ML22217A111
| ML22217A111 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/09/2022 |
| From: | John Dixon NRC/RGN-IV/DORS/PBD |
| To: | Ferrick J Entergy Operations |
| References | |
| IR 2022002 | |
| Download: ML22217A111 (51) | |
See also: IR 05000382/2022002
Text
August 09, 2022
Mr. John Ferrick, Site Vice President
Entergy Operations, Inc
17265 River Road
Killona, LA 70057
SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - INTEGRATED
INSPECTION REPORT 05000382/2022002
Dear Mr. Ferrick:
On June 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at
Waterford Steam Electric Station, Unit 3. On July 19, 2022, the NRC inspectors discussed the
results of this inspection with Mr. Matthew Lewis, General Manager of Plant Operations, and
other members of your staff. The results of this inspection are documented in the enclosed
report.
Eight findings of very low safety significance (Green) are documented in this report. Eight of
these findings involved violations of NRC requirements. We are treating these violations as
non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this
inspection report, you should provide a response within 30 days of the date of this inspection
report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional
Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector
at Waterford Steam Electric Station, Unit 3.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a
response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,
Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the
NRC Resident Inspector at Waterford Steam Electric Station, Unit 3.
J. Ferrick 2
This letter, its enclosure, and your response (if any) will be made available for public inspection
and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document
Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public
Inspections, Exemptions, Requests for Withholding.
Sincerely,
Signed by Dixon, John
on 08/09/22
John L. Dixon, Jr., Chief
Projects Branch D
Division of Operating Reactor Safety
Docket No. 05000382
License No. NPF-38
Enclosure:
As stated
cc w/ encl: Distribution via LISTSERV
Non-Sensitive Publicly Available
SUNSI Review
Sensitive Non-Publicly Available
OFFICE SRI:DRP/D RI:DRP/D BC:DORS/IPAT BC:DORS/EB1
NAME APatz/ADP AChilds/ACC AAgrawal/ARP VGaddy/VGG
DATE 08/05/2022 08/08/2022 08/08/2022 08/08/2022
OFFICE ABC:DORS/EB2 BC:DORS/RCB BC:DRS/OB ABC:DRSS/DIOR
NAME JDrake/JFD MHaire MSH HGepford/HJG Sanderson/SMG
DATE 08/05/2022 08/08/2022 08/08/2022 08/05/2022
OFFICE SPE:DORS/D BC:DORS/D
NAME ASanchez/AAS JDixon
DATE 08/08/2022 8/9/2022
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number: 05000382
License Number: NPF-38
Report Number: 05000382/2022002
Enterprise Identifier: I-2022-002-0007
Licensee: Entergy Operations, Inc
Facility: Waterford Steam Electric Station, Unit 3
Location: Killona, LA 70057
Inspection Dates: April 1, 2022 to June 30, 2022
Inspectors: D. Antonangeli, Health Physicist
B. Baca, Health Physicist
D. Childs, Resident Inspector
L. Flores, Technical Assistant
N. Greene, Senior Health Physicist
R. Kopriva, Senior Reactor Inspector
A. Patz, Senior Resident Inspector
A. Sanchez, Senior Project Engineer
E. Simpson, Health Physicist
C. Stott, Resident Inspector
J. Vera, Senior Resident Inspector
Approved By: John L. Dixon, Jr, Chief
Projects Branch D
Division of Operating Reactor Safety
Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting an integrated inspection at Waterford Steam Electric Station, Unit 3,
in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs
program for overseeing the safe operation of commercial nuclear power reactors. Refer to
https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Adequately Plan and Control Worker Exposures As Low As (is) Reasonably
Achievable (ALARA) During the Removal of Pressurizer Heaters Resulting in Worker
Uptakes.
Cornerstone Significance Cross-Cutting Report
Aspect Section
Occupational Green [P.5] - 71124.01
Radiation Safety NCV 05000382/2022002-02 Operating
Open/Closed Experience
The inspectors identified a finding of very low safety significance (Green) for the licensee
having unplanned and unintended occupational internal radiation exposure because of
deficiencies in the licensees work planning and work control program. Specifically, the
licensee failed to appropriately implement aspects of EN-RP-105, Radiological Work
Permits (RWP), to maintain doses ALARA. Four workers (two radiation protection technicians
and two contract workers) received an uptake of airborne radioactive material during the
removal of pressurizer heaters. The highest internal uptake was 13 mrem committed effective
dose equivalent (CEDE).
Failure to Follow Procedures with an Improper Entry into a High Radiation Area
Cornerstone Significance Cross-Cutting Report
Aspect Section
Occupational Green [H.11] - 71124.01
Radiation Safety NCV 05000382/2022002-01 Challenge the
Open/Closed Unknown
The inspectors reviewed a self-revealed Green non-cited violation of Technical Specification
6.8.1(a) for a worker's failure to follow procedures resulting in an improper entry to a high
radiation area. Specifically, on April 8, 2022, an operator worker received a dose rate alarm as
he entered into a high radiation area that he had not been made aware of the radiological
conditions and was not briefed for prior to entry.
Failure to Follow Procedures Regarding the Use of Lapel Air Sample Results
Cornerstone Significance Cross-Cutting Report
Aspect Section
Occupational Green [H.13] - 71124.03
Radiation Safety NCV 05000382/2022002-03 Consistent
Open/Closed Process
The inspectors identified a Green, non-cited violation of Technical Specification 6.8.1(a) for
the licensees failure to follow written radiation procedure, EN-RP-131, Air Sampling,
revision 17. Specifically, the licensee failed to follow section 5.1.12 for a lapel air sample
which indicated an intake could occur greater than four derived air concentration hours
(DAC-hrs) in an area that was not posted and controlled as an airborne radioactivity area.
2
This step required, in part, the licensee stop work; evacuate workers, collect grab samples,
and identify the source; inform workers in the area without respiratory protection that airborne
radioactivity was measured, and potential exposures would be evaluated; and if the conditions
causing the airborne radioactivity may still exist or are unknown, then immediately post and
control the area as an airborne radioactivity area.
Failure to Follow a Radiological Work Permit Requirement
Cornerstone Significance Cross-Cutting Report
Aspect Section
Occupational Green [H.5] - Work 71124.03
Radiation Safety NCV 05000382/2022002-04 Management
Open/Closed
The inspectors identified a Green, non-cited violation of Technical Specification 6.8.1(a) for
the licensees failure to follow radiation procedure, EN-RP-100, Radiation Worker
Expectations, revision 13, steps to follow the requirements set forth within a radiological work
permit (RWP). Specifically, workers failed to follow RWP 2022-0615, task 2, Removal of old
pressurizer heaters (includes cutting/grinding and all supporting activities), revision 2, which
required a continuous air monitor be located within the pressurizer cubicle during work
evolutions which have the potential for generating airborne activity.
Failure to Survey for an Airborne Radioactivity Area
Cornerstone Significance Cross-Cutting Report
Aspect Section
Occupational Green [H.14] - 71124.03
Radiation Safety NCV 05000382/2022002-05 Conservative
Open/Closed Bias
The inspectors identified a Green, non-cited violation of 10 Code of Federal Regulations
(CFR) 20.1501(a) for the licensees failure to reasonably evaluate surveys under the
circumstances to identify and post an airborne radioactivity area in accordance with
10 CFR 20.1902(d). Specifically, air sample survey WