ML13324B133
| ML13324B133 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/20/2013 |
| From: | Greg Werner NRC/RGN-IV/DRP/RPB-E |
| To: | Jacobs D Entergy Operations |
| References | |
| EA-12-257 IR-13-004 | |
| Download: ML13324B133 (66) | |
See also: IR 05000382/2013004
Text
UNITED STATE S
NUC LEAR REGULATOR Y C OMMI S SI ON
R E G IO N I V
1600 EAST LAMAR BLVD
AR L INGTON , TEXAS 76011- 4511
November 20, 2013
Donna Jacobs, Vice President, Operations
Entergy Operations, Inc.
Waterford Steam Electric Station, Unit 3
Killona, LA 70057-0751
SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED
INSPECTION REPORT 05000382/2013004
Dear Ms. Jacobs:
On September 30, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Waterford Steam Electric Station, Unit 3 facility. On October 1, 2013, the
NRC inspectors discussed the results of this inspection with you and other members of your
staff. Inspectors documented the results of this inspection in the enclosed inspection report.
NRC inspectors documented two findings of very low safety significance (Green) in this report.
Further, inspectors documented a licensee-identified violation which was determined to be a
Severity Level IV in this report. All of these findings involved violations of NRC requirements.
The NRC is treating these violations as non-cited violations (NCVs) consistent with
Section 2.3.2.a of the Enforcement Policy.
In addition, the enclosed inspection report discusses a Severity Level IV violation that was
identified during the closure of unresolved item 05000382/2009010-01, documented in NRC
Inspection Report 05000382/2009010 (ML093100238). This violation was evaluated in
accordance with the NRC Enforcement Policy, dated September 1, 2009, (ML092440278)
which was in effect at the time the special inspection report was issued. In accordance with
Supplement VII, Section C.6, of that Enforcement Policy, this violation would normally be
assessed as Severity Level III. However, in accordance with the Enforcement Policy, the
severity level of an untimely report may be reduced depending on the circumstances
surrounding the matter. Since the affected components were already removed from service as
part of an unrelated manufacturers recall and no longer considered a substantial safety hazard,
the NRC concluded this violation is more appropriately assessed as Severity Level IV with a
written response required.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. If you have additional information that you
believe the NRC should consider, you may provide it in your response to the Notice. The NRCs
review of your response to the Notice will also determine whether further enforcement action is
necessary to ensure compliance with regulatory requirements.
D. Jacobs -2-
If you contest the violation or significance of these NCVs, you should provide a response within
30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear
Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with
copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, U.S.
Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector
at the Waterford Steam Electric Station, Unit 3 facility.
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 Regional Administrator,
Region IV; and the NRC resident inspector at the Waterford Steam Electric Station, Unit 3
facility.
In accordance with Title 10 of the Code of Federal Regulations (10CFR) 2.390, Public
Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your
response (if any) will be available electronically for public inspection in the NRCs Public
Document Room or from the Publicly Available Records (PARS) component of the NRC's
Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible
from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic
Reading Room).
Sincerely,
/RA/ Michael R. Bloodgood for
Gregory E. Werner, Acting Chief
Project Branch E
Division of Reactor Projects
Docket No.: 50-382
License No.: NPF-38
Enclosures:
1. Notice of Violation EA-12-257
2. Inspection Report 05000382/2013004
w/Attachment: Supplemental Information
Electronic Distribution to Waterford Steam Electric Station, Unit 3
SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials MD
Publicly Avail. Yes No Sensitive Yes No Sens. Type Initials MD
SRI:DRP/E RI:DRP/E C:DRP/E C:DRS/EB1 C:DRS/EB2 C:DRS/OB
MDavis CSpeer GWerner TFarnholtz GMiller VGaddy
/RA/ E /RA/ E /RA/ /RA/ /RA/ /RA/
11/14/13 11/14/13 11/15/13 11/15/13 11/18/13 11/18/13
C:DRS/PSB1 C:DRS/PSB2 C:DRS/TSB C:ORA/ACES BC:DRP/E
MHaire JDrake RKellar HGepford GWerner
/RA/ /RA/ /RA/ /RA/ /RA/MBloodgood for
11/15/13 11/18/13 11/18/13 11/18/13 11/20/2013
NOTICE OF VIOLATION
Entergy Operations, Inc. Docket No: 50-382
Waterford Steam Electric Station, Unit 3 License No: NPF-38
During the NRC inspection conducted from July 20-October 19, 2009, a violation of the NRC
requirements was identified. In accordance with the NRC Enforcement Policy, the violation is
listed below:
Title 10 CFR, Part 21.21(a)(1) requires, in part, that entities subject to the regulations in
this part shall evaluate deviations and failures to comply to identify defects associated
with substantial safety hazards as soon as practicable, and except as provided in
paragraph (a)(2) of this section, in all cases within 60 days of discovery, in order to
identify a reportable defect that could create a substantial safety hazard, were it to
remain uncorrected.
Title 10 CFR, Part 21.21(a)(2) requires, in part, that entities subject to the regulations in
the part shall ensure that if an evaluation of identified deviation or failure to comply
potentially associated with a substantial safety hazard cannot be completed within
60 days from discovery of the deviation or failure to comply, an interim report is prepared
and submitted to the Commission. The interim report must be submitted in writing within
60 days of discovery of the deviation of failure to comply.
Contrary to the above, from December 14, 2008 to April 29, 2010, the licensee failed to
evaluate deviations and failures to comply to identify defects associated with substantial
safety hazards as soon as practicable and to submit a report or interim report within
60 days of its discovery, in order to identify a reportable defect or failure to comply that
could create a substantial safety hazard, were it to remain uncorrected.
Specifically, on October 14, 2008, the licensee performed bench testing on an Agastat
E7024PB relay with date code 0835 and noted that the relay had a loose terminal point.
Two more relays were obtained from the warehouse; one of these also had a bad
terminal point. On October 27, 2008, the licensee quarantined the remaining four relays
in stock. Two of these quarantined relays were identified to have similarly deficient
terminal points. The licensee identified these relays as defective and returned them to
the manufacturer, for cause evaluation. All four affected relays shared a date code of
0835. On January 28, 2009, the licensee received a report from the manufacturer,
which did not provide a cause evaluation. On August 18, 2009, the licensee submitted
Licensee Event Report 2009-003-00, (ML092310548). This Licensee Event Report did
not mention the date code 0835 relays or loose terminal points. Rather, the Licensee
Event Report described relays that failed due to incorrect adjustment of terminal blocks,
a deviation different from that observed in the 0835 date code relays. On April 29, 2010,
the licensee issued updated Licensee Event Report 2009003-01 (ML101230323). This
revision to the Licensee Event Report described loose terminal points on two spare date
code 0835 relays as one of the defects identified in its Agastat E7024PB relays. The
April 29, 2010, Licensee Event Report revision would have met Part 21 evaluation and
reporting requirements, but it was 501 days late.
-1- Enclosure 1
This is a Severity Level IV violation (Supplement VII of Enforcement Policy dated September 1,
2009).
Pursuant to the provisions of 10 CFR 2.201, the Waterford Steam Electric Station, Unit 3 is
hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the
Regional Administrator, Region IV, and a copy to the NRC Resident Inspector at the facility that
is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of
Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of
Violation; EA 12-257" and should include (1) the reason for the violation, or, if contested, the
basis for disputing the violation or severity level, (2) the corrective steps that have been taken
and the results achieved, (3) the corrective steps that will be taken, and (4) the date when full
compliance will be achieved. Your response may reference or include previous docketed
correspondence, if the correspondence adequately addresses the required response. If an
adequate reply is not received within the time specified in this Notice, an order or a Demand for
Information may be issued as to why the license should not be modified, suspended, or
revoked, or why such other action as may be proper should not be taken. Where good cause is
shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the NRCs document system (ADAMS), accessible from the
NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not
include any personal privacy, proprietary, or safeguards information so that it can be made
available to the public without redaction. If personal privacy or proprietary information is
necessary to provide an acceptable response, then please provide a bracketed copy of your
response that identifies the information that should be protected and a redacted copy of your
response that deletes such information. If you request withholding of such material, you must
specifically identify the portions of your response that you seek to have withheld and provide in
detail the bases for your claim of withholding (e.g., explain why the disclosure of information will
create an unwarranted invasion of personal privacy or provide the information required
by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial
information). If safeguards information is necessary to provide an acceptable response, please
provide the level of protection described in 10 CFR 73.21.
Dated this 20th day of November 2013
-2- Enclosure 1
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 05000382
License: NPF-38
Report: 05000382/2013004
Licensee: Entergy Operations, Inc.
Facility: Waterford Steam Electric Station, Unit 3
Location: 17265 River Road
Killona, LA 70057
Dates: July 1 through September 30, 2013
Inspectors: M. Davis, Senior Resident Inspector
C. Speer, Resident Inspector
T. Farina, Operations Engineer
C. Steely, Operations Engineer
L. Carson, Senior Health Physicist
L. Ricketson, Senior Health Physicist
C. Alldredge, Health Physicist
N. Greene, Health Physicist
P. Hernandez, Health Physicist
J. ODonnell, Health Physicist
E. Ruesch, Senior Reactor Engineer
Approved G. Werner, Acting Chief
By: Project Branch E
Division of Reactor Projects
-1- Enclosure 2
SUMMARY OF FINDINGS
IR 05000382/2013004; 07/01/2013 - 09/30/2013; Waterford Steam Electric Station, Unit 3,
Integrated Resident and Regional Report; Fire Protection, Post-Maintenance Testing, and Other
Activities.
The report covered a 3-month period of inspection by resident inspectors and an announced
baseline inspections by region-based inspectors. Two Green non-cited violations and one
severity level IV violation were identified. The significance of most findings is indicated by their
color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609, Significance
Determination Process. The cross-cutting aspect is determined using Inspection Manual
Chapter 0310, Components Within the Cross-Cutting Areas. Findings for which the
significance determination process does not apply may be Green or be assigned a severity level
after NRC management review. The NRC's program for overseeing the safe operation of
commercial nuclear power reactors is described in NUREG - 1649, Reactor Oversight
Process, Revision 4, dated December 2006.
A. NRC-Identified Findings and Self-Revealing Findings
Cornerstone: Mitigating Systems
- Green. The inspectors identified a non-cited violation of Waterfords Facility
Operating License Number NPF-38, License Condition 2.C.9, because the licensee
did not implement fire protection procedure FP-001-014, Duties of a Fire Watch.
Specifically, the licensees fire watch personnel did not implement Section 6.5 of
FP-001-014 to remove firefighting equipment from work areas when securing from a
fire watch. As a result, multiple undercharged fire extinguishers were left in a fire
area. The inspectors determined that this would affect safety-related equipment
because it would delay the response to fires in the fire areas. The licensee entered
this condition into their corrective action program as CR-WF3-2013-03398 and
CR-WF3-2013-03523 for resolution. The immediate corrective actions taken to
restore compliance included the removal of all undercharged fire extinguishers from
deactivated posts and returning them to their proper storage location.
The failure to implement a fire protection program procedure was a performance
deficiency. The performance deficiency was more than minor because it was
associated with the protection against external factors (i.e., fire) attribute of the
Mitigating Systems Cornerstone and adversely affected the cornerstone objective of
ensuring the availability, reliability, and capability of systems that respond to initiating
events to prevent undesirable consequences. Specifically, the failure to remove
undercharged fire extinguishers from work areas that contained safe shutdown
equipment could hinder responses to fires in the fire area. The inspectors used the
NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of
Findings, to evaluate this issue. The initial screening directed the inspectors to use
Appendix F, Fire Protection Significance Determination Process, to determine the
significance of the finding. The inspectors determined that the finding had a low
degradation rating because it reflected a fire protection program element whose
-2- Enclosure 2
performance and reliability would be minimally impacted. Specifically, in all cases
identified, there were permanent fully charged portable fire extinguishers of the
proper type nearby. Therefore, the finding was of very low safety significance
(Green). The inspectors concluded that the finding reflected current licensee
performance and involved a cross-cutting aspect in the work practices component of
the human performance area in that the licensee did not ensure supervisory and
management oversight of work activities, including contractors, such that nuclear
safety is supported H.4(c) (Section 1R05).
- Green. The inspectors identified a non-cited violation of 10 CFR Part 50,
Appendix B, Criterion V, Instructions, Procedures, and Drawings, because the
licensee did not accomplish activities affecting quality on a degraded safety-related
train B component cooling water (CCW) bypass valve (CC-134B) in accordance with
maintenance procedure EN-MA-101, Fundamentals of Maintenance. Specifically,
the licensee did not control and perform testing on a leaking solenoid valve related to
the operation of a safety-related bypass valve (CC-134B) after maintenance
personnel removed the degraded equipment from service as required by Section
5.10 of EN-MA-101. As a result, the licensee could not characterize and determine
the cause of the leakage for the safety-related valve. The inspectors determined that
this would challenge the safety function of the valve to provide CCW to the ultimate
heat sink following a tornado event. The licensee entered this condition into their
corrective action program as CR-WF3-2012-05991, CR-WF3-2012-06288, and
CR-WF3-2013-04047. The immediate corrective actions taken to restore compliance
included the installation of a new valve and debriefing personnel about controlling
equipment removed from service when combining preventative and corrective
maintenance tasks in one work order.
The failure to control failed equipment removed from the plant to determine the
cause in accordance with maintenance procedure requirements was a performance
deficiency. The performance deficiency was more than minor because it was
associated with the equipment performance attribute of the Mitigating System
Cornerstone and adversely affected the cornerstone objective to ensure the
availability, reliability, and capability of systems that respond to initiating events to
prevent undesirable consequences. Specifically, the degraded condition challenged
the safety function of the valve (CC-134B) to limit the loss of CCW through damaged
portions of the dry cooling tower fans following a tornado-generated missile strike.
The inspectors used the NRC Inspection Manual 0609, Attachment 4, Initial
Characterization of Findings, to evaluate this issue. The finding required a detailed
analysis because it was potentially risk significant for an external event (tornado).
Therefore, the senior reactor analyst performed a bounding detailed risk evaluation.
