IR 05000382/2024004
| ML25036A094 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 02/06/2025 |
| From: | John Dixon NRC/RGN-IV/DORS/PBD |
| To: | Sullivan J Entergy Operations |
| References | |
| IR 2024004 | |
| Download: ML25036A094 (1) | |
Text
February 06, 2025
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - INTEGRATED INSPECTION REPORT 05000382/2024004
Dear Joseph Sullivan:
On December 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Waterford Steam Electric Station, Unit 3. On January 27, 2025, 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.
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. 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 Operating Reactor Safety Docket No. 05000382 License No. NPF-38
Enclosure:
As stated
Inspection Report
Docket Number:
05000382
License Number:
Report Number:
Enterprise Identifier:
I-2024-004-0003
Licensee:
Entergy Operations Inc.
Facility:
Waterford Steam Electric Station, Unit 3
Location:
Killona, LA
Inspection Dates:
October 01, 2024 to December 31, 2024
Inspectors:
D. Childs, Reliability and Risk Analyst
K. Cook-Smith, Resident Inspector
P. Elkmann, Senior Emergency Preparedness Inspector
E. Powell, Senior Resident Inspector
A. Sanchez, Senior Project Engineer
Approved By:
John L. Dixon, Jr., Chief
Reactor Projects Branch D
Division of Operating Reactor Safety
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
Failure to Comply with Requirements of the Emergency Plan Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000382/2024004-01 Open/Closed
[P.1] -
Identification 71114.05 The inspectors identified a Green finding and associated non-cited violation of 10 CFR 50.54(q)(2)(i) associated with the licensees failure to follow their emergency plan.
Specifically, the inspectors identified three examples in which the licensee failed to follow requirements of the licensees emergency plan related to the conduct of drills and exercises.
Additional Tracking Items
None.
PLANT STATUS
Waterford Steam Electric Station, Unit 3, began the inspection period at approximately 94 percent rated thermal power. On December 2, 2024, the plant went into a forced outage for maintenance on main transformer B, and the unit was shut down. The unit remained shut down until December 9, 2024, when the station entered mode 2 and commenced start-up procedures.
On December 11, 2023, the unit returned to approximately 94 percent power where it remained 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 activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensees performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)emergency diesel generator train B while emergency generator train A was inoperable on October 10, 2024 (2)high-pressure safety injection train B on October 31, 2024 (3)emergency feedwater train B on November 20, 2024
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (8 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 area RAB 37-001, elevation -35.00 feet motor driven emergency feed pump room A on October 23, 2024 (2)fire area RAB 38-001, elevation -35.00 feet motor driven emergency feed pump room B on October 23, 2024 (3)fire area RAB 36-001, elevation -35.00 feet safety injection pump room A on October 24, 2024 (4)fire area RAB 35-001, elevation -35.00 feet safety injection pump room B on October 24, 2024 (5)fire area RAB 19-001, elevation +21.00 feet component cooling water pump room A on October 31, 2024 (6)fire area RAB 21-001, elevation +21.00 feet component cooling water pump room B on October 31, 2024 (7)fire area RAB 8B-001, 8B, 8E, 8F, elevation +21.00 feet switchgear room B on December 27, 2024 (8)fire area RAB 8C-001, elevation +21.00 feet switchgear room A/B, on December 27, 2024
Fire Brigade Drill Performance Sample (IP Section 03.02) (2 Samples)
- (1) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill on October 11, 2024.
- (2) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill on November 18, 2024.
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
- (1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered on September 02 to October 3, 2024.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (3 Samples)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during shield building ventilation B post-maintenance testing on October 31, 2024.
- (2) The inspectors observed and evaluated licensed operator performance in the control room during control element assembly testing on November 7, 2024.
