive Mechanism Control System The inspectors identified an adverse trend involving operability reviews for repetitive failures involving subgroup 10 of the control element drive mechanism control system. From April 29, 2019, through September 9, 2019, the licensee initiated 18 condition reports involving apparent repetitive failures of control element assemblies in subgroup 10 that caused the assemblies to become immovable, but remain trippable. Each condition report affected at least one of the four control element assemblies in subgroup 10. In each instance, the licensee declared the affected rods inoperable and took the actions required by Technical Specification 3.1.3.1, Moveable Control Assemblies.

After six of the condition reports were generated, the inspectors noted that for each identified condition, the licensee reviewed the impact of the condition on the individually affected control element assemblies and made the appropriate operability determination, but the licensee did not review the impact of the aggregate conditions on the operability of subgroup 10 overall.

The licensee addressed the operability of equipment using licensee procedure EN-OP-104, Operability Determination Process, Revision 16. Section 8.10.11 of EN-OP-104 specifically addresses reduced reliability as a degraded or nonconforming condition. Section 8.10.11 requires that the licensee review repetitive failures and, if reliability has been reduced, to consider the equipment degraded or non-conforming and assess its operability.

The inspectors questioned the licensee regarding the operability of subgroup 10 given the guidance in Section 8.10.11 of EN-OP-104. Due to inspector questioning, the licensee reclassified subgroup 10 as operable but degraded or non-conforming due to reduced reliability in condition report CR-WF3-2019-05729. The licensee concluded that subgroup 10 was still capable of performing its safety function to insert control element assemblies into the reactor core.

The inspectors determined that the licensees failure to address the impact of reduced reliability on the operability of subgroup 10 as required by EN-OP-104 was a minor violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings. The licensees cause evaluation for the underlying conditions leading to the repetitive failures of subgroup 10 is still ongoing. The inspectors will document any findings related to the underlying condition in a future inspection report.

Failure to Implement Procedures for Main Generator Exciter Maintenance Cornerstone Significance Cross-Cutting Report Aspect Section Initiating Events Green [H.5] - Work 71153 FIN 05000382/2019003-03 Management Open The inspectors reviewed a self-revealed Green finding because the licensee did not follow procedure requirements when performing periodic maintenance on the main generator exciter. Specifically, the licensee did not implement the preventative maintenance steps required by procedure ME-004-003, Main Exciter, Revisions 300 through 303, to perform inspection, cleaning, and testing of the main exciter during refueling outages.

Description:

On May 16, 2019, the Waterford, Unit 3, main generator automatically tripped as designed following a loss of excitation field. As part of their troubleshooting, the licensee disassembled the main exciter and discovered that the rotating rectifier had 13 of the 72 outboard fuses failed, 12 of the 36 outboard diodes failed, 2 additional outboard diodes arced and shorted between phases, and one of the 36 inboard diodes failed. The design of the rotating rectifier is to operate at full capacity with up to two diodes per phase out of service. In addition to the component failures, the licensee discovered excessive dirt and debris buildup in the interior of the rotating rectifier.

The licensee established a preventative maintenance program for the main exciter that required the main exciter to be sent offsite to a specialist vendor for major refurbishment every 8 years. This was last performed as part of the refueling outage in 2012. The licensees preventative maintenance program also required minor refurbishment be performed on the main exciter during refueling outages where major refurbishment was not performed. The licensee accomplished this minor refurbishment using licensee Procedure ME-004-003, Main Exciter. Procedure ME-004-003 provides instructions for maintenance and testing of the main exciter, including instructions to ensure electrical and mechanical integrity of the rotating rectifier and its components. The licensee scheduled the minor refurbishment tasks using procedure ME-004-003 during refueling outages in 2014, 2015, 2017, and 2019.

In their review of the past maintenance on the main generator exciter, the licensee found that large portions of procedure ME-004-003 were not performed. During refueling outages 19, 20, 21, and 22, electrical maintenance personnel only inspected the rectifier wheel fuses and cleaned accessible portions of the exciter. Since the main generator exciter was not fully disassembled when Procedure ME-004-003 was performed during those refueling outages, the steps to clean, inspect, and test the internal components of the main exciter were marked as not applicable and not performed. In each instance, electrical maintenance personnel documented the concurrence of systems engineering personnel to not perform the applicable portions of Procedure ME-004-003.

