IR 05000382/2017008
| ML17362A424 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/28/2017 |
| From: | Thomas Farnholtz Region 4 Engineering Branch 1 |
| To: | Dinelli J Entergy Operations |
| References | |
| IR 2017008 | |
| Download: ML17362A424 (33) | |
Text
ber 28, 2017
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC DESIGN BASES ASSURANCE INSPECTION REPORT 05000382/2017008
Dear Mr. Dinelli:
On November 16, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford Steam Electric Station, Unit 3 and discussed the preliminary results of this inspection with you and other members of your staff. On December 14, 2017, the inspectors discussed the final results of this inspection with Mr. D. Brenton, General Manager-Plant Operations, and other members of your staff. The results of this inspection are documented in the enclosed report.
Nuclear Regulatory Commission inspectors documented two findings of very low safety significance (Green). 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.
Additionally, the inspectors documented one Severity Level IV traditional enforcement violation associated with impacting the ability of the NRC to perform its regulatory oversight function.
The NRC is treating this violation as non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
From December 2016 to December 2017, the NRC issued four Severity Level IV traditional enforcement violations associated with impacting the ability of the NRC to perform its regulatory oversight function. As a result of the four Severity Level IV traditional enforcement violations, the NRC determined that the additional inspection was not warranted because the cause of the most recent violation occurred in 2006 and 2014 and current Waterford procedures and practices should prevent recurrence. Therefore, the NRC will not conduct Inspection Procedure 92723, Follow up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period.
If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Grand Gulf Nuclear Station. If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Grand Gulf Nuclear Station.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Thomas R. Farnholtz, Chief Engineering Branch 1 Division of Reactor Safety Docket No. 50-382 License No. NPF-38 Enclosure:
Inspection Report 05000382/2017008 w/Attachments:
1. Supplemental Information 2. Additional Information Request cc w/enclosure: Electronic Distribution
U.S. NUCLEAR REGULATORY COMMISSION INSPECTION REPORT Docket: 05000382 License: NPF-38 Report Nos.: 05000382/2017008 Enterprise Identifier: I-2017-008-0023 Licensee: Entergy Operations, Inc.
Facility: Waterford Steam Electric Station, Unit 3 Location: 17265 River Road Killona, LA 70057 On-site Dates: October 23 through November 16, 2017 Exit Date: December 14, 2017 Team Leader: G. George, Senior Reactor Inspector, Engineering Branch 1 Inspectors: J. Braisted, Reactor Inspector, Engineering Branch 1 N. Okonkwo, Reactor Inspector, Engineering Branch 2 G. Callaway, Senior Reactor Technology Instructor, Technical Training Center Accompanying A. Athar, Reactor Operations Engineer, ROP Assessment Branch, Personnel: Nuclear Reactor Regulation C. Baron, Contractor, Beckman and Associates S. Gardner, Contractor, Beckman and Associates Approved By: Thomas R. Farnholtz Branch Chief, Engineering Branch 1 Division of Reactor Safety Enclosure
SUMMARY
The NRC continued monitoring licensees performance by conducting an Inspection
Procedure 71111.21M, Design Bases Assurance (Teams), inspection at Waterford Steam Electric Station, Unit 3, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC and self-revealed findings, violations, and additional items are summarized in the table below.
List of Findings and Violations Three examples of Failure to Establish and Maintain Preventive Maintenance Procedures for Safety-Related Electrical Equipment Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Green Not Applicable 71111.21M Systems NCV 05000382/2017008-01 Closed The team identified three examples of a Green non-cited violation of Waterford Steam Electric Station, Unit 3, Technical Specification 6.8.1.a, for failure to establish, implement, and maintain written procedures for activities referenced in Appendix A of Regulatory Guide 1.33,
Revision 2, dated February 1978. Specifically, prior to November 16, 2017, the licensee failed to establish and maintain procedures covered in Regulatory Guide 1.33, Appendix A,
Section 9, Procedures for Performing Maintenance, to implement maintenance for safety-related 1600 A, 600 V non-segregated metal-enclosed bus ducts, safety-related 4.16 kV G.E. Magne-Blast circuit breakers, and safety-related 480 V G.E. switchgear AKR breakers.
Failure to Meet RG 1.9 Emergency Diesel Testing Requirements during Surveillance Test Results in Missed Surveillance Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Green H.11 - Human 71111.21M Systems NCV 05000382/2017008-02 Performance,
Closed Challenge the Unknown The team identified a Green non-cited violation of Waterford Steam Electric Station, Unit 3,
Technical Specification Limiting Condition for Operation 3.8.1.1 for failure to maintain operability of two separate independent diesel generators. Specifically, on May 23, 2017, the licensee failed to verify that the train A emergency diesel generator energized all auto-connected shutdown loads through the load sequencer and operated for greater than or equal to five minutes in accordance with Technical Specification Surveillance Requirement 4.8.1.1.2.
Two Examples of Failure to Submit and Receive Prior Authorization of Alternatives to ASME OM Code Leak Testing Requirements Cornerstone Significance Cross-cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 71111.21M NCV 05000382/2017008-03 Closed The team identified two examples of a Severity Level IV, non-cited violation of 10 CFR 50.55a(z), for failure to submit and obtain authorization prior to implementation of multiple alternatives to leak testing requirements of the American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) of Nuclear Power Plants Code.
Specifically, prior to November 16, 2017, the licensee did not submit and receive prior authorization to alternative leak testing requirements for safety injection valves SI-512A and SI-602B.
Additional Tracking Items Type Issue Number Title Report Section Status URI 05000382/2017008- Potential Failure to Obtain a License 71111.21M Open 04 Amendment for Changes to Diesel Generator Surveillance Test Interval
TABLE OF CONTENTS
INSPECTION SCOPES
...............5
REACTOR SAFETY
..................................................................................................................
INSPECTION RESULTS
..............................................................................................................
EXIT MEETINGS AND DEBRIEFS
............................................................................................ 16 LIST OF
DOCUMENTS REVIEWED
...................................................................................... A1-1
ADDITIONAL REQUESTS ..................................................................................................... A2-1
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures in effect
at the beginning of the inspection unless otherwise noted. Currently approved inspection
procedures with their attached revision histories are located on the public Web site at
http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.
Samples were declared complete when the inspection procedure requirements most
appropriate to the inspection activity were met consistent with Inspection Manual Chapter 2515,
Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed
selected procedures and records, observed activities, and interviewed personnel to assess
licensee performance and compliance with Commission rules and regulations, license
conditions, site procedures, and standards.
REACTOR SAFETY
Inspection Procedure 71111.21M - Design Bases Assurance (Team) Inspection
From October 23, 2017, to November 16, 2017, the team inspected the following
components and listed applicable attributes, permanent modifications, operating experience,
and operator actions.
Components - 71111.21M (5 Samples)
(1) Emergency feedwater turbine steam supply valves, MSMVAAA401A and 401B:
a) Component maintenance history and corrective action program reports to verify the
monitoring of potential degradation.
b) Calculations for valve thrust and torque to verify the capability of the valve to perform
its required function under the most limiting conditions.
c) Evaluation of the electric heat tracing installed downstream of the motor-operated
valves to verify excessive condensate will not be generated in the event of a cold
start of the emergency feedwater turbine.
d) Procedures for testing the bypass of motor-operated valve thermal overloads under
accident conditions to verify operability of valve.
(2) 125 VDC Bus 3AB-DC-S
a) Component maintenance history and corrective action program reports to verify the
monitoring of potential degradation.
b) Calculations for electrical distribution, system load flow/voltage drop, short-circuit,
and electrical protection to verify that bus capacity and voltages remained within
minimum acceptable limits.
c) The protective device settings and circuit breaker ratings to ensure adequate
selective protection coordination of connected equipment during worst-case short
circuit conditions.
d) Procedures for circuit breaker preventive maintenance, inspection, and testing to
compare maintenance practices against industry and vendor guidance.