The senior reactor analyst determined that the finding was of very low safety
significance (Green). The bounding change to the core damage frequency was less
than 3E-7/year. The finding was not significant with respect to the large early
release frequency. The dominant core damage sequences included tornado induced
losses of offsite power, failure of the dry cooling tower pressure boundary, failure to
isolate the damaged dry cooling tower, and failure to recover instrument air. The
redundant train A component cooling water system combined with the tornado
-3- Enclosure 2
frequency helped to reduce the risk exposure. The inspectors concluded that the
finding reflected current licensee performance and involved a cross-cutting aspect in
the work control component of the human performance area in that the licensee did
not appropriately coordinate work activities by incorporating actions to address the
impact of changes to work scope or activity on plant and human performance
H.3(b) (Section 1R19).
Cornerstone: Miscellaneous
- Severity Level IV. The team identified a violation of 10 CFR 21.21 that occurred
when the licensee failed to submit a report or interim report on a deviation in a basic
component within 60 days of discovery.
The failure of the licensee to adequately evaluate deviations in basic components
and to report defects is a performance deficiency. The NRCs significance
determination process (SDP) considers the safety significance of findings by
evaluating their potential safety consequences. This performance deficiency was of
minor safety significance. The traditional enforcement process separately considers
the significance of willful violations, violations that impact the regulatory process, and
violations that result in actual safety consequences. Traditional enforcement applied
to this finding because it involved a violation that impacted the regulatory process.
Supplement VII to the version of the NRC Enforcement Policy that was in effect at
the time the violation was identified provided as an example of a violation of
significant regulatory concern (Severity Level III), An inadequate review or failure to
review such that, if an appropriate review had been made as required, a
10 CFR Part 21 report would have been made. Based on this example, the NRC
determined that the violation met the criteria to be cited as a Severity Level III
violation. However, because of the circumstances surrounding the violation,
including the removal from service of the affected components by an unrelated
manufacturers recall, the severity of the cited violation is being reduced to Severity
Level IV. Cross-cutting aspects are not assigned to traditional enforcement
violations. (Section 4OA5.2)
B. Licensee-Identified Violations
A violation of very low safety significance (Severity Level IV), which was identified by the
licensee, has been reviewed by the inspectors. Corrective actions taken or planned by
the licensee have been entered into the licensees corrective action program. This
violation and associated corrective action tracking numbers are listed in Section 4OA7 of
this report.
-4- Enclosure 2
PLANT STATUS
The Waterford Steam Electric Station, Unit 3, began the inspection period at 100 percent power.
On September 18, 2013, operators commenced a reactor down power to approximately
82 percent to perform maintenance on the normal level control valve 2B and the heater drain
pump B, respectively. Operators began to raise power to 100 percent the same day. The unit
maintained a 100 percent power for the remainder of the inspection period.
REPORT DETAILS
1. REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity and
1R01 Adverse Weather Protection (71111.01)
Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
Since tropical depression Dorian was forecast in the vicinity of the facility for August 4,
2013, the inspectors reviewed the plant personnels overall preparations and protection
for the expected weather conditions. On August 2, 2013, the inspectors did a partial
walkdown of the switchyard and the startup unit transformer systems because their
functions could be affected, as a result of high winds, tornado-generated missiles, or the
loss of offsite power. The inspectors evaluated the plant staffs preparations against site
procedures and determined that the staffs actions were adequate. During the
inspection, the inspectors focused on plant design features and the licensees
procedures to respond to tornadoes and high winds. The inspectors also toured the
plant grounds to look for any loose debris that could become missiles during a tornado.
The inspectors evaluated operator staffing and accessibility of controls and indications
for those systems required to control the plant. Additionally, the inspectors reviewed the
final safety analysis report and performance requirements for the systems selected for
inspection, and verified that operator actions were appropriate as specified by plant-
specific procedures. The inspectors also reviewed a sample of corrective action
program items to verify that the licensee had identified adverse weather issues at an
appropriate threshold and entered them into the corrective action program for resolution.
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of one sample of impending adverse weather
conditions, as defined in Inspection Procedure 71111.01.
b. Findings
No findings were identified.
-5- Enclosure 2
1R04 Equipment Alignment (71111.04)
Partial Walkdown
a. Inspection Scope
The inspectors performed partial system walkdowns of the following risk-significant
systems:
- On July 29, 2013, high pressure safety injection train B while train A was out of
service for maintenance activities
- On August 20, 2013, essential chiller AB while essential chiller B was out of
service for maintenance activities
- On September 5, 2013, auxiliary component cooling water train B while train A
was out of service for maintenance activities
The inspectors selected these systems based on their risk significance relative to the
reactor safety cornerstones at the time they were inspected, while considering out of
service time, inoperable or degraded conditions, recent system outages, and
maintenance, modification, and testing. The inspectors attempted to identify any
discrepancies that could affect the function of the system, and, therefore, potentially
increase risk. The inspectors reviewed applicable operating procedures, system
diagrams, final safety analysis report, technical specification requirements,
administrative technical specifications, outstanding work orders, condition reports, and
the impact of ongoing work activities on redundant trains of equipment in order to identify
conditions that could have rendered the systems incapable of performing their intended
functions. The inspectors also inspected accessible portions of the systems to verify
system components and support equipment were aligned correctly and operable. The
inspectors examined the material condition of the components and observed operating
parameters of equipment to verify that there were no obvious deficiencies. The
inspectors also verified that the licensee had properly identified and resolved equipment
alignment problems that could cause initiating events or impact the capability of
mitigating systems or barriers and entered them into the corrective action program with
the appropriate significance characterization. Specific documents reviewed during this
inspection are listed in the attachment.
These activities constitute completion of three partial system walkdown samples, as
defined in Inspection Procedure 71111.04.
b. Findings
No findings were identified.
-6- Enclosure 2
1R05 Fire Protection (71111.05)
Quarterly Fire Inspection Tours
a. Inspection Scope
The inspectors conducted fire protection walkdowns that were focused on availability,
accessibility, and the condition of firefighting equipment in the following risk-significant
plant areas:
- On July 18, 2013, reactor auxiliary building, fire area 2, heat and ventilation
mechanical room
- On July 30, 2013, reactor auxiliary building, fire area 7, relay room
- On August 12, 2013, reactor auxiliary building, fire area 39, -35 foot elevation
general area
- On August 27, 2013, turbine building, fire area 2, turbine building +15.00 foot
elevation west side area
The inspectors reviewed areas to assess if licensee personnel had implemented a fire
protection program that adequately controlled combustibles and ignition sources within
the plant; effectively maintained fire detection and suppression capability; maintained
passive fire protection features in good material condition; and had implemented
adequate compensatory measures for out of service, degraded or inoperable fire
protection equipment, systems, or features, in accordance with the licensees fire plan.
The inspectors selected fire areas based on their overall contribution to internal fire risk
as documented in the plants Individual Plant Examination of External Events with later
additional insights, their potential to affect equipment that could initiate or mitigate a
plant transient, or their impact on the plants ability to respond to a security event. Using
the documents listed in the attachment, the inspectors verified that fire hoses and
extinguishers were in their designated locations and available for immediate use; that
fire detectors and sprinklers were unobstructed; that transient material loading was
within the analyzed limits; and fire doors, dampers, and penetration seals appeared to
be in satisfactory condition and verified that adequate compensatory measures were put
in place by the licensee for out of service, degraded, or inoperable fire protection
equipment systems or features. The inspectors also verified that minor issues identified
during the inspection were entered into the licensees corrective action program.
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of four quarterly fire protection inspection samples,
as defined in Inspection Procedure 71111.05-05.
b. Findings
Introduction. The inspectors identified a Green non-cited violation of Waterfords Facility
Operating License Number NPF-38, License Condition 2.C.9, because the licensee did
-7- Enclosure 2
not implement fire protection procedure FP-001-014, Duties of a Fire Watch.
Specifically, the licensees fire watch personnel did not implement section 6.5 of
FP-001-014 to remove firefighting equipment from work areas when securing from
a fire watch.
Description. On July 18, 2013, during a walkdown of the reactor auxiliary building (RAB)
fire area number two, inspectors identified an undercharged and improperly stored fire
extinguisher in the fire area. The inspectors communicated this concern to the licensee.
The licensee dispatched personnel to remove the extinguisher and discovered two
additional fire extinguishers in the same area with degraded charges. The licensee
initiated condition report CR-WF3-2013-03398 and removed the undercharged fire
extinguishers from the area. Upon further questioning from the inspectors, the licensee
stated that all of the uncharged fire extinguishers identified and removed from this fire
area were equipment used by fire watch personnel during recent hot work activities. The
inspectors reviewed the initial condition report, hot work permits, fire protection program
procedures EN-DC-127, Control of Hot Work and Ignition Sources, and FP-001-014,
Duties of a Fire Watch. The inspectors noted that procedure FP-001-014 required, in
part, that when a fire watch is deactivated the fire watch shall return all equipment to
their proper storage location. The inspectors determined that the licensees fire watch
personnel did not implement section 6.5.4.2 of FP-001-014 to remove firefighting
equipment from work areas when securing from a fire watch. The inspectors concluded
that this could affect the safety-related equipment located in the area because it would
delay the response to fires in the fire area by using undercharged fire extinguishers.
In addition, the inspectors noted that procedure EN-DC-127 stated, in part, that for hot
work, fire watches shall ensure that the proper fire extinguishers are available and fully
charged. The inspectors questioned if the licensee could confirm if the fire extinguishers
lost their charge after being left in the area over time or if personnel received the
extinguishers uncharged prior to establishing their fire watch. At the time the inspectors
proposed this question, the licensee could not confirm if the fire watch extinguishers
were undercharged because of the improper storage or if personnel was issued
degraded extinguishers. Due to the inspectors questioning, the licensee initiated
another condition report CR-WF3-2013-03523 and determined that no controls existed
to assure fire extinguishers were in acceptable condition prior to assigning them to fire
watches or that fire extinguishers were returned to their proper storage location. The
inspectors concluded that given the lack of controls over the fire watch extinguishers, the
licensee did not ensure supervisory and management oversight of fire watches. As a
result, the licensee established measures for tracking extinguishers prior to and after
being assigned to fire watches. Additionally, the licensee planned to conduct training for
all departments with fire watch responsibilities on procedural requirements.
Analysis. The failure to implement a fire protection program procedure was a
performance deficiency. The inspectors determined that this deficiency was reasonably
within the licensees ability to foresee and correct. The performance deficiency was
more than minor because it was associated with the protection against external factors
(i.e., fire) attribute of the Mitigating Systems Cornerstone and adversely affected the
cornerstone objective of ensuring the availability, reliability, and capability of systems
-8- Enclosure 2
that respond to initiating events to prevent undesirable consequences. Specifically, the
failure to remove undercharged fire extinguishers from work areas could hinder
responses to fires in the area. The inspectors used NRC Inspection Manual
Chapter 0609, Attachment 4, Initial Characterization of Findings, to evaluate this issue.
The initial screening directed the inspectors to use Appendix F, Fire Protection
Significance Determination Process, to determine the significance of the finding. The
inspectors determined that the finding had a low degradation rating because it reflected
a fire protection program element whose performance and reliability would be minimally
impacted. Specifically, in accordance with Appendix F, Attachment 2, in all cases
identified, there were fully charged portable fire extinguishers of the proper type nearby.
Therefore, the finding was of very low safety significance (Green). The inspectors
concluded that the finding reflected current licensee performance and involved a cross-
cutting aspect in the work practices component of human performance area in that the
licensee did not ensure supervisory and management oversight of work activities,
including contractors, such that nuclear safety is supported H.4(c).
Enforcement. Waterfords Facility Operating License Number NPF-38, License
Condition 2.C.9, requires, in part, that the licensee shall implement and maintain in effect
all provisions of the approved fire protection program as described in the Final Safety
Analysis Report for the facility. Final Safety Analysis Report, Section 9.5.1.6.3, specifies
Procedure UNT-005-013, Fire Protection Program, which describes responsibilities,
controls, and implementing requirements for the Waterford 3 Fire Protection Program.
Procedure UNT-005-013, Section 5.9.2 specifies that individual fire watch activities shall
be performed in accordance with Procedure FP-001-014, Duties of A Fire Watch.
Procedure FP-001-014, Section 6.5.4.2, states, in part, that to deactivate a fire watch
post, the fire watch shall return all equipment to their proper storage location.
Contrary to the above, as of July 2013, the licensee failed to comply with License
Condition 2.C.9 to implement and maintain in effect all provisions of the approved fire
protection program as described in the final safety analysis report for the facility and as
approved in the Safety Evaluation Report. Specifically, fire watch personnel failed to
return fire extinguishers assigned to fire watches to their proper storage location when
the fire watch personnel deactivated their fire watch posts. The licensee entered this
condition into their corrective action program as Condition Reports CR-WF3-2013-03398
and CR-WF3-2013-03523 for resolution. The immediate corrective action taken to
restore compliance was to remove and store fire watch extinguishers to their proper
storage location. The planned corrective actions include establishing a tool to track the
return of all equipment once personnel deactivate a fire watch post.
Because this violation was of very low safety significance and the licensee entered the
issue into their corrective action program, this violation was treated as a non-cited
violation, consistent with Section 2.3.2.a of the Enforcement Policy:
(NCV 05000382/2013004-02, Failure to Implement Fire Protection Program Procedure
Requirements When Securing from a Fire Watch.
-9- Enclosure 2
1R06 Flood Protection Measures (71111.06)
a. Inspection Scope
The inspectors reviewed the final safety analysis report, the flooding analysis, and plant
procedures to assess susceptibilities involving internal flooding; reviewed the corrective
action program to determine if licensee personnel identified and corrected flooding
problems; inspected underground bunkers/manholes to verify the adequacy of sump
pumps, level alarm circuits, cable splices subject to submergence, and drainage for
bunkers/manholes; and verified that operator actions for coping with flooding can
reasonably achieve the desired outcomes. The inspectors also inspected the areas
listed below to verify the adequacy of equipment seals located below the flood line, floor
and wall penetration seals, watertight door seals, common drain lines and sumps, sump
pumps, level alarms, and control circuits, and temporary or removable flood barriers.
Specific documents reviewed during this inspection are listed in the attachment.
- On September 16, 2013, heater drain pump B motor feeder cable
- On September 18, 2013, safeguards pump room B
These activities constitute completion of one flood protection measure inspection sample
and one bunker/manhole sample, as defined in Inspection Procedure 71111.06-05.
b. Findings
No findings were identified.
