IR 05000382/2021002

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Integrated Inspection Report 05000382/2021002
ML21216A444
Person / Time
Site: Waterford Entergy icon.png
Issue date: 08/05/2021
From: John Dixon
NRC/RGN-IV/DRP
To: Ferrick J
Entergy Operations
References
EA-20-114 IR 2021002
Preceding documents:
Download: ML21216A444 (18)


Text

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 - INTEGRATED INSPECTION REPORT 05000382/2021002

Dear Mr. Ferrick:

On June 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Waterford Steam Electric Station, Unit 3. On July 8, 2021, the NRC inspectors discussed the results of this inspection with Mr. Matthew Lewis and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding 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.

If you contest the violation or the 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 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 Waterford Steam Electric Station, Unit 3.

August 5, 2021 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, 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:

05000382/2021002

Enterprise Identifier:

I-2021-002-0111

Licensee:

Entergy Operations, Inc.

Facility:

Waterford Steam Electric Station, Unit 3

Location:

Killona, LA 70057

Inspection Dates:

April 1, 2021 to June 30, 2021

Inspectors:

R. Alexander, Senior Emergency Preparedness Inspector

J. Braisted, Senior Reactor Inspector

D. Childs, Resident Inspector

W. Cullum, Reactor Inspector

R. Kopriva, Senior Reactor Inspector

A. Patz, Senior Resident Inspector

C. Smith, Health Physicist

Approved By:

John L. Dixon, Jr., Chief

Reactor Projects Branch D

Division of Reactor Projects

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.

List of Findings and Violations

Inadequate Procedure for Assembly of Control Element Drive Mechanism Voltage Regulator Card Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000382/2021002-01 Open/Closed

[H.1] -

Resources 71152 The inspectors reviewed a self-revealed Green finding and associated non-cited violation of Technical Specification 6.8.1.a, Procedures and Programs, for the licensees failure to have an adequate maintenance procedure as required by Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2. Specifically, station procedure MI-004-300,

Maintenance Procedure Guidelines for Rework of Electronic Equipment, Revision 302, did not adequately provide the level of detail required to ensure the control element drive mechanism (CEDM) motor generator set B voltage regulator card was properly reassembled after maintenance was completed on the card.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000382/2020-003-00 Procedure Deficiency for MG Set Voltage Regulator Installation Results in a Reactor Trip 71153 Closed Type Issue Number Title Report Section Status NOV 05000382/2021013-01 EA-20-114 Procedure Violation During Fuel Oil Storage Tank Replacement Project Results in Cut Rebar Without Proper Evaluation 71153 Closed

PLANT STATUS

Waterford, Unit 3, began the inspection period in the process of reducing power for a forced outage to repair a leak in feedwater heater 6B. The reactor was placed in hot standby on April 1, 2021 and remained in that state until it was restarted on April 3, 2021. The reactor was at full power on April 5, 2021. On April 7, 2021, the unit reduced power to 98.5 percent due to increased governor valve #4 position oscillations. On April 8, 2021, the unit was returned to near full power after governor valve troubleshooting. On May 2, 2021, the unit reduced power to 77 percent power to close governor valve #4 and troubleshoot valve position oscillations. The unit was returned to 100 percent power on May 3, 2021 and remained near full power through 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 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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week, increasing the amount of time on site as local COVID-19 conditions permitted.

As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of hurricane season (June 1 to November 30) on May 27, 2021.

External Flooding Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding on April 21, 2021.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (2 Samples)

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

(1) Main steam, steam bypass, and atmospheric dump valve systems while reactor was in Mode 3 on April 1-2, 2021
(2) Emergency diesel generator A while emergency diesel generator B was unavailable for planned maintenance on June 16, 2021

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Fire Areas RAB 2-001 and RAB 24-002, reactor auxiliary building heating, ventilating, and air conditioning equipment rooms on May 19, 2021
(2) Fire Areas NS-CP-01 and NS-CP-02, condensate polisher building first floor and upper levels on June 28, 2021

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire drill on May 21, 2021.

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 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during reactor startup following repairs to feedwater heater 6B on April 3-4, 2021.

