IR 05000382/2018001
| ML18128A066 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 05/08/2018 |
| From: | Geoffrey Miller NRC/RGN-IV/DRP/RPB-D |
| To: | Dinelli J Entergy Operations |
| Miller G | |
| References | |
| IR 2018001 | |
| Download: ML18128A066 (29) | |
Text
May 8, 2018
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED INSPECTION REPORT 05000382/2018001
Dear Mr. Dinelli:
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford Steam Electric Station, Unit 3. On April 12, 2018, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
NRC inspectors documented one Severity Level IV violation with no associated finding. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
From April 2017 to April 2018, the NRC issued three Severity Level IV traditional enforcement violations associated with impacting the ability of the NRC to perform its regulatory oversight function. This includes the one Severity Level IV violation documented in this report. However, 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, because one of the violations occurred in 2006 and is not representative of present performance.
If you contest the violation or significance of this NCV, 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 Waterford Steam Electric Station, Unit 3. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Geoffrey Miller, Branch Chief Project Branch D Division of Reactor Projects
Docket No. 50-382 License No. NPF-38
Enclosure:
Inspection Report 05000382/2018001 w/ Attachments:
1. Documents Reviewed 2. O
Inspection Report
Docket Number:
05000382
License Number:
Report Number:
Enterprise Identifier: I-2018-001-0002
Licensee:
Entergy Operations, Inc.
Facility:
Waterford Steam Electric Station, Unit 3
Location:
17265 River Road
Killona, LA 70057
Inspection Dates:
January 1, 2018, to March 31, 2018
Inspectors:
F. Ramírez, Senior Resident Inspector
C. Speer, Resident Inspector
J. Choate, Project Engineer
J. Dixon, Senior Project Engineer
N. Greene, PhD, Senior Health Physicist
S. Money, Health Physicist
J. ODonnell, CHP, Health Physicist
Approved By:
G. Miller, Chief
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Waterford Steam Electric Station, Unit 3, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. An NRC-identified violation and additional items are summarized in the tables below.
List of Findings and Violations
Failure to Obtain NRC Staff Authorization Prior to Changing a Procedure that Impacts Implementation of Technical Specifications Cornerstone Significance Cross-cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000382/2018001-01 Closed Not Applicable 71152 The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.59, Changes,
Tests, and Experiments, Section (c)(1), for the licensees failure to submit and obtain authorization prior to implementation procedures described in the Final Safety Analysis Report.
Additional Tracking Items
Type Issue number Title Report Section Status LER 05000382/2017-002-00 Automatic Reactor Scram due to the Failure of Fast Bus Transfer Relays to Automatically Transfer Station Loads to Off-site Power on a Main Generator Trip 71153 Closed
PLANT STATUS
Waterford Steam Electric Station Unit 3 operated at or near 100 percent rated thermal power for the entire inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather (1 Sample)
The inspectors evaluated readiness for impending adverse weather conditions prior to the onset of and during extreme low temperatures for the area on January 16, 2018.
71111.04 - Equipment Alignment
Partial Walkdown (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Emergency feedwater train A following maintenance on January 12, 2018
- (2) Component cooling water train A with train B out of service for maintenance on January 24, 2018
- (3) Low pressure safety injection train A with train B out of service for maintenance on March 13, 2018
71111.05 - Fire Protection
Quarterly Inspection (5 Samples)
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) Shutdown cooling heat exchanger rooms A and B, Fire Area RAB 33, on January 4, 2018
- (2) Switchgear room B, Fire Area RAB 8B, E, and F on February 12, 2018
- (3) Control room, Fire Area RAB 1A, B, C, and D on February 12, 2018
- (4) Component cooling water heat exchanger B, Fire Area RAB 17 on March 13, 2018
- (5) Component cooling water pump room A, Fire Area RAB 19 on March 14, 2018
71111.07 - Heat Sink Performance
Heat Sink (1 Sample)
The inspectors evaluated the ultimate heat sink performance test on January 23, 2018.
71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance
Operator Requalification (1 Sample)
The inspectors observed and evaluated operator performance in the simulator during an evaluated emergency plan exercise on February 21, 2018.
Operator Performance (1 Sample)
The inspectors observed and evaluated control room operator performance during main turbine governor valve testing on January 19, 2018.
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness (3 Samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
- (1) Component cooling water on January 25, 2018
- (2) 125 Vdc distribution system on March 12, 2018
- (3) Plant protection system on March 28, 2018
Quality Control (1 Sample)
The inspectors evaluated maintenance and quality control activities associated with the following equipment performance issues:
- (1) Fuel oil storage tank A1 vendor and licensee quality documents related to receipt of segments from vendor and associated welding on March 7, 2018
71111.13 - Maintenance Risk Assessments and Emergent Work Control
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Risk assessment associated with maintenance on boric acid makeup tanks A and B on January 3, 2018
- (2) Risk assessment and risk management actions associated with maintenance on emergency diesel generator A on January 31, 2018
- (3) Control element assembly emergency work and unexpected limiting condition for operation on February 6, 2018
71111.15 - Operability Determinations and Functionality Assessments
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Core element assembly calculator 2 unexpected trend on January 2, 2018
- (2) Atmospheric dump valve A leakage on February 8, 2018
- (3) Component cooling water heat exchanger B failed performance test on February 9, 2018
- (4) Reactor coolant pump 2A oil leak on March 8, 2018
- (5) Core protection calculator Channel C failure on March 26, 2018
- (6) Ultimate heat sink on March 28, 2018
71111.18 - Plant Modifications
The inspectors evaluated the following temporary or permanent modifications:
- (1) Dry cooling tower train A recirculation barrier installation, Phase 3, on March 16, 2018
71111.19 - Post Maintenance Testing
The inspectors evaluated the following post maintenance tests:
- (1) Reactor trip circuit breaker 6 on January 9, 2018
- (2) High pressure safety injection train B on January 23, 2018
- (3) Emergency diesel generator A on February 3, 2018
- (4) Auxiliary component cooling water train B on February 21, 2018
- (5) Component cooling water pump B to AB suction cross-connect valve solenoid valve replacement on March 8, 2018
- (6) Component cooling water pump B to AB discharge cross-connect valve solenoid valve replacement on March 8, 2018
- (7) Low pressure safety injection pump B on March 14, 2018
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Routine
- (1) Emergency diesel generator A monthly surveillance on January 8, 2018
- (2) Safety Channel A nuclear instrumentation functional test on January 24, 2018
- (3) Functional test of plant protective system Channel C on February 23, 2018
71114.06 - Drill Evaluation
Emergency Planning Drill (1 Sample)
The inspectors evaluated a site emergency plan drill on February 21,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (1 Sample)
The inspectors evaluated radiological hazards assessments and controls.
Instructions to Workers (1 Sample)
The inspectors evaluated worker instructions.
Contamination and Radioactive Material Control (1 Sample)
The inspectors evaluated contamination and radioactive material controls.
Radiological Hazards Control and Work Coverage (1 Sample)
The inspectors evaluated radiological hazards control and work coverage.
High Radiation Area and Very High Radiation Area Controls (1 Sample)
The inspectors evaluated risk-significant high radiation area and very high radiation area controls.
Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample)
The inspectors evaluated radiation worker performance and radiation protection technician proficiency.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Engineering Controls (1 Sample)
The inspectors evaluated airborne controls and monitoring.
Use of Respiratory Protection Devices
The inspectors evaluated respiratory protection.
Self-Contained Breathing Apparatus for Emergency Use (1 Sample)
The inspectors evaluated the licensees self-contained breathing apparatus program.
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicator submittals listed below:
- (1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (January 1, 2017, through December 31, 2017)
- (2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample (January 1, 2017, through December 31, 2017)
- (3) IE04: Unplanned Scrams with Complications (USwC) Sample (January 1, 2017, through December 31, 2017)
- (4) OR01: Occupational Exposure Control Effectiveness Sample (April 1, 2017, through December 31, 2017)
- (5) PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (April 1, 2017, through December 31, 2017)
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issue:
- (1) Implementation of change to technical specification and technical requirements compliance procedure
71153 - Follow-up of Events and Notices of Enforcement Discretion Licensee Event Reports
The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:
- (1) Licensee Event Report (LER) 05000382/2017-002-00, Automatic Reactor Scram due to the Failure of Fast Bus Transfer Relays to Automatically Transfer Station Loads to Off-site Power on a Main Generator Trip, on July 17,
INSPECTION RESULTS
Failure to Obtain NRC Staff Authorization Prior to Changing a Procedure that Impacts Implementation of Technical Specifications Cornerstone Significance Cross-cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000382/2018001-01 Closed Not Applicable 71152 The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.59, Changes, Tests, and Experiments, Section (c)(1), for the licensees failure to submit and obtain authorization prior to implementation procedures described in the Final Safety Analysis Report.
Description:
Waterford Technical Specification 3.7.4, states, in part, that two independent trains of ultimate heat sink cooling towers shall be Operable in Modes 1, 2, 3, and 4. Each train consists of a dry cooling tower and a wet cooling tower and its associated water basin.
Action c of Technical Specification 3.7.4 states that with a tornado watch in effect, all nine dry cooling tower fans under the missile protected portion of the dry cooling tower shall be Operable. If the number of Operable fans is less than required, restore the inoperable fan(s)to Operable status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, or be in at least Hot Standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Hot Shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The licensee established Procedure OP-100-014, Technical Specification and Technical Requirements Compliance, Revision 336, to provide guidance for determining Operability of equipment and ensuring compliance with the technical specifications and technical requirements manual. Procedure OP-100-014, Attachment 6.6, Specific System Guidelines, provides guidelines on actions when declaring a system inoperable. One of the systems listed and discussed is the ultimate heat sink and its associated Technical Specification 3.7.4.
The Process Applicability Determination process is a method for determining which plant licensing basis documents and processes are affected by a proposed activity and must be revised to reflect that activity. The licensee revised Procedure OP-100-014, Revision 336, using a Process Applicability Determination Evaluation [PAD-OP-100-014, Revision 337] to provide additional guidance on implementation of Technical Specification 3.7.4.
Procedure OP-100-014, Revision 337, was implemented in February 2017 with an added note stating, in part, if the dry cooling tower fans are declared inoperable solely due to wet cooling tower fans being out of service (cascading technical specification), then Technical Specification 3.7.4.c does not need to be applied upon a tornado watch/warning. The licensee performed a technical analysis and concluded that the missile-protected dry cooling tower fans were to be considered Operable for the tornado event because wet cooling tower fan operation is not credited in the tornado event analysis.
The licensee used Procedure EN-LI-100, Process Applicability Determination, to evaluate the change in licensing basis documents. When answering the question, does the proposed activity affect, invalidate, or render incorrect, OR have the potential to affect, invalidate, or render incorrect, information contained in any of the following Licensing Basis Documents?
the licensee answered no for impact on Operating License/Technical Specifications.
However, the inspectors determined that this addition to the site procedure could adversely impact the bases for the acceptability to ultimate heat sink design and operations. As a result, that question should have been answered yes and the licensee would have had to prepare a licensing basis document change request. The inspectors concluded that if Procedure OP-100-014, Revision 337, would have been implemented as written, it would have constituted a change affecting an evaluation that demonstrates the function of the ultimate heat sink.
The inspectors confirmed that between February 2017 and January 2018, there were no tornado watches that coincided with ultimate heat sink system work windows. Therefore, during the time this note was in the procedure, the licensee did not invoke the provision.
Corrective Action(s): The licensee removed the note from Procedure OP-100-014, and corrected the interpretation of the technical specification. Procedure OP-100-014, Revision 342, which removed the note, became effective January 2018. Therefore, if the wet cooling tower fans are inoperable, and there is a simultaneous tornado watch/warning, the licensee will implement Technical Specification 3.7.4, Action c.
Corrective Action Reference(s): CR-WF3-2018-02111
Performance Assessment:
Performance Deficiency: The licensees failure to submit a licensing basis document change request when performing a change impacting technical specifications in accordance with Procedure EN-LI-100, Process Applicability Determination, was a performance deficiency.
Specifically, Procedure EN-LI-100 states that if proposed activities affect, invalidate, or render incorrect information contained in Licensing Basis Documents such as the Operating License/Technical Specifications, then the proper regulatory reviews are performed. The procedure instructs the licensee to prepare a licensing basis document change request in accordance with the licensing basis document change process.
Screening: The inspectors determined the performance deficiency was of minor significance because the licensee did not implement this procedure change and as a result, did not incur a violation of technical specifications. However, because 10 CFR 50.59 violations could potentially impede or impact the regulatory process, the inspectors processed this performance deficiency using the traditional enforcement process and the examples in Section 6.1 of the Enforcement Policy.
Enforcement:
Severity: The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter noncompliance. 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 inspectors determined the violation to be a Severity Level IV violation similar to violation Example 6.1.d.2 in the NRC Enforcement Policy.