1R07 Heat Sink Performance (71111.07)
a. Inspection Scope
On August 14, 2013, the inspectors reviewed licensee programs, verified performance
against industry standards, and reviewed critical operating parameters and maintenance
records for the essential chillers B and A/B. The inspectors verified that performance
tests were satisfactorily conducted for heat exchangers/heat sinks and reviewed for
problems or errors; the licensee utilized the periodic maintenance method outlined in
EPRI Report NP 7552, Heat Exchanger Performance Monitoring Guidelines; the
licensee properly utilized bio-fouling controls; the licensees heat exchanger inspections
adequately assessed the state of cleanliness of their tubes; and the heat exchanger was
correctly categorized under 10 CFR 50.65, Requirements for Monitoring the
Effectiveness of Maintenance at Nuclear Power Plants. Specific documents reviewed
during this inspection are listed in the attachment.
These activities constitute completion of two heat sink inspection sample, as defined in
Inspection Procedure 71111.07-05.
- 10 - Enclosure 2
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
(71111.11)
.1 Quarterly Review of Licensed Operator Requalification Program
a. Inspection Scope
On July 22, 2013, the inspectors observed a crew of licensed operators in the plants
simulator during training. The inspectors assessed the following areas:
- Licensed operator performance
- The ability of the licensee to administer the evaluations
- The modeling and performance of the control room simulator
- The quality of post-scenario critiques
- Follow-up actions taken by the licensee for identified discrepancies
These activities constitute completion of one quarterly licensed operator requalification
program sample, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
.2 Quarterly Observation of Licensed Operator Performance
a. Inspection Scope
On September 18, 2013, the inspectors observed the performance of on-shift licensed
operators in the plants main control room. At the time of the observations, the plant was
in a period of heightened activity due to reactivity management maneuvers. The
inspectors observed the operators performance of the following activities:
- the pre-job brief
- start-up activities
- reactivity control
In addition, the inspectors assessed the operators adherence to plant procedures,
including conduct of operations procedure and other operations department policies.
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These activities constitute completion of one quarterly licensed-operator performance
sample, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
.3 Licensed Operator Requalification Biennial Inspection (71111.11B)
The licensed operator requalification program involves two training cycles that are
conducted over a 2-year period. In the first cycle, the annual cycle, the operators are
administered an operating test consisting of job performance measures and simulator
scenarios. In the second part of the training cycle, the biennial cycle, operators are
administered an operating test and a comprehensive written examination.
a. Inspection Scope
To assess the performance effectiveness of the licensed operator requalification
program, the inspectors interviewed training staff, reviewed both the operating tests and
written examinations, and observed ongoing operating test activities.
The inspectors reviewed operator performance on the written exams and operating
tests. These reviews included observations of portions of the operating tests by the
inspectors, as well as observing exam security measures taken during written exam
administration. The operating tests observed included five job performance measures
and two scenarios that were used in the current biennial requalification cycle,
administered to multiple operators. These observations allowed the inspectors to
assess the licensee's effectiveness in conducting the operating test to ensure operator
mastery of the training program content. The inspectors also reviewed medical records
of 8 licensed operators for conformance to license conditions and the licensees system
for tracking qualifications and records of license reactivation.
The results of these examinations were reviewed to determine the effectiveness of the
licensees appraisal of operator performance and to determine if feedback of
performance analyses into the requalification training program was being accomplished.
The inspectors interviewed members of the training department and reviewed corrective
actions related to operator errors to assess the responsiveness of the licensed operator
requalification program to incorporate the lessons learned from both plant and industry
events. Examination results were also assessed to determine if they were consistent
with the guidance contained in NUREG 1021, "Operator Licensing Examination
Standards for Power Reactors", Revision 9, Supplement 1, and NRC Manual
Chapter 0609, Appendix I, "Operator Requalification Human Performance Significance
Determination Process."
In addition to the above, the inspectors reviewed examination security measures,
simulator fidelity, existing logs of simulator deficiencies, and Problem Identification and
- 12 - Enclosure 2
Resolution records related to training. The inspectors conducted a detailed review for
quality of five full weeks of operating tests and one full written exam.
On August 8, 2013, the licensee informed the lead inspector of the results of the written
examinations and operating tests for the Licensed Operator Requalification Program.
The inspectors compared the written and operating test results to the Appendix I,
Licensed Operator Requalification Significance Determination Process, values and
determined that there were no findings based on these results and because the
individuals that failed the applicable portions of their exams and/or operating tests were
remediated, retested, and passed their retake exams prior to returning to shift.
The inspectors completed one inspection sample of the biennial licensed operator
requalification program.
b. Findings
One licensee-identified Severity Level IV NCV was evaluated during this inspection. It is
documented in section 4OA7 of this report.
1R12 Maintenance Effectiveness (71111.12)
a. Inspection Scope
The inspectors evaluated degraded performance issues involving the following risk
significant systems:
- On September 2, 2013, essential chiller B
- On September 10, 2013, control room air handling unit train A inlet damper
(HCV-103A)
The inspectors reviewed events such as where ineffective equipment maintenance has
resulted in valid or invalid automatic actuations of engineered safeguards systems and
independently verified the licensee's actions to address system performance or condition
problems in terms of the following:
- Implementing appropriate work practices
- Identifying and addressing common cause failures
- Scoping of systems in accordance with 10 CFR 50.65(b)
- Characterizing system reliability issues for performance
- Charging unavailability for performance
- Trending key parameters for condition monitoring
- 13 - Enclosure 2
- Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or -(a)(2)
- Verifying appropriate performance criteria for structures, systems, and
components classified as having an adequate demonstration of performance
through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as
requiring the establishment of appropriate and adequate goals and corrective
actions for systems classified as not having adequate performance, as described
The inspectors assessed performance issues with respect to the reliability, availability,
and condition monitoring of the system. In addition, the inspectors verified maintenance
effectiveness issues were appropriately handled by a screening and identification
process and that those issues were entered into the corrective action program with the
appropriate significance characterization. Specific documents reviewed during this
inspection are listed in the attachment.
These activities constitute completion of two maintenance effectiveness samples, as
defined in Inspection Procedure 71111.12-05.
b Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
a. Inspection Scope
The inspectors reviewed licensee personnel's evaluation and management of plant risk
for the maintenance and emergent work activities affecting risk-significant and safety-
related equipment listed below to verify that the appropriate risk assessments were
performed prior to removing equipment for work:
- On July 31, 2013, scheduled replacement of reactor trip circuit breaker number 5
- On August 19, 2013, emergent maintenance on the EDG A2 compressor
component
- On August 21, 2013, scheduled maintenance on the component cooling water
pump and auxiliary feedwater pump breaker with the EDG A2 and B1 air
compressors out of service
- On September 3, 2013, scheduled maintenance on the switchgear ventilation
system air handling unit AH-30A with EDG A1 air receiver out of service
The inspectors selected these activities based on potential risk significance relative to
the reactor safety cornerstones. As applicable for each activity, the inspectors verified
- 14 - Enclosure 2
that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)
and that the assessments were accurate and complete. When licensee personnel
performed emergent work, the inspectors verified that the licensee personnel promptly
assessed and managed plant risk. The inspectors reviewed the scope of maintenance
work, discussed the results of the assessment with the licensee's probabilistic risk
analyst or shift technical advisor, and verified plant conditions were consistent with the
risk assessment. The inspectors also reviewed the technical specification requirements
and inspected portions of redundant safety systems, when applicable, to verify risk
analysis assumptions were valid and applicable requirements were met. Specific
documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of four maintenance risk assessments and
emergent work control inspection samples, as defined in Inspection
Procedure 71111.13-05.
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments (71111.15)
a. Inspection Scope
The inspectors reviewed the following assessments:
- On August 5, 2013, pressurizer level control system
- On August 15, 2013, essential chiller A/B
- On August 20, 2013, main steam isolation valve number 2 steam leak
- On August 25, 2013, control room air handling unit A inlet damper (HCV-103A)
- On September 5, 2013, snubber pin (FWSR-60) missing
The inspectors selected these operability and functionality assessments based on the
risk significance of the associated components and systems along with other factors,
such as engineering analysis and judgment, operating experience, and performance
history. The inspectors evaluated the technical adequacy of the evaluations to ensure
technical specification operability was properly justified and to verify the subject
component or system remained available such that no unrecognized increase in risk
occurred. The inspectors compared the operability and design criteria in the appropriate
sections of the technical specifications and final safety analysis report to the licensees
evaluations to determine whether the components or systems were operable. Where
compensatory measures were required to maintain operability, the inspectors
determined whether the measures in place would function as intended and were
properly controlled. Additionally, the inspectors reviewed a sampling of corrective action
- 15 - Enclosure 2
documents to verify that the licensee was identifying and correcting any deficiencies
associated with operability evaluations. Specific documents reviewed during this
inspection are listed in the attachment.
These activities constitute completion of five operability evaluations inspection samples,
as defined in Inspection Procedure 71111.15 - 05.
b. Findings
No findings were identified.
1R18 Plant Modifications (71111.18)
a. Inspection Scope
To verify that the safety functions of important safety systems were not degraded, on
August 28, 2013, the inspectors reviewed the temporary modification identified as
EC-45995, main steam isolation valve B to repair a bonnet vent plug.
The inspectors reviewed the temporary modification and the associated safety-
evaluation screening against the system design bases documentation, including the final
safety analysis report and the technical specifications, and verified that the modification
did not adversely affect the system operability/availability. The inspectors also verified
that the installation and restoration were consistent with the modification documents and
that configuration control was adequate. Additionally, the inspectors verified that the
temporary modification was identified on control room drawings, appropriate tags were
placed on the affected equipment, and licensee personnel evaluated the combined
effects on mitigating systems and the integrity of radiological barriers.
These activities constitute completion of one sample for temporary plant modifications,
as defined in Inspection Procedure 71111.18-05.
b. Findings
No findings were identified.
.2 Permanent Modifications
a. Inspection Scope
On September 26, 2013, the inspectors reviewed key parameters associated with
materials, replacement components, operations, flow paths, pressure boundary,
ventilation boundary, structural, process medium properties, licensing basis, and failure
modes for the permanent modification identified as EC-46914, main feedwater isolation
valve A nitrogen accumulator B tubing replacement.
- 16 - Enclosure 2
The inspectors verified that modification preparation, staging, and implementation did
not impair emergency/abnormal operating procedure actions, key safety functions, or
operator response to loss of key safety functions; post modification testing will maintain
the plant in a safe configuration during testing by verifying that unintended system
interactions will not occur; systems, structures and components performance
characteristics still meet the design basis; the modification design assumptions were
appropriate; the modification test acceptance criteria will be met; and licensee personnel
identified and implemented appropriate corrective actions associated with permanent
plant modifications. Specific documents reviewed during this inspection are listed in the
attachment.
These activities constitute completion of one sample for permanent plant modifications,
as defined in Inspection Procedure 71111.18-05.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing (71111.19)
a. Inspection Scope
The inspectors reviewed the following post-maintenance activities to verify that
procedures and test activities were adequate to ensure system operability and functional
capability:
- On July 29, 2013, emergency feedwater to steam generator 1 backup flow
control valve (EFW-223A)
- On July 30, 2013, dry cooling tower B component cooling water bypass valve
(CC-134B)
- On August 1, 2013, replaced reactor trip circuit breakers
- On August 6, 2013, corrective maintenance on the emergency generator A1
compressor pressure switch
- On September 24, 2013, replaced control room air handling unit A inlet damper
(HCV-103A)
The inspectors selected these activities based upon the structure, system, or
component's ability to affect risk. The inspectors evaluated these activities for the
following (as applicable):
- The effect of testing on the plant had been adequately addressed; testing was
adequate for the maintenance performed
- 17 - Enclosure 2
- Acceptance criteria were clear and demonstrated operational readiness; test
instrumentation was appropriate
The inspectors evaluated the activities against the technical specifications, the final
safety analysis report, 10 CFR Part 50 requirements, licensee procedures, and various
NRC generic communications to ensure that the test results adequately ensured that the
equipment met the licensing basis and design requirements. In addition, the inspectors
reviewed corrective action documents associated with post-maintenance tests to
determine whether the licensee was identifying problems and entering them in the
corrective action program and that the problems were being corrected commensurate
with their importance to safety. Specific documents reviewed during this inspection are
listed in the attachment.
These activities constitute completion of five post-maintenance testing inspection
samples, as defined in Inspection Procedure 71111.19-05.
b. Findings
.1 Failure to Control Failed Equipment Removed from the Plant in Accordance with
Procedure Requirements
Introduction. The inspectors identified a Green non-cited violation of 10 CFR Part 50,
Appendix B, Criterion V, Instructions, Procedures, and Drawings, because the
licensee did not control and determine the extent of leaking safety-related bypass valve
associated with the dry cooling tower B component cooling water solenoid valve
(CC-134B) after maintenance personnel removed the degraded equipment from service
as required by Section 5.10 of EN-MA-101.
Description. On October 31, 2012, the licensee conducted a post-maintenance leak test
on the actuator for a safety-related air operate solenoid valve CC-134B. During the
process of conducting the leak test, maintenance personnel identified air coming from
the exhaust vent port of a solenoid valve associated with the operation of CC-134B. The
licensee replaced the valve on November 1, 2012, and restored valve CC-134B to an
operable status. However, the licensee did not retain the original solenoid valve for
testing to determine the cause or extent of the leakage. Without supporting information
regarding the leak rate or cause, the licensee assumed that CC-134B and its air
accumulator were inoperable from October 20, 2011, the dates of the last satisfactory
leak test, until November 1, 2012, when maintenance personnel replaced the valve.
The licensee initiated a condition report and performed an apparent cause evaluation.
The inspectors performed a review of the apparent cause evaluation, the event timeline,
work orders, and maintenance history of valve CC-134B. The licensee determined that
the valve leakage could have adversely affected the backup air accumulator inventory.
However, the licensee did not retain the leaking valve to perform any testing. As a
result, the licensee could not characterize and determine the cause of the leakage for
the safety-related valve. The inspectors determined that the licensee did not accomplish
- 18 - Enclosure 2
activities in accordance with maintenance procedure EN-MA-101, Fundamentals of
Maintenance. Section 5.10, Control of Failed Plant Equipment, of EN-MA-101,
requires, in part, that the licensee control failed equipment removed from the plant to
determine necessary testing to establish the cause of the failure.
As a part of the review of the apparent cause evaluation, the inspectors also noted that
an incomplete work order contributed to discarding the solenoid valve prior to testing.
The licensee combined a corrective maintenance with a preventative maintenance task
into the existing work order for CC-134B during the replacement of the solenoid valve.