Licensee Procedure EN-HU-106, Procedure and Work Instruction Use and Adherence, Revisions 3 through 7, is used to control when personnel may mark procedural steps as not applicable. Section 7.1.3 of Procedure EN-HU-106 only allows the use of not applicable when doing so does not change the intent of the steps or sections.

Prior to performing Procedure ME-004-003, electrical maintenance personnel requested guidance from systems engineering personnel for which portions were required. Systems engineering personnel advised that the scope of work should be based off the previous refueling outages. System engineering personnel did not confirm the adequacy of the scope of maintenance performed during previous outages. Additionally, electrical maintenance personnel did not ensure that marking sections of Procedure ME-004-003 as not applicable did not change the intent of the steps or sections.

Corrective Actions: The licensees immediate corrective action was to disassemble and clean the main generator exciter, and to either repair or replace the failed components associated with the rotating rectifier. Long term corrective actions include revising the preventative maintenance strategy and procedures to ensure the correct scope of maintenance is included in both the 8-year major and every refueling cycle minor refurbishments.

Corrective Action References: CR-WF3-2019-04788

Performance Assessment:

Performance Deficiency: The failure to implement the requirements of Procedure ME-004-003 when required by the preventative maintenance program was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the equipment performance attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure to perform maintenance in accordance with Procedure ME-004-003 to ensure the integrity and cleanliness of internal components of the main generator exciter resulted in an electrical fault that caused an automatic trip of the main turbine and generator.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using IMC 0609, Appendix A, Exhibit 1, Initiating Events Screening Questions, the inspectors determined the finding to be of very low safety significance (Green) because the finding did not cause a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition.

Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, the licensee did not implement the process of controlling and executing work activities controlled by Procedure EN-HU-104 when personnel implementing Procedure ME-004-003 regularly marked large sections as not applicable which changed the intent of the sections.

Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

LER Automatic Reactor SCRAM due to Steam Generator 1 71153 (Discussed) High Level Resulting from a Main Turbine Trip and Subsequent Reactor Power Cutback due to Failed Diode Modules within the Main Exciter LER 05000382/2019-005-00

Description:

On May 16, 2019, the Waterford main generator automatically tripped as designed following a loss of excitation field. Following the trip, the reactor power cutback system actuated as designed to reduce reactor power. Following the reactor power cutback, the reactor automatically tripped due to high feedwater level in steam generator 1. The inspectors documented a Green finding in this report related to the cause of the automatic main generator trip. The cause evaluation of the subsequent automatic reactor trip due to high steam generator level is still ongoing and will be documented in a later inspection report.

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 an NCV, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Technical Specification 3.1.2.9, Boron Dilution, requires, in part, that with one boron dilution alarm inoperable and the primary makeup water flow path to the reactor coolant system not isolated, determine reactor coolant system boron concentration within one hour. Contrary to the above, on March 10, 2019, with one boron dilution alarm inoperable and the primary makeup water flow path to the reactor coolant system not isolated, the licensee did not determine reactor coolant system boron concentration within one hour.

On March 10, 2019, startup channel 1, one of the boron dilution alarms, was de-energized and rendered inoperable during the performance of surveillance testing at approximately 3:30 p.m. on March 10, 2019. The licensee identified that startup channel 1 was de-energized while taking Technical Specification logs and re-energized startup channel 1 on March 10, 2019, at 11:18 p.m., exceeding the Technical Specification 3.1.2.9 allowed outage time by approximately 7 hours.

Significance/Severity: The finding was of very low safety significance, Green, in accordance with Inspection Manual Chapter 0609, Appendix G, Attachment 1, Exhibit 3, Mitigating Systems Screening Questions because the loss of the boron dilution alarms did not represent the actual loss of a safety function.