Violation: As stated, in part, in 10 CFR 50.59, Changes, Tests, and Experiments, Section (c)(1), a licensee may make changes in the facility as described in the final safety analysis report (as updated), make changes in the procedure as described in the final safety analysis report (as updated), and conduct tests or experiments not described in the final safety analysis report (as updated) without obtaining a license amendment pursuant to Sec. 50.90 only if:
- (i) a change to the Technical Specifications incorporated in the license is not required. The licensee established Procedure EN-LI-100, Process Applicability Determination, Revision 19, to comply with this requirement. Attachment 9.1 of Procedure EN-LI-100 states, in part, to prepare a licensing basis document change request if a proposed activity affects, invalidates, or renders incorrect, information contained in Technical Specifications.
Contrary to the above requirements, from February 2017, until December 2017, the licensee completed an activity that affected Technical Specifications and did not prepare a licensing basis document change request. Specifically, the licensee implemented a change to Technical Specification 3.7.4, Action c, through the implementation of Procedure OP-100-014, Technical Specification and Technical Requirements Compliance, Revision 337, by adding a note that instructed Operations personnel to not enter Technical Specification 3.7.4.c in the event of a tornado watch/warning if the dry cooling tower fans were declared inoperable solely due to wet cooling tower fans being out of service. This action was inconsistent with the current licensing basis and would have constituted a violation of technical specifications.
Enforcement Action: Because this violation was not repetitive or willful, and was entered into the licensees corrective action program as CR-WF3-2018-02111, this violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy.
Licensee Event Report (Closed)
Automatic Reactor Scram due to the Failure of Fast Bus Transfer Relays to Automatically Transfer Station Loads to Off-site Power on a Main Generator Trip 05000382/2017-002-00 71153
Description:
The NRC conducted a special inspection to better understand the facts and circumstances surrounding this event. The results and findings of that inspection are documented in NRC Inspection Report 05000382/2017011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17354A690). The inspectors did not identify any new deficiencies as a result of this review. This LER is closed.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On January 25, 2018, the inspectors presented the radiation safety inspection results to Mr. J. Dinelli, Site Vice President, and other members of the licensee staff.
On April 12, 2018, the resident inspectors presented the quarterly resident inspector inspection results to Mr. J. Dinelli, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
71111.01 - Adverse Weather Protection
Procedures
Number
Title
Revision
OP-002-007
Freeze Protection and Temperature Maintenance
OP-901-521
Severe Weather and Flooding
25
Condition Reports (CRs)
CR-WF3-2018-00004
CR-WF3-2018-00098
71111.04 - Equipment Alignment
Procedures
Number
Title
Revision
OP-002-003
Component Cooling Water
317
OP-009-003
Emergency Feedwater
309
OP-009-008
Safety Injection System
71111.05 - Fire Protection
Miscellaneous Documents
Number
Title
Revision
RAB1A-B-C-D-
001
Control Room Proper, H&V Room, Emergency Living
Quarters, and Computer Room
RAB8B-E-F-001
Switchgear B
RAB 17-001
Component Cooling Water Heat Exchanger B
RAB 19-001
Component Cooling Water Pump Room A
RAB 33-001
Shutdown Cooling Heat Exchanger Rooms A and B
Procedures
Number
Title
Revision
Pre-fire Strategies, Development and Revision
304
71111.11 - Licensed Operator Requalification Program and Licensed Operator
Performance
Procedures
Number
Title
Revision
OP-901-111
303
OP-901-403
High Airborne Activity in Containment
OP-901-404
High Airborne Activity in FHB
OP-901-405
Fuel Handling Incident
OP-901-513
Spent Fuel Pool Cooling Malfunction
OP-902-002
Loss of Coolant Accident Recovery
71111.12 - Maintenance Effectiveness
Miscellaneous Documents
Number
Title
Revision
910163-001
PCI Quality Assurance Traveler - FOST A1 Fabrication
Station Battery B Cell Lid Cracking
Station Battery A Cell Lid Cracks
QPP-205
Graham, Visual Inspection
QPP-205
Addenda
Graham, Visual Inspection addenda
WDT-0528
PCI Welding EDG Supplemental Fuel Oil Storage Tank
WF3-FOST-DN-
21
Deviation Notice for Waterford 3 Fuel Oil Storage Tank,
Tank A1 - Rust and Arc Strikes on Shell
Procedures
Number
Title
Revision
ME-003-200
Station Battery Bank and Charger (Weekly)
314
Condition Reports (CRs)
CR-WF3-2014-06375
CR-WF3-2015-00842
CR-WF3-2015-04849
CR-WF3-2015-04854
CR-WF3-2017-03607
CR-WF3-2017-08771
CR-WF3-2017-09167
Work Orders
446024
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Procedures
Number
Title
Revision
OP-903-005
Control Element Assembly Operability Check
71111.15 - Operability Determinations and Functionality Assessments
Miscellaneous Documents
Number
Title
Revision/Date
Protected Equipment List
January 31,
2018
Revised Impact AST Dose Analyses to Address MSSV and
ADV Leakages
Component Cooling Water Heat Exchanger Degraded
Performance
ECM95-008
Ultimate Heat Sink Design Basis
ECS05-13
Ultimate Head Sink Containment Heat Loads
MNQ9-2
Component Cooling Water System
MNQ9-50
ACCW System Resistance
TD-G080.0495
General Electric Spare Reactor Coolant Pump Motor
Drawings
WF3-ME-16-
00001
Meteorological Parameters and Parameter Relationships for
Design and Operability of the Waterford 3 Ultimate Heat
Sink
Procedures
Number
Title
Revision
OP-001-002
Reactor Coolant Pump Operation
PE-004-021
CCW Heat Exchanger Performance Test
Condition Reports (CRs)
CR-WF3-2012-02332
CR-WF3-2018-00785
CR-WF3-2018-00951
CR-WF3-2018-01225
Condition Reports (CRs)
CR-WF3-2018-01549
Work Orders
481333
495770
495771
496893
2348919
71111.18 - Plant Modifications
Miscellaneous Documents
Number
Title
Revision
6W12CM10
Common Mat Stress Analysis - Cooling Tower Area
ECC16-004
Horizontal Air Flow Barrier Roof and Gutters at Dry Cooling
Tower Outside Missile Protection
ECM95-008
Ultimate Heat Sink Design Basis
MNQ9-52
Ultimate Heat Sink Performance based on data
WF3-ME-16-
00001
Meteorological Parameters and Parameter Relationships for
Design and Operability of the Waterford 3 Ultimate Heat
Sink
Condition Reports (CRs)
Work Orders
444257
71111.19 - Post-Maintenance Testing
Miscellaneous Documents
Number
Title
Revision
AR 184566184566Replace Solenoid Valve
AR 186060186060Align PMRQs for AOV PM Optimization Program
TD A610.0155
ASCO Installation and Maintenance Instructions for 3-Way
Solenoid Valves Series 8316
Procedures
Number
Title
Revision/Date
ME-007-019
ASCO/AVCO/MAC/Parker Hannifin Solenoid Valves
306
Procedures
Number
Title
Revision/Date
MM-003-041
Six Year Emergency Diesel Engine Inspection
February 2,
2018
OP-903-030
Safety Injection Pump Operability Verification
OP-903-050
Component Cooling Water and Auxiliary Component
Cooling Water Pump and Valve Operational Test
039
OP-903-118
Primary Auxiliaries Quarterly IST Valve Tests
OP-903-121
Safety System Quarterly IST Valve Tests
Condition Reports (CRs)
CR-WF3-2018-00441
CR-WF3-2018-01498
Work Orders
436357
2649596
2673039
2701091
71111.22 - Surveillance Testing
Miscellaneous Documents
Number
Title
Date
TD-C490.0485
Combustion Engineering Ex-Core Neutron Flux Monitoring
System Safety Channel Operation and Maintenance Manual
April, 1985
Procedures
Number
Title
Revision
MI-003-002
Safety Channel Nuclear Instrumentation Functional Test
OP-903-068
Emergency Diesel Generator and Subgroup Relay
Operability Verification
319
OP-903-107
Plant Protection System Channel C Functional Test
2
Work Orders
2800018
2800019
71114.06 - Drill Evaluation
Procedures
Number
Title
Revision
Unusual Event
306
Alert
309
Site Area Emergency
308
Notifications and Communications
315
OP-902-002
Loss of Coolant Accident Recovery
Condition Reports (CRs)
CR-WF3-2018-01083
CR-WF3-2018-01095
71124.01 - Radiological Hazard Assessment and Exposure Controls
Number
Title
Date
OL-011518-002
Pool Purification Pump Shaft Removal
January 15,
2018
OL-02112017-
013
Sluice CVC IX A
February 11,
2017
OL-032717-006
Lapel Air Sample for RWP 2017-0064
March 27,
2017
OL-040417-004
Alpha Air - RAB -35 Safeguards Room A
April 4, 2017
OL-072217-0015 Alpha Air - Letdown Valve Gallery
July 22, 2017
RF-05162017-
561
Alpha Air - Top of UGS
May 16, 2017
Audits and Self-Assessments
Number
Title
Date
LO-WLO-2017-
00068 CA-00005 Pre-NRC Self-Assessment Radiation Safety - IP 71124.01
November
30, 2017
Miscellaneous Documents
Number
Title
Date
NSTS Annual Inventory Reconciliation Report
January 4,
2018
Miscellaneous Documents
Number
Title
Date
Periodic Review of Plant Isotopic Mix Compared to
Radiation Protection Instrument, Revision 1
September
21, 2017
Review of Smears Taken for Alpha Characterization During
RF21
September
19, 2017
Spent Fuel Pool Inventory
October 25,
2017
Update to the Review of the Capabilities of Our Passive
Monitoring Program to Detect Intakes at Waterford-3
October 4,
2017
2017-2018
Entergy Waterford 3 Radiation Protection Department
Respiratory Improvement Plan
August 10,
2017
Att. 9.6 to EN-
RP-101
LHRA/VHRA Key Log
January 23-
25, 2018
Sealed Source Leak Test
June 22,
2017
Semi-Annual Source Inventory
December
11, 2017
Procedures
Number
Title
Revision
PWR Control of Miscellaneous Materials in the Spent Fuel
Pool
Radiation Worker Expectations
Access Control for Radiologically Controlled Areas
Radiological Control
Personnel Contamination Events
Radiological Work Permits
Radiological Survey Documentation
Radiation Protection Posting
Hot Spot Program
Radioactive Material Control
Alpha Monitoring
Source Control
Operation and Calibration of the CRONOS Contamination
Monitor
Radiation Surveys
Number
Title
Date
+46 Pressurizer Cubicle
April 18, 2017
FHB +46 Fuel Handling Area
May 1, 2017
FHB +46 Fuel Handling Area
November
30, 2017
FHB +46 Fuel Handling Area
November
30, 2017
RAB -4 Hallways
January 16,
2018
RAB -35 Hallways
January 18,
2018
RAB -21 Hallways
January 24,
2018
Radiation Work Permits
Number
Title
Revision
2017-0101
Work Activities in the Spent Fuel Pool and the Transfer
Canal
2017-0509
RF21 Remove/Replace Steam Generator Primary
Manways/Diaphragms
2017-0510
Install/Remove Steam Generator Nozzle Dams, Pin
Verification and Closure
2017-0705
RF21 Reassembly of Reactor Head and Associated Work
Activities
2017-0727
RF21 Perform Reactor Vessel (ISI) Inspection Using the
WestDyne (ROSA) and a Submarine
2018-0004
Maintenance Activities in all Radiologically Controlled Areas 0
2018-0007
Perform Various Decon and Housekeeping Activities in all
Radiologically Controlled Areas
Condition Reports (CRs)
CR-WF3-2017-02718
CR-WF3-2017-03344
CR-WF3-2017-03362
CR-WF3-2017-03872
CR-WF3-2017-06030
CR-WF3-2017-07988
CR-WF3-2018-00506
WT-WTWF3-2017-
273
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Air Quality Testing Results
Number
Title
Date
296484-0
Compressed Air/Gas Quality Testing Laboratory Report
February 15,
2017
296614-0
Compressed Air/Gas Quality Testing Laboratory Report
February 16,
2017
309752-0
Compressed Air/Gas Quality Testing Laboratory Report
July 28, 2017
309780-0
Compressed Air/Gas Quality Testing Laboratory Report
July 31, 2017
Audits and Self-Assessments
Number
Title
Date
LO-WLO-2017-
00068
Pre-NRC Assessment IP 71124.03 In-Plant Airborne
Radioactivity Control and Mitigation
November
23, 2017
Filtration Testing Results
Number
Title
Date
257571
Charcoal Sample Testing
May 31, 2016
2577572
In-Place HEPA Filter Testing
June 1, 2016
2704414
In-Place Charcoal Filter Testing
November 8,
2017
Miscellaneous Documents
Number
Title
Date
Inspection and Maintenance of Respiratory Protection
Equipment - Face Piece Inspection Log
December
27, 2017
Inspection and Maintenance of Respiratory Protection
Equipment - SCBA Inspection Log
December
27, 2017
2017-0702-04
TEDE-ALARA Evaluation
November
15, 2016
Procedures
Number
Title
Revision
Operation and Initial Setup of the Eberline AMS-4
Continuous Air Monitor
Respiratory Protection Program
Procedures
Number
Title
Revision
Inspection and Maintenance of Respiratory Protection
Equipment
EN-RP-502-01
Fire Hawk M7 SCBA
Selection, Issue And Use Of Respiratory Protection
Equipment
Breathing Air