(3) High pressure safety injection pump B:
a) Component maintenance history and corrective action program reports to verify the
monitoring of potential degradation.
b) Calculations for system flow, system flow balance, net positive suction head,
surveillance test acceptance criteria minimum flow, and runout flow.
c) The impact of minimum and maximum allowable electrical power supply frequency
on pump performance and net positive suction head.
d) Procedures for operation of the high pressure safety injection system under accident
conditions.
e) Routing of pump motor cables.
f) Corrective action documents issued in the past five years.
g) Procedures for preventive maintenance, inspection, and testing to compare
maintenance practices against industry and vendor guidance.
h) Motor sizing calculations to verify input assumptions and design loading to ensure
adequate design for pumping capacity. The team put special emphasis on pump
motor testing methodology, the values assigned to acceptance criteria, and whether
the values supported design parameters and assumptions.
(4) Safety injection sump outlet motor-operated valve, SI-602A:
a) Component maintenance history and corrective action program reports to verify the
monitoring of potential degradation.
b) Calculations for the determination of allowable leakage, target torque values for
stroke testing, maximum rim-pull force, and torque switch settings to ensure valve
functionality.
c) Procedures for valve and operator preventive maintenance, inspection, and testing to
compare maintenance practices against industry and vendor guidance.
d) Site specific commitments to NRC Generic Letter 89-10, Safety-Related
Motor-Operated Valve Testing and Surveillance.
(5) 480 VAC Class 1E switchgear, Bus 3B31S:
a) System health reports, component maintenance history, and corrective action
program reports to verify the monitoring and correction of potential degradation.
b) Calculations for electrical distribution, system load flow/voltage drop, short-circuit,
and electrical protection to verify that bus capacity and voltages remained within the
minimum acceptable limits.
c) The protective device settings and feeder circuit breaker ratings to ensure adequate
selective protection coordination of connected equipment during worst-case short
circuit conditions.
d) Procedures for preventive maintenance, inspection, and testing to compare
maintenance practices against industry and vendor guidance; including the cable
aging management program.
e) Results of completed preventative maintenance on switchgear and breakers,
including breaker tracking.
Large Early Release Frequency Containment Related Structures, Systems, or
Components - 71111.21M (1 Sample)
(1) Containment isolation actuation system:
a) Pressurizer low pressure and containment high pressure transmitter environmental
qualification files and replacement history to maintain pressure transmitters
environmental qualification.
b) Calculations for measurement loop uncertainty and response time test acceptance
criteria.
c) Surveillance test procedures for emergency safety features relay testing and plant
protection system channel testing.
Modifications to Mitigation Structures, Systems, or Components - 71111.21M (6 Samples)
(1) Engineering Change 530, Ultimate Heat Sink Water Replenishment for Tornado Event
(2) Engineering Change 40828, Evaluation of Replacement Bushings for Unit Auxiliary
Transformer
(3) Engineering Change 46556, CC ISV0807A Solenoid Preventative Maintenance
Equivalency
(4) Engineering Change 44782, Emergency Diesel Generator Governor Upgrade
(5) Engineering Change 55752, Replace SI-512B with a Swing Check Valve
(6) Engineering Change 63801, Emergency Feedwater Circuitry Modification
Operating Experience - 71111.21M (3 Samples)
(1) NRC Generic Letter 1988-03, Resolution of Generic Safety Issue 93, Steam Binding of
Auxiliary Feedwater Pumps
(2) NRC Information Notice 2013-05, Battery Expected Life and its Potential Impact on
Surveillance Requirements
(3) NRC Information Notice 2014-03, Turbine-Driven Auxiliary Feedwater Pump Overspeed
Trip Mechanism Issues
Evaluation of Inspection Sample Related Operator Procedures and Actions
(1) Control room operator actions resulting from a simulated small break loss-of-coolant
accident followed by a post reactor trip loss-of-offsite power with a single failure of
component cooling water pump B.
a) Control room crew expected to enter procedures for standard post trip actions and
loss of coolant accident recovery.
b) Following the component cooling water pump B trip, the crew was expected to
restore cooling to emergency diesel generator B, using component cooling water
pump AB, and prior to emergency diesel generator failure.
INSPECTION RESULTS
Three examples of Failure to Establish and Maintain Preventive Maintenance Procedures for
Safety-Related Electrical Equipment
Cornerstone Significance Cross-cutting Report
Aspect Section
Mitigating Green Not Applicable 71111.21M
Systems NCV 05000382/2017008-01
Closed
The team identified three examples of a Green non-cited violation of Waterford Steam Electric
Station, Unit 3, Technical Specification 6.8.1.a, for failure to establish, implement, and maintain
written procedures for activities referenced in Appendix A of Regulatory Guide 1.33,
Revision 2, dated February 1978. Specifically, prior to November 16, 2017, the licensee failed
to establish and maintain procedures covered in Regulatory Guide 1.33, Appendix A,
Section 9, Procedures for Performing Maintenance, to implement maintenance for
safety-related 1600 A, 600 V non-segregated metal-enclosed bus ducts, safety-related 4.16 kV
- G.E. Magne-Blast circuit breakers, and safety-related 480 V G.E. switchgear AKR breakers.
Description:
Example 1: The team identified that the licensee failed to establish a procedure to perform
maintenance and inspection of safety-related 1600 A, 600 V non-segregated metal enclosed
bus ducts as recommended by the vendor. The vendor manual, TD-G080.0735, General
Electric Important Instructions for Armor-Clad Indoor Feeder Busway, GEH-2636, included
recommendations for cleaning dust and dirt on the busway, checking for signs of overheating,
megger checks, visually check for loose bolts at the joints, proper spring tension, excessive
wear, arc spatter, and sooty deposits. No procedure for performing maintenance or plans for
performing maintenance were established for the safety-related metal-enclosed bus ducts.
This represented a failure to establish procedures for activities covered by Regulatory
Guide 1.33, Appendix A, Section 9, Procedures for Performing Maintenance.
Example 2: The team identified that the licensee failed to revise safety-related 4.16 kV G.E.
Magne-Blast circuit breaker preventive maintenance procedures to include auxiliary switch
contact resistance and functional tests. Entergy maintenance procedures are written to
include requirements set forth in the Entergy preventive maintenance templates. The Entergy
preventive maintenance templates for circuit breakers include vendor recommendations and
industry best practices, such as EPRI Technical Report 109641, Guidance on Routine
Preventive Maintenance for Magne-Blast Breakers. EPRI Technical Report 109641, Section
7, Preventive Maintenance Tasks, provides guidance on performing auxiliary switch contact
resistance tests and justifies the tests inclusion using industry operating experience. The
Task Content section of the Preventive Maintenance Template, EN-Switchgear - Medium
Voltage - 1KV-7KV, Revision 3, requires during inspections, cleaning and testing, and
breaker overhauls to Perform contact resistance test. The teams review of maintenance
Procedure ME-003-327, 4.16 KV
- G.E Magne Blast Breaker, Revision 18, identified that the
procedure did not include the performance of auxiliary switch contact resistance tests as
required by the preventive maintenance template. This represented a failure to maintain
procedures for activities covered by Regulatory Guide 1.33, Appendix A, Section 9,
Procedures for Performing Maintenance.
Example 3: The team identified that the licensee failed to revise 480 V G.E. AKR circuit
breakers preventive maintenance procedures to include reduced control voltage tests. Entergy
maintenance procedures are written to include requirements set forth in the Entergy preventive
maintenance templates. The Entergy preventive maintenance templates for circuit breakers
include vendor recommendations and industry best practices, such as EPRI Technical
Report 112938, Routine Preventive Maintenance Guidance for AK and AKR Type Circuit
Breakers. EPRI Technical Report 112938 provides guidance on performing reduced control
voltage tests. In September 2008, Preventive Maintenance Template, EN-Switchgear - Low
Voltage, was changed to include a required reduced control voltage test in the visual
inspection task for low voltage circuit breakers. However, as of September 12, 2017,
Maintenance Procedure ME-003-330, 480 V
- G.E Switchgear Breakers, Revision 310 did not
include the performance of reduced control voltage tests required by the preventive
maintenance template. This represented a failure to maintain procedures for activities covered
by Regulatory Guide 1.33, Appendix A, Section 9, Procedures for Performing Maintenance.
This represented a failure to establish procedures for activities covered by Regulatory
Guide 1.33, Appendix A, Section 9, Procedures for Performing Maintenance.
Corrective Action(s): In response to this issue, the licensee created corrective actions to
evaluate the appropriateness and scheduling for each preventive maintenance task. This
finding does not represent an immediate safety concern.
Corrective Action Reference(s): Condition Reports CR-WF3-2017-08574,
CR-WF3-2017-08611, CR-WF3 2017-08632, CR-WF3-2017-08635, and CR-WF3-2017-08737
Performance Assessment:
Performance Deficiency: The team determined that the failure to establish and maintain
maintenance procedures for activities covered by Regulatory Guide 1.33, Appendix A,
Section 9, Procedures for Performing Maintenance, was a performance deficiency.
Screening: This performance deficiency was more than minor, and therefore a finding,
because it was associated with the procedure quality attribute of the Mitigating Systems
Cornerstone and adversely affected the cornerstone objective to ensure the availability,
reliability, and capability of systems to respond to initiating events to prevent undesirable
consequences. Specifically, the failure to incorporate the testing, and inspection requirements
into preventive maintenance procedures could cause unacceptable conditions to go
undetected.
Significance: In accordance with Inspection Manual Chapter 0609, Appendix A, The
Significance Determination Process (SDP) for Findings At Power, dated July 19, 2012, the
finding screened as having very low safety significance (Green) because it was a design or
qualification deficiency that did not represent a loss of operability or functionality; did not
represent an actual loss of safety function of the system or train; did not result in the loss of
one or more trains of non-technical specification equipment; and did not screen as potentially
risk-significant due to seismic, flooding, or severe weather.
Cross Cutting Aspect: The team determined that this finding did not have a cross-cutting
aspect because the most significant contributor did not reflect current licensee performance.
Enforcement:
Violation: Waterford Steam Electric Station, Unit 3, Technical Specification 6.8.1.a, requires
that written procedures shall be established, implemented, and maintained to cover the
applicable procedures recommended in Appendix A of Regulatory Guide RG 1.33, Revision 2,
dated February 1978. Appendix A, Section 9, Procedures for Performing Maintenance
recommends in part that, Maintenance that can affect the performance of a safety-related
equipment should be properly pre-planned and performed in accordance with written
procedures, documented instructions, or drawings appropriate to the circumstance.
Contrary to the above, prior to November 16, 2017, the licensee failed to establish and
maintain written procedures for performing maintenance that can affect the performance of
safety-related equipment. Specifically, the licensee failed to establish and maintain
procedures covered in Regulatory Guide 1.33, Appendix A, Section 9, Procedures for
Performing Maintenance, to implement maintenance for safety-related 1600 A,
600 V non-segregated metal-enclosed bus ducts, safety-related 4.16 kV G.E. Magne-Blast
circuit breakers, and safety-related 480 V G.E. Switchgear AKR Breakers.
Enforcement Action(s): This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Failure to Meet RG 1.9 Emergency Diesel Testing Requirements during Surveillance Test
Results in Missed Surveillance
Cornerstone Significance Cross-cutting Report
Aspect Section
Mitigating Green H.11 - Human 71111.21M
Systems NCV 05000382/2017008-02 Performance,
Closed Challenge the
Unknown
The team identified a Green non-cited violation of Waterford Steam Electric Station, Unit 3,
Technical Specification Limiting Condition for Operation 3.8.1.1 for failure to maintain
operability of two separate independent diesel generators. Specifically, on May 23, 2017, the
licensee failed to verify that the train A emergency diesel generator energized all auto-
connected shutdown loads through the load sequencer and operated for greater than or equal
to five minutes in accordance with Technical Specification Surveillance Requirement 4.8.1.1.2
Description:
Technical Specification Surveillance Requirement 4.8.1.1.2 requires the licensee to
demonstrate each diesel generators operability by verification, for a simulated loss-of-offsite
power and simulated loss-of-offsite power in conjunction with safety injection actuation system
test signal, that the following is met:
Verifying the diesel starts on the auto-start signal, energizes the emergency busses and the
permanently connected loads within 10 seconds after the auto-start signal, energizes the auto-
connected shutdown loads through the load sequencer and operates for greater than or equal
to 5 minutes while its generator is loaded with the shutdown loads. After energization, the
steady-state voltage and frequency of the emergency busses shall be maintained at
4160 +420, -240 volts and 60 +1.2, -0.3 Hz during this test.
The surveillance requirement for demonstrating operability is consistent with the
recommendations of Regulatory Guide 1.9, Selection of Diesel Generator Set Capacity for
Standby Power Supplies, Revision 4, March 2007. The licensee performs Operating
Procedure OP-903-115, Integrated Emergency Diesel Generator/Emergency Safety Features
Test - Train A, Revision 39, to accomplish this Surveillance Requirement.
Procedure OP-903-115 contains Component List(s) which identifies all the emergency safety
features loads required to auto-connect on the emergency diesel generator bus for both the
simulated loss-of-offsite power and the simulated loss-of-offsite power concurrent with a safety
injection actuation signal. In various steps, Procedure OP-903-115 directs the operators to
verify all components listed on the Component List are energized while performing the
various tests.
On May 23, 2017, Procedure OP-903-115 was performed without verifying all components on
the Component List were energized. Specifically, the surveillance test was performed
without verifying that the listed safety components, boric acid makeup pump B and dry cooling
tower fan 6A, auto-connected and were energized. In the test results, as documented in Work Order 52685292, the licensee acknowledged the components were not available because of
equipment issues and determined the test was satisfactory. On May 24, 2017, the licensee
initiated Condition Report CR-WF3-2017-04435 for the unavailable components, further
determining that the train A emergency diesel generator was operable because the addition of
the loads was within the capacity of the diesel generator.
Regulatory Guide 1.9, Revision 4, Section 2.2.5, LOOP Test, states that the loss-of-offsite
power test must demonstrate that the emergency diesel generator energizes all
auto-connected shutdown loads through the load sequencer. It further states, If the required
loads are not available, one or more equivalent load(s) may be used. Based on Regulatory
Guide 1.9, the inspectors determined that the licensee failed to perform a satisfactory
surveillance test, in accordance with Surveillance Requirement 4.8.1.1.2, because all auto-
connected loads were not energized and equivalent loads were not energized on the safety
bus when the licensee determined the components were not available. This resulted in a
missed surveillance, in accordance with Surveillance Requirement 4.0.3, and a failure to meet
Technical Specification Limiting Condition for Operation 3.8.1.1 when reactor startup
commenced on June 1, 2017.
Corrective Action(s): The licensee entered these issues into the corrective action program,
initiated the Surveillance Requirement 4.0.3 risk evaluation, and scheduled the performance of
Surveillance Requirement 4.8.1.1.2 at the first opportunity.
Corrective Action Reference(s): Condition Reports CR-WF3-2017-09106 and
Performance Assessment:
Performance Deficiency: The team determined that the failure to perform the emergency
diesel generator surveillance test in accordance with written test procedures was a
performance deficiency.
Screening: This performance deficiency was more than minor, and therefore a finding,
because it was associated with the equipment performance attribute of the Mitigating Systems
Cornerstone and adversely affected the cornerstone objective to ensure the availability,
reliability, and capability of systems to respond to initiating events to prevent undesirable
consequences. Specifically, the failure to ensure all components would auto-connect did not
ensure that the emergency diesel generator and sequencer would be capable of carrying
required loads during an event.
Significance: In accordance with Inspection Manual Chapter 0609, Appendix A, The
Significance Determination Process (SDP) for Findings At Power, dated July 19, 2012, the
finding screened as having very low safety significance (Green) because it was a design or
qualification deficiency that did not represent a loss of operability or functionality; did not
represent an actual loss of safety function of the system or train; did not result in the loss of
one or more trains of non-technical specification equipment; and did not screen as potentially
risk-significant due to seismic, flooding, or severe weather.
Cross Cutting Aspect: This finding had a human performance cross-cutting aspect, associated
with challenge the unknown, because the licensee failed to stop when faced with uncertain
conditions. Specifically, individuals failed to stop work when it was determined that the
surveillance test procedure could not be performed as written [H.11].
Enforcement:
Violation: Waterford Steam Electric Station, Unit 3, Technical Specification 3/4.8.1,
- A.C.
Sources, Limiting Condition for Operation 3.8.1.1 which requires that two separate and
independent diesel generators shall be operable in Modes 1, 2, 3, and 4.
Contrary to the above, from June 1, 2017, to November 16, 2017, the licensee failed to
maintain two separate and independent diesel generators operable in Modes 1, 2, 3, and 4.
Specifically, the licensee failed to perform a satisfactory surveillance test on train A emergency
diesel generator, in accordance with Surveillance Requirement 4.8.1.1.2, because all auto-
connected loads were not energized and equivalent loads were not energized on the safety
bus when the licensee determined the components were not available.
Enforcement Action(s): This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Two Examples of Failure to Submit and Receive Prior Authorization of Alternatives to ASME
OM Code Leak Testing Requirements
Cornerstone Significance Cross-cutting Report
Aspect Section
Not Applicable Severity Level IV Not Applicable 71111.21M
Closed
The team identified two examples of a Severity Level IV, non-cited violation of
CFR 50.55a(z), for failure to submit and obtain authorization prior to implementation of
multiple alternatives to leak testing requirements of the American Society of Mechanical
Engineers (ASME) Operation and Maintenance (OM) of Nuclear Power Plants Code.
Description:
Example 1: Reactor coolant loop 2 hot leg injection check valve, SI-512B, is an ASME Code
Class 1, 3-inch swing check valve that is inservice testing Categories A and C with an active
safety function. During the teams inspection of Engineering Change 55752, Replace SI-512B
with a Swing Check Valve, the team reviewed completed work orders associated with leak
rate testing. ASME OM Code required leak rate testing for SI-512B is performed using
Procedure OP-903-008, Reactor Coolant System Isolation Leakage Test. The team noted
that the licensee had modified the procedure based on an evaluation performed in Engineering
Change 47766, Safety Injection Check Valve Leak Test Method, approved on January 8,
2014. The changes to the test methodology involved measuring the pressure rise downstream
of the valve and correlating that rise to a leak rate. If the pressure rise was less than
pounds per square inch, gauge, over a 30-minute period, the test result was considered
satisfactory and recorded as less than the acceptance criteria of 1 gallon per minute. If
pressure were to rise above 30 pounds per square inch, gauge, a leak rate would be obtained
by another test.
The team determined that this test did not conform to the leak testing requirements of the
ASME OM Code, Subsection ISTC, Inservice Testing of Valves, Paragraph ISTC-3630,
Leakage Rate for Other Than Containment Isolation Valves, and the licensee did not obtain
prior authorization for this alternative test. The team also observed that the alternative test did
not guarantee a valid leak rate result because it assumed another downstream check valve,
SI-510B, was leak tight and that the piping system downstream of SI-512B was water solid,
without the test verifying those assumptions. These observations called into question whether
or not the alternative test, as written, would have obtained a valid result.
Example 2: Safety injection sump outlet header A isolation valve, SI-602A, is a 24-inch
butterfly valve that is ASME Code Class 2 and inservice testing Category A with an active
safety function. The team reviewed completed work orders associated with leak rate testing.
Required leak rate testing for valve SI-602A is performed in accordance with
Procedure OP-903-128, Category A Leak Test. The team noted that the procedure allows for
two tests for determining SI-602A valve leakage, depending on whether or not a spool piece is
removed. One of the tests allows the use of a leak detection fluid. If no evidence of leakage
exists (i.e., bubbles), the test result is recorded as satisfactory and no further leak testing is
performed. If evidence of leakage exists, a leak rate is then obtained by another test.
The team determined that this test does not conform to the leak testing requirements of the
ASME OM Code, Subsection ISTC, Inservice Testing of Valves, Paragraph ISTC-3630,
Leakage Rate for Other Than Containment Isolation Valves, and the licensee did not obtain
prior authorization for this alternative test. Although the use of leak detection fluid is not
complicated, the team observed that the test did not provide specific instructions, for example,
as to how much fluid to use, how long to wait, or where to apply the fluid. These observations
called into question whether or not the alternative test, as written, would have obtained a valid
result.
Corrective Action(s): For SI-512B, the licensee performed an operability determination which
concluded that SI-512B met technical specification leakage rate acceptance criteria of
gallon per minute or less based on a review of the reactor coolant system leak rate program.
For SI-602A, an initial review conducted by the licensee identified that the last time the use of
leak detection fluid alone for the leakage rate test of SI-602A occurred in 2006. All other tests
since 2006 obtained leak rates by tests in compliance with the ASME OM Code and were less
than the specified leakage rate limit.
Corrective Action Reference(s): Condition Report CR-WF3-2017-09143 and
Performance Assessment:
The team determined that the failure to submit and receive prior authorization for alternatives
to leak testing requirements for safety injection valves SI-512B and SI-602A was a violation of
CFR 50.55a(z).
Screening: The team determined this violation was associated with a minor performance
deficiency.
Significance: The team determined the violation to be a Severity Level IV violation similar to
violation example 6.1.d.2 in the NRC Enforcement Policy.
Enforcement:
Severity: Because this violation affected the NRCs ability to perform its regulatory function,
the inspectors evaluated this violation using the traditional enforcement process in accordance
with the NRC Enforcement Policy, dated November 1, 2016. This violation was more than
minor because there was a reasonable likelihood the change would require NRC review and
approval prior to implementation, similar to violations assessed in Section 2.1.3 of the NRC
Enforcement Manual. The team determined the violation to be a Severity Level IV violation
similar to violation example 6.1.d.2 in the NRC Enforcement Policy.
Violation: 10 CFR 50.55a(z), Alternatives to codes and standards requirements, requires, in
part, Alternatives to the requirements of paragraphs (b) through (h) of this section or portions
thereof may be used when authorized by the Director, Office of Nuclear Reactor Regulation, or
Director, Office of New Reactors, as appropriate. A proposed alternative must be submitted
and authorized prior to implementation.
Paragraph (f) of 10 CFR 50.55a, Inservice testing requirements, requires, in part, Systems
and components of boiling and pressurized water cooled nuclear power reactors must meet
the requirements of the ASME BPV Code and ASME OM Code as specified in this paragraph.
Paragraph (4) of 10 CFR 50.55a(f), Inservice testing standards requirement for operating
plants, requires, in part, that Throughout the service life of a boiling or pressurized water-
cooled nuclear power facility, pumps and valves that are classified as ASME Code Class 1,
Class 2, and Class 3 must meet the inservice test requirements (except design and access
provisions) set forth in the ASME OM Code and addenda that become effective subsequent to
editions and addenda specified in paragraphs (f)(2) and (3) of this section and that are
incorporated by reference in paragraph (a)(1)(iv) of this section, to the extent practical within
the limitations of design, geometry, and materials of construction of the components.
Contrary to the above, prior to November 16, 2017, ASME Code Class 1 and 2 valves did not
meet the inservice test requirements of the ASME OM Code and the alternatives were not
submitted and authorized prior to implementation. Specifically, the licensee did not submit and
receive prior authorization to alternative leak testing requirements for safety injection
valves SI-512A and SI 602B, which are ASME Code Class 1 and 2 valves, respectively.
Enforcement Action(s): This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Unresolved Item Potential Failure to Obtain a License Amendment for 71111.21M
(Open) Changes to Diesel Generator Surveillance Test Interval
Description:
The team identified an unresolved item for the licensees failure to perform a 10 CFR 50.59
safety evaluation and subsequently obtain a license amendment for changes to the
surveillance testing frequency of the emergency diesel generators.
The licensees process for changing surveillance test intervals is controlled by Technical Specification 6.5.18, Surveillance Frequency Control Program. The licensees changes to
the surveillance test intervals are made in accordance with NEI 04-10, Risk Informed Method
for Control of Surveillance Frequencies, Revision 1, as written in procedure EN-DC-355,
Engineering Evaluation of Proposed Surveillance Test Interval Changes, Revision 2.
The team reviewed the licensees changes to the surveillance test interval, as required by
Technical Specification Surveillance Requirements 4.8.1.1.2.e, for emergency diesel
generators. The licensee changed the surveillance test interval for the train A and B
emergency diesel generators from both emergency diesel generators tested every 18 months
to each emergency diesel generator tested every 36 months. The team determined that
testing the emergency diesel generators once every 36 months was contrary to guidance in
Regulatory Guide 1.9, Application and Testing of Safety-Related Diesel Generators in
Nuclear Power Plants, Revision 4. Specifically, Section 2.3.2.3, Refueling Outage Testing,
requires the capability of the overall emergency diesel generator design should be
demonstrated during every refueling outage not exceeding a period of 24 months.
The team determined that the licensee did not correctly evaluate the change to the
surveillance interval in accordance with surveillance frequency control program change
process. Specifically, the licensee did not correctly evaluate NEI 04-10, step 1, Check for
Prohibitive Commitments, and step 2, Can Commitments be Changed? of the change
process. The team determined that this change would require a 10 CFR 50.59 safety
evaluation and subsequent license amendment because it would result in more than a
minimal increase in likelihood of a malfunction of a component important to safety as
previously described in the final safety analysis report. Specifically, the test interval would no
longer meet the applicable acceptance standard, Regulatory Guide 1.9, to which the licensee
is committed.
Planned Closure Action(s): The NRC inspectors will review the final corrective actions,
pending NRC resolution of applicability of 10 CFR 50.59 to the surveillance frequency control
program.
Licensee Action(s): Prior to this inspection, the licensee identified this 10 CFR 50.59 issue in
the corrective action program because of industry operating experience. At the time of this
inspection, the licensee had not completed the final corrective action and 10 CFR 50.59
activities. These corrective actions will be completed once industry guidance on the NRC
resolution of applicability of 10 CFR 50.59 to the surveillance frequency control program was
available.
Corrective Action Reference(s): Condition Reports CR-WF3-2017-05590 and
NRC Tracking Number: 05000382/2017008-04
EXIT MEETINGS AND DEBRIEFS
The inspection team verified no proprietary information was retained or documented in this
report.
On November 16, 2017, the team presented the preliminary results of the Inspection
Procedure 71111.21M inspection to Mr.
- J. Dinelli, Senior Vice President, and other members
of the licensee staff.
On December 14, 2017, the team presented the final results of the Inspection
Procedure 71111.21M inspection to Mr.
- D. Brenton, General Manager-Plant Operations, and
other members of the licensee staff.
LIST OF DOCUMENTS REVIEWED
Calculations
Number Title Revision/Date
ECC99-008 TORMIS ANALYSIS: Tornado Generated Missile Strike at 1
Waterford 3
ECE89-008 Electrical Design Criteria 8
ECE90-006 EDG Loading and Fuel Oil Consumption 10
ECE91-016 Battery 3AB-S Cell Sizing 6
ECE91-055 AC Short Circuit Calculations 7
ECE91-056 Relay Settings and Coordination Curves for 6,9KV, 4.16KV 4
and 480 Volt Buses
ECE91-195 Load Study for PDP 3AB-DC-S, 346AB, 346AB-1 and 3FDAB 2
ECE91-252 Short Circuit Study for 3AB-S 0
ECE93-003 Voltage at Motor-Operated Valve February 12,
1994
ECE9I-050 Degraded Voltage Relay Set-point & Plant Load Study 7
ECI01-007 Determination of ECCS Measurement Channels Functional 1
Safety Significance
ECI92-019 Plant Protection System Uncertainty Calculation 4
ECI93-058 Transmitter Uncertainties 4
ECI95-011 HPSI Cold Leg Injection Flow Instrumentation Loop 2
Uncertainty Calculation
ECI99-001 ESF Response Time Acceptance Criteria Basis 2
ECM00-004 Emergency Feedwater Turbine Steam Supply RELAP Model 0
ECM05-003 High Pressure Safety Injection System Capacity 1
ECM07-001 NPSH Analysis of Safety Injection and Containment Spray 1
Pumps
ECM89-018 SI 602 A&B Pressure Requirements 1
ECM91-011 NPSH for Safeguard Pumps in Recirculation with 4
Valve SI-106A(B) Failed Open
ECM92-037 MOV Design Basis Review Calculation No. SI.002 4
ECM92-042 MOV Design Basis Review Calculation MS-401A&B 4
ECM97-022 Wet Cooling Tower Makeup requirements A
Calculations
Number Title Revision/Date
ECS04-019 Risk Assessment of Sl-6028 Not Fully Closed 0
ECS91-016 SI-602 Leakage Study 0
ECS98-015 Containment P&T Response Analysis 2
EE2-12-05 4.16KV Switchgears High Resistance Grounding 0
EE2-16-06 Station Service Transformer Impedance and MCC Bus 0
Reactor Calculation
HVAC-059 Battery Room Air Flow Required To Limit Hydrogen 2
Concentration To 1%
HVAC-070 Hydrogen Generation By Station Batteries 2
IM1024 Piping Stress Qualification for IM1024 due to Replacement of 3
Valve SI-512B
MN(Q)-6-29 SIS Maximum Operating Suction Pressure 1
MNQ9-17 Tornado Multiple Missile Protection of Cooling Towers 3
MNQ93 Heat Removal Capacities of DCT and WCT After LOCA 4
SQ-MN-352 3 - 2500# FLOWSERVE Check Valve 0
SQ-MN-370 Size 3 Class 2500 (CF8M) Swing Check Valve 0
Drawings
Number Title Revision/Date
2-441-0653-3 SMB-00 & 000 STANDARD UNITS WITH: A1 H0BC- February 20,
H3BC WORM GEAR ASSEMBLY B1 SEISMIC 1987
SUPPORT BRACKET
2B8124 24 BODY SMB-00-HBC2 ACTUATOR LIMITORQUE - B
200 ELECTRIC ACTUATED CONTROL VALVE
75B70058, Sh.16 Electrical Diagram 52 Control CKT 0
75B70058, Sh.17 Electrical Diagram 52 Control CKT 0
75D700340, Sh. Connection Diagram 4
75D701437 Indoor AKD-5 Power Master SWGR 3
B-289, Sh. 110 Power Distribution and Motor Data Panel 3AB-DC-S 8
B-289, Sh. 110A Power Distribution and Motor Data Panel 3AB-DC-S 13
B-289, Sh. 157 Power Distribution and Motor Data 480V SWGR Front 12
View
Drawings
Number Title Revision/Date
B-289, Sh. 16 Power Distribution and Motor Data 4.16KV SWGR 3B3-S 12
One-line Diagram
B-289, Sh. 16-1 Power Distribution and Motor Data 4.16KV SWGR 3B3-S 4
One-line Diagram
B-289, Sh. 16A Power Distribution and Motor Data 4.16KV SWGR 3B3-S 9
Protective Relay Settings
B-289, Sh. 20 Power Distribution and Motor Data 480V SWGR 3A31-S 16
One-line Diagram
B-289, Sh. 21 Power Distribution and Motor Data 480V SWGR 3B31-S 19
One-line Diagram
B-289, Sh. 21-1 Power Distribution and Motor Data 480V SWGR 3B31-S 6
One-line Diagram
B-289, Sh. 22 Power Distribution and Motor Data 480V SWGR 3AB31-S 12
One-line Diagram
B-289, Sh. 22-1 Power Distribution and Motor Data 480 SWGR 3AB31-S 3
One-line Diagram
B-424, Sh. 1535 Emergency FW Pump Turbine Steam Shut-off Valve 611 23
B-424, Sh. 1541 Emergency FWPT Governor Valve 20
B-424, Sh. 2389S Control Wiring Diagram, 480V MCC 3B31-S Undervoltage 8
Relays Sh.1
B-424, Sh. 2390 Control Wiring Diagram, 480V Bus 3B31-S Undervoltage 17
Relays Sheet 2
B-424, Sh. 2390S Control Wiring Diagram, 480V Bus 3B31-S Undervoltage 12
Relays Sheet 1
B-424, Sh. 2397S Control Wiring Diagram, Station Services Transformer 10
3B31-S Feeder
B-424, Sh. 2410S Control Wiring Diagram, 480V Bus 3AB31-S Undervoltage 10
Relays Sh.1
B-424, Sh. 2506S Control Wiring Diagram, 480V MCC 3B313-S Feeder 8
B-424, Sh. 2507S Control Wiring Diagram, 480V MCC 3B314-S Feeder 8
B-424, Sh. 2925 Control Wiring Diagram, Annunciator Display Cabinet D 8
B-424, Sh. 3016S Control Wiring Diagram - EFAS Test Module Channel A 5
B-424, Sh. 3017S Control Wiring Diagram - EFAS Test Module Channel A 5
B-424, Sh. 509 Control Wiring Diagram, High Pressure Safety Injection 16
Pump B
Drawings
Number Title Revision/Date
B-424, Sh. E1535 Control Wiring Diagram - Emergency Feedwater pump 9
Turbine Shutoff Valve VA 2MS-V611a
B-424, Sh. E509 Control Wiring Diagram, High Pressure Safety Injection 6
Pump B
G-167, Sh. 1 Safety Injection System Flow Diagram July 8, 1991
G-167, Sh. 2 Safety Injection System Flow Diagram July 8, 1991
G-250S07 Reactor Aux. Bldg. El. -35.00 Conduit Details & Sections 2
G-285 Main One Line Diagram 23
G-286 1977-1165 MW Installation Key Auxiliary One Line 19
Diagram
G-287, Sh. 1 125VDC and 120VAC One Line Diagram 28
G-317-S01 Reactor Aux Bldg. - El. +7.00 Conduit, Trays & 14
Grounding - Sh.1
G-329 Reactor Aux. BLDG-El-4.00 Conduit, Trays and 10
Grounding, Sh. 4
G-335-S01 Reactor Auxiliary Building - EL-35.00 Conduit, Tray & 14
Grounding- Sh. 3
G-344-S01 Electrical Equipment Room SWGR, MCC & Panel Detail 7
Sh. 1
T025W2000HM, Type O Plus C, IEEE, Condenser Bushing 4
Procedures
Number Title Revision/Date
01-002-000 Annunciator and Control Room Instrumentation Status Control 309
ECT-64802 Emergency Feedwater Control Valves EFWMVMA 224B and 0
EFWMVAAA223A
ECT-64803 Emergency Feedwater Control Valves EFWMVAAA 224A and 0
EFWMVAAA223B
EN-AD-101 NMM Procedure Process 29
EN-DC-115 Engineering Change Process 21
EN-DC-115 Engineering Change Process 15
EN-DC-153 Preventative Maintenance Component Classification 15
EN-DC-310 Predictive Maintenance Program 8
EN-DC-324 Preventive Maintenance Program 18
Procedures
Number Title Revision/Date
EN-DC-355 Engineering Evaluation of Proposed Surveillance Test Interval 2
change
EN-LI-101 10 CFR 50.59 Evaluations 15
EN-LI-102 Corrective Action Program 30
EN-MA-101 Conduct of Maintenance 22
EN-MA-101- Maintenance Work Preparation Process 7
EN-MA-119-01 Control, Storage, and Inspection of Lifting Equipment 7
EN-OP-104 Operability Determination Process 13
EN-WM-105 RAB Train "AB" Thermography Route June 21,
2011
ME-001-012 Temporary Power from Temporary Diesel for 3A2 and 3B2 4kV 313
Buses (MODES 1-6)
ME-003-210 Performance Test on DC Battery 21
ME-003-230 Battery Service Test 315
ME-003-240 Performance Test on DC EBATAB Battery 313
ME-003-301 480 VAC Overcurrent Protective Integrated Device Functional 8
Test
ME-003-327 4.16 kV G.E. Magne-Blast Breaker 18
ME-003-330 480 Volt GE Switchgear Breakers 310
ME-003-410 Motor-Operated Valve Thermal Overload Channel Calibration 311
ME-004-021 Emergency Diesel Generator 31
ME-004-061 Unit Auxiliary Transformer 308
ME-004-115 4.16/6.9 kV G.E. Magne-Blast Breaker Overhaul 3
ME-004-141 Low Voltage Switchgear 302
ME-004-142 480 Volt GE Switchgear AKR Breaker Overhaul 3
ME-004-161 Low Voltage Power Distribution Panels 9
ME-004-211 Station Battery Quarterly 12
ME-007-043 Viper Testing of MOVs 1
ME-007-047 VOTES Testing of MOVs 5
Procedures
Number Title Revision/Date
ME-007-073 Testing Procedure, Unit Auxiliary Transformer Power Factor 1
Testing
MI-003-219 Plant Protection System Sensor Bi-stable Response Time 301
Verification Channel A, B, C, or D
MI-003-222 Matrix Response Time Verification for Reactor Protection 307
System and Engineered Safety Features Actuation System
Channels A, B, C, or D
MI-003-302 Containment Pressure (Narrow Range) Loop Check and 304
Calibration CB IP6701 SMA, SMB, SMC, or SMD
MI-003-316 Pressurizer Pressure (Wide Range) Loop Check and 302
Calibration RC IP0102 A, B, C, or D
MI-003-514 Emergency Feedwater Control Loop Check and Calibration 311
MI-003-515 Emergency Feedwater Control Loop Check and Calibration 309
MI-005-204 Calibration of Temperature Instruments 8
MI-005-464 Plant Protection System Power Supply Calibration 305
MI-005-705 Engineered Safety Features Actuation System Auxiliary Relay 301
Cabinet 3A or 3B Power Supply and Ground Detector Test
MI-013-522 PPS Ground Detection Test 5
MM-006-053 Check Valve Inspection (Swing) 5
OP-002-007 Freeze Protection and Temperature Maintenance 25
OP-006-001 Plant Distribution (7KV, 4KV and SSD) System 326
OP-009-002 Emergency Diesel Generator 341
OP-009-008 Safety Injection System 40
OP-100-014 Technical Specification and Technical Requirements 337, 341
Compliance
OP-500-004, 480V Bus SB Bkr Trip/Trouble 20
Attach. 4.113
OP-500-004, SS Xfmr. 3B31-S Ground/Temp Hi 20
Attach. 4.85
OP-500-011 Control Room Cabinet M 38
OP-500-012 Control Room Cabinet N 37
OP-500-013 Control Room Cabinet SA 22
OP-500-014 Control Room Cabinet SB 21
OP-901-521 Severe Weather and Flooding 325
Procedures
Number Title Revision/Date
OP-902-002 Loss of Coolant Accident Recovery 20
OP-903-008 Reactor Coolant System Isolation Leakage Test 18
OP-903-011 High Safety Injection Pump Operability Check 14
OP-903-029 Safety Injection Actuation Signal Test 24
OP-903-030 Safety Injection Pump Operability Verification 34
OP-903-033 Cold Shutdown IST Valve Tests 50
OP-903-066 Electrical Breaker Alignment Check 302
OP-903-094 ESFAS Subgroup Relay Test - Operating 30
OP-903-095 ESFAS Subgroup Relay Test - Shutdown 13
OP-903-100 MOV Overload Bypass Test 310
OP-903-107 Plant Protection System Channel A B C D Function Test 310
OP-903-108 SI Flow Balance Test 15
OP-903-108, Completed Flow Balance for HPSI Pump B 14
Att. 10.3
OP-903-115 Integrated Emergency Diesel Generator/Emergency Safety 39
Features Test - Train A
OP-903-116 Train B Integrated Emergency Diesel Generator/ Engineering 39
Safety Features Test
OP-903-128 Category A Leak Test 11
SEP-ISI-104 ASME SECTION XI, DIVISION I INSERVICE INSPECTION 6
PROGRAM
SEP-WF3- WF3 INSERVICE TESTING BASES DOCUMENT 6
IST-1
SEP-WF3- WF3 INSERVICE TESTING PLAN 6
IST-2
SEP-WF3- WF3 INSERVICE TESTING CROSS REFERENCE 6
IST-3 DOCUMENT
UNT-006-033 Technical Specifications Surveillance Frequency List 1
W2.109 Procedure Development, Review and Approval 23
Engineering Changes
Number Title Revision/Date
EC 31892 Documentation of Waterford 3's Response to NRC Generic 0
Letter No. 96-01 "Testing of Safety-Related Logic Circuits"
EC 40828 Evaluation of Replacement Bushing for UAT 1
EC 44782 Emergency Diesel Generator Governor Upgrade April 23, 2014
EC 47766 Safety Injection Check Valve Leak Test Method OP-903-008 0
EC 53772 Issue Markup to ECC99-008 For EDG Lines (Tormis) not 0
Protected for Tornado Missiles
EC 54307 Leak Repair of EDG Fuel Oil Feed Tank Vent Pipes 0
EC 55752 Replace SI-512B with a Swing Check Valve 0
EC 59135 Child EC For SI-512B Hard Seat Option 0
EC 61267 EDG Day Tank Vent Lines Installation Clarification 0
EC 64801 Emergency Feedwater Circuitry Modification 0
Environmental Qualification Documents
Number Title Revision
EC 40278 Mark-up of LPLEQA8.1D LPLEQA8.1C 4
EC 59039 Mark-up of EQMI-8.1 LPLEQA8.1D 11
EC 73625 Mark-up of EQMI-8.1 11
LPL-EQA08.01C Rosemount 1153 Series D Transmitters 3
LPL-EQA-8.01D Rosemount Model 1154 Series H Transmitters 3
LPL-EQA-8.01D Rosemount Model 1154 Series H Transmitters 4
LPL-EQA-8.0I Rosemount Model 3154N Transmitters 0
LPL-EQMI-08.01 Rosemount Model 1153 Series A, B &D, 1154 &1154 11
Series H Transmitters and 1159 Remote Seals
LPL-EQMI-8.01B Rosemount Model 3152N, 3153N, and 3154N Series 0
Transmitters and 3159 Remote Seals
Vendor Documents
Number Title Revision/Date
15-111494-001 SWING CHECK VALVE STAINLESS STEEL. NOREM 1
TRIM BUTT WELD ENDS. SIZE: 3 CLASS: 2500
Form 2432 Instruction Manual Type 9200 T-Ring Butterfly Valve March 1974
Bodies
Vendor Documents
Number Title Revision/Date
GEK-721 Instructions for Type AKD-6 Low voltage August 1977
Letter-C&D Battery Cover Crack May 15, 2013
Technologies
Lou-1564.261-B Ebasco Purchase Specification for Metal-Enclosed 13
600Volt Class Draw-out type Class 1E Buses 3A31-S,
3B31-S, 3AB31-S, Transformer 3A315-S, 3B315-S & Non-
Class 1E Buses 3A32, 3B32
RAL-21146 Design and Seismic Analysis Report (Size 3 Class 2500 0
(CF8M) Swing Check Valve Drawing 15-111494-001)
RS-1476 Standby Battery Vented Cell Installation and Operating 6
Instruction
TD-A1800.0095 Allis-Chalmers Installation Operation Maintenance October 31,
Instruction Induction Motors/Generators Horizontal 500, 1996
580, 30 Frames M3514-02
TD-F994.0085 Swing check Valve, Size 3 Class 2500 Operation and 0
Maintenance Manual
TD-G080,0735 General Electric Important Instructions for Armor-Clad 0
Indoor Feeder Busway, GEH-2636
TD-G080.0625 General Electric Station Service Ventilated Dry 0
Transformer
TD-G080-0095 General Electric Switchgear Magne-Blast Breaker 6
TD-G080-0145 GE Low Voltage Switchgear Tech Manual 0
TD-L200.0055 LIMITORQUE VALVE CONTROLS TYPE SB-1 AND SMB 0
AND 00 FOR OPERATING AT HIGH TEMPERATURE
TD-S440.0015 Struthers Dunn Type A112 & 112 Relays July 31, 1997
TD-W120.3115 Westinghouse MCCB AB De-ion breaker 0
TD-W120.3135 Westinghouse MCCB 0
TD-W120.3145 Westinghouse Tri-Pac Breaker April 1976
W290.0055 2301A Load Sharing and Speed Control 0
W290.0065 Digital Reference Unit 0
W290.0075 EDG Proportional Governor/Actuator 0
Design Basis Documents
Number Title Revision
W3-DBD-001 Safety Injection System 305
Design Basis Documents
Number Title Revision
W3-DBD-002 Emergency Diesel Generator & Automatic Load 305
Sequencer
W3-DBD-003 Emergency Feedwater System 302
W3-DBD-006 Main Steam System 2
W3-DBD-008 Electrical Distribution (DC Portion) 1
W3-DBD-009 Reactor Coolant System & Steam Generator Blowdown 304
System
W3-DBD-011 Electrical Distribution (AC Portion) 1
W3-DBD-012 Plant Protection System Design Basis Document 2
W3-DBD-014 Safety Related, Air Operated Valves 303
W3-DBD-026 Containment Isolation and Leakage Rate Testing 0
Quality Assurance Audit Reports
Number Title Date
QA-4-2016-W3-1 Engineering (Design Control) April 14, 2016
QA-8-2017-W3-1 Engineering Programs March 13, 2017
QA-8-2017-W3-2 Engineering Programs April 25, 2017
Miscellaneous
Number Title Revision/Date
CN7C7244 Connection To Auxiliary Transformer 1
DC System Health Report, 125VDC Distribution Q2-2017
EG System Health Report, Emergency Diesel Generator Q2-2017
EN-Motor EN-Motor-Medium Voltage (>600V/<15KV) 4
ER-W3-2004- Reclassify SI-602 A & B as IST Category A 0
0575-001
LO-WLO-2017- 2017 Pre NRC DBAI Focus Self-Assessment October 10, 2017
00011
Procurement Switch, Temperature Hot Spot, Indicating ---
Eval. 00155992
SD-CC Component Cooling Water System Description 22
SD-SI Safety Injection 15
Miscellaneous
Number Title Revision/Date
SPEC-15-00002- Reactor Coolant Hot Leg Injection Check Valve SI 1
W MVAAA512 B Replacement
SSD SSD - 480V Station Service Distribution Q2-2017
STI 17-001 Integrated EDG/ESF Test 0
WLP-OPS-DG00 Emergency Diesel Generator Training 32
Condition Reports
CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3-
2014-05582 2014-05662 2014-05690 2014-05131 2016-01754 2017-01231
CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3-