- (3) The inspectors observed and evaluated licensed operator performance in the control room during reactor startup on December 9, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator training scenario in the simulator on November 5, 2024.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
(1)shield building ventilation trains A and B on November 6, 2024 (2)emergency feedwater trains A and B on November 13, 2024
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
(1)reactor coolant pump 1A oil addition on December 19, 2024
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 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)elevated risk due to planned maintenance outage of component cooling water system train A on October 2, 2024 (2)elevated risk due to planned maintenance on emergency feedwater pump AB on November 6, 2024 (3)elevated risk due to planned maintenance on emergency feedwater pump B on November 20, 2024 (4)elevated risk due to maintenance on emergency diesel generator A on December 27, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (7 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
(1)reactor coolant pump 2B after a failed bleed rate test on snubber PD18113253 on October 1, 2024 (2)charging pump A high oil pressure on October 28, 2024 (3)pressurizer after hot leg 2 went lower than normal for one second and pressurizer level hi-hi annunciator was received and cleared on November 1, 2024 (4)low pressure safety injection recirculation valve, SI-1161B, due to condensation discovered while troubleshooting for a stroke time issue on December 16, 2024 (5)component cooling water dry cooling tower tube bundle inlet drain for excessive corrosion on December 16, 2024 (6)train B pressurizer heater capacity due to a 49 percent reduction in one operating cycle on December 17, 2024 (7)train B emergency feedwater piping for corrosion on December 18, 2024
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)temporary modification EC-0054066875 to provide a temporary instrument air compressor to provide additional compressed air to the instrument air system and station air system on December 12, 2024
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (11 Samples)
(1)component cooling water pump A after planned maintenance on October 2, 2024 (2)auxiliary component cooling water pump A after planned maintenance on October 3, 2024 (3)emergency diesel generator A after repairs made due to erratic MVAR indications and a disconnected governor linkage on October 10, 2024 (4)essential chiller A after planned maintenance on October 15, 2024 (5)containment spray pump B after planned maintenance on October 22, 2024 (6)shield building ventilation A planned maintenance on October 31, 2024 (7)emergency diesel generator A after planned maintenance on November 5, 2024 (8)high-pressure safety injection A after planned maintenance on November 5, 2024 (9)reactor trip circuit breaker 5 after planned maintenance on November 6, 2024 (10)emergency diesel generator B after planned maintenance on November 11, 2024 (11)emergency diesel generator A after planned maintenance on December 26, 2024
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
- (1) The inspectors evaluated the following documents and records related to the maintenance and testing of the offsite emergency alert and notification system:
- Licensee procedures for system maintenance
- Licensee procedures for system testing
- Condition reports associated with the emergency alert and notification system
- Records of monthly silent and audible tests of the alert and notification system
- Records of the annual preventative maintenance activities for the alert and notification system
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02) (1 Sample)
- (1) The inspectors validated that the licensee had sufficient emergency responders to respond to an emergency event at their facility and evaluated the licensee's ability to staff their emergency response facilities in a timely manner. The inspectors reviewed the current licensee Shift Staffing study, licensee procedures for staffing their emergency response facilities, rosters of emergency response organization positions and personnel, licensee procedures for testing the staffing of emergency response facilities, and records from quarterly tests of the staffing of licensees emergency response facilities.
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The inspectors reviewed the licensee's procedures for performing evaluations of changes to the licensee's emergency plan and procedures and the licensee's Emergency Action Levels. There were no unreviewed changes to the licensees emergency plan and emergency action levels available for review.
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11) (1 Sample)
- (1) The inspectors evaluated the licensee's maintenance of their emergency preparedness program. The inspectors reviewed licensee procedures for performing routine emergency preparedness activities, reviewed licensee critiques of drills and exercises conducted in the inspection period, reviewed condition reports related to the emergency preparedness program generated during the inspection period, reviewed surveillances of the licensee's emergency preparedness facilities conducted in the inspection period, reviewed the licensee's program for the training of the emergency response organization, and evaluated the effectiveness of the licensee's interface with offsite emergency response organizations.
71114.06 - Drill Evaluation
Additional Drill and/or Training Evolution (2 Samples)
The inspectors evaluated:
- (1) Simulator exam observation on October 22, 2024
- (2) Simulator exam observation on October 29,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10)===
- (1) October 1, 2023, through September 30, 2024
BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)
- (1) October 1, 2023, through September 30, 2024
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
The inspectors reviewed the licensee's reported Drill and Exercise Performance (DEP)performance indicator statistic for the fourth quarter 2023 through the third quarter 2024.
The inspectors reviewed drill and exercise scenarios to identify DEP opportunities and evaluated the licensee's conduct and critique of DEP opportunities to validate the accuracy of the reported DEP statistic.
- (1) January 1, 2023, through June 30, 2024 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
The inspectors reviewed the licensee's reported Emergency Response Organization (ERO)drill participation performance indicator statistic for the fourth quarter 2023 through the third quarter 2024. The inspectors reviewed records of the associated drill and exercise performance opportunities, the roster of key emergency response personnel, the training status of key emergency response personnel, and the licensee's critique of drill and exercise performance to validate the accuracy of the reported ERO statistic.
- (1) January 1, 2023, through June 30, 2024 EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
The inspectors reviewed the licensee's reported Alert and Notification System (ANS)reliability performance indicator statistic for the fourth quarter 2023 through the third quarter 2024. The inspectors reviewed the licensee's procedures for testing the offsite emergency alert and notification system, and records of monthly silent and audible tests of the alert and notification system to validate the accuracy of the reported ANS statistic.
- (1) January 1, 2023, through June 30, 2024
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed the licensees corrective action program to identify potential trends in safety systems, structures, and components that might be indicative of a more significant safety issue. Specifically, the inspectors reviewed condition reports, system health reports, and extended unplanned technical specification entries (where applicable) regarding safety chillers, emergency diesel generators A and B, and instrument air. No issues of more than minor significance were identified.
INSPECTION RESULTS
Failure to Comply with Requirements of the Emergency Plan Cornerstone Significance Cross-Cutting Aspect Report Section Emergency Preparedness Green NCV 05000382/2024004-01 Open/Closed
[P.1] -
Identification 71114.05 The inspectors identified a Green finding and associated non-cited violation of 10 CFR 50.54(q)(2)(i) associated with the licensees failure to follow their emergency plan.
Specifically, the inspectors identified three examples in which the licensee failed to follow requirements of the licensees emergency plan related to the conduct of drills and exercises.
Description:
The inspectors reviewed records of drills and exercises conducted by the licensee in 2022, 2023, and 2024, and compared the drills conducted to the requirements of the Waterford Steam Electric Station, Unit 3, Emergency Plan revision 52, dated August 02, 2021, section 8.1.2.4. The inspectors identified three examples for not complying with the requirements of the emergency plan.
In the first example, between January 1 through December 31, 2023, the licensee failed to conduct a required offsite medical drill as required by section 8.1.2.4(4) of the licensee emergency plan. Section 8.1.2.4(4) requires, in part, that a medical emergency drill, involving a simulated contaminated individual shall be conducted annually, and that the offsite portions of the medical drill may be performed as part of an exercise. The licensee performed an onsite contaminated injured worker medical drill on March 21, 2023, but did not conduct an offsite portion of the medical drill at any time during the year.
The Waterford Emergency Plan, Appendix I, section 3.0, Responsibilities, requires, in part, that the licensee3.1.4 provide technical guidance and assistance to protect emergency medical personnel involved in the treatment and transportation of the radiation accident patient, 3.1.5 provide a Health Physics Technician to support hospital emergency departments with monitoring and decontamination of the radiation accident patient, 3.1.6 provide personnel, equipment, and facilities for the radiological monitoring and decontamination of any and all ambulance vehicles and equipment, 3.1.8 coordinate medical drills per calendar year involving a simulated contaminated patient which require participation by local offsite emergency medical services. Section 8.1.2.4(2)(A) of the licensee Emergency Plan, states, in part, that a medical emergency drill involving a simulated contaminated individual is conducted annually and that the offsite portions of the medical drill may be performed as part of an exercise or other scheduled drills. Section 8.1.2.4(2)(A) establishes that the annual medical drill requires both onsite and offsite activities, although not necessarily as a single activity. The licensee did not conduct an offsite medical drill during 2023 as required by the licensees Emergency Plan Section 8.1.2.4(4) and Appendix I, section 3.1.8.