This led to an error-trap, as explicit instructions for retaining failed parts were not a part
of the preventative maintenance tasks. The immediate corrective actions taken to
restore compliance included the installation of a new valve and debriefing personnel
about controlling equipment removed from service when combining preventative and
corrective maintenance tasks in one work order. The licensee entered this condition into
their corrective action program as Condition Reports CR-WF3-2012-05991 and
CR-WF3-2012-06288. However, inspectors questioned the effectiveness of the original
corrective action by the licensee to have personnel briefed on the effects of combining
preventative and corrective maintenance tasks in a work order. The inspectors felt that
a briefing did not provide an adequate barrier to prevent this from happening again. As
a result, the licensee initiated CR-HQN-2013-00709 and CR-WF3-2013-04047 to
determine additional corrective actions to address the error trap. The inspectors
determined that the licensee did not appropriately coordinate work activities by
incorporating actions to address the impact of changes to work scope on the plant and
human performance.
Analysis. The failure to control failed equipment removed from the plant to determine
the cause was a performance deficiency. The inspectors determined that this deficiency
was reasonably within the licensees ability to foresee and correct. The performance
deficiency was more than minor because it was associated with the equipment
performance attribute of the Mitigating System Cornerstone and adversely affected the
cornerstone objective to ensure the availability, reliability, and capability of systems that
respond to initiating events to prevent undesirable consequences. Specifically, the
degraded condition challenged the safety function of valve CC-134B to limit the loss of
component cooling water through damaged portions of the dry cooling towers following a
tornado-generated missile strike.
The inspectors used NRC Inspection Manual Chapter 0609, Attachment 4, Initial
Characterization of Findings, and Appendix A, The Significance Determination Process
(SDP) for Findings At-Power, to evaluate this issue. The inspectors determined that the
finding required a detailed analysis because it was potentially risk significant for an
external event (tornado) based on using Exhibit 4, External Events Screening
Questions. Therefore, the senior reactor analyst performed the following bounding
detailed risk evaluation:
Tornado Statistics: About one out of every three tornadoes (29 percent) is classified as
"strong." Strong tornadoes have an average path length of 9 miles and a path width of
200 yards (approximately 1 square mile of land affected). Although very rare
- 19 - Enclosure 2
(about 2 percent are violent), violent tornadoes can last for hours. Average path lengths
and widths are 26 miles and 425 yards, respectively.
Since the strong tornadoes can affect approximately 1 square mile, weaker tornadoes,
on average, would affect significantly less than 1 square mile. Most tornadoes are of the
weaker variety. Violent tornadoes can affect approximately 6 to 7 square miles (on
average), but are relatively rare. Therefore, the analyst assumed that the average
tornado would affect 1 square mile of land.
The average number of tornadoes in Louisiana per year was 27.
The total area for the state of Louisiana was 51,840 square miles.
Plant Area: For this risk evaluation, the analyst assumed that the Waterford-3 nuclear
island and switchyard occupied one square mile of land. This was conservative, in that
this equipment occupies less than one square mile.
The analyst conservatively assumed that a tornado within a 1 square mile area would
cause a loss of offsite power and cause physical damage to the train B dry cooling tower
train. This in turn would cause the B component cooling water train to fail. Because the
dry cooling towers are at least partially protected from missiles by the surrounding
building, this is a very conservative assumption. Not all tornadoes will result in
damaging this equipment.
Tornado Frequency: The frequency of a tornado hitting the Waterford-3 nuclear island
and switchyard was therefore:
= 27 tornadoes/year / 51840 sq miles = 5.2E-4/yr.
Calculations: The analyst used the NRCs Waterford-3 Standardized Plant Analysis
Risk (SPAR) model, Revision 8.16, with a truncation limit of E-11, to evaluate this
finding. The analyst assumed a full year exposure period.
The analyst calculated the incremental conditional core damage probability (ICCDP)
considering a loss of offsite power (LOOP) coincident with the failure of the train B
component cooling water system. To account for an earlier finding at Waterford-3, the
analyst set the basic event for alternate room cooling to 1.0. The analyst used this
adjustment in both the nominal case (no performance deficiency) and the current case
(with the performance deficiency). In addition, for both cases the analyst set the basic
event for a LOOP to 1.0. The analyst solved only the LOOP sequences. The nominal
case CCDP was 2.15E-4.
For the current case calculation, the analyst additionally set the basic events for the
B and AB (swing) motor driven component cooling water pumps to 1.0. The resultant
CCDP was 5.9E-3.
- 20 - Enclosure 2
The initial ICCDP was therefore the difference between the nominal and current case
CCDPs = 5.7E-3.
The analyst considered recovery of the instrument air system. As noted in Licensee
Event Report 2012-007, dated December 31, 2012, operators could recover an
instrument air compressor and power the unit from an operable running emergency
diesel generator. The resident inspectors had reviewed these procedures and estimated
that it may take 2.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> to perform this action. The analyst assumed a non-recovery
probability of 0.1 for this action. The nominal non-recovery probability as specified in
NUREG/CR-6883, The SPAR-H Human Reliability Analysis Method, was 1.1E-2.
Therefore, 0.1 was conservative when compared to 1.1E-2. The resultant ICCDP,
considering recovery, was 5.7E-4.
The change to the core damage frequency (delta CDF) was the tornado frequency
multiplied by the ICCDP = 5.2E-4/yr * 5.7E-4 = 2.9E-7/yr.
The dominant core damage sequences included tornado induced losses of offsite power,
failure of the dry cooling tower pressure boundary, failure to isolate the damaged dry
cooling tower, and failure to recovery instrument air. The redundant train A component
cooling water system combined with the tornado frequency helped to reduce the risk
exposure.
Large Early Release Frequency (LERF): To address the contribution to conditional large
early release frequency, the analyst used NRC Inspection Manual Chapter 0609,
Appendix H, Containment Integrity Significance Determination Process, dated May 6,
2004. The finding was not significant to LERF because it did not directly affect the
steam generator tube rupture or the intersystem loss of coolant accident sequences.
The inspectors concluded that the finding reflected current licensee performance and
involved a cross-cutting aspect in the work control component of the human
performance area in that the licensee did not appropriately coordinate work activities by
incorporating actions to address the impact changes to work scope or activity on plant
and human performance H.3(b).
Enforcement. Title 10 of CFR, Part 50, Appendix B, Criterion V, Instructions,
Procedures, and Drawings, requires, in part, that activities affecting quality shall be
prescribed by documented instructions, procedures, or drawings, of a type appropriate to
the circumstances and shall be accomplished in accordance with these instructions,
procedures, or drawings. Specifically, Section 5.10, Control of Failed Plant Equipment
of maintenance procedure EN-MA-101, Fundamentals of Maintenance, requires, in
part, that it be determined whether the component should be tested to establish cause
of failure before it is scrapped.
Contrary to the above, on November 1, 2012, the licensee did not accomplish activities
in accordance with maintenance procedure requirements. Specifically, the licensee did
not control failed plant equipment to determine whether the component should be tested
to establish the cause of failure before it was scrapped. The licensee discarded the
- 21 - Enclosure 2
solenoid valve prior to performing any analysis to determine the cause or severity of the
valves failure. Consequently, the licensee assumed that the valve was unable to fulfill
its safety function if called upon after a tornado-generated missile strike on dry cooling
tower train B. The licensee entered this condition into their corrective action program
as Condition Reports CR-WF3-2012-05991, CR-WF3-2012-06288, and
CR-WF3-2013-04047 for resolution. Although corrective actions are on-going, the
immediate corrective action taken to restore compliance included replacing the leaking
valve and to brief personnel about the potential problems regarding combining
preventative and corrective maintenance tasks in one work order.
Because this violation was of very low safety significance and the licensee entered the
issue into their corrective action program, this violation was treated as a non-cited
violation, consistent with Section 2.3.2.a of the Enforcement Policy:
NCV 05000382/2013004-03, Failure to Accomplish Activities Affecting Quality on a
Degraded Safety-Related Solenoid Valve In Accordance With Procedure Requirements.
1R22 Surveillance Testing (71111.22)
a. Inspection Scope
The inspectors selected risk-significant surveillance activities based on risk information
and reviewed the final safety analysis report, procedure requirements, and technical
specifications to ensure that the surveillance activities listed below demonstrated that the
systems, structures, and/or components tested were capable of performing their
intended safety functions. The inspectors either witnessed or reviewed test data to
verify that the significant surveillance test attributes were adequate to address the
following:
- Preconditioning
- Evaluation of testing impact on the plant
- Acceptance criteria
- Test equipment
- Procedures
- Jumper/lifted lead controls
- Test data
- Testing frequency and method demonstrated technical specification operability
- Test equipment removal
- Restoration of plant systems
- 22 - Enclosure 2
- Fulfillment of ASME Code requirements
- Updating of performance indicator data
- Engineering evaluations, root causes, and bases for returning tested systems,
structures, and components not meeting the test acceptance criteria were correct
- Reference setting data
- Annunciators and alarms setpoints
The inspectors also verified that licensee personnel identified and implemented any
needed corrective actions associated with the surveillance testing.
- On August 6, 2013, surveillance test on containment vacuum relief train A control
valve CVR-201A (in-service test)
- On August 19, 2013, surveillance test on auxiliary component cooling water
pump B (in-service test)
- On August 22, 2013, surveillance test on containment cooling fans
- On August 28, 2013, surveillance test on low pressure safety injection pump A
- On September 9, 2013, surveillance test on component cooling water pump A/B
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of five surveillance testing inspection samples, as
defined in Inspection Procedure 71111.22-05.
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation (71114.06)
Training Observations
a. Inspection Scope
The inspectors observed a simulator training evolution for licensed operators on
July 22, 2013, this required emergency plan implementation by a licensee operations
crew. This evolution was planned to be evaluated and included in performance indicator
- 23 - Enclosure 2
data regarding drill and exercise performance. The inspectors observed event
classification and notification activities performed by the crew. The inspectors also
attended the post evolution critique for the scenario. The focus of the inspectors
activities was to note any weaknesses and deficiencies in the crews performance and
ensure that the licensee evaluators noted the same issues and entered them into the
corrective action program. As part of the inspection, the inspectors reviewed the
scenario package and other documents listed in the attachment.
These activities constitute completion of one training observation sample, as defined in
Inspection Procedure 71114.06-05.
b. Findings
No findings were identified.
2. RADIATION SAFETY
Cornerstone: Public Radiation Safety and Occupational Radiation Safety
2RS01 Radiological Hazard Assessment and Exposure Controls (71124.01)
a. Inspection Scope
This area was inspected to: (1) review and assess licensees performance in assessing
the radiological hazards in the workplace associated with licensed activities and the
implementation of appropriate radiation monitoring and exposure control measures for
both individual and collective exposures, (2) verify the licensee is properly identifying
and reporting Occupational Radiation Safety Cornerstone performance indicators, and
(3) identify those performance deficiencies that were reportable as a performance
indicator and which may have represented a substantial potential for overexposure of
the worker.
The inspectors used the requirements in 10 CFR Part 20, the technical specifications,
and the licensees procedures required by technical specifications as criteria for
determining compliance. During the inspection, the inspectors interviewed the radiation
protection manager, radiation protection supervisors, and radiation workers. The
inspectors performed walkdowns of various portions of the plant, performed independent
radiation dose rate measurements and reviewed the following items:
- Performance indicator events and associated documentation reported by the
licensee in the Occupational Radiation Safety Cornerstone
- The hazard assessment program, including a review of the licensees evaluations
of changes in plant operations and radiological surveys to detect dose rates,
airborne radioactivity, and surface contamination levels
- 24 - Enclosure 2
- Instructions and notices to workers, including labeling or marking containers of
radioactive material, radiation work permits, actions for electronic dosimeter
alarms, and changes to radiological conditions
- Programs and processes for control of sealed sources and release of potentially
contaminated material from the radiologically controlled area, including survey
performance, instrument sensitivity, release criteria, procedural guidance, and
sealed source accountability
- Radiological hazards control and work coverage, including the adequacy of
surveys, radiation protection job coverage, and contamination controls; the use of
electronic dosimeters in high noise areas; dosimetry placement; airborne
radioactivity monitoring; controls for highly activated or contaminated materials
(non-fuel) stored within spent fuel and other storage pools; and posting and
physical controls for high radiation areas and very high radiation areas
- Radiation worker and radiation protection technician performance with respect to
radiation protection work requirements
- Emergency contingencies in place during the steam generator replacement
activities
- Project staffing and training plans for the previous steam generator replacement
activities
- Audits, self-assessments, and corrective action documents related to radiological
hazard assessment and exposure controls since the last inspection
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of the one required sample as defined in
Inspection Procedure 71124.01-05.
b. Findings
No findings were identified.
2RS02 Occupational ALARA Planning and Controls (71124.02)
a. Inspection Scope
This area was inspected to assess performance with respect to maintaining occupational
individual and collective radiation exposures as low as is reasonably achievable
(ALARA). The inspectors used the requirements in 10 CFR Part 20, the technical
specifications, and the licensees procedures required by technical specifications as
criteria for determining compliance. During the inspection, the inspectors interviewed
licensee personnel and reviewed the following items:
- 25 - Enclosure 2
- Site-specific ALARA procedures and collective exposure history, including the
current 3-year rolling average, site-specific trends in collective exposures, and
source-term measurements
- ALARA work activity evaluations/post job reviews, exposure estimates, and
exposure mitigation requirements
- The methodology for estimating work activity exposures, the intended dose
outcome, the accuracy of dose rate and man-hour estimates, and intended
versus actual work activity doses and the reasons for any inconsistencies
- Records detailing the historical trends and current status of tracked plant source
terms and contingency plans for expected changes in the source term due to
changes in plant fuel performance issues or changes in plant primary chemistry
- Radiation worker and radiation protection technician performance during work
activities in radiation areas, airborne radioactivity areas, or high radiation areas
- Audits, self-assessments, and corrective action documents related to ALARA
planning and controls since the last inspection
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of the one required sample as defined in
Inspection Procedure 71124.02-05.
b. Findings
No findings were identified.
2RS05 Radiation Monitoring Instrumentation (71124.05)
a. Inspection Scope
This area was inspected to verify the licensee is assuring the accuracy and operability of
radiation monitoring instruments that are used to: (1) monitor areas, materials, and
workers to ensure a radiologically safe work environment; and (2) detect and quantify
radioactive process streams and effluent releases. The inspectors used the
requirements in 10 CFR Part 20, the technical specifications, and the licensees
procedures required by technical specifications as criteria for determining compliance.
During the inspection, the inspectors interviewed licensee personnel, performed
walkdowns of various portions of the plant, and reviewed the following items:
- Selected plant configurations and alignments of process, postaccident, and
effluent monitors with descriptions in the Final Safety Analysis Report and the
offsite dose calculation manual
- 26 - Enclosure 2
- Select instrumentation, including effluent monitoring instrument, portable survey
instruments, area radiation monitors, continuous air monitors, personnel
contamination monitors, portal monitors, and small article monitors to examine
their configurations and source checks
- Calibration and testing of process and effluent monitors, laboratory
instrumentation, whole body counters, postaccident monitoring instrumentation,
portal monitors, personnel contamination monitors, small article monitors,
portable survey instruments, area radiation monitors, electronic dosimetry, air
samplers, continuous air monitors
- Audits, self-assessments, and corrective action documents related to radiation
monitoring instrumentation since the last inspection
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of the one required sample as defined in
Inspection Procedure 71124.05-05.
b. Findings
No findings were identified.
2RS06 Radioactive Gaseous and Liquid Effluent Treatment (71124.06)
a. Inspection Scope
This area was inspected to: (1) ensure the gaseous and liquid effluent processing
systems are maintained so radiological discharges are properly mitigated, monitored,
and evaluated with respect to public exposure; (2) ensure abnormal radioactive gaseous
or liquid discharges and conditions, when effluent radiation monitors are out-of-service,
are controlled in accordance with the applicable regulatory requirements and licensee
procedures; (3) verify the licensees quality control program ensures the radioactive
effluent sampling and analysis requirements are satisfied so discharges of radioactive
materials are adequately quantified and evaluated; and (4) verify the adequacy of public
dose projections resulting from radioactive effluent discharges. The inspectors used the
requirements in 10 CFR Part 20; 10 CFR Part 50, Appendices A and I; 40 CFR Part 190;
the Offsite Dose Calculation Manual, and licensee procedures required by the Technical
Specifications as criteria for determining compliance. The inspectors interviewed
licensee personnel and reviewed and/or observed the following items:
- Radiological effluent release reports since the previous inspection and reports
related to the effluent program issued since the previous inspection, if any
- Effluent program implementing procedures, including sampling, monitor setpoint
determinations and dose calculations
- 27 - Enclosure 2
- Equipment configuration and flow paths of selected gaseous and liquid discharge
system components, filtered ventilation system material condition, and significant
changes to their effluent release points, if any, and associated 10 CFR 50.59
reviews
- Selected portions of the routine processing and discharge of radioactive gaseous
and liquid effluents (including sample collection and analysis)
- Controls used to ensure representative sampling and appropriate compensatory
sampling
- Results of the inter-laboratory comparison program
- Effluent stack flow rates
- Surveillance test results of technical specification-required ventilation effluent
discharge systems since the previous inspection
- Significant changes in reported dose values, if any
- A selection of radioactive liquid and gaseous waste discharge permits
- Part 61 analyses and methods used to determine which isotopes are included in
the source term
- Offsite dose calculation manual changes, if any
- Meteorological dispersion and deposition factors
- Latest land use census
- Records of abnormal gaseous or liquid tank discharges, if any
- Groundwater monitoring results
- Changes to the licensees written program for indentifying and controlling
contaminated spills/leaks to groundwater, if any
- Identified leakage or spill events and entries made into 10 CFR 50.75 (g)
records, if any, and associated evaluations of the extent of the contamination and
the radiological source term
- Offsite notifications, and reports of events associated with spills, leaks, or
groundwater monitoring results, if any
- 28 - Enclosure 2
- Audits, self-assessments, reports, and corrective action documents related to
radioactive gaseous and liquid effluent treatment since the last inspection
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of the one required sample, as defined in
Inspection Procedure 71124.06-05.
b. Findings
No findings were identified.
2RS07 Radiological Environmental Monitoring Program (71124.07)
a. Inspection Scope
This area was inspected to: (1) ensure that the radiological environmental monitoring
program verifies the impact of radioactive effluent releases to the environment and
sufficiently validates the integrity of the radioactive gaseous and liquid effluent release
program; (2) verify that the radiological environmental monitoring program is
implemented consistent with the licensees technical specifications and/or offsite dose
calculation manual, and to validate that the radioactive effluent release program meets
the design objective contained in Appendix I to 10 CFR Part 50; and (3) ensure that the
radiological environmental monitoring program monitors non-effluent exposure
pathways, is based on sound principles and assumptions, and validates that doses to
members of the public are within the dose limits of 10 CFR Part 20 and
40 CFR Part 190, as applicable. The inspectors reviewed and/or observed the following
items:
- Annual environmental monitoring reports and offsite dose calculation manual
- Selected air sampling and thermoluminescence dosimeter monitoring stations
- Collection and preparation of environmental samples
Operability, calibration, and maintenance of meteorological instruments
- Selected events documented in the annual environmental monitoring report
which involved a missed sample, inoperable sampler, lost thermo luminescence
dosimeter, or anomalous measurement
- Selected structures, systems, or components that may contain licensed material
and has a credible mechanism for licensed material to reach ground water
- Records required by 10 CFR 50.75(g)
- 29 - Enclosure 2
- Significant changes made by the licensee to the offsite dose calculation manual
as the result of changes to the land census or sampler station modifications since
the last inspection
- Calibration and maintenance records for selected air samplers and
environmental sample radiation measurement instrumentation
- Inter-laboratory comparison program results
- Audits, self-assessments, reports, and corrective action documents related to the
radiological environmental monitoring program since the last inspection
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of the one required sample as defined in
Inspection Procedure 71124.07-05.
b. Findings
No findings were identified.
2RS08 Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage,
and Transportation (71124.08)
a. Inspection Scope
This area was inspected to verify the effectiveness of the licensees programs for
processing, handling, storage, and transportation of radioactive material. The inspectors
used the requirements of 10 CFR Parts 20, 61, and 71 and Department of
Transportation regulations contained in 49 CFR Parts 171-180 for determining
compliance. The inspectors interviewed licensee personnel and reviewed the following
items:
- The solid radioactive waste system description, process control program, and the
scope of the licensees audit program
- Control of radioactive waste storage areas including container labeling/marking
and monitoring containers for deformation or signs of waste decomposition
- Changes to the liquid and solid waste processing system configuration including
a review of waste processing equipment that is not operational or abandoned in
place
- Radio-chemical sample analysis results for radioactive waste streams and use of
scaling factors and calculations to account for difficult-to-measure radionuclides
- 30 - Enclosure 2
- Processes for waste classification including use of scaling factors and
10 CFR Part 61 analysis
- Shipment packaging, surveying, labeling, marking, placarding, vehicle checking,
driver instructing, and preparation of the disposal manifest
- Audits, self-assessments, reports, and corrective action reports radioactive solid
waste processing, and radioactive material handling, storage, and transportation
performed since the last inspection
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of the one required sample as defined in
Inspection Procedure 71124.08-05.
b. Findings
No findings were identified.
4. OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency
Preparedness, Public Radiation Safety, Occupational Radiation Safety, and
Security Protection
4OA1 Performance Indicator Verification (71151)
.1 Data Submission Issue
a. Inspection Scope
The inspectors performed a review of the performance indicator data submitted by the
licensee for the second Quarter 2013 performance indicators for any obvious
inconsistencies prior to its public release in accordance with Inspection Manual
Chapter 0608, Performance Indicator Program.
This review was performed as part of the inspectors normal plant status activities and,
as such, did not constitute a separate inspection sample.
b. Findings
No findings were identified.
- 31 - Enclosure 2
.2 Safety System Functional Failures (MS05)
a. Inspection Scope
The inspectors sampled licensee submittals for the safety system functional failures
performance indicator for the period from the fourth quarter 2012 through the
second quarter 2013. To determine the accuracy of the performance indicator data
reported during those periods, the inspectors used definitions and guidance contained in
NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,
Revision 6, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73."
The inspectors reviewed the licensees operator narrative logs, operability assessments,
maintenance rule records, maintenance work orders, issue reports, event reports, and
NRC integrated inspection reports for the period of October 2012 through September
2013 to validate the accuracy of the submittals. The inspectors also reviewed the
licensees issue report database to determine if any problems had been identified with
the performance indicator data collected or transmitted for this indicator and none were
identified. Specific documents reviewed are described in the attachment to this report.
These activities constitute completion of one safety system functional failures sample, as
defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
.3 Mitigating Systems Performance Index - Residual Heat Removal System (MS09)
a. Inspection Scope
The inspectors sampled licensee submittals for the mitigating systems performance
index - residual heat removal system performance indicator for the period from the third
quarter 2012 through the third quarter 2013. To determine the accuracy of the
performance indicator data reported during those periods, the inspectors used definitions
and guidance contained in NEI Document 99-02, Regulatory Assessment Performance
Indicator Guideline, Revision 6. The inspectors reviewed the licensees operator
narrative logs, issue reports, mitigating systems performance index derivation reports,
event reports, and NRC integrated inspection reports for the period of July 2012 through
September 2013 to validate the accuracy of the submittals. The inspectors reviewed the
mitigating systems performance index component risk coefficient to determine if it had
changed by more than 25 percent in value since the previous inspection, and if so, that
the change was in accordance with applicable NEI guidance. The inspectors also
reviewed the licensees issue report database to determine if any problems had been
identified with the performance indicator data collected or transmitted for this indicator
and none were identified. Specific documents reviewed are described in the attachment
to this report.
These activities constitute completion of one mitigating systems performance index -
residual heat removal system sample, as defined in Inspection Procedure 71151-05.
- 32 - Enclosure 2
b. Findings
No findings were identified.
.4 Mitigating Systems Performance Index - Cooling Water Systems (MS10)
a. Inspection Scope
The inspectors sampled licensee submittals for the mitigating systems performance
index - cooling water systems performance indicator for the period from the third quarter
2012 through the third quarter 2013. To determine the accuracy of the performance
indicator data reported during those periods, the inspectors used definitions and
guidance contained in NEI Document 99-02, Regulatory Assessment Performance
Indicator Guideline, Revision 6. The inspectors reviewed the licensees operator
narrative logs, issue reports, mitigating systems performance index derivation reports,
event reports, and NRC integrated inspection reports for the period of July 2012 through
September 2013 to validate the accuracy of the submittals. The inspectors reviewed the
mitigating systems performance index component risk coefficient to determine if it had
changed by more than 25 percent in value since the previous inspection, and if so, that
the change was in accordance with applicable NEI guidance. The inspectors also
reviewed the licensees issue report database to determine if any problems had been
identified with the performance indicator data collected or transmitted for this indicator
and none were identified. Specific documents reviewed are described in the attachment
to this report.
These activities constitute completion of one mitigating systems performance index -
cooling water system sample, as defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
.5 Occupational Exposure Control Effectiveness (OR01)
a. Inspection Scope
Cornerstone: Occupational Radiation Safety
The inspectors reviewed performance indicator data for the fourth quarter 2012 through
the third quarter 2013. The objective of the inspection was to determine the accuracy
and completeness of the performance indicator data reported during these periods. The
inspectors used the definitions and clarifying notes contained in NEI Document 99-02,
Regulatory Assessment Performance Indicator Guideline, Revision 6, as criteria for
determining whether the licensee was in compliance.
- 33 - Enclosure 2
The inspectors reviewed corrective action program records associated with high
radiation area (greater than 1 rem/hr) and very high radiation area nonconformances.
The inspectors reviewed radiological, controlled area exit transactions greater than
100 mrem. The inspectors also conducted walkdowns of high radiation areas (greater
than 1 rem/hr) and very high radiation area entrances to determine the adequacy of the
controls of these areas.
These activities constitute completion of the occupational exposure control effectiveness
sample as defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
.6 Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual
Radiological Effluent Occurrences (PR01)
a. Inspection Scope
Cornerstone: Public Radiation Safety
The inspectors reviewed performance indicator data for fourth quarter 2012 through the
third quarter 2013. The objective of the inspection was to determine the accuracy and
completeness of the performance indicator data reported during these periods. The
inspectors used the definitions and clarifying notes contained in NEI Document 99-02,
Regulatory Assessment Performance Indicator Guideline, Revision 6, as criteria for
determining whether the licensee was in compliance.
The inspectors reviewed the licensees corrective action program records and selected
individual annual or special reports to identify potential occurrences such as
unmonitored, uncontrolled, or improperly calculated effluent releases that may have
impacted offsite dose.
These activities constitute completion of the radiological effluent technical
specifications/offsite dose calculation manual radiological effluent occurrences sample
as defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution (71152)
.1 Routine Review of Identification and Resolution of Problems
a. Inspection Scope
As part of the various baseline inspection procedures discussed in previous sections of
this report, the inspectors routinely reviewed issues during baseline inspection activities
- 34 - Enclosure 2
and plant status reviews to verify that they were being entered into the licensees
corrective action program at an appropriate threshold, that adequate attention was being
given to timely corrective actions, and that adverse trends were identified and
addressed. The inspectors reviewed attributes that included the complete and accurate
identification of the problem; the timely correction, commensurate with the safety
significance; the evaluation and disposition of performance issues, generic implications,
common causes, contributing factors, root causes, extent of condition reviews, and
previous occurrences reviews; and the classification, prioritization, focus, and timeliness
of corrective actions. Minor issues entered into the licensees corrective action program
because of the inspectors observations are included in the attached list of documents
reviewed.
These routine reviews for the identification and resolution of problems did not constitute
any additional inspection samples. Instead, by procedure, they were considered an
integral part of the inspections performed during the quarter and documented in
Section 1 of this report.
c. Findings
No findings were identified.
.2 Daily Corrective Action Program Reviews
a. Inspection Scope
In order to assist with the identification of repetitive equipment failures and specific
human performance issues for follow-up, the inspectors performed a daily screening of
items entered into the licensees corrective action program. The inspectors
accomplished this through review of the stations daily corrective action documents.
The inspectors performed these daily reviews as part of their daily plant status
monitoring activities and, as such, did not constitute any separate inspection samples.
b. Findings
No findings were identified.
.3 In-depth Review of Operator Workarounds
a. Inspection Scope
On August 14, 2013, during a review of items entered in the licensees corrective action
program, the inspectors reviewed operator workarounds and burdens. The inspectors
considered the following during the review of the licensees actions: (1) complete and
accurate identification of problems in a timely manner; (2) evaluation and disposition of
operability/reportability issues; (3) consideration of extent of condition, generic
implications, common cause, and previous occurrences; (4) classification and
prioritization of the resolution of the problem; (5) identification of root and contributing
- 35 - Enclosure 2
causes of the problem; (6) identification of corrective actions; and (7) completion of
corrective actions in a timely manner.