Corrective Action References: CR-WF3-2019-03161

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On September 19, 2019, the inspectors presented the Public Radiation Safety exit meeting inspection results to Mr. B. Lanka, Acting Site Vice President, and other members of the licensee staff.
• On September 24, 2019, the inspectors presented the 2019003 Biennial Requalification telephonic exit debrief inspection results to Mr. V. Ford, Operations Training Superintendent, and other members of the licensee staff.
• On October 10, 2019, the inspectors presented the integrated inspection results to Mr. S. Vazquez, Site Vice President, and other members of the licensee staff.
• On October 17, 2019, the inspectors presented the Final Exit Meeting for Radiation Safety Inspection results to Mr. S. Vazquez, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Procedure Date 71111.01 Calculations ECM15-004 Waterford FLEX Internal Flooding Calculation 0 MNQ3-5 Flooding Analysis Outside Containment 6 Corrective Action CR-WF3-YYYY- 2018-06958, 2019-03900, 2019-05201 Documents NNNN Procedures OP-901-521 Severe Weather and Flooding 71111.04Q Corrective Action CR-WF3-YYYY- 2019-04798, 2019-03258 Documents NNNN Procedures OP-002-001 Auxiliary Component Cooling Water 315 OP-003-035 Auxiliary Feedwater 310 OP-009-002 Emergency Diesel Generator 351 OP-009-003 Emergency Feedwater 309 71111.05Q Corrective Action CR-WF3-YYYY- 2019-03742, 2019-05956 Documents NNNN Miscellaneous NS-TB-002 Turbine Building +15.00' West including Feedwater Pump 3