SCBA Maintenance Records
Number
Title
Date
UEM-6123
Posi3 USB Test Results - Complete SCBA Test
March 31,
2016
UEM-6123
Posi3 USB Test Results - Complete SCBA Test
February 13,
2017
UEM-6259
Posi3 USB Test Results - Complete SCBA Test
March 30,
2016
UEM-6259
Posi3 USB Test Results - Complete SCBA Test
February 14,
2017
Condition Reports (CRs)
CR-WF3-2017-00011
CR-WF3-2017-00678
CR-WF3-2017-05533
CR-WF3-2017-06758
71151 - Performance Indicator Verification
Audits and Self-Assessments
Number
Title
Date
LO-WLO-2017-
00068
Radiation Safety 71151 OR01 Occupational Exposure
Control Effectiveness
November
29, 2017
Miscellaneous Documents
Number
Title
Date
0036
NRC Performance Indicator (PI) Data - 1st Quarter 2017
ROP Data
April 12, 2017
0058
NRC Performance Indicator (PI) Data - 2nd Quarter 2017
ROP Data
July 13, 2017
Miscellaneous Documents
Number
Title
Date
0076
NRC Performance Indicator (PI) Data - 3rd Quarter 2017
ROP Data
October 6,
2017
0004
NRC Performance Indicator (PI) Data - 4th Quarter 2017
ROP Data
January 9,
2018
Procedures
Number
Title
Revision
Regulatory Performance Indicator Process
71152 - Problem Identification and Resolution
Miscellaneous Documents
Number
Title
Date
White Paper
Cascading Technical Specifications During Emergency
Diesel Generator Outages
February,
2018
Procedures
Number
Title
Revision
Process Applicability Determination Form
OP-100-014
Technical Specification and Technical Requirements
Compliance
336, 337, 340
Condition Reports (CRs)
CR-WF3-2017-00785
Occupational Radiation Safety Inspection
Waterford-3
Dates of Inspection: January 22 - 26, 2018
Integrated Inspection Report 2018001
Inspection areas are listed in the attachments below.
Please provide the requested information on or before January 5, 2018.
Please submit this information using the same lettering system as below. For example, all
contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled
1-A, applicable organization charts in file/folder 1-B, etc.
If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at
least 30 days later than the onsite inspection dates, so the inspectors will have access to the
information while writing the report.
In addition to the corrective action document lists provided for each inspection procedure listed
below, please provide updated lists of corrective action documents at the entrance meeting.
The dates for these lists should range from the end dates of the original lists to the day of the
entrance meeting.
If more than one inspection procedure is to be conducted and the information requests appear
to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which
file the information can be found.
If you have any questions or comments, please contact Natasha Greene at (817) 200-1154 or
Natasha.Greene@nrc.gov.
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.
1.
Radiological Hazard Assessment and Exposure Controls (71124.01) and
Performance Indicator Verification (71151)
Date of Last Inspection:
4/24/2017
A.
List of contacts and telephone numbers for the Radiation Protection Organization Staff
and Technicians
B.
Applicable organization charts
C.
Audits, self-assessments, and LERs written since 4/24/2017, related to this inspection
area
D.
Procedure indexes for the radiation protection procedures
E.
Please provide procedures related to the following areas noted below. Additional
procedures may be requested by number after the inspector reviews the procedure
indexes.
1. Radiation Protection Program
2. Radiation Protection Conduct of Operations, if not included in #1.
3. Personnel Dosimetry
4. Posting of Radiological Areas
5. High Radiation Area Controls
6. RCA Access Controls and Radiation Worker Instructions
7. Conduct of Radiological Surveys
8. Radioactive Source Inventory and Control
F.
List of corrective action documents (including corporate and sub-tiered systems) since
4/24/2017.
a. Initiated by the radiation protection organization
b. Assigned to the radiation protection organization
NOTE: The lists should indicate the significance level of each issue and the search
criteria used. Please provide in document formats which are searchable so that
the inspector can perform word searches.
G.
List of radiologically significant work activities scheduled to be conducted during the
inspection period. (If the inspection is scheduled during an outage, please also include a
list of work activities greater than 1 rem, scheduled during the outage with the dose
estimate for the work activity.)
H.
List of active radiation work permits
I.
Radioactive source inventory list all radioactive sources that are required to be leak
tested. Indicate which sources are 10 CFR Part 20, Appendix E, Category 1 or Category
2. Please indicate the radioisotope, initial and current activity (w/assay date), and
storage location for each applicable source.
J.
The last two leak test results for the Category 1 or 2 radioactive sources and any other
radioactive source(s) that have failed its leak test within the last two years
K.
A list of any non-fuel items stored in the spent fuel pools, and if available, their
appropriate dose rates (Contact / @ 30cm)
L.
A list of radiological controlled area entries greater than 100 millirem since 4/24/2017.
The list should include the date of entry, some form of worker identification, the radiation
work permit used by the worker, dose accrued by the worker, and the electronic
dosimeter dose alarm set-point used during the entry (for Occupational Radiation Safety
Performance Indicator verification in accordance with IP 71151).
3.
In-Plant Airborne Radioactivity Control and Mitigation (71124.03)
Date of Last Inspection:
3/21/2016
A.
List of contacts and telephone numbers for the following areas:
1. Respiratory Protection Program
2. Self-contained breathing apparatus
B.
Applicable organization charts
C.
Copies of audits, self-assessments, vendor or NUPIC audits for contractor support
(SCBA), and LERs, written since 3/21/2016 related to:
1. Installed air filtration systems
2. Self-contained breathing apparatuses
D.
Procedure index for:
1. Use and operation of continuous air monitors
2. Use and operation of temporary air filtration units
3. Respiratory protection
E.
Please provide specific procedures related to the following areas noted below.
Additional Specific Procedures may be requested by number after the inspector reviews
the procedure indexes.
1. Respiratory protection program
2. Use of self-contained breathing apparatuses
3. Air quality testing for SCBAs
4. Use of installed plant systems, such as containment purge, spent fuel pool
ventilation, and auxiliary building ventilation
F.
A summary list of corrective action documents (including corporate and sub-tiered
systems) written since 3/21/2016, related to the Airborne Monitoring program including:
1. Continuous air monitors
2. Self-contained breathing apparatuses
3. Respiratory protection program
NOTE: The lists should indicate the significance level of each issue and the search
criteria used. Please provide in document formats which are searchable so that
the inspector can perform word searches.
G.
List of SCBA qualified personnel - reactor operators and emergency response personnel
H.
Inspection records for self-contained breathing apparatuses (SCBAs) staged in the plant
for use since 3/21/2016.
I.
SCBA training and qualification records for control room operators, shift supervisors,
STAs, and OSC personnel for the last year.
A selection of personnel may be asked to demonstrate proficiency in donning, doffing,
and performance of functionality check for respiratory devices
J.
List of respirators (available for use) by type (APR, SCBA, PAPR, etc.), manufacturer,
and model.
J. Dinelli
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED INSPECTION
REPORT 05000382/2018001 DATED MAY 8, 2018
DISTRIBUTION
KKennedy, RA
SMorris, DRA
AVegel, DRP
RLantz, DRP
MShaffer, DRS
JClark, DRS
SKirkwood, RC
GMiller, DRP
JDixon, DRP
JChoate, DRP
FRamirez, DRP
CSpeer, DRP
AElam, DRP
JBowen, RIV/OEDO
VDricks, ORA
JWeil, OCA
APulvirenti, NRR
AMoreno, RIV/CAO
BMaier, RSLO
EUribe, IPAT
MHerrera, DRMA
R4Enforcement
ROP Reports
Electronic Distribution for Waterford
OFFICIAL RECORD COPY
ADAMS ACCESSION NUMBER: ML18128A066
SUNSI Review
By: JDixon/rdr
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available
Keyword:
OFFICE
SRI:DRP/D
RI:DRP/D
PE:DRP/D
BC:DRS/EB1
BC:DRS/EB2
BC:DRS/PSB2
NAME
FRamirez
CSpeer
JChoate
TFarnholtz
JDrake
HGepford
SIGNATURE
/RA/
/RA/
/RA/
/RA/
/RA/
/RA/
DATE
5/7/18
5/4/18
5/7/18
5/3/2018
5/3/18
5/3/18
OFFICE
BC:DRS/OB
TL:DRS/IPAT
SPE:DRP/D
BC:DRP/D
NAME
VGaddy
GGeorge
JDixon
GMiller
SIGNATURE
/RA/
/RA/
/RA/
/RA/
DATE
5/7/18
5/3/18
5/3/18
5/8/18
May 8, 2018
Mr. John Dinelli
Site Vice President
Entergy Operations, Inc.
265 River Road
Killona, LA 70057-0751
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED
INSPECTION REPORT 05000382/2018001
Dear Mr. Dinelli:
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at your Waterford Steam Electric Station, Unit 3. On April 12, 2018, the NRC inspectors
discussed the results of this inspection with you and other members of your staff. The results of
this inspection are documented in the enclosed report.
NRC inspectors documented one Severity Level IV violation with no associated finding. The
NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of
the Enforcement Policy.
From April 2017 to April 2018, the NRC issued three Severity Level IV traditional enforcement
violations associated with impacting the ability of the NRC to perform its regulatory oversight
function. This includes the one Severity Level IV violation documented in this report. However,
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,
because one of the violations occurred in 2006 and is not representative of present
performance.
If you contest the violation or significance of this NCV, you should provide a response within
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 Waterford Steam Electric Station, Unit 3.
J. Dinelli
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/
Geoffrey Miller, Branch Chief
Project Branch D
Division of Reactor Projects
Docket No. 50-382
License No. NPF-38
Enclosure:
Inspection Report 05000382/2018001
w/ Attachments:
1. Documents Reviewed
2. Occupational Radiation Safety Inspection
Request for Information
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number:
05000382
License Number:
Report Number:
Enterprise Identifier: I-2018-001-0002
Licensee:
Entergy Operations, Inc.
Facility:
Waterford Steam Electric Station, Unit 3
Location:
265 River Road
Killona, LA 70057
Inspection Dates:
January 1, 2018, to March 31, 2018
Inspectors:
- F. Ramírez, Senior Resident Inspector
- C. Speer, Resident Inspector
- J. Choate, Project Engineer
- J. Dixon, Senior Project Engineer
- N. Greene, PhD, Senior Health Physicist
- S. Money, Health Physicist
- J. ODonnell, CHP, Health Physicist
Approved By:
- G. Miller, Chief
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting an integrated inspection at Waterford Steam Electric Station, Unit 3,
in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the
NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer
to https://www.nrc.gov/reactors/operating/oversight.html for more information. An
NRC-identified violation and additional items are summarized in the tables below.
List of Findings and Violations
Failure to Obtain NRC Staff Authorization Prior to Changing a Procedure that Impacts
Implementation of Technical Specifications
Cornerstone
Significance
Cross-cutting
Aspect
Report
Section
Not Applicable
Closed
Not Applicable
The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.59, Changes,
Tests, and Experiments, Section (c)(1), for the licensees failure to submit and obtain
authorization prior to implementation procedures described in the Final Safety Analysis Report.
Additional Tracking Items
Type
Issue number
Title
Report
Section
Status
due to the Failure of Fast Bus
Transfer Relays to
Automatically Transfer
Station Loads to Off-site
Power on a Main Generator
Trip
Closed
PLANT STATUS
Waterford Steam Electric Station Unit 3 operated at or near 100 percent rated thermal power for
the entire inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
complete when the IP requirements most appropriate to the inspection activity were met
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors performed plant status activities described in
IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem
Identification and Resolution. The inspectors reviewed selected procedures and records,
observed activities, and interviewed personnel to assess licensee performance and compliance
with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather (1 Sample)
The inspectors evaluated readiness for impending adverse weather conditions prior to the
onset of and during extreme low temperatures for the area on January 16, 2018.
71111.04 - Equipment Alignment
Partial Walkdown (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) Emergency feedwater train A following maintenance on January 12, 2018
(2) Component cooling water train A with train B out of service for maintenance on
January 24, 2018
(3) Low pressure safety injection train A with train B out of service for maintenance on
March 13, 2018
71111.05 - Fire Protection
Quarterly Inspection (5 Samples)
The inspectors evaluated fire protection program implementation in the following selected
areas:
(1) Shutdown cooling heat exchanger rooms A and B, Fire Area RAB 33, on
January 4, 2018
(2) Switchgear room B, Fire Area RAB 8B, E, and F on February 12, 2018
(3) Control room, Fire Area RAB 1A, B, C, and D on February 12, 2018
(4) Component cooling water heat exchanger B, Fire Area RAB 17 on March 13, 2018
(5) Component cooling water pump room A, Fire Area RAB 19 on March 14, 2018
71111.07 - Heat Sink Performance
Heat Sink (1 Sample)
The inspectors evaluated the ultimate heat sink performance test on January 23, 2018.
71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance
Operator Requalification (1 Sample)
The inspectors observed and evaluated operator performance in the simulator during an
evaluated emergency plan exercise on February 21, 2018.
Operator Performance (1 Sample)
The inspectors observed and evaluated control room operator performance during main turbine
governor valve testing on January 19, 2018.
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness (3 Samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated
with the following equipment and/or safety significant functions:
(1) Component cooling water on January 25, 2018
(2) 125 Vdc distribution system on March 12, 2018
(3) Plant protection system on March 28, 2018
Quality Control (1 Sample)
The inspectors evaluated maintenance and quality control activities associated with the
following equipment performance issues:
(1) Fuel oil storage tank A1 vendor and licensee quality documents related to receipt of
segments from vendor and associated welding on March 7, 2018
71111.13 - Maintenance Risk Assessments and Emergent Work Control (3 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent
work activities:
(1) Risk assessment associated with maintenance on boric acid makeup tanks A and B on
January 3, 2018
(2) Risk assessment and risk management actions associated with maintenance on
emergency diesel generator A on January 31, 2018
(3) Control element assembly emergency work and unexpected limiting condition for
operation on February 6, 2018
71111.15 - Operability Determinations and Functionality Assessments (6 Samples)
The inspectors evaluated the following operability determinations and functionality
assessments:
(1) Core element assembly calculator 2 unexpected trend on January 2, 2018
(2) Atmospheric dump valve A leakage on February 8, 2018
(3) Component cooling water heat exchanger B failed performance test on February 9, 2018
(4) Reactor coolant pump 2A oil leak on March 8, 2018
(5) Core protection calculator Channel C failure on March 26, 2018
(6) Ultimate heat sink on March 28, 2018
71111.18 - Plant Modifications (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
(1) Dry cooling tower train A recirculation barrier installation, Phase 3, on March 16, 2018
71111.19 - Post Maintenance Testing (7 Samples)
The inspectors evaluated the following post maintenance tests:
(1) Reactor trip circuit breaker 6 on January 9, 2018
(2) High pressure safety injection train B on January 23, 2018
(3) Emergency diesel generator A on February 3, 2018
(4) Auxiliary component cooling water train B on February 21, 2018
(5) Component cooling water pump B to AB suction cross-connect valve solenoid valve
replacement on March 8, 2018
(6) Component cooling water pump B to AB discharge cross-connect valve solenoid valve
replacement on March 8, 2018
(7) Low pressure safety injection pump B on March 14, 2018
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Routine (3 Samples)
(1) Emergency diesel generator A monthly surveillance on January 8, 2018
(2) Safety Channel A nuclear instrumentation functional test on January 24, 2018
(3) Functional test of plant protective system Channel C on February 23, 2018
71114.06 - Drill Evaluation
Emergency Planning Drill (1 Sample)
The inspectors evaluated a site emergency plan drill on February 21, 2018.
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (1 Sample)
The inspectors evaluated radiological hazards assessments and controls.
Instructions to Workers (1 Sample)
The inspectors evaluated worker instructions.
Contamination and Radioactive Material Control (1 Sample)
The inspectors evaluated contamination and radioactive material controls.
Radiological Hazards Control and Work Coverage (1 Sample)
The inspectors evaluated radiological hazards control and work coverage.
High Radiation Area and Very High Radiation Area Controls (1 Sample)
The inspectors evaluated risk-significant high radiation area and very high radiation area
controls.
Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample)
The inspectors evaluated radiation worker performance and radiation protection technician
proficiency.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Engineering Controls (1 Sample)
The inspectors evaluated airborne controls and monitoring.
Use of Respiratory Protection Devices (1 Sample)
The inspectors evaluated respiratory protection.
Self-Contained Breathing Apparatus for Emergency Use (1 Sample)
The inspectors evaluated the licensees self-contained breathing apparatus program.
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification (5 Samples)
The inspectors verified licensee performance indicator submittals listed below:
(1)
IE01: Unplanned Scrams per 7000 Critical Hours Sample (January 1, 2017, through
December 31, 2017)
(2)
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (January 1, 2017,
through December 31, 2017)
(3)
IE04: Unplanned Scrams with Complications (USwC) Sample (January 1, 2017,
through December 31, 2017)
(4)
OR01: Occupational Exposure Control Effectiveness Sample (April 1, 2017, through
December 31, 2017)
(5)
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation
Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent
Occurrences Sample (April 1, 2017, through December 31, 2017)
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issue:
(1) Implementation of change to technical specification and technical requirements
compliance procedure
71153 - Follow-up of Events and Notices of Enforcement Discretion
Licensee Event Reports (1 Sample)
The inspectors evaluated the following licensee event reports which can be accessed at
https://lersearch.inl.gov/LERSearchCriteria.aspx:
(1) Licensee Event Report (LER) 05000382/2017-002-00, Automatic Reactor Scram due to
the Failure of Fast Bus Transfer Relays to Automatically Transfer Station Loads to
Off-site Power on a Main Generator Trip, on July 17, 2017
INSPECTION RESULTS
Failure to Obtain NRC Staff Authorization Prior to Changing a Procedure that Impacts
Implementation of Technical Specifications
Cornerstone
Significance
Cross-cutting
Aspect
Report
Section
Not Applicable
Closed
Not Applicable
The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.59, Changes,
Tests, and Experiments, Section (c)(1), for the licensees failure to submit and obtain
authorization prior to implementation procedures described in the Final Safety Analysis
Report.
Description: Waterford Technical Specification 3.7.4, states, in part, that two independent
trains of ultimate heat sink cooling towers shall be Operable in Modes 1, 2, 3, and 4. Each
train consists of a dry cooling tower and a wet cooling tower and its associated water basin.