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

(1) The inspectors observed and evaluated a series of simulator-based training scenarios that required use of updated emergency action levels on May 13, 2021.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Partial)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1)

(Partial)

Control room emergency air filtration system due to hydramotor actuator failures

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Unplanned high risk for reactor downpower due to continued unexpected oscillations of governor valve 4 position from April 6-8, 2021
(2) Planned high risk during train B outages for static uninterruptible power supplies, auxiliary component cooling water, and safety-related heating, ventilating, and air conditioning systems from May 24-28, 2021
(3) Planned high risk during emergency diesel generator B outage from June 14-19, 2021

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Train A component cooling water after identification of large differential temperature across phases in wet cooling tower motor 7A fan contactors on April 15, 2021
(2) Trains A and B broad range gas monitors following multiple indications of toxic gas on May 6, 2021
(3) Reactor vessel level monitoring system following loss of communication with qualified safety parameter display system channel 1 on May 26, 2021
(4) All FLEX equipment following identification of an incorrectly wired power receptacle for the FLEX N and N+1 core cooling pump on June 1, 2021
(5) Main steam isolation valve 2 following identification of hydraulic fluid on the nitrogen-filled side of the piston actuator on June 16, 2021

71111.17T - Evaluations of Changes, Tests, and Experiments Sample Selection (IP Section 02.01)

The inspectors reviewed the following evaluations, screenings, and/or applicability determinations for 10 CFR 50.59 from April 5-9, 2021.

(1) EC-00530, Ultimate Heat Sink Water Replenishment for Tornado Event
(2) EC-72536, Implement SG Feedwater Pump B Modification during RF22 to Eliminate Morton Effect
(3) EC-73060, Base EC for W3C23 Fuel Reload
(4) EC-76133, RCS Leakrate Calculation Change to Use Shorter Input Smoothing
(5) EC-78601, Technical Requirements Manual 3.3.4 Turbine Valve Testing One Time Extension
(6) EC-79872, Equivalent Change EC to Address 10CFR Part 21 Wedge Pin Replacement for SI-407A(B)
(7) EC-83949, Replace Common Relief Valve for Both EH Pumps with Separate Relief Valves
(8) EC-86104, 2020 Toxic Chemical Survey and Calculation Update
(9) EC-86321, Steam Generator Level Deviation Setpoint Change
(10) EC-86657, Turbine Valve Testing Frequency Change From 6 Months To 12 Months, and then 18 Months Following Re-baseline at 12 Month Interval
(11) EC-87568, Evaluate Effect on Turbine Valve Testing from not Inspecting the Low Pressure Turbine at RF23
(12) EC-81569, Administrative EC to Allow Electronic Processing of LBDCR 19-007 TRM 3/4.9.6 One Time Exception
(13) EC-82583, Calculation Updates Addressing CR-WF3-2018-7188 and 7253
(14) EC-43927, Vital Instrument SUPS Upgrade Project
(15) EC-75652, Support Procedure Changes Made to EOPs for 2 EDGs Operation with One Failed CCW Pump
(16) EC-80327, Revise Documentation for CC-835A(B) Stroke Time
(17) EC-82156, CR-WF3-2018-6302 Resolution Update of NAMCO Limit Switch EQ Files
(18) EC-83049, Operability Input for Electroswitch 10CFR50 Part 21
(19) EC-68240, Increase Containment Spray Pump Bearing Cooling and Seal Cooling by CCW
(20) PAD-EN-MA-133, Long Term Scaffold Evaluations
(21) PAD-UNT-006-033, Technical Specification Surveillance Frequency List

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:

(1) Feedwater heater 6B following repair of sheared tube on April 4, 2021
(2) Component cooling water wet cooling tower fan 7A following motor contactor internal repairs on April 25, 2021
(3) Main steam governor valve 4 following repair of electrical connections on May 2, 2021
(4) Reactor vessel level monitoring system following loss of communication to channel 1 of the qualified safety parameter display system on June 3, 2021
(5) Control element assembly 77 following replacement of power switch on June 28, 2021

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Train B emergency feedwater actuation system test on April 19, 2021

FLEX Testing (IP Section 03.02) (1 Sample)

(1) FLEX N diesel generator surveillance on May 19, 2021

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Partial)

(1)

(Partial)

The inspectors evaluated the following recently submitted Emergency Action Level and Emergency Plan changes.