In the second example, between January 1 through December 31, 2023, the licensee failed to conduct a required communication drill, as required by section 8.1.2.4(2)(A). The licensee emergency plan required that communications be tested between the licensee's emergency operations facility and offsite radiological monitoring (field) teams, including verifying that the content of messages were understood. The licensee conducted drills and exercises on March 21, 2023, May 2, 2023, June 21, 2023, August 15, 2023, and September 19, 2023 in which radiological monitoring teams were deployed offsite and evaluated the radiological monitoring function using the licensee's exercise evaluation checklist. However, section 8.1.2.5 has required attributes of a drill, which include drill-specific objectives and evaluation criteria, the dates and times and places and organizations participating in the drill, the simulated events which constitute the drill, a narrative summary describing the conduct of the drill (ground rules), and a drill specific critique. The evaluations of the radiological monitoring function lacked these drill attributes as the licensee did not consider the evaluations to be drills. Although the licensee conducted drills that met the requirements of section 8.1.2.5, the licensee failed to identify this issue as a noncompliance with requirements of the licensee's emergency plan.
The licensee takes credit for the overall exercise scenario as meeting the drill requirements 8.1.2.5(2), 8.1.2.5(3), and 8.1.2.5(4). The inspectors evaluated six exercise scenario and concluded that exercise scenarios do not have the depth of detail as the simulated events as they apply to offsite monitoring teams and the evaluation of communications to and from the teams. The licensee also takes credit for objectives in their Standard Evaluation Checklist as meeting the drill requirement 8.1.2.5(1) objectives and evaluation criteria. The licensee has four evaluation objectives in their Standard Evaluation Checklist which are related to the evaluation of communications to and from offsite monitoring teams.
- Evaluation Objective F4.4 (team communications were used effectively to transmit and document information necessary for assigned task completion and personnel safety)
- Evaluation Objective I6.9 (teams communicate radiological information to dose assessment staff)
- Evaluation Objective I7.4) (teams report survey results accurately and in a timely manner)
- Evaluation Objective I8.3 (teams are kept aware of plant conditions)
The inspectors concluded that none of the four relevant evaluation objectives fully incorporates or evaluates the understanding of messages. For the licensee evaluations that were reviewed by the inspectors, none of the licensee evaluations provided any comments concerning any of the four objectives, all were rated satisfactory without comment.
In the third example, between January 1 through December 31, 2023, the licensee failed, to comply with the requirements of section 8.1.2 of the licensee emergency plan, Drills and Exercises. Section 8.1.2 requires, in part, that the licensee conduct drills and exercises to meet the following objectives...(1) ensure that the participants are familiar with their respective duties and responsibilities...(3) test communications networks and systems. The licensee failed to ensure that Health Physics Communicators were familiar with their duties and responsibilities in that the Health Physics Communicator position was not staffed for any drills or exercises between January 1 through December 31, 2023. Licensee procedure EP-001-102, Emergency Operations Facility Activation, Operations, and Deactivation, revision 311, Radiological Assessment Coordinator Instruction, section 1.5 states that when responsibilities are transferred to the EOF then the RAC is the contact for the NRC Health Physics line. Section 2.8 states that the RAC is the contact for the NRC Health Physic Network line when activities are transferred to the EOF. (A) Personnel assigned to the man this line should be knowledgeable of the following dose assessment parametersSource Term InformationRelease Pathway Information Current Meteorology(B) Ensure that the HPN line at the TSC is manned to provide plant radiological data to the NRC. The Radiological Assessment Coordinator also has other assigned duties, such as assessing overseeing dose assessment, and communicating with offsite emergency monitoring teams.
The Radiological Coordinator did not have to demonstrate the ability to simultaneously perform their other duties while maintaining open line communication with the NRC because the simulated NRC did not request staffing the Health Physics Network. Section 2.8(A)implies, but does not state, that the RAC may assign other health physics personnel to the Health Physics Network, the RAC did not demonstrate this assignment because the Health Physics Network was not requested to be staffed. Licensee evaluators were unable to evaluate whether the RAC assigned personnel with the skills listed in section 2.8(A) or evaluate the effect on the duties of the health physics staff in the emergency response facility when another individual is assigned to open-line communication with the NRC.
Corrective Actions: The licensee entered these issues into the corrective action program.
Performance Assessment:
Performance Deficiency: The inspectors determined that the failure to follow the emergency plan with respect to the conduct of drills and exercises is a performance deficiency within the licensees ability to foresee and correct.
Screening: The inspectors determined the performance deficiency was more than minor, and therefore a finding, because it was associated with the Emergency Response Organization Readiness attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The emergency response organization may not be capable of implement adequate measures to protect the health and safety of the public, and of emergency workers, when drills have not been conducted to maintain the emergency response organizations familiarity with their duties and responsibilities.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix B, Emergency Preparedness SDP. The performance deficiency was determined to have very low safety significance (Green) because it was a failure to comply with NRC requirements, was not a loss of planning standard function, and was not a degraded risk-significant planning standard function. The planning standard function was not lost because the licensee did not fail to conduct three drills during a two-year period.
Cross-Cutting Aspect: P.1 - Identification: The organization implements a corrective action program with a low threshold for identifying issues, individuals identify issues completely, accurately, and in a timely manner in accordance with the program. Specifically, the licensee had opportunities to identify the drills which were not conducted through the licensees audit and assessment programs, and the licensees drill and exercise procedure, and failed to identify the missed requirements.
Enforcement:
Violation: Title 10 CFR 50.54(q)(2)(i) requires, in part, a power reactor licensee follow an emergency plan which meets the requirements of Appendix E to 10 CFR 50 and the standards of 10 CFR 50.47(b).
Contrary to the above, the licensee between January 1, 2023, and December 31, 2023, failed to follow and maintain the effectiveness of an emergency plan which met the requirements of 10 CFR 50 Appendix E and the planning standards of 10 CFR 50.47(b). Specifically, three examples were identified in which the licensee failed to comply with requirements of licensee's approved emergency plan:
- (1) the licensee failed to conduct an offsite medical drill as required by section 8.1.2.4(4);
- (2) the licensee failed to conduct a communications drill as required by section 8.1.2.4(2)(A); and
- (3) the licensee failed to ensure that health physics communicators were familiar with their duties and responsibilities as required by section 8.1.2 of the emergency plan.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On November 21, 2024, the inspectors presented the emergency preparedness program inspection results to John Twarog, Regulatory Assurance Manager, and other members of the licensee staff.
- On January 27, 2025, the inspectors presented the integrated inspection results to Joseph Sullivan, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Drawings
G153
Flow Diagram Feedwater, Condensate & Air Evacuation
Systems
Procedures
OP-009-002
360
Procedures
OP-009-003
Emergency Feedwater
313
Procedures
OP-009-008
Safety Injection System
Procedures
OP-903-045
Emergency Feedwater Flow Path Lineup Verification
Fire Plans
RAB 19-001
Component Cooling Water Pump A
Fire Plans
RAB 21-001
Component Cooling Water Pump B
Fire Plans
RAB 35-001
Safety Injection Pump Room B
Fire Plans
RAB 36-001
Safety Injection Pump Room A
Fire Plans
RAB 37-001
Motor Driven Emergency Feed Pump Room A
Fire Plans
RAB 38-001
Motor Driven Emergency Feed Pump Room B
Fire Plans
RAB 8B, 8E, 8F
Switchgear Room B
Fire Plans
Switchgear Room B
Fire Plans
Switchgear Room A/B
Miscellaneous
24 WF3 LOR Annual Operating Exam Results
10/10/2024
Engineering
Changes
EC TO CHANGE RCP OIL TYPE FROM MOBIL SHC-626
TO CONOCO PHILIPS SYNCON SYNTHETIC R&O 68
Miscellaneous
TD-G080.0415
Robertshaw Instruction Manual for Model 158A Level-Tel
909GF197
Work Orders
54186935
10/01/2024
Corrective Action
Documents
CR-WF3-2023-13759, CR-WF3-2023-17123, CR-WF3-2023-
17876, 2023-16830, CR-WF3-2024-04707, CR-WF3-2024-
222, CR-WF3-2024-05295
Engineering
Changes
CR-WF3-2023-16830-00001 Evaluate Effects of RC-MSNB-
253-2B Failure on RCS Operability (TRM 3.7.8)
Miscellaneous
TD-E250.0065
Enertech Hydraulic Shock Suppressors for Reactor Coolant
System (RCS) Component Support Installation & Operation
& Maintenance Manual
Work Orders
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
9/29/2020
Corrective Action
Documents
10/17/2023
Engineering
Changes
0054066875
Install Temporary Air Compressor to SA
000
Engineering
Changes
0054115699
Instrument Air Compressor Replacement
000
Procedures
Engineering Change Process
034
Procedures
2
Corrective Action
Documents
24-04923, 2024-04960, 2024-04987, 2024-04988, 2024-
06017
Procedures
OP-009-002
360
Procedures
OP-903-006
Reactor Trip Circuit Breaker Test
Procedures
OP-903-013
Monthly Channel Checks
Procedures
OP-903-030
Safety Injection Pump Operability Verification
Procedures
OP-903-035
Containment spray pump operability check
Procedures
OP-903-043
Shield Building Ventilation Operability Check
317
Procedures
OP-903-050
Component Cooling Water and Auxiliary Component Cooling
Water Pump and Valve Operability Test
Procedures
OP-903-068
Emergency Diesel Generator and Subgroup Relay
Operability Verification
27
Procedures
OP-903-094
ESFAS Subgroup Relay Test - Operating
Procedures
OP-903-118
Primary Auxiliaries Quarterly IST Valve Tests
Work Orders
53019538, 54165262, 54171135, 54165604, 54166061,
54187278, 54198399, 54199348, 53032624, 53021092,
22309, 54085149, 53022474
Work Orders
Miscellaneous
10CFR50.54(Q) Screening, Movement of Siren SC5
03/01/2024
Miscellaneous
Monthly Helicopter Warning System Maintenance Checklists,
January 2023 through August 2024
Miscellaneous
Monthly Siren System Audible Test Record, January 2023
through September 2024
Miscellaneous
Monthly Silent Siren System Activation Test Record, January
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
23 through September 2024
Miscellaneous
Siren Maintenance Tickets 6506, 6512, 6541, 6544, 6551
Miscellaneous
Letter dated January 20, 2020, from Oscar Martinez Jr.,
FEMA Region IV Regional Assistance Committee Chair to
Jerry Lang, Administrator, Louisiana Department of
Environmental Quality, Assessment Division, approving
Revision 9 to the Waterford3 Alert and Notification System
Design Report
Miscellaneous
Updated Alert and Notification System Design Report for
Waterford3 Steam Electric Station
01/20/2023
Procedures
EPP-422
Siren and Helicopter Warning System Maintenance, R17
04/24/2024
Procedures
EPP-424
Siren Testing and Siren System Administrative Controls, R23
06/13/2024
Work Orders
22 Annual Siren Preventive Maintenance Report
08/08/2022
Work Orders
23 Annual Siren Preventive Maintenance Report
09/13/2023
Miscellaneous
Waterford3 Emergency Response Organization Rosters,
1Q2023 through 2Q2024
Miscellaneous
Quarterly Emergency Response Organization Callout Tests,
1Q2023 through 2Q2024
Procedures
EPP-462
Evaluation of ERO Callout Test, R7
2/06/2021
Miscellaneous
10CFR50.54(Q) Screening for the 2022 Evacuation Time
Estimate Study Impact on Protective Action
Recommendations
09/08/2023