                                              "A" Auxiliary Feedwater Pump, Main Lube Oil Storage Tank

and Condensate Pump Procedures EN-TQ-125 Fire Brigade Drills 8 FP-001-019 Fire Brigade Equipment 310 FP-001-020 Fire Emergency/Fire Report 312 RAB 13-001 Battery Room 3A 7 RAB 1A, B, C, D- Control Room, H&V Room, Emergency Living Quarters and 12 001 Computer Room RAB 8B,E,F-001 Switchgear Room B 13 RAB 8C-001 Switchgear Room A/B 11 ROOF W-001 Roof W (MSIV A) 2 UNT-005-013 Fire Protection Program 14 71111.06 Calculations ECM05-004 Required Isolation Time to Prevent Depletion of CCW Surge 0 Tank due to SSE ECM15-004 Waterford FLEX Internal Flooding Calculation 0 MNQ3-5 Flooding Analysis Outside Containment 6 PRA-W3-01-002 W3 Internal Flooding Analysis 3 Inspection Type Designation Description or Title Revision or Procedure Date Corrective Action CR-WF3-YYYY- 2019-01724, 2019-01719 Documents NNNN Procedures OP-002-004 Chilled Water System 317 71111.07A Corrective Action CR-WF3-YYYY- 2018-05404, 2018-06396, 2018-07109, 2019-2164 Documents NNNN Procedures CE-002-003 Maintaining Auxiliary Component Cooling Water Chemistry 306 CE-002-007 Maintaining Component Cooling Water Chemistry 309 71111.11B Corrective Action Control Room Control Room Condition Report Summary for 2018-2019 06/25/2019 Documents Condition Report Summary for 2018-2019 Miscellaneous Simulator Simulator Differences List June 26, Differences List 2019 Simulator Simulator Discrepancy Report July 2017 to July 2019 07/02/2019 Discrepancy Report July 2017 to July 2019 Waterford 2019 Operations Exam 07/29/2019 Requalification Exam Week 1 - 3 Waterford 2019 Written Exam 07/29/2019 Requalification Exam Week 1 - 3 Procedures EN-TQ-114 Licensed Operator Requalification Training Program 12 Description EN-TQ-201 Systematic Approach to Training Process Revision 23 EN-TQ-202 Simulator Configuration Control Revision 10 EN-TQ-210 Conduct of Simulator Training Revision 15 EN-TQ-217 Examination Security Revision 8 OI-024-000 Maintaining Active SRO-RO Status 314 TQF-202-SBT Scenario Based Testing Checklist Revision 1 TQF-210-DD03 LOR Simulator Crew performance Evaluation Grading Revision 5 Criteria WSIM-DIR-002 Simulator Core Reload Acceptance Test Revision 4 Inspection Type Designation Description or Title Revision or Procedure Date 71111.11Q Miscellaneous WSXM-LOR- 2019 Cycle 4 Biennial Simulator Exam Week 5 0 194EXM Procedures OP-010-005 Plant Shutdown 336 OP-010-006 Outage Operations 333 OP-901-113 Volume Control Tank Makeup Control Malfunction 305 OP-901-311 Loss of Train B Safety Bus 312 OP-902-000 Standard Post Trip Actions 16 OP-902-003 Loss of Offsite Power/Loss of Forced Circulation Recovery 11 71111.12 Corrective Action CR-WF3-YYYY- 2017-05763, 2017-05844, 2019-04788, 2019-04813, 2019- Documents NNNN 04848, 2019-07376 Procedures EN-DC-203 Maintenance Rule Program 4 EN-DC-204 Maintenance Rule Scope and Basis 4 EN-DC-205 Maintenance Rule Monitoring 7 71111.13 Corrective Action CR-WF3-YYYY- 2019-06375 Documents NNNN Procedures EN-OU-108 Shutdown Safety Management Program (SSMP) 9 EN-WM-104 On Line Risk Assessment 20 OI-37-000 Operations Risk Assessment Guideline 313 Work Orders 52790245 71111.15 Calculations SI Calculation Evaluation of Leaking 1-inch Line Upstream of Valve CVC- 0 1900769.301 186 Corrective Action CR-WF3-YYYY- 2019-05704, 2019-05755, 2019-06307, 2019-07242, 2019- Documents NNNN 07462 Miscellaneous BOP-RT-19-001 Digital Radiographic Examination 07/09/2019 BOP-VT-19-019 Visual Examination of Welds 07/09/2019 Procedures EN-OP-104 Operability Determination Process 16 71111.18 Calculations EC 102-001 Ultimate Heat Sink Margin Restoration - WCT Basin Level 1 Setpoint Change - Train A EC 64016 COLSS Analysis/Station Interface Calculation 0 ECI91-005 Wet Cooling Tower Basin Water Level Instrumentation 1 Loops Uncertainty Calculation MN(Q)-9-38 Capacity of