Emergency Action Levels EP-001-001, Revision 34, submitted to the NRC on March 11, 2021 As of the end of the 2nd quarter, the inspectors' evaluation had not yet been completed, and is expected to conclude early in the 3rd quarter inspection period.

However, when complete, this evaluation will not constitute NRC approval of the changes.

OTHER ACTIVITIES - BASELINE

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

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===

(1) April 1, 2020 through March 31, 2021

MS06: Emergency AC Power Systems (IP Section 02.05) (1 Sample)

(1) April 1, 2020 through March 31, 2021

MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)

(1) April 1, 2020 through March 31, 2021

71152 - Problem Identification and Resolution

Semiannual Trend Review (IP Section 02.02) (1 Sample)

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in reactivity control that might be indicative of a more significant safety issue. The inspectors identified an observation that is documented in the Inspections Results section below.

Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)

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

(1) Incorrect reassembly of control element drive mechanism motor generator set B voltage regulator card and subsequent automatic reactor trip on November 2, 2020

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 05000382/2020-003-00, Procedure Deficiency for MG Set Voltage Regulator Installation Results in a Reactor Trip (ADAMS Accession No. ML20365A126). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section 71152.

Personnel Performance (IP Section 03.03) (1 Sample)

The inspectors assessed the adequacy of the licensee's evaluation, extent of condition/cause review and associated corrective actions for the following notice of violation (NOV), which involved the inappropriate cutting of structural rebar during a diesel fuel oil storage tank replacement project at the Waterford Steam Electric Station, Unit 3, on November 9 and 10, 2016:

(1) NOV 05000382/2021013-01, Procedure Violation During Fuel Oil Storage Tank Replacement Project Results in Cut Rebar Without Proper Evaluation, on February 9,

INSPECTION RESULTS

Inadequate Procedure for Assembly of Control Element Drive Mechanism Voltage Regulator Card Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000382/2021002-01 Open/Closed

[H.1] -

Resources 71152 The inspectors reviewed a self-revealed Green finding and associated non-cited violation of Technical Specification 6.8.1.a, Procedures and Programs, for the licensees failure to have an adequate maintenance procedure as required by Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2. Specifically, station procedure MI-004-300, Maintenance Procedure Guidelines for Rework of Electronic Equipment, Revision 302, did not adequately provide the level of detail required to ensure the control element drive mechanism (CEDM) motor generator set B voltage regulator card was properly reassembled after maintenance was completed on the card.

Description:

On October 28, 2020, operators were unable to achieve the required steady-state voltage while attempting to place CEDM motor generator set B in service. A failure modes analysis was completed, and, after troubleshooting, the probable cause was determined to be a faulty voltage regulator card. The voltage regulator card was repaired.

The reactor was taken critical on October 31, 2020 using only CEDM motor generator set A.

Motor generator set B was started up on November 1, 2020 to burn in the repaired card and verify proper operation. On November 2, 2020, after a 2-hour burn-in, the licensee attempted to parallel motor generator set B with motor generator set A. When the generator neutral circuit on motor generator set B was closed an electrical ground occurred causing voltage to be degraded for the CEDM system. At least two control element assemblies dropped into the core causing an automatic scram to be initiated from the core protection calculator. All control element assemblies inserted into the core; all equipment required for shutdown functioned as designed. The licensee stabilized the plant in Mode 3. The cause of the ground on motor generator set B was that the recently rebuilt voltage regulator card insulators were not reassembled correctly to prevent an electrical short to ground when the voltage regulator was reinstalled in the cabinet. This occurred due to the procedure not containing adequate information to ensure the insulators would perform their function.

Corrective Actions: The licensee repaired the deficient voltage regulator card. Actions planned to be implemented are to include the following formal practices in card repair procedure MI-004-300:

(1) maintenance configuration control practices during disassembly/reassembly of equipment components in for card repair (before and after pictures, drawings, like-for-like comparisons) and
(2) verify items leaving card repair shop for installation in plant. This will be a documented verification step with sign-off and date.

Additionally, all instrumentation and control personnel will be required to review the lessons learned because of this incident.

Corrective Action References: Condition Report CR-WF3-2020-06336

Performance Assessment:

Performance Deficiency: The inspectors determined that the failure to have an adequate maintenance procedure to correctly reassemble the voltage regulator card in accordance with Technical Specification 6.8.1.a, Regulatory Guide 1.33 was a performance deficiency.

Screening: The inspectors determined the performance deficiency is more than minor because it is associated with the procedure quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, procedure MI-004-300, Maintenance Procedure Guidelines for Rework of Electronic Equipment, Revision 302, did not adequately provide the level of detail required to ensure the CEDM motor generator set B voltage regulator card was properly reassembled which caused a ground to the neutral circuit and subsequent automatic reactor trip.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, dated November 30, 2020. The inspectors determined that this finding is of very low safety significance (Green), because while the performance deficiency did result in a reactor trip, it did not cause a loss of mitigation equipment relied upon to transition the plant from the onset of a trip to a stable shutdown condition.

Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.

Specifically, the licensees leaders promoted and accommodated organizational behaviors that allowed card repair activities to be performed in an informal manner. This informal culture accepted the use of an inadequate procedure instead of leaders ensuring that procedure MI-004-300, Maintenance Procedure Guidelines for Rework of Electronic Equipment, Revision 302, contained a sufficient level of detail to adequately support the proper assembly of the CEDM generator set B voltage regulator card.

Enforcement:

Violation: Technical Specification 6.8.1, requires, in part, that procedures shall be established, implemented, and maintained covering the applicable procedures recommended in NRC Regulatory Guide 1.33, Revision 2. Regulatory Guide 1.33, Revision 2, Appendix A, Section 9, Procedures for Performing Maintenance, requires, in part, that maintenance should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

Contrary to the above, prior to November 2, 2020, the licensee failed to create written procedures, documented instructions, or drawings appropriate to the circumstances to perform work on the CEDM motor generator voltage regulator cards. Specifically, the licensee did not provide an adequate level of detail in procedure MI-004-300, Maintenance Procedure Guidelines for Rework of Electronic Equipment, Revision 302 to ensure the CEDM motor generator voltage regulator cards were properly reassembled. The incorrect assembly of the voltage regulator card caused a ground to the neutral circuit and subsequent automatic reactor trip.

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

Observation: Semi-Annual Trend Review 71152 The inspectors identified an adverse trend in reactivity control due to unexpected oscillations in the main steam governor valve positions. Over the past 3 years, the following CRs detail an issue with movement of the governor valves outside of the expected control band:

CR-WF3-2019-05210 - Oscillations in governor valve 4 position caused a small change in reactor power. From June to July 2019, approximately 15-20 occurrences of about 5 minutes each. The cause was determined to be either a loose wiring connection or separate damaged wiring connection and both were fixed during Forced Outage 23-02 in August 2019.

CR-WF3-2020-06795 - Oscillations in governor valve 1 position caused a small change in reactor power. The licensee reduced reactor power to 89 percent to troubleshoot the issue.

The issue was determined to be high resistance terminals for position indication which were replaced, and the reactor returned to full power.

CR-WF3-2021-01768 - Oscillations in governor valve 4 position caused a small change in reactor power. First appeared in April 2021 following a forced outage for feedwater heater leaks. Reactor power was reduced to 75 percent power and governor valve 4 was isolated.

The cause was found to be high resistance wiring connections on position indication lug terminations in the governor valve actuator control box.

CR-WF3-2021-02980 - During performance monitoring in June 2021, the licensee identified small perturbations on governor valve 1 position that did not have a noticeable impact on reactor power. CR-WF3-2021-03241 documented larger oscillations, but the larger oscillations still do not cause a noticeable change in reactor power.

The licensee has previously identified this adverse trend and implemented several actions to solve this issue including installing extra instrumentation, pre-emptively replacing components, and consulting industry experts. Additionally, an adverse condition monitoring plan is in place that prescribes operator actions in case of increasing oscillations and plant impact.

In each case of oscillations, the source of the oscillations is identified to be loose electrical connections. Though these valves are not required for safe shutdown of the reactor, they can be initiating events for reactor transients. Until the underlying condition is solved, these oscillations represent a plant risk.