These activities constitute completion of one in-depth problem identification and
resolution sample as defined in Inspection Procedure 71152-05
b. Findings
No findings were identified.
4OA3 Follow-up of Events and Notices of Enforcement Discretion (71153)
.1 (Closed) Licensee Event Report 05000382/2012-007-00, Inoperability Of A Safety
Related Valve Due To Backup Air Accumulator Leakage
On October 10, 2012, during refueling outage RFO-18, the licensee identified a dual
solenoid valve CC ISV0134B1/B2 associated with train B dry cooling tower component
cooling water bypass valve CC-134B was leaking air through the solenoid valve exhaust
vent port. Following replacement of the solenoid valve, the licensee discarded it without
determining the cause or rate of leakage. The licensee determined on November 1,
2012, that the solenoid valve leakage could have adversely affected the backup air
accumulator relied on to allow valve CC-134B to fulfill its safety function in the event that
a tornado-generated missile damaged the train B dry cooling tower. The licensee
concluded that the valve may have been inoperable since the last accumulator leak test
because the rate of the leakage was unknown. As part of the review of this event, the
inspectors identified a Green non-cited violation 05000382/2013004-03, Failure to
accomplish activities affecting quality on a degraded safety-related solenoid valve in
accordance with procedure requirements. The inspectors documented this violation of
NRC requirements in Section 1R19 of this report. This licensee event report is closed.
4OA5 Other Activities
.1 (Closed) Temporary Instruction 2515/185, Follow-up on the Industrys Ground Water
Protection Initiative
a. Inspection Scope
The ground water protection program was inspected September 16-19, 2013, to
determine whether the licensee had implemented the program elements which were
found to be incomplete when previously reviewed during NRC Inspection Report 05000382/2012003. Inspectors interviewed cognizant licensee personnel and
performed walk-downs.
b. Findings
The following element had been implemented since the previous review:
- 36 - Enclosure 2
- Element 1.4.a - Establish written procedures outlining the decision making
process for remediation of leaks and spills or other instances of inadvertent
releases.
The following element had not been implemented since the previous review and is
documented in the corrective action document listed with the element:
- Element 1.3.f - Establish a long-term program for preventative maintenance of
ground water wells (CR-HQN-2013-00861). This element lacked an
implementing procedure or process. Additionally, the appropriateness for
preventative maintenance in relation to the specific type of ground water wells
has yet to be determined.
.2 (Closed) Unresolved Item 05000382/2009010-01, Failures to Evaluate Adverse
Conditions for Reportability to the NRC
On October 19, 2009, the NRC completed a special inspection at the Waterford 3
initiated in response to a series of failures of safety-related Agastat timing relays. During
this inspection, the team identified two examples in which the licensee failed to
adequately review a deviation observed in specific batches of relays to determine
whether the deviations were required to be reported to the NRC. The first of these
examples involved a number of relays from the same manufacturing lot (date code 9948)
that, after being installed in the plant, were determined to be unreliable, thus deviating
from procurement requirements. The second of these examples involved several relays
from a different manufacturing lot (date code 0835) that also did not conform to
specifications; however, the deviation of the date code 0835 relays was discovered
during bench testing prior to installation. On November 5, 2009, the NRC issued
inspection report 05000382/2009010, documenting an unresolved item pending a
determination of whether the licensees failures to evaluate and report the deviations
constituted violations of one or more of the reporting requirements contained in
10 CFR Part 21, 10 CFR 50.72, and 10 CFR 50.73.
The NRC has determined that these deviations in basic components were not evaluated
in accordance with 10 CFR 21.21(a)(1). Further, the NRC determined that had the
licensee evaluated the deviations, it would have concluded that the deviations
constituted defects as defined in 10 CFR 21.3. Where Part 21 applies, such defects are
required to be reported to the NRC in accordance with 10 CFR 21.21(d)(1).
The NRC is developing new guidance to clarify the reporting requirements of
10 CFR Part 21 including whether in-service failure of installed parts-those subject to the
reporting requirements in Part 50 (§§ 50.72 and 50.73)-are also subject to the evaluation
and reporting requirements of Part 21. See Task Interface Agreement (TIA) 2010-003
(ML11319A134). However, Part 21 evaluation and reporting criteria continue to apply to
basic components that are not installed. Therefore, section 4OA5.2 below documents a
violation of 10 CFR Part 21 for only the date code 0835 relays, in which the deviations
were discovered prior to installation of the components. No violation will be issued for
the licensees failure to evaluate the installed relays in accordance with Part 21
requirements.
- 37 - Enclosure 2
.3 Failures to perform evaluations and make a report as required by 10 CFR Part 21
Introduction. The team identified a Severity Level IV violation of 10 CFR 21.21 that
occurred when the licensee failed to complete an evaluation of a deviation in a basic
component within 60 days of discovery.
Description. On October 14, 2008, while replacing a failed Agastat E7024PB relay,
maintenance personnel noted that the replacement relay obtained from the warehouse
had a loose terminal point. Two more relays were obtained from the warehouse; one of
these also had a bad terminal point. On October 27, 2008, the licensee quarantined the
remaining four relays in stock. Two of these were identified to have similarly deficient
terminal points. All four affected relays shared a date code of 0835. The licensee
identified these relays as defective. On November 4, 2008, the licensee issued a
corrective action request to Tyco Electronics requesting an investigation into the cause,
extent of condition, potential reporting, and development of corrective and preventive
action for the Agastat E7024PB relays with date code 0835 noted to have defective
terminal points.
On November 11, 2008, the licensee incorrectly determined that the deficiencies with the
four 0835 date code relays were the same condition as had been previously captured in
Condition Report CR-WF3-2008-4765. This condition report had been written for date
code 0804 relays that had failed in service on September 11 and October 13, 2008. The
licensee incorrectly documented in Condition Report CR-WF3-2008-4782 that a
reportability evaluation for that previous condition would satisfy the requirements to
evaluate the October 14 deficiencies for reportability.
On November 25, 2008, Tyco Electronics issued a 10 CFR 21 report regarding an
Agastat E7024PB relay, date code 0813, which was manufactured with an incorrect
recycle spring. Coincident with this Part 21 report, on November 26, 2008, Tyco
Electronics issued a recall of Agastat E7024PB relays with date codes ranging from
0808 through 0835. This recall included seven relays with a 0835 date code that had
been sold to the Waterford 3 and two which had been procured by the Waterford 3 from
another station. Four of these recalled relays were the subject of the November 4, 2008,
corrective action request issued to Tyco by the licensee. It was later determined that
none of the relays procured by the Waterford 3 had an incorrect recycle spring installed.
On January 28, 2009, the Waterford 3 received an evaluation from Tyco Electronics
which identified misadjusted terminal blocks as the cause of the failures of the two 0804
date code relays, a different failure mechanism than that initially identified for the 0835
relays. The Tyco Electronics report did not provide an evaluation for the 0835 relays.
In August 2009, the licensee issued Licensee Event Report (LER) 2009-003-00
(ML092310548). This LER did not mention relay 0835 or loose terminal points. It
instead discussed incorrect adjustment of terminal blocks. In April 2010, the licensee
issued an updated LER 2009-003-01 (ML101230323). This revision discussed relay
0835 and listed loose terminal points on two spare relays as a Part 21-reportable defect.
- 38 - Enclosure 2
The NRC identified that the licensee had failed to evaluate the loose terminal points on
the four relays with date code 0835 in accordance with 10 CFR Part 21. Though the
licensees initial actions to have the vendor perform an evaluation may have been
appropriate, it was the licensees responsibility and obligation under Part 21 to complete
such an evaluation within 60 days of the initial discovery, or issue an interim report within
60 days of the initial discovery.
The initial LER or Part 21 report should have been made in December 2008 (60 days
after the date of discovery in October 2008). However, the Part 21 report that describes
relay 0835 was made approximately 16 months later (April 2010).
Analysis. The failure of the licensee to adequately evaluate deviations in basic
components and to report defects is a performance deficiency. The NRCs significance
determination process (SDP) considers the safety significance of findings by evaluating
their potential safety consequences. This performance deficiency was of minor safety
significance. The traditional enforcement process separately considers the significance
of willful violations, violations that impact the regulatory process, and violations that
result in actual safety consequences. Traditional enforcement applied to this finding
because it involved a violation that impacted the regulatory process. Supplement VII to
the version of the NRC Enforcement Policy that was in effect at the time the violation
was identified provided as an example of a violation of significant regulatory concern
(Severity Level III), An inadequate review or failure to review such that, if an appropriate
review had been made as required, a 10 CFR Part 21 report would have been made.
Based on this example, the NRC determined that the violation met the criteria to be cited
as a Severity Level III violation. However, in accordance with the Enforcement Policy,
because the affected components were already removed from service as part of an
unrelated manufacturers recall, the severity of the cited violation is being assessed as
Severity Level IV. Cross-cutting aspects are not assigned to traditional enforcement
violations.
Enforcement. Title 10, CFR Part 21.21(a)(1) requires, in part, that entities subject to the
regulations in this part shall evaluate deviations and failures to comply to identify defects
associated with substantial safety hazards as soon as practicable except as provided in
paragraph (a)(2) of this section, and in all cases within 60 days of discovery, in order to
identify a reportable defect that could create a substantial safety hazard, were it to
remain uncorrected.
Title 10 CFR, Part 21.21(a)(2) requires, in part, that entities subject to the regulations in
the part shall ensure that if an evaluation of identified deviation or failure to comply
potentially associated with a substantial safety hazard cannot be completed within
60 days from discovery of the deviation or failure to comply, an interim report is prepared
and submitted to the Commission. The interim report must be submitted in writing within
60 days of discovery of the deviation of failure to comply.
Contrary to the above, from December 14, 2008, to April 29, 2010, the licensee failed to
evaluate deviations and failures to comply to identify defects associated with substantial
safety hazards as soon as practicable and to submit a report or interim report within
- 39 - Enclosure 2
60 days of its discovery, in order to identify a reportable defect or failure to comply that
could create a substantial safety hazard, were it to remain uncorrected.
Specifically, on October 14, 2008, the licensee performed bench test on an
Agastat E7024PB relay with date code 0835 and noted that the relay had a loose
terminal point. Two more relays were obtained from the warehouse; one of these also
had a bad terminal point. On October 27, 2008, the licensee quarantined the remaining
four relays in stock. Two of these quarantined relays were identified to have similarly
deficient terminal points. The licensee identified these relays as defective and returned
them to the manufacturer, Tyco Electronics, for cause evaluation. All four affected
relays shared a date code of 0835. On January 28, 2009, the licensee received a report
from the manufacturer, which had failed to perform the required evaluation. On
August 18, 2009, the licensee submitted LER 2009-003-00, (ML092310548). This LER
did not mention the date code 0835 relays or loose terminal points. Rather, the LER
described relays that failed due to incorrect adjustment of terminal blocks, a deviation
different from that observed in the 0835 date code relays. On April 29, 2010, the
licensee issued updated LER 2009003-01 (ML101230323). This revision to the LER
described loose terminal points on two spare date code 0835 relays as one of the
defects identified in its Agastat E7024PB relays. The April 29, 2010, LER revision would
have met Part 21 evaluation and reporting requirements, but it was 501 days late:
VIO 05000382/2013004-01, Failure to Make a Report Required by 10 CFR 21.21.
4OA6 Meetings, Including Exit
Exit Meeting Summary
The inspectors debriefed Mr. Carl Rich, Director of Nuclear Safety Assurance, and other
members of the licensee's staff of the results of the licensed operator requalification
program inspection on July 25, 2013, and telephonically exited with Mr. Carl Rich and
other staff members on August 19, 2013. The licensee representatives acknowledged
the findings presented. The inspectors asked the licensee whether any materials
examined during the inspection should be considered proprietary. No proprietary
information was identified.
On September 19, 2013, the inspectors presented the results of the radiation safety
inspections to Ms. D. Jacobs, Vice President, Operations, and other members of the
licensee staff. The licensee acknowledged the issues presented. The inspector asked
the licensee whether any materials examined during the inspection should be
considered proprietary. No proprietary information was identified.
On October 1, 2013, the inspectors presented the inspection results to Ms. D. Jacobs,
Vice President, Operations, and other members of the licensee staff. The licensee
acknowledged the issues presented. The inspector asked the licensee whether any
materials examined during the inspection should be considered proprietary. No
proprietary information was identified.
- 40 - Enclosure 2
On November 19, 2013, a re-exit was held with Mr. John Jarrell, Regulatory Assurance
Manager, and other members of your staff. The purpose of this re-exit was to further
discuss the violations contained in the report.
4OA7 Licensee-Identified Violations
The following violation of very low safety significance (SL-IV) was identified by the
licensee and is a violation of NRC requirements which meets the criteria of the
NRC Enforcement Policy for being dispositioned as a Non-Cited Violation.
Title 10 CFR, Part 55.9, Completeness and Accuracy of Information, requires that
information provided to the Commission by an applicant for a license or by a licensee
shall be complete and accurate in all material respects. Contrary to the above, on
September 13, 2012, an NRC Form 396, Certification of Medical Examination by Facility
Licensee, was submitted to the NRC for a licensed operator applicant with inaccurate
information. Specifically, a restriction for corrective lenses was omitted, even though the
applicants medical exam stated that the individual required corrective lenses. An
operating license was granted by the NRC to the individual without a corrective lens
restriction. The error was identified during the operators subsequent annual medical
examination in July 2013, after which the operator reported to licensing that an additional
restriction was being placed on his license though his vision had not changed. The
licensee confirmed that the operator had not performed any licensed duties and a
revised NRC Form 396 was submitted to Region IV on July 29, 2013. The licensee
documented the deficiency in Condition Report 2013-03181. The submission of
inaccurate information to the NRC is a violation. The violation was evaluated using the
traditional enforcement process because it impacted the NRCs ability to perform its
regulatory function. The violation was determined to be Severity Level IV because it fits
the example of Enforcement Policy Section 6.4.d.1(d), Violation Examples: Licensed
Reactor Operators. This section states, SL IV violations involve, for example an
individual operator who met ANSI/ANS 3.4, Section 5, as certified on NRC Form 396,
required by Title 10, Part CFR 55.23, but failed to report a condition that would have
required a license restriction to establish or maintain medical qualification based on
having the undisclosed medical condition. In this case, the individual operator did
report the condition to the licensee, but the licensee failed to include that information in
its original license application to the NRC.