Wet Cooling Tower Basins 4 Drawings B425 L7079A ACC - WET COOLING TOWER A BASIN WATER LEVEL 3 Inspection Type Designation Description or Title Revision or Procedure Date Miscellaneous DEIC-I-502 Setpoint and Uncertainty Determination 6 EC 52043 Ultimate Heat Sink Margin Restoration 0 71111.19 Corrective Action CR-WF3-YYYY- 2019-06374 Documents NNNN Procedures EN-OP-104 Operability Determination Process 16 ME-003-318 G.E. Undervoltage Relay Model 12IAV55C 306 ME-007-036 G.E. Auxiliary Relays 12HFA51B and 12HFA151B7F 306 OP-903-005 Control Element Assembly Operability Check 15 OP-903-121 Safety Systems Quarterly IT Valve Tests 30 Work Orders 00528219, 00529055, 52811969, 530144 71111.20 Corrective Action CR-WF3-YYYY- 2019-06358, 2019-06379, 2019-06384 Documents NNNN Procedures EN-OM-119 On-Site Safety Review Committee 19 EN-OU-108 Shutdown Safety Management Program (SSMP) 9 OP-003-033 Main Feedwater 325 OP-003-035 Auxiliary Feedwater 310 OP-010-003 Plant Startup 349 OP-010-006 Outage Operations 333 71111.22 Calculations ECP96-007 Auxiliary Component Cooling Water Supply and Return 1 Piping Corrective Action CR-WF3-YYYY- 2019-06518, 2018-01724, 2018-01719 Documents NNNN Procedures EN-MA-135 Online Motor Electrical Testing 9 MI-005-219 Calibration Check and Verification of Thermocouples and 304 RTDs OP-903-119 Secondary Auxiliaries Quarterly IST Valve Test 34 Work Orders 52798924, 52877149, 52814428 71114.06 Corrective Action CR-WF3-YYYY- 2019-07397, 2019-07422, 2019-07424, 2019-07445, 2019- Documents NNNN 07449, 2019-07450, 2019-07451, 2019-07467 Procedures EP-001-001 Recognition & Classification of Emergency Conditions 33 EP-001-020 Alert 310 EP-001-030 Site Area Emergency 309 Inspection Type Designation Description or Title Revision or Procedure Date EP-001-040 General Emergency 310 OP-010-005 Plant Shutdown 337 OP-901-102 CEA or CEDMCS Malfunction 305 OP-901-212 Rapid Plant Power Reduction 11 OP-901-402 High Airborne Radioactivity in Reactor Auxiliary Building 5 OP-901-410 High Activity in Reactor Coolant System 4 OP-901-512 Loss of Turbine Cooling Water 3 OP-902-000 Standard Post Trip Actions 16 OP-902-001 Reactor Trip Recovery 16 OP-902-007 Steam Generator Tube Rupture Recovery Procedure 30 71124.05 Calibration 2018-B2.28- Portable Instrumentation Calibration Data Sheet: Ludlum 10/01/2018 Records CALDAT-04015 LM-177 (CHP-CR-186) 2018-B2.28- Portable Instrumentation Calibration Data Sheet: AMP100 09/06/2018 CALDAT-05747 (CHP-ARM014) 2018-B2.28- Portable Instrumentation Calibration Data Sheet: Wide 10/10/2018 CALDAT-06937 Range Telepole (CHP-TEL034) 2018-B2.28- Portable Instrumentation Calibration Data Sheet: Wide 10/10/2018 CALDAT-06939 Range Telepole (CHP-TEL039) 2018-B2.28- Portable Instrumentation Calibration Data Sheet: RO-20 11/14/2018 CALDAT-07490 (CHP-DR-119) 2018-B2.28- Portable Instrumentation Calibration Data Sheet: Ludlum 12/18/2018 CALDAT-08281 LM-177 (CHP-CR-195) 2018-B2.28- Portable Instrumentation Calibration Data Sheet: AMS-4 12/27/2018 CALDAT-08396 Particulate Detector (HP-RD-261) 2019-B2.28- Portable Instrumentation Calibration Data Sheet: SAC-4 01/08/2019 CALDAT-00247 (HP-DS-066) 2019-B2.28- Portable Instrumentation Calibration Data Sheet: Ludlum 04/11/2019 CALDAT-03118 LM-177 (CHP-CR-148) 2019-B2.28- Portable Instrumentation Calibration Data Sheet: Wide 04/15/2019 CALDAT-03128 Range Telepole (CHP-TEL138) 2019-B2.28- Portable Instrumentation Calibration Data Sheet: Ludlum 9-3 04/16/2019 CALDAT-03199 (CHP-DR-286) 2019-B2.28- Portable Instrumentation Calibration Data Sheet: Ludlum 9-3 04/17/2019 CALDAT-03211 (HP-DR-562) Inspection Type Designation Description or Title Revision or Procedure Date 2019-B2.28- Portable Instrumentation Calibration Data Sheet: Ludlum 9-3 08/20/2019 CALDAT-04802 (CHP-DR-661) ARGOS ARGOS Calibration Data Sheet: HP-DS-077, Westside 5/8/2019 Calibration Data Access Sheet HP-DS-077 ARGOS ARGOS Calibration Data Sheet: HP-DS-098, Westside 05/07/2019 Calibration Data Access Sheet HP-DS-098 Canberra GEM-5 Canberra GEM-5 Calibration Sheet HP-DS-080, Westside 07/10/2019 Calibration Sheet Access HP-DS-080 Canberra GEM-5 Canberra GEM-5 Calibration Sheet HP-DS-095, PAP 10/30/2018 Calibration Sheet HP-DS-095 CRONOS CRONOS Calibration Data Sheet: HP-DS-090, Westside 3/26/2019 Calibration Data Access Sheet HP-DS-090 CRONOS CRONOS Calibration Data Sheet: HP-DS-091, Westside 08/12/2019 Calibration Data Access Sheet HP-DS-091 Fastscan 2019 Fastscan Recalibration Waterford 3 West Side Access 07/14/2019 Fastscan 2019 Fastscan Recalibration Waterford 3 Dosimetry Office 07/14/2019 Corrective Action CR-WF3-YYYY- 2017-09300; 2017-09392; 2017-09662; 2018-00104; 2018- Documents NNNNN 00239; 2018-00362; 2018-00547; 2018-00983; 2018-01348; 2018-01371; 2018-02007; 2018-02085; 2018-02917; 2018- 03146; 2018-03680; 2018-03868; 2018-05670; 2018-05842; 2018-06684; 2019-00461; 2019-00780; 2019-01532; 2019- 03504; 2019-03529; 2019-03899; 2019-04105; 2019-04407; 2019-04624 Miscellaneous Results of the Radiochemistry Cross Check Program - 07/24/2019 Entergy Waterford 4 - 2nd Quarter 2019 Results of the Radiochemistry Cross Check Program - 11/27/2018 Entergy Waterford 4 - 3rd Quarter 2018 Results of the Radiochemistry Cross Check Program - 10/04/2017 Inspection Type Designation Description or Title Revision or Procedure Date Entergy Waterford 4 - 2nd Quarter 2017 Instrument Source Checking Source Inventory 09/11/2019 2018-B2.28- Laboratory Standard - Calibration/verification Data: V-570 06/12/2018 LABSTN-0004 Meter 2018-B2.28- Source Verification: MODEL-89 (400) Serial Number: 2414- 12/18/2018 SRCVER-0006 SRC1993001 TD-G063.0115 General Atomic Area Radiation Monitoring Systems 12/10/1987 Equipment Manual E-115-930 Procedures EN-CY-102 Laboratory Analytical Quality Control 13 EN-CY-102-01 Quality Control for Analytical Laboratory Interlab and Intralab 1 Cross-Check Programs EN-CY-102-02 Analytical Method Development Quality Assurance 1 EN-CY-102-03 Calculation Guide for Laboratory QAQC 0 EN-DC-153 Preventive Maintenance Component Classification 20 EN-DC-204 Maintenance Rule Scope and Basis 4 EN-DC-324 Preventive Maintenance Program 22 MI-005-906 RADIATION MONITORING SYSTEM DESK GUIDE 4 MI-005-923 Calibration Procedure - General Atomic Area Radiation 4 Monitor Assemblies 0359-360: ARMIR5013, 5014, 5015, 5018 Self-Assessments LO-WLO-2017- Pre-NRC Self-Assessment IP 71124.05 Radiation Monitoring 09/20/2017 0032 Instrumentation LO-WLO-2019- Pre-NRC Self-Assessment, IP71124.05 Radiation Monitoring 07/18/2019 0015 Instrumentation Work Orders WO-WF3- 180572; 180573; 425005; 470721; 485439; 495141; 519720; 51693877; 52329961; 52668978; 52675543; 2739065; 52743583; 52745414; 52759169; 52780184; 2780545; 52780748; 52781284; 52782394; 2782394; 52878443 71124.06 Calibration WO52717425 Component Cooling Water Blowdown (RE-7050B) 03/12/2018 Records WO52719287 Fuel Handling Building Ventilation System B (RE-5107B) 03/20/2018 WO52721495 Circulating Water Discharge (RE-1900) 04/02/2018 WO52730813 Gaseous Waste Management System (GWMS) (RE-0648) 07/16/2018 WO52734471 Dry Cooling Tower Sump B (RE-6776) 06/21/2018 Inspection Type Designation Description or Title Revision or Procedure Date WO52748891 Fuel Handling Building Ventilation System A (RE-5107A) 12/03/2018 WO52773476 Turbine Building Industrial Waste Sump (RE-6778) 05/06/2019 WO52776602 Main Condenser Evacuation System (MCES) (RE-002) 03/19/2019 WO52798848 RAB Ventilation System/Plant Stack A (RE-0100.1) 06/03/2019 Corrective Action CR-HQN-YYYY- 2017-00319 Documents NNNNN CR-WF3-YYYY- 2017-08186; 2017-09325; 2017-09736; 2018-00983; 2018- NNNNN 02000; 2018-02007; 2018-03972; 2019-04516; 2019-04712; 2019-06735; 2019-006736; 2019-06737; 2019-06748 Miscellaneous 2018 Annual Radioactive