Assessment 71153 On May 18, 2021, the U.S. Nuclear Regulatory Commission (NRC) issued a notice of violation (NOV) to Entergy Operations, Inc. (Entergy), Waterford Steam Electric Station, Unit 3 (Inspection Report 0500382/2021090 (Agencywide Documents Access and Management System (ADAMS) accession number ML21138A858). The Severity Level III NOV (EA-20-114) was associated with a contract supervisor who directed subordinate employees to perform concrete drilling in the safety-related B1 fuel oil storage tank vault cubicle concrete walls without first obtaining engineering evaluation, approval, and documentation, as required by a quality-related procedure. This resulted in the cutting of structural rebar without engineering evaluation and approval, in violation of a quality-related licensee procedure. This issue was characterized as a violation of 10 CFR Part 50, Appendix B, Criterion V.

Due to the age of the initial issue itself, when the NOV was communicated to the licensee in Inspection Report 05000382/2021090, the licensee had already performed a cause evaluation, developed, and implemented corrective actions that prevented any further violations. The NRC assessed the adequacy of the licensee's evaluation, extent of condition/cause review and associated corrective actions. The inspectors determined that the licensee performed an adequate evaluation of the specific performance issue and that comprehensive corrective actions were completed to address each of the specific causes.

This finding is closed.

EXIT MEETINGS AND DEBRIEFS

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

On April 8, 2021, the inspectors presented the Evaluations of Changes, Tests and Experiments inspection results to Crystal Garbe, Director, Engineering, and other members of the licensee staff.

On July 8, 2021, the inspectors presented the integrated inspection results to Mr.

Matthew Lewis and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Engineering

Evaluations

W3F1-2017-0042

Focused Evaluation of External Flooding for Waterford

Steam Electric Station, Unit 3

05/17/2017

EN-FAP-EP-010

Severe Weather Response

71111.01

Procedures

OP-901-521

Severe Weather and Flooding

336 and 337

Miscellaneous

W3-DBD-006

Main Steam System Design Basis Document

2

OP-005-004

Main Steam

71111.04

Procedures

OP-009-002

Emergency Diesel Generator

358

RAB 2-001

Prefire Strategy for Elevation +46 Reactor Auxiliary Building

Heating and Ventilating Mechanical Room

RAB 24-001

Prefire Strategy for Elevation +46 Reactor Auxiliary Building

Decontamination Area Heating, Ventilating, and Air

Conditioning Area

RAB 5-001

Prefire Strategy for Elevation +35 Reactor Auxiliary Building

Electrical Penetration Area "B"

Fire Plans

RAB 6-001

Prefire Strategy for Elevation +35 Reactor Auxiliary Building

Electrical Penetration Area "A"

NS-CP-001

Waterford-3 S.E.S. Pre Fire Strategy Condensate Polisher

Building - 1st Floor

71111.05

Procedures

NS-CP-002

Waterford-3 S.E.S. Pre Fire Strategy Condensate Polisher

Building - Upper Levels

EN-OP-115

Conduct of Operations

EP-001-001

Recognition and Classification of Emergency Conditions

OP-010-003

Plant Startup

355

71111.11Q

Procedures

OP-902-000

Standard Post Trip Actions

71111.12

Corrective Action

Documents

CR-WF3-YYYY-

NNNN

20-07328

Corrective Action

Documents

CR-WF3-YYYY-

NNNN

21-02346

EN-MA-125

Troubleshooting Control of Maintenance Activities

71111.13

Procedures

EN-WM-104

On-Line Risk Assessment

71111.15

Corrective Action

Documents

CR-WF3-YYYY-

NNNN

21-00184, 2021-01896, 2021-01899, 2021-02269, 2021-

2375, 2021-02412, 2021-02757, 2021-003084

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

W3-DBD-006

Main Steam System Design Basis Document

Miscellaneous

W3-DBD-038

Control Room Safety-Related Heating, Ventilating, and Air

Conditioning Design Basis Document

301

Operability

Evaluations

CR-WF3-YYYY-

NNNN

21-01986

EN-DC-310

Predictive Maintenance Program

EP-001-001

Recognition and Classification of Emergency Conditions

Procedures

OP-903-013

Monthly Channel Checks

Work Orders

2958435

3T1-18

Turbine Missiles

Calculations

WDI-PJF-

1303505

ENGINEERING STUDY ON DISC RUPTURE AND MISSILE

PROBABILITIES BASED ON VALVE INSPECTION

INTERVALS

Condition Reports

(CR-HQN-)