- 41 - Enclosure 2
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
D. Jacobs, Vice President, Operations
K. Cook, General Manager, Plant Operations
S. Adams, Senior Manager, Production
D. Boan, Supervisor, Radiation Protection
J. Briggs, Superintendent, Electrical Maintenance
K. Crissman, Senior Manager, Maintenance
D. Frey, Manager, Radiation Protection
R. Gilmore, Manager, Systems and Components
W. Hardin, Senior Licensing Specialist, Licensing
A. James, Manager, Security
B. Lanka, Director, Engineering
N. Lawless Manager, Chemistry
B. Lindsey, Senior Manager, Operations
M. Mason, Senior Licensing Specialist, Licensing
M. Mills, Manager, Nuclear Oversight
W. McKinney Manager, Performance Improvement
S.W. Meiklejohn, Superintendent, I & C Maintenance
B. Pellegrin, Manager, Regulatory Assurance
G. Pierce, Manager, Training
R. Porter, Manager, Design & Program Engineering
D. Reider, Supervisor, Quality Assurance
C. Rich, Jr., Director, Regulatory & Performance Improvement
J. Russo, Supervisor, Design Engineering
J. Signorelli, Supervisor, Simulator Support
R. Simpson, Superintendent, Licensed Operator Requalification
P. Stanton, Supervisor, Design Engineering
J. Williams, Senior Licensing Specialist
A1-1 Attachment
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
05000382-2013004-01 VIO Failure to Make a Report Required by 10 CFR 21.21
(Section 4OA5)
Opened and Closed
05000382-2013004-02 NCV Failure to Implement Fire Protection Program Procedure
Requirements When Securing from a Fire Watch
(Section 1R05)05000382-2013004-03 NCV Failure to Accomplish Activities Affecting Quality on a
Degraded Safety-Related Solenoid Valve In Accordance With
Procedure Requirements (Section 1R19)
Closed
05000382/2012-007-00 LER Inoperability of a Safety Related Valve Due to Backup Air
Accumulator Leakage
05000382/2009010-01 URI Failure to Evaluate Adverse Conditions for Reportability to the
NRC (Section 4OA5)
LIST OF DOCUMENTS REVIEWED
Section 1R01: Adverse Weather Protection
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
OP-901-521 Severe Weather and Flooding 309
ENS-EP-302 Severe Weather Response 11
Section 1R04: Equipment Alignment
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
OP-009-008 Safety Injection System 33
OP-002-004 Chilled Water System 311
OP-002-001 Auxiliary Component Cooling Water 305
A1-2
Section 1R05: Fire Protection
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
UNT-005-013 Fire Protection Program 12
FP-001-014 Duties of a Fire Watch 16
RAB 2-001 Prefire Strategy Elevation +46.00 RAB HVAC 12
Equipment Room
RAB 7-001 Prefire Strategy Elevation +35.00 RAB HVAC Relay 9
Room
RAB 39-001 Prefire Strategy Elevation -35.00 RAB General Area 11
FP-001-018 Pre Fire Strategies, Development and Revision 301
NS-TB-002 Prefire Strategy Turbing Building +15.00 West 2
CONDITION REPORTS
CR-WF3-2013-03523 CR-WF3-2013-03398
Section 1R06: Flood Protection Measures
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
EN-DC-346 Cable Reliability Program 5
MNQ3-5 Flooding Analysis Outside Containment 4
W3F1-2007-0017 Response to Generic Letter 2007-01 0
W3F1-2009-0066 Clarification of Response to Generic Letter 2007-01 0
SEP-UIP-WF3 Underground Components Inspection Plan 1
WORK ORDERS
Section 1R07: Heat Sink Performance
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
EN-DC-316 Heat Exchanger Performance and Condition 3
A1-3
Section 1R07: Heat Sink Performance
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
Monitoring
PE-001-004 Heat Exchanger Performance 2
SEP-HX-WF3-001 Waterfords Generic Letter 89-13 Heat Exchanger 0
Test Basis
Section 1R11: Licensed Operator Requalification Program
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION/
DATE
EN-OP-115 Conduct of Operations 12
EN-TQ-114 Licensed Operator Requalification Training Program 8
Description
TM-OP-100 Operations Training Manual 24
ANSI/ANS-3.4- Medical Certification and Monitoring of Personnel April 29, 1983
1983 Requiring Operator Licenses for Nuclear Power Plants
ANSI/ANS-3.5- Nuclear Power Plant Simulators for Use in Operator September 4, 2009
2009 Training and Examination
ACAD 07-001 Guidelines for the Continuing Training of Licensed January 2007
Personnel
EN-TQ-217 Examination Security 2
OI-024-000 Maintaining Active SRO/RO Status 306
EN-NS-112 Medical Program 11
TM-OP-100 Operations Training Manual 24
MISCELLANEOUS DOCUMENTS
NUMBER TITLE DATE
WSIM-DIR-003- Steady State Test - 20%, 70%, 100% May 5, 2013
ANNUALTESTS
Att. 4.1
WSIM-DIR-003- Manual Reactor Trip May 5, 2013
ANNUALTESTS
Att. 4.2
A1-4
WSIM-DIR-003- Trip of any single RCP May 15, 2013
ANNUALTESTS
Att. 4.6
WWEX-LOR- 2011 LOR Biennial RO Exam Week 4 August 4, 2011
11044R
WWEX-LOR- 2011 LOR Biennial RO Exam Week 4 (Remedial) August 18, 2011
11046R
N/A 2013 LOR Cycle Written Exam Question Matrix July 23, 2013
WWEX-LOR- 2013 LOR Biennial RO Exam Week 2 July 18, 2013
13042R
TQF-201-IM06 Academic Review Board Recommendation November 14, 2011
N/A Simulator Differences List July 22, 2013
DR-08-0158 Simulator Discrepancy Report July 28, 2008
DR-13-0056 Simulator Discrepancy Report April 3, 2013
DR-10-0239 Simulator Discrepancy Report September 23, 2010
DR-13-0048 Simulator Discrepancy Report March 26, 2013
DR-13-0044 Simulator Discrepancy Report March 25, 2013
DR-12-0166 Simulator Discrepancy Report December 5, 2012
N/A Scenarios, LOR Annual Op Tests Weeks 1-6 (18) July 22, 2013
N/A JPMs, LOR Annual Op Tests Weeks 1-6 (36) July 22, 2013
N/A 2013 Annual Exam Schedule, Weeks 1-6 July 22, 2013
TQF-210-DD03 LOR Simulator Crew Performance Evaluation Report - July 25, 2013
Crews A and 3 (6)
W-OPS-LOR- Requal Training Attendance Records for 2012 July 22, 2013
2012-Cycles 1-6 Cycles 1-6
CONDITION REPORTS
CR-WF3-2013-03181 CR-WF3-2013-03441 CR-WF3-2013-00747 CR-WF3-2013-00961
CR-HQN-2013-00708 CR-WF3-2013-02266 CR-WF3-2013-03522
A1-5
Section 1R12: Maintenance Effectiveness
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
ECM97-006 Design Basis for CCW Makeup 1
CONDITION REPORTS
CR-WF3-2013-02876 CR-WF3-2013-3170 CR-WF3-2013-3245 CR-WF3-2013-2897
WORK ORDERS
Section 1R13: Maintenance Risk Assessment and Emergent Work Controls
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
EN-WM-104 On Line Risk Assessment 7
Integrated Risk Summary Form for Week of 7/29/13 0
8/4/13
Integrated Risk Summary Form for Week of 9/02/13 0
9/8/13
OI-037-000 Operations Risk Assessment Guideline 304
CONDITION REPORTS
Section 1R15: Operability Determinations and Functionality Assessments
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
EN-LI-108 Event Notification and Reporting 8
EN-OP-104 Operability Determinations 6
EC 46218 Provide Minimum Wall Thickness Data for Degraded 0
Piping Identified in CR-WF3-2012-3855
PS-S-004 Thermal Expansion Evaluation of Low Temperature 1
Piping Systems
EN-PS-S-021-W Design Guide for Pipe Stress Analysis 0
A1-6
Section 1R15: Operability Determinations and Functionality Assessments
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
OP-100-014 Technical Specifications and Technical Requirement 313
Compliance
OI-037-000 Operations Risk Assessment Guideline 304
EN-CS-S-008- Pipe Wall Thinning Structural Evaluation 0
MULTI
CONDITION REPORTS
CR-WF3-2013-03641 CR-WF3-2013-02876 CR-WF3-2013-03170 CR-WF3-2013-03245
CR-WF3-2013-03855 CR-WF3-2013-4098
Section 1R18: Plant Modifications
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
EC 45995 Main Steam Isolation Valve B to Repair a Bonnet Vent 0
Plug
EC 46914 Main Feedwater Isolation Valve A Nitrogen 0
Accumulator B tubing replacement
Section 1R19: Post-Maintenance Testing
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
EC 38218 Operability Input for CR-WF3-2012-2870, ACC- 0
126A(B) Potential Leakage
EC-M90-013 Auxiliary Component Cooling Water (ACCW) Jockey 0
Pump Analysis
EN-WM-107 Post Maintenance Testing 4
MI-005-211 Calibration of Control Valves and Accessories 8
MI-005-211 Calibration of Control Valves and Accessories 9
MN(Q)9-50 ACCW System Resistance 2
OP-002-001 Auxiliary Component Cooling Water 305
OP-903-006 Reactor Trip Circuit Breaker Test 10
A1-7
Section 1R18: Plant Modifications
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
OP-903-050 Component Cooling Water and Auxiliary Component 28
Cooling Water Pump and Valve Operability Test
OP-903-065 Emergency Diesel Generator and Subgroup Relay 307
Operability Verification
OP-903-118 Primary Auxiliaries Quarterly IST Valve Tests 31
OP-903-119 Secondary Auxiliaries Quarterly IST Valve Test 18
STA-001-005 Leakage Testing of Air and Nitrogen Accumulators for 310
Safety Related Valves
TD-M120.0045 Masoneilan Instruction Manual 2034 for Electro- 0
Pneumatic Positioner Models 8012 & 8012-1-C &
8012-2-C & 8012-3-C
TD-M120.0055 Masoneilan Instruction Manual ES-5000 for Electro- 1
Pneumatic Positioner Models 8012 & 8012-2-C &
8012-3-C & 8012-5-C & 8012-6-C
W3-DBD-14 Safety Related Air Operated Valves 301
CONDITION REPORTS
CR-WF3-2013-00451 CR-WF3-2013-00447 CR-WF3-2013-00491 CR-HQN-2013-00709
CR-WF3-2012-05991 CR-WF3-2012-03280 CR-WF3-2012-02870 CR-WF3-2013-04290
CR-WF3-2013-04332 CR-WF3-2013-04324 CR-WF3-2013-04274 CR-WF3-2012-02870
CR-WF3-2012-03217 CR-WF3-2010-03602 CR-WF3-2013-04047
WORK ORDERS
Section 1R22: Surveillance Testing
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
EC 18218 Change CVRIDPIS5220A & B Setpoints 0
EC 18219 Replace CVRIDPIS5220A, B CVRIDPIS5221A, 0
B Design Basis
OP-903-050 Component Cooling Water and Auxiliary Component 28
A1-8
Section 1R22: Surveillance Testing
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
Cooling Water Pump and Valve Operability Test
OP-903-120 Containment and Miscellaneous Systems Quarterly 15
IST Valve Tests
W3-DBD-04 Design Basis Document: Component Cooling Water, 302
Auxiliary Component Cooling Water
SD-CCS Containment Cooling and Ventilation System 7
Description
OP-903-037 Containment Cooling Fan Operability Verification 6
OP-903-037 Safety Injection Pump Operability Verification 19
WORK ORDERS
Section 1EP6: Drill Evaluation
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
EP Emergency Plan 44
EP-001-001 Recognition and Classification of Emergency 30
Conditions
2RS1 Radiological Hazard Assessment and Exposure Controls (71124.01)
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
EN-RP-101 Access Control for Radiologically Controlled Areas 7
EN-RP-106-01 Radiological Survey Guidelines 0
EN-RP-108 Radiation Protection Postings 13
EN-RP-121 Radioactive Material Control 7
EN-RP-143 Source Control 9
A1-9
AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES
NUMBER TITLE DATE
QA-14115-2011- Quality Assurance Audit - Combined Radiation November 16, 2011
W3-1 Protection and Radwaste
CONDITION REPORTS
CR-WF3-2013-2256 CR-WF3-2013-3086 CR-WF3-2013-6848 CR-WF3-2012-06131
RADIATION SURVEY RECORDS
NUMBER TITLE DATE
WF3-1212-1262 Reactor Containment Building +46-foot December 23, 2012
WF3-1210-0434 Reactor Coolant Pump 2B October 20, 2012
WF3-1211-1617 Reactor Coolant Pump 2B November 24, 2012
WF3-1210-0719 Reactor Coolant Pump 2B October 24, 2012
WF3-1210-0365 Reactor Coolant Pump 1A October 18, 2012
WF3-1210-0626 Reactor Cavity +21-foot October 23, 2012
WF3-1210-0560 Reactor Containment Building October 22, 2012
WF3-1210-0502 Lower Reactor Cavity October 21, 2012
WF3-1211-1720 Reactor Coolant Pump 1B November 26, 2012
WF3-1211-1722 No. 1 Steam Generator Platform November 26, 2012
WF3-1211-1822 D Ring November 27, 2012
AIR SAMPLE RECORDS
NUMBER TITLE DATE
112512-003 Reactor Coolant Pump 2B November 24, 2012
112512-007 Reactor Coolant Pump 2B November 24, 2012
4022475 HP Lapel Sample - Upper Cavity October 20, 2012
4022484 HP Lapel Sample - Canal October 20, 2012
5019973 HP Lapel Sample - Canal Under Reactor October 20, 2012
5019974 HP Lapel Sample - Canal Under Reactor October 20, 2012
SEALED SOURCE INVENTORY AND LEAK TESTS
NUMBER DATE
310182 July 2, 2013
A1-10
2RS2 Occupational ALARA Planning and Controls (71124.02)
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
EN-RP-105 Radiological Work Permits 012
EN-RP-110-03 Collective Radiation Exposure (CRE) Reduction 002
Guidelines
EN-RP-110-04 Radiation Protection Risk Assessment Process 002
EN-RP-110-05 ALARA Planning and Controls 002
EN-RP-110-06 Outage Dose Estimation and Tracking 001
RADIATION WORK PERMIT ALARA PACKAGES
NUMBER TITLE DATE
2012-0414 SI-109 A and B Refurbishing/Repair February 25, 2013
2012-0515 RCP 2B Motor Removal and Replacement. January 10, 2013
2012-0915 RSG Reactor Coolant System (RCS) Cutting and January 8, 2013
Welding.