Effluent Release Report 2018 Results of Radiochemistry Cross Check Program - 4th 05/13/2019 Quarter 2018 Results of Radiochemistry Cross Check Program - 3rd 11/27/2018 Quarter 2018 Results of Radiochemistry Cross Check Program - 2nd 08/12/2019 Quarter 2019 2017 Annual Radioactive Effluent Release Report 2017 Results of Radiochemistry Cross Check Program - 4th 07/11/2018 Quarter 2017 W3GB2017-151 Containment Gas Effluent Release Report - Batch 12/20/2017 W3GB2018-038 Containment Gas Effluent Release Report - Batch 03/22/2018 W3GB2019-017 Miscellaneous Gas Effluent Release Report - Batch 02/22/2019 W3GC2018-063 Plant Stack Gas Effluent Release Report - Continuous 05/17/2018 W3GC2018-150 Main Condenser Evacuation System (MCES) Gas Effluent 11/29/2018 Release Report - Continuous W3GC2019-020 Fuel Handling Building (FHB) Gas Effluent Release Report - 02/19/2019 Continuous W3LB2017-269 Boric Acid Condenser Tank C Liquid Effluent Release 12/01/2017 Report - Batch W3LB2018-078 Liquid Waste Management Liquid Effluent Release Report - 05/12/2018 Batch W3LB2019-023 Steam Generator Blowdown Liquid Effluent Release Report - 01/29/2019 Batch W3LC2017-267 Turbine Building Industrial Waste System (TBIWS) Liquid 12/04/2017 Inspection Type Designation Description or Title Revision or Procedure Date Effluent Release Report - Continuous W3LC2018-242 Turbine Building Industrial Waste System (TBIWS) Liquid 01/01/2019 Effluent Release Report - Continuous W3LC2019-016 Dry Cooling Tower Sump 1 (DCTS1) Liquid Effluent Release 01/01/2019 Report - Continuous Procedures CE-001-004 Periodic Analysis Scheduling Program 318 CE-003-509 Routine Filter Replacement and Grab Sampling on 308 Particulate Iodine Gas (PIG) Monitors and Wide Range Gas Monitors (WRGMs) CE-003-512 Liquid Radioactive Waste Release Permit (Manual) 002 CE-003-513 Gaseous Radioactive Waste Release Permit (Manual) 304 CE-003-514 Liquid Radioactive Waste Release Permit (Computer) 303 CE-003-515 Gaseous Radioactive Waste Release Permit (Computer) 304 CE-003-516 Calculation and Adjustment of Radiation Monitoring 302 Setpoints CE-003-700 General Grab Sampling Techniques 316 MI-003-368 Fuel Handling Building Ventilation System Normal Effluent 016 Exhaust A or B Particulate and Gaseous Radiation Monitor Calibration PRMIR5107.A or PRMIR5107.B MI-003-380 Plant Vent Stack Safety Channel A or B Particulate and 309 Gaseous Radiation Monitor Calibration PRMIR0100.1 or PRMIR0100.2 MI-003-466 Dry Cooling Tower Sumps Liquid Effluent Radiation Monitor 308 Channel Calibration PRMIR6775 or PRMIR6776 MI-003-469 Turbine Building Industrial Waste Sumps Combined 013 Discharge Liquid Effluent Radiation Monitor Channel Calibration PRMIR6778 MI-003-471 Circulating Water Discharge Liquid Effluent Radiation 011 Monitor Channel Calibration PRMIR1900 MI-003-473 Gaseous Waste Management Discharge Noble Gas 305 Radiation Monitor Channel Calibration PRMIR0648 UNT-005-014 Offsite Dose Calculation Manual 307 Self-Assessments LO-WLO-2019- Pre-NRC Assessment of Radiation Safety Inspection Criteria 08/07/2019 0016 Inspection Type Designation Description or Title Revision or Procedure Date Work Orders WO-52714811 CVAS B - Controlled Ventilation Areas Filtration Unit In- 03/15/2018 Place Charcoal Testing WO-52716247 HVC B - Control Room Emergency Filtration Unit Charcoal 02/14/2018 Sampling WO-52716248 HVC B - Control Room Emergency Filtration Unit In-Place 02/14/2018 Charcoal Testing WO-52728264 SBV A - Shield Building Ventilation Unit Charcoal Sampling 06/04/2018 WO-52767953 CVAS A - Controlled Ventilation Areas Filtration Unit In- 01/11/2019 Place Charcoal Testing WO-52795776 HVC A - Control Room Emergency Filtration Unit In-Place 07/09/2019 Charcoal Testing 71124.07 Calibration ENV-FT-016 Flow Totalizer for APQ-1 03/13/2019 Records W/O 52817697 EM IM0110, Calibrate Backup Met Tower IAW MI-003-396 09/19/2019 W/O 