2019-01913

Corrective Action

Documents

Condition Reports

(CR-WF3-)

2016-4109, 2016-6312, 2019-07087, 2019-08040, 2021-

01429, 2019-05457, 2019-02114

Condition Reports

(CR-HQN-)

21-00607, 2021-00614, 2021-00623

Corrective Action

Documents

Resulting from

Inspection

Condition Reports

(CR-WF3-)

21-01826, 2021-01846

STI 19-003

Containment Spray Riser Level (Technical Specification

Requirement 4.6.2.1.a)

TCAPB

Time Critical Action Program Bases

Miscellaneous

W3F1-2020-0032

Report of Facility Changes, Tests and Experiments and

Commitment Changes for Two Year Period Ending April 28,

20

04/30/2020

EN-DC-115

Engineering Change Process

EN-DC-115-01

Industry Standard Design Process (IP-ENG-001, Rev 1)

EN-LI-100

Process Applicability Determination

EN-LI-101

CFR 50.59 Evaluations

EN-MA-133

Control of Scaffolding

EN-OP-102-01

Protective and Caution Tagging Forms & Checklist

71111.17T

Procedures

EN-OP-115-07

Configuration Control

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

EP-002-100

Technical Support Center (TSC) Activation, Operation, and

Deactivation

OP-100-014

Technical Specification and Technical Requirements

Compliance

355

OP-903-007

Turbine Inlet Valve Cycling Test

LO-WLO-2019-

00035

Regulatory Assurance - Annual PAD Self-Assessment

2/12/2019

Self-Assessments

LO-WLO-2021-

00013

Pre-Inspection Self-Assessment for NRC Inspection per

Inspection Procedure (IP) 71111.17T, "Evaluations of

Changes, Tests, and Experiments"

2/15/2021

Work Orders

Work Orders

(WO-)

108105, 52878440, 52887244, 541703, 527140

Corrective Action

Documents

CR-WF3-YYYY-

NNNN

21-02281, 2021-02859

EN-MA-107

Post-Maintenance Testing

OP-010-003

Plant Startup

336

Procedures

OP-903-013

Monthly Channel Checks

71111.19

Work Orders

2578076, 005566440, 00560489, 00563239, 52969823

OP-903-026

Emergency Core Cooling System Valve Lineup Verification

28

Procedures

OP-903-047

Emergency Feedwater Actuation Signal Test

71111.22

Work Orders

2897819, 52931250, 52952291

Calculations

WF3-EC-

0000088621

Radiation Monitoring Calculations for Monitor Spans to

Support EALs and Plant Operations

2/15/2021

Corrective Action

Documents

CR-WF3-YYYY-

NNNN

2019-07175, 2020-06312

Corrective Action

Documents

Resulting from

Inspection

CR-WF3-YYYY-

NNNN

21-02016

10CFR50.54(Q)(3) Evaluation: EP-001-001, Revision 34

2/18/2021

71114.04

Miscellaneous

NRC Letter to Licensee: Waterford Steam Electric Station,

Unit 3 - Approval of Conversion of the Emergency Action

Level Scheme to Scheme Based on Nuclear Energy Institute

(NEI) 99-01, Revision 5 (TAC No. ME4726)

07/18/2011

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

10CFR50.54(Q)(3) Screening: EP-001-001, Revision 34

2/18/2021

W3F1-2010-0052

Proposed Emergency Action Levels Using NEI 99-01

Revision 5 Scheme, Waterford Steam Electric Station Unit 3,

Docket No. 50-382, License No. NPF-38

09/16/2010

W3F1-2011-0034

Correction to Response to Request for Additional

Information (RAI) on the proposed revision to the Emergency

Plan (EP) Emergency Action Levels (EALs), Waterford

Steam Electric Station, Unit 3 (Waterford 3), Docket No. 50-

2, License No. NPF-38

05/04/2011

EP-001-001

Recognition and Classification of Emergency Conditions

Procedures

EP-001-001

Recognition and Classification of Emergency Conditions

71151

Procedures

EN-LI-114

Regulatory Performance Indicator Process

71152

Corrective Action

Documents

CR-WF3-YYYY-

NNNN

20-06336