Action c of Technical Specification 3.7.4 states that with a tornado watch in effect, all nine dry
cooling tower fans under the missile protected portion of the dry cooling tower shall be
Operable. If the number of Operable fans is less than required, restore the inoperable fan(s)
to Operable status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, or be in at least Hot Standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Hot
Shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The licensee established Procedure OP-100-014,
Technical Specification and Technical Requirements Compliance, Revision 336, to provide
guidance for determining Operability of equipment and ensuring compliance with the technical
specifications and technical requirements manual. Procedure OP-100-014, Attachment 6.6,
Specific System Guidelines, provides guidelines on actions when declaring a system
inoperable. One of the systems listed and discussed is the ultimate heat sink and its
associated Technical Specification 3.7.4.
The Process Applicability Determination process is a method for determining which plant
licensing basis documents and processes are affected by a proposed activity and must be
revised to reflect that activity. The licensee revised Procedure OP-100-014, Revision 336,
using a Process Applicability Determination Evaluation [PAD-OP-100-014, Revision 337] to
provide additional guidance on implementation of Technical Specification 3.7.4.
Procedure OP-100-014, Revision 337, was implemented in February 2017 with an added
note stating, in part, if the dry cooling tower fans are declared inoperable solely due to wet
cooling tower fans being out of service (cascading technical specification), then Technical Specification 3.7.4.c does not need to be applied upon a tornado watch/warning. The
licensee performed a technical analysis and concluded that the missile-protected dry cooling
tower fans were to be considered Operable for the tornado event because wet cooling tower
fan operation is not credited in the tornado event analysis.
The licensee used Procedure EN-LI-100, Process Applicability Determination, to evaluate
the change in licensing basis documents. When answering the question, does the proposed
activity affect, invalidate, or render incorrect, OR have the potential to affect, invalidate, or
render incorrect, information contained in any of the following Licensing Basis Documents?
the licensee answered no for impact on Operating License/Technical Specifications.
However, the inspectors determined that this addition to the site procedure could adversely
impact the bases for the acceptability to ultimate heat sink design and operations. As a
result, that question should have been answered yes and the licensee would have had to
prepare a licensing basis document change request. The inspectors concluded that if
Procedure OP-100-014, Revision 337, would have been implemented as written, it would
have constituted a change affecting an evaluation that demonstrates the function of the
The inspectors confirmed that between February 2017 and January 2018, there were no
tornado watches that coincided with ultimate heat sink system work windows. Therefore,
during the time this note was in the procedure, the licensee did not invoke the provision.
Corrective Action(s): The licensee removed the note from Procedure OP-100-014, and
corrected the interpretation of the technical specification. Procedure OP-100-014,
Revision 342, which removed the note, became effective January 2018. Therefore, if the wet
cooling tower fans are inoperable, and there is a simultaneous tornado watch/warning, the
licensee will implement Technical Specification 3.7.4, Action c.
Corrective Action Reference(s): CR-WF3-2018-02111
Performance Assessment:
Performance Deficiency: The licensees failure to submit a licensing basis document change
request when performing a change impacting technical specifications in accordance with
Procedure EN-LI-100, Process Applicability Determination, was a performance deficiency.
Specifically, Procedure EN-LI-100 states that if proposed activities affect, invalidate, or render
incorrect information contained in Licensing Basis Documents such as the Operating
License/Technical Specifications, then the proper regulatory reviews are performed. The
procedure instructs the licensee to prepare a licensing basis document change request in
accordance with the licensing basis document change process.
Screening: The inspectors determined the performance deficiency was of minor significance
because the licensee did not implement this procedure change and as a result, did not incur a
violation of technical specifications. However, because 10 CFR 50.59 violations could
potentially impede or impact the regulatory process, the inspectors processed this
performance deficiency using the traditional enforcement process and the examples in
Section 6.1 of the Enforcement Policy.
Enforcement:
Severity: The ROPs significance determination process does not specifically consider the
regulatory process impact in its assessment of licensee performance. Therefore, it is
necessary to address this violation which impedes the NRCs ability to regulate using
traditional enforcement to adequately deter noncompliance. 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 inspectors determined the violation to be a Severity Level IV
violation similar to violation Example 6.1.d.2 in the NRC Enforcement Policy.
Violation: As stated, in part, in 10 CFR 50.59, Changes, Tests, and Experiments,
Section (c)(1), a licensee may make changes in the facility as described in the final safety
analysis report (as updated), make changes in the procedure as described in the final safety
analysis report (as updated), and conduct tests or experiments not described in the final
safety analysis report (as updated) without obtaining a license amendment pursuant to
Sec. 50.90 only if: (i) a change to the Technical Specifications incorporated in the license is
not required. The licensee established Procedure EN-LI-100, Process Applicability
Determination, Revision 19, to comply with this requirement. Attachment 9.1 of
Procedure EN-LI-100 states, in part, to prepare a licensing basis document change request if
a proposed activity affects, invalidates, or renders incorrect, information contained in
Technical Specifications.
Contrary to the above requirements, from February 2017, until December 2017, the licensee
completed an activity that affected Technical Specifications and did not prepare a licensing
basis document change request. Specifically, the licensee implemented a change to
Technical Specification 3.7.4, Action c, through the implementation of
Procedure OP-100-014, Technical Specification and Technical Requirements Compliance,
Revision 337, by adding a note that instructed Operations personnel to not enter Technical Specification 3.7.4.c in the event of a tornado watch/warning if the dry cooling tower fans
were declared inoperable solely due to wet cooling tower fans being out of service. This
action was inconsistent with the current licensing basis and would have constituted a violation
of technical specifications.
Enforcement Action: Because this violation was not repetitive or willful, and was entered into
the licensees corrective action program as CR-WF3-2018-02111, this violation is being
treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy.
Licensee Event
Report
(Closed)
Automatic Reactor Scram due to the Failure of Fast Bus
Transfer Relays to Automatically Transfer Station Loads to
Off-site Power on a Main Generator Trip
05000382/2017-002-00
Description: The NRC conducted a special inspection to better understand the facts and
circumstances surrounding this event. The results and findings of that inspection are
documented in NRC Inspection Report 05000382/2017011 (Agencywide Documents Access
and Management System (ADAMS) Accession No. ML17354A690). The inspectors did not
identify any new deficiencies as a result of this review. This LER is closed.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On January 25, 2018, the inspectors presented the radiation safety inspection results to
M