2017-04865 2017-07888 2017-08621 2017-08618 2017-08589 2017-08448
CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3-
2015-05792 2016-05473 2017-02670 2017-07682 2015-06557 2016-05478
CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3- OE-NOE-
2017-02727 2017-06067 2015-07737 2017-02633 2017-04436 2005-00338
CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3-
2017-06067 2014-05529 2014-05341 2014-05413 2014-05690 2017-07223
CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3-
2014-05131 2004-02847 1998-00516 2015-04850 2008-05183 2017-07462
CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3-
2015-04850 2008-05183 2017-05602 2017-5590 2017-04435 2017-0572
CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3-
2017-7462 2017-03768 2016-07647 2016-07921 2016-04038 2016-04038
CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3-
2015-07975 2015-05346 2015-07907 2015-06950 2009-05400 2014-05458
CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3-
2017-01148 2017-01055 2017-01045 2017-01046 2017-01047 2014-05369
CR-WF3- CR-WF3-
2014-05131 2014-05841
Condition Reports Generated During this Inspection
CR-HQN- CR-HQN- CR-WF3- CR-WF3- CR-WF3- CR-WF3-
2017-01724 2017-01906 2017-07462 2017-08432 2017-08448 2017-08511
CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3-
2017-08518 2017-08519 2017-08521 2017-08559 2017-08568 2017-08572
Condition Reports Generated During this Inspection
CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3-
2017-08574 2017-08580 2017-08582 2017-08583 2017-08585 2017-08589
CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3-
2017-08606 2017-08611 2017-08616 2017-08618 2017-08621 2017-08627
CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3-
2017-08632 2017-08634 2017-08635 2017-08678 2017-08680 2017-08689
CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3-
2017-08737 2017-08757 2017-08940 2017-08962 2017-08982 2017-08983
CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3-
2017-09093 2017-09106 2017-09107 2017-09108 2017-09125 2017-09132
CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3- CR-WF3-
2017-09140 2017-09143 2017-09144 2017-09164 2017-09165 2017-09185
CR-WF3-
2017-09201
Work Orders
WR37471 12694 15069 27321 01 44570 01 48893 01
53699 57714 01 124211 01 125122 01 127292 153521 01
154929 01 183024 01 183173 01 212639 01 263714 263714
309077 357372 395966 396915 411850 411921
50010020 51523197 01 51523197 04 51523197 06 51655055 01 51663303 01
51663303 01 52320766 01 52333000 01 52369790 52369908 01 52433042
2442300 52475662 52475662 52485562 01 52496264 01 52504349 01
2505058 01 52507904 01 52507904 02 52514258 01 52523350 01 52534002
2550025 52570374 01 52577433 52581739 01 52591365 01 52610648
2610648 52628265 52645751 52647626 52655753 01 52679221 01
2680941 52683228 52683228 52685151 52737542 01
ADDITIONAL REQUESTS
Paperwork Reduction Act Statement
This letter does not contain new or amended information collection requirements subject
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information
collection requirements were approved by the Office of Management and Budget, control
number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to
respond to, a request for information or an information collection requirement unless the
requesting document displays a currently valid Office of Management and Budget control
number.
Modification Selections
Number Title System Inspector
40828 EVALUATION OF REPLACEMENT BUSHINGS FOR UAT N Okonkwo
44782 EDG GOVERNOR UPGRADE (BASE EC) EG S Gardner
46556 CC ISV0807A SOLENOID PREVENTATIVE CC J Braisted
MAINTENANCE EQUIVALENCY
55752 REPLACE SI-512B WITH A SWING CHECK VALVE SI J Braisted
63801 Emergency Feedwater Circuitry Modification EFW C Baron
LBDCR Change to OP-100-014 Revision 337, Ultimate Heat UHS C Baron
Sink
EC 530 Ultimate Heat Sink Water Replenishment for Tornado Event UHS C Baron
Component Selections
No. Component Inspector
Turbine Emergency Feedwater Steam Supply Valves, MSMVAAA401A C Baron
AND 401B, (DC valves)
125V dc Bus 3AB-DC-S S Gardner
High Pressure Safety Injection Pump B and Motor C Baron
Sump Outlet Motor-Operated Valve Safety Injection SI-602A J Braisted
480 Vac Class 1E switchgear, Bus 3B31S N Okonkwo
Containment isolation System/Actuation System G George
Operating Experience
Number Title Inspector
IN 2013-05 Battery Expected Life and its Potential Impact S Gardner
on Surveillance Requirements
IN 2014-03 Turbine-Driven Auxiliary Feedwater Pump A Athar
Overspeed Trip Mechanism Issues
GL 88-03 Resolution of Generic Safety Issue 93, "Steam A Athar
Binding of Auxiliary Feedwater Pumps"
Problem Identification CRs
CR Subject Inspector
Diesel generator day tank degradation Jon Braisted
3B31 issue Nnaerika Okonkwo
Additional Requests
1. Please create an item (link) in Certrec for each component listed.
2. Provide the following documents for each component, in addition to Section II of the RFI:
a. Preventive maintenance, surveillance, and test procedures; and
normal/abnormal/emergency operating procedures.
b. Frequency of preventive maintenance.
c. A List with brief description of corrective action documents for previous 3 years.
Provide an additional list of operability evaluations which discuss degraded or
nonconforming conditions.
d. Vendor Manuals.
3. Please the following program procedures in one certrec item:
a. Corrective Action Program
c. Engineering Change
d. Procedure Change
e. 50.59 Procedures
f. Preventive Maintenance Programs
4. Please provide electronic copies of the following CRs and corrective actions in one
certrec item:
2014-5162 2014-5375 2014-5414 2014-5446 2014-5662
2014-5173 2014-5377 2014-5417 2014-5448 2014-5670
2014-5175 2014-5384 2014-5419 2014-5450 2014-5690
2014-5212 2014-5385 2014-5420 2014-5452 2014-5704
2014-5213 2014-5388 2014-5421 2014-5458 2014-5708
2014-5224 2014-5390 2014-5422 2014-5497 2014-5714
2014-5304 2014-5392 2014-5423 2014-5520 2014-5720
2014-5341 2014-5407 2014-5429 2014-5529 2014-5725
2014-5343 2014-5412 2014-5441 2014-5582 2014-5730
2014-5374 2014-5413 2014-5445 2014-5584 2014-5732
SUNSI Review ADAMS: Non-Publicly Available Non-Sensitive Keyword:
By: GGeorge Yes No Publicly Available Sensitive NRC-002
OFFICE SRI:EB1 RI:EB1 RI:EB2 SRTI:TTC ROE:NRR/IPAB C:PBD
NAME GGeorge JBraisted NOkonkwo GCallaway AAthar GMiller
SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/
DATE 12/26/17 12/21/17 12/26/17 12/20/17 12/27/17 12/27/17
OFFICE C:EB1
NAME TFarnholtz
SIGNATURE /RA/
DATE 12/28/17