52835981 EM IM0100, Calibrate Primary Met Tower IAW MI-003-395 12/20/2018 W/O 52843683 EM IM0110, Calibrate Backup Met Tower MI-003-396 03/20/2019 W/O 52859453 EM IM0100, Calibrate Primary Met Tower IAW MI-003-395 07/05/2019 Corrective Action CR-HQN-YYYY- 2017-01911; 2018-02412 Documents NNNNN CR-WF3-YYYY- 2017-09465; 2017-09810; 2018-00539; 2018-01625; 2018- NNNNN 01749; 2018-02620; 2018-04363; 2018-05354; 2018-06463; 2018-07201; 2018-07297; 2019-02608; 2019-03611; 2019- 03804; 2019-04264; 2019-04329; 2019-04412; 2019-05720; 2019-05762; 2019-05882; 2019-06851 Miscellaneous Ground Water Monitoring Plan 02/10/2014 2017 Annual Radioactive Effluent Release Report 2018 2017 Annual Radiological Environmental Operating Report 2018 2018 Annual Radioactive Effluent Release Report 2019 2018 Annual Radiological Environmental Operating Report 2019 CR-WF3-2019- CR with attached Inspections of Met Towers 09/19/2019 07315 PR-PRHQN- Procedure Revision Tracker associated with CR-HQN-2018- 11/06/2018 2018-00908 02412 for EN-FAP-OM-012 Primary Guyed Tower Inspection Report 6/3/2019 Secondary Guyed Tower Inspection Report 6/3/2019 Inspection Type Designation Description or Title Revision or Procedure Date WF3-CR-2017- Response to Contaminated Spills/Leaks 11/10/2017 09001 WF3-CR-2018- Response to Contaminated Spills/Leaks 06/16/2018 03420 Procedures CE-001-004 Periodic Analysis Scheduling 318 CE-003-522 Meteorological Data Collection and Processing 6 CE-003-523 Meteorological Monitoring Program 1 EN-CY-108 Monitoring of Nonradioactive Systems 6 EN-CY-111 Radiological Ground Water Monitoring Program 9 EN-CY-130 Radiological Environmental Monitoring Program 0 EN-RP-113 Response to Contaminated Spills/Leaks 9 MI-003-395 Primary Meteorological Tower Instrument Calibration EM 302 IM0110 MI-003-396 Secondary Meteorological Tower Instrument Calibration EM 11 IM0110 UNT-005-014 Offsite Dose Calculation Manual 307 Self-Assessments Teledyne Brown Engineering Knoxville Laboratory Internal 11/13/2018 QA Audit 2018 Internal Assessment - Stanford Dosimetry 01/29/2019 NUPIC Joint Utility Audit No. 24791 05/09/2019 LO-WLO-2019- Pre-NRC Assessment of Radiation Safety Inspection Criteria 08/07/2019 0016 Work Orders WO 488788 Primary Met Tower Reading Suspect 12/19/2017 WO 501576 Troubleshoot/Repair Secondary Met Tower 08/22/2018 From WR 437511 WO 523912 Troubleshoot/Repair BU Met Tower 33 ft. Wind Direction 05/01/2019 CR-19-4329 71124.08 Corrective Action CR-HQN-YYYY- 2017-01400; 2017-01543 Documents NNNNN CR-WF3-YYYY- 2017-03321; 2017-07899; 2017-07903; 2019-4177 NNNNN Procedures EN-RW-105 Process Control Program 5 EN-RW-106 Integrated Transportation Security Plan 6 Inspection Type Designation Description or Title Revision or Procedure Date Self-Assessments WLO-2019- Pre-Assessment of NRC IP71124.08 8/21/2019 000015 Shipping Records 17-1009 Unitech ORSC: Blowdown Resin 4/20/17 17-1017 Unitech-ORSC: Wood waste 6/19/17 17-1018 Unitech-ORSC: Wood waste 7/28/17 18-1013 ESM: Scaffolding 18-1014 ESBS: Cask Liner with Resin and Sludge 5/24/18 18-3002 Radiation Instruments: GA 1/18/18 19-1015 ESBC: Resin in a Shielded Cask 19-1019 ESBC: Resin in a Shielded Cask 8/15/19 71151 Miscellaneous W3F1-2018-0066 NRC Performance Indicator (PI) Data - 3rd Quarter 2018 10/21/2018 ROP Data W3F1-2019-0003 NRC Performance Indicator (PI) Data - 4th Quarter 2018 01/10/2019 ROP Data W3F1-2019-0030 NRC Performance Indicator (PI) Data - 1st Quarter ROP 04/11/2019 Data W3F1-2019-0053 NRC Performance Indicator (PI) Data - 2nd Quarter ROP 07/15/2019 Data 71152 Corrective Action CR-WF3-YYYY- 2019-03572, 2019-04410, 2019-04628, 2019-04654, Documents NNNN 2019-04988, 2019-05014, 2019-05026, 2019-05279, 2019-05488, 2019-05489, 2019-05662, 2019-05729, 2019-06000, 2019-07075, 2019-07529 Procedures EN-OP-104 Operability Determination Process 16 OP-004-004 Control Element Drive 24 34| ]]