2012-0916 RSG Pipe End Decontamination (PED) Activities and January 25, 2013
Support Activities
2012-0917 RSG Steam Generator Removal/Installation Activities February 18, 2013
and Support. Including Rigging Activities
2012-0924 RSG Support Structure / Restraints Modifications February 7, 2013
CONDITION REPORTS
CR-W3-2012-06441 CR-W3-2012-06446 CR-W3-2012-06502 CR-W3-2012-06515
CR-W3-2012-06543 CR-W3-2012-06593 CR-W3-2012-06660 CR-W3-2012-06770
CR-W3-2012-06778 CR-W3-2012-06843 CR-W3-2012-06877 CR-W3-2012-06879
CR-W3-2012-07150 CR-W3-2012-07289 CR-W3-2012-07493 CR-W3-2013-00306
CR-W3-2013-00344
A1-11
SURVEYS
WF3-1210-0855 WF3-1210-0859 WF3-1210-0932 WF3-1210-0880
WF3-1211-0112 WF3-1211-0194 WF3-1211-0572 WF3-1211-0948
WF3-1211-1122 WF3-1211-1113 WF3-1211-1116 WF3-1211-1175
WF3-1211-1189 WF3-1211-1313 WF3-1211-1332 WF3-1211-1508
WF3-1211-1571 WF3-1211-1822 WF3-1211-1907 WF3-1212-0179
MISCELLANEOUS DOCUMENTS
NUMBER TITLE DATE
CR-W3-2013- LT - Apparent Cause Evaluation Report Refuel 18 May 13, 2013
00250 Dose Goal Exceeded
Refuel 18 Outage ALARA Report
2RS5 Radiation Monitoring Instrumentation (71124.05)
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
MI-005-906 Radiation Monitoring System Desk Guide 002
MI-003-387 Condenser Vacuum Pump Discharge Wide Range 12
Noble Gas Radiation Monitor Channel Calibration
(PRMIR0002)
MI-003-461 Boric Acid Condensate Discharge Liquid Effluent 12
Radiation Monitor Channel Calibration (PRMIR0627)
MI-003-371 Fuel Handling Building Ventilation System Emergency 306
Exhaust High Range Noble Gas Radiation Monitor
Channel Calibration (PRMIR3032)
MI-003-391 Component Cooling Water System A or B Liquid 306
Radiation Monitor Channel Calibration (PRMIR7050A
or B)
CE-003-321 Use of EG&G Ortec Gamma Spectroscopy System 303
EN-CY-110 Chemistry Gamma Spectroscopy System Operation 2
CE-003-332 Use of the Beckman LS6500 2
EN-RP-301 Radiation Protection Instrument Control 5
A1-12
NUMBER TITLE REVISION
EN-RP-303-01 Automated Contamination Monitor Performance 0
Testing
AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES
NUMBER TITLE DATE
QS-2012-W3- Quality Assurance Surveillance Report May 15, 2012
008
QA-14/15-2011- Quality Assurance Audit November 10, 2011
W3-1
CONDITION REPORTS
2013-04550 2013-04559 2013-04552 2013-04551
2012-04918
RADIATION MONITORING SYSTEM CALIBRATION RECORDS
WO# NUMBER TITLE DATE
52321504 PRMIR7050A, Cal CCW System Rad Monitor per March 1, 2012
MI-003-391
52321537 PRMIR0002, Calibrate Electronics as per MI-003-387 August, 2012
52321563 PRMIR0627, Cal Boric Acid Cond Disch Liquid Mon July 2, 2012
MI-003-461
52324842 PRMIR0002, Calibrate Flow Portion per MI003-387 October 15, 2012
52335214 PRMIR3032, Calibrate Electronics as per MI-003-371 January 10, 2013
52358658 PRMIR3032, Calibrate Flow Portion per MI-003-371 June 3, 2013
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
CE-003-300 Preparation of Liquid Samples for Radiological Chemical 008
Analysis
A1-13
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
CE-003-509 Routine Filter Replacement and Grab Sampling on PIG 302
Monitors and WRGMS
CE-003-512 Liquid Radioactive Waste Release Permit (Manual) 001
CE-003-513 Gaseous Radioactive Waste Release Permit (Manual) 303
CE-003-514 Liquid Radioactive Waste Release Permit (Computer) 301
CE-003-515 Gaseous Radioactive Waste Release Permit (Computer) 303
CE-003-516 Calculation and Adjustment of Radiation Monitor 302
Setpoints
CE-003-700 General Grab Sampling Techniques 306
EN-CY-102 Laboratory Analytical Quality Control 004
EN-CY-108 Monitoring of Nonradioactive Systems 005
EN-CY-113 Response to Contaminated Spills/Leaks 007
MM-003-044 Shield Building Ventilation System Surveillance 301
MM-003-045 Control Room Air Conditioning 304
MM-003-046 Controlled Ventilation Area System Surveillance 301
UNT-005-014 Offsite Dose Calculation Manual 303
AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES
NUMBER TITLE DATE
22873 Audit of GEL Laboratories December 13, 2011
WLO-2013-00016 Pre-NRC Inspection Focused Assessment May 3, 2012
23428 Exelon Nuclear Audit of NUCON International, Inc. March 11, 2013
A1-14
CONDITION REPORTS
CR-WF3-2012-00910 CR-WF3-2012-01284 CR-WF3-2012-02107 CR-WF3-2012-02240
CR-WF3-2012-02491 CR-WF3-2012-03509 CR-WF3-2012-03956 CR-WF3-2012-04363
CR-WF3-2012-04571 CR-WF3-2012-04840 CR-WF3-2012-04995 CR-WF3-2012-05597
CR-WF3-2012-06182 CR-WF3-2012-06551 CR-WF3-2013-00282 CR-WF3-2013-00318
CR-WF3-2013-00677 CR-WF3-2013-02795 CR-WF3-2013-03087 CR-WF3-2013-04547
10 CFR 50.75(g) CONDITION REPORTS
CR-WF3-2011-06065 CR-WF3-2012-02705
EFFLUENT RELEASE PERMITS
PERMIT NO TYPE RELEASE SYSTEM DATE
W3LB2012-147 Liquid Boric Acid Condensate Tank B (BWM) July 25, 2012
W3LC2012-202 Liquid Turbine Building Industrial Waste Tank September 26, 2012
(TBIWS)
W3LB2013-066 Liquid Waste Condensate Tank B (LWM) April 2, 2013
W3GC2012-079 Gaseous Plant Stack June 27, 2012
EFFLUENT RELEASE PERMITS
PERMIT NO TYPE RELEASE SYSTEM DATE
W3GB2013-050 Gaseous Containment May 9, 2013
W3GC2013-057 Gaseous Fuel Handling Building May 13, 2013
IN-PLACE FILTER TESTING RECORDS
WORK ORDER SYSTEM TRAIN TEST DATE
52434436 Shield Building Ventilation B Charcoal absorber December 19, 2012
52321632 Shield Building Ventilation A HEPA Filter February 10, 2012
52351427 Control Room Emergency B Charcoal absorber March 29, 2013
Filtration Unit
52331428 Control Room Emergency B HEPA Filter March 27, 2013
Filtration Unit
A1-15
52376581 Controlled Ventilation Area B HEPA Filter June 25, 2013
52376581 Controlled Ventilation Area B Charcoal absorber June 29, 2013
MISCELLANEOUS DOCUMENTS
NUMBER TITLE DATE
2011 Annual Radiological Effluent Release Report April 30, 2012
2012 Annual Radiological Effluent Release Report April 30, 2013
Intra-Laboratory Comparison Results 2011
EC-10953 Engineering Change for Modified Release Path to May 11, 2009
EC-28466 Engineering Change for Circulating Water System Piping In Progress
Rerouting
2RS7 Radiological Environmental Monitoring Program (71124.07)
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
CE-003-522 Meteorological Data Collection and Processing 4
CE-003-523 Meteorological Monitoring Program 1
CE-003-525 REMP Evaluations and Reports 301
CE-003-526 Collection and Preparation of REMP Liquid Samples 302
CE-003-527 Collection of Milk Samples 1
CE-003-528 Collection of Sediment Samples 1
CE-003-529 Collection of Vegetation Samples 1
CE-003-530 Collection and Preparation of Fish Sample 1
CE-003-531 Collection and Preparation of REMP Air Samples 1
CE-003-532 Preparation and Distribution of REMP Thermoluminescent 301
Dosimeters
CE-003-533 REMP Shipping 1
CE-003-534 Land Use Census 2
A1-16
ESP-8-069 Radiological Environmental Analytical Services 00
UNT-005-014 Offsite Dose Calculation Manual 303
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
EN-QV-108 QA Surveillance Process 9
EN-QV-109 Audit Process 24
Quality Assurance Program Manual 24
AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES
NUMBER TITLE REVISION
EN-LI-104 Pre-NRC Inspection Focused Assessment - 9
Effluents and Environmental
CONDITION REPORTS
CR-WF3-2012-1360 CR-WF3-2012-2737 CR-WF3-2012-2942 CR-WF3-2012-4067
CR-WF3-2012-4281 CR-WF3-2012-4296 CR-WF3-2012-4385 CR-WF3-2012-4408
CR-WF3-2012-7354 CR-WF3-2012-7487 CR-WF3-2013-1967 CR-WF3-2013-2941
CALIBRATION AND MAINTENANCE RECORDS
NUMBER TITLE DATE
WO-WF3-52410699 Primary Met Tower Calibration Package October 2012
WO-WF3-52447365 Primary Met Tower Calibration Package May 2013
WO-WF3-52431357 Secondary Met Tower Calibration Package February 2012
WO-WF3-52469672 Secondary Met Tower Calibration Package August 2013
MISCELLANEOUS DOCUMENTS
TITLE DATE
Annual Radiological Environmental Operating Report 2011
Annual Radiological Environmental Operating Report 2012
Annual Radioactive Effluent Release Report 2011
Annual Radioactive Effluent Release Report 2012
Annual Meteorological Monitoring Program Report 2011
Annual Meteorological Monitoring Program Report 2012
A1-17
2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,
and Transportation (71124.08)
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
EN-RP-121 Radioactive Material Control 7
EN-RW-102 Radioactive Shipping Procedure 10
EN-RW-104 Scaling Factors 3
RW-002-200 Collection & Packaging of Solid Radwaste 303
RW-002-210 Radioactive Waste Solidification & Dewatering 301
RW-002-240 Package and Handling Radwaste DAW 300
RW-002-300 Blowdown Demineralizer Resin Transfer 300
AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES
NUMBER TITLE DATE
NUPIC Audit No. Energy Solutions Mega Audit November 23, 2012
2012-011
EN-LI-104 Pre-Assessment Radioactive Solid Waste Processing April 24, 2012
and Radioactive Material Handling, Storage, and
Transportation
QA-14/15- Quality Assurance Audit Report: Radiation October 11, 2011
20011-GGNS-1 Protection/Radwaste
CONDITION REPORTS
CR-WF3-2011-07711 CR-WF3-2012-03042 CR-WF3-2012-07168 CR-WF3-2013-00508
CR-WF3-2013-01253 CR-WF3-2013-01682 CR-WF3-2013-02905 CR-WF3-2013-03335
CR-WF3-2013-03952 CR-WF3-2013-04553 CR-WF3-2013-04556 CR-WF3-2013-04557
CR-HQN-2013-00858 CR-HQN-2013-00859
RADIOACTIVE MATERIAL AND WASTE SHIPMENTS
NUMBER TITLE DATE
11-1010 Bead Resin and Dry Active Waste, Oak Ridge, TN June 23, 2011
11-1011 LWM Resin, Oak Ridge, TN August 22, 2011
11-1011 Dewatered Resin, Studsvik Erwin, TN September 21, 2011
11-3024 Lead Blankets, 3-Mile Island, Harrisburg, PA February 25, 2011
12-1008 Dry Active Waste, Energy Solutions, Oak Ridge, TN June 21,2012
12-1009 SGBD Resin, Energy Solutions, Oak Ridge, TN October 24, 2012
12-3049 Empty Fuel Cask, Energy Solutions, Oak Ridge, TN August 9, 2012
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MISCELLANEOUS DOCUMENTS
NUMBER TITLE REVISION / DATE
FSAR Chapter WSES Updated Final Safety Analysis Report 12
11
FSAR Chapter WSES Updated Final Safety Analysis Report 12
12
2012 Annual Radiological Effluent Release Report April 30, 2012
2011 Annual Radiological Effluent Release Report April 30, 2013
Section 4OA1: Performance Indicator Verification
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
EN-LI-104 Performance Indicator Process 6
EN-FAP-OM-005 Nuclear Performance Indicator Process 0
ECH-NE-09- Waterford 3 Mitigating System Performance Index Basis 2
00036 Document
MISCELLANEOUS DOCUMENTS
NUMBER TITLE REVISION
NEI 99-02 Regulatory Assessment Performance Indicator Guideline 6
Section 4OA2: Identification and Resolution of Problems
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
EN-LI-102 Corrective Action Process 20
EN-LI-119 Apparent Cause Evaluation (ACE) Process 16
Section 4OA3: Event Follow-Up
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
LER Inoperability Of A Safety Related Valve Due To Backup 0
05000382/2012- Air Accumulator Leakage
007-00
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Section 4OA5: Other Activities
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
EN-CY-109 Sampling and Analysis of Groundwater Monitoring Wells 2
EN-CY-111 Radiological Ground Water Monitoring Program 2
CONDITION REPORTS
CR-HQN-2012-00676 CR-HQN-2012-00673 CR-HQN-2013-00861
MISCELLANEOUS DOCUMENTS
NUMBER TITLE REVISION/
DATE
LO-WTHQN- Focused Self-Assessment Report - NEI 07-07 November 30, 2011
2011-123 Compliance - Waterford-3
NEI Ground Water Protection Initiative NEI Peer December 9, 2009
Assessment Report
Ground Water Monitoring Plan - Entergy Nuclear 2
Waterford-3 Station
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