Miscellaneous
10CFR50.54(Q) Screening, Movement of Siren SC5
03/11/2024
Procedures
Emergency Planning 10CFR50.54(Q) Review Program, R8
2/12/2019
Corrective Action
Documents
After Action Report for the Declared Unusual Event at
Waterford3 due to a Main Transformer B Fire
04/02/2024
Corrective Action
Documents
After Action Report for the Medical Services and Exception
Drill at Ochsner Medical Center, St. Charles Parish
03/28/2024
Corrective Action
Documents
Training Attendance Roster for the 2024 Annual Offsite
Agency EAL Training
08/17/2024
Corrective Action
Documents
Corrective Action
Documents
Training Attendance Roster for the 2023 Annual Offsite
Agency EAL Training
10/12/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
2018-00160-46, 2022: 07490, 07514, 07670, 07752, 07999,
253; 2023: 00891, 01455, 01554, 01803, 02086, 02103,
275, 13680, 13891,13932. 13942, 13952. 13971, 14361,
14671, 14817, 15018, 15016, 15020, 15061, 15550, 18226,
18365; 2024: 00456, 00595, 00776, 01007, 01163, 02685,
03866, 04304, 04390, 04783
Miscellaneous
Site Accountability Drill
2/22/2023
Miscellaneous
Medical Emergency Drill Critique
03/21/2023
Miscellaneous
Red Team Dress Rehearsal Exercise Critique
05/02/2023
Miscellaneous
Red Team Biennial Exercise Critique
06/21/2023
Miscellaneous
Green Team WANO Dress Rehearsal Exercise Critique
08/15/2023
Miscellaneous
Orange Team Exercise Critique
03/21/2023
Miscellaneous
Radiation Monitoring (Sampling) Drill Critique
03/21/2023
Miscellaneous
Green Team WANO Observed Exercise Critique
09/10/2023
Miscellaneous
Orange Team Exercise Critique
03/21/2023
Miscellaneous
Green and Blue Teams Turnover Exercise Critique
08/27/2024
Miscellaneous
Radiation Protect Drill Critique, 2023-05
05/02/2023
Miscellaneous
Audit QA-7-2023-
W3-01
Emergency Preparedness Audit
03/23/2023
Miscellaneous
Drill 2023-20
Control Room Breathing Air Drill Critique
09/05/2023
Miscellaneous
Drill 2024-06
Semi-Annual Health Physics Drill Critique
06/10/2024
Miscellaneous
Drill 2024-14
Control Room Breathing Air Drill
06/11/2024
Miscellaneous
IT2023
Nuclear Independent Oversight Functional Area
Performance Report
06/13/2023
Miscellaneous
KLD-TR-24-1422
Final 2024 Population Update for the Waterford3 Evacuation
Time Estimate
07/16/2024
Miscellaneous
KLD_TR-1336
Final 2023 Population Update for the Waterford3 Evacuation
Time Estimate
07/17/2023
Miscellaneous
LO-WF3-2023-
00082
Pre-NRC Emergency Planning Program Inspection
Assessment
07/01/2024
Miscellaneous
LO-WLO-2021-
00068
23 Pre-NRC Evaluated Exercise Assessment
05/25/2023
Miscellaneous
Surveillance
Report QS-2024-
24 Fleet NIOS Surveillance for Implementing a 24-month
Frequency for the Emergency Preparedness Program
04/25/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
ECH-001
Miscellaneous
Control Room Emergency Breathing Air Drill
Procedures
Waterford3 Appendix B, Evacuation Time Estimate Criteria,
Table B-1, ETE Review Criteria Checklist
Procedures
Waterford3 Emergency Plan, R52
07/31/2021
Procedures
Corrective Action Program, R52
05/01/2024
Procedures
Self Assessment and Benchmark Process, R19
2/29/2024
Procedures
Emergency Preparedness Drills and Exercises, R304
2/19/2016
71151
Procedures
EPP-001-001
Recognition and Classification of Emergency Conditions,
R37
10/25/2022
71151
Procedures
EPP-001-010
Unusual Event, R308
07/18/2023
71151
Procedures
EPP-001-020
Alert, R312
07/18/2023
71151
Procedures
EPP-001-030
Site Area Emergency, R311
07/18/2023
71151
Procedures
EPP-001-040
General Emergency. R312
07/18/2023
71151
Procedures
EPP-002-010
Notification and Communication, R317
08/02/2021
71151
Procedures
EPP-002-050
Offsite Dose Assessment, R309
01/08/2023
71151
Procedures
EPP-002-052
Protective Action Guidelines, R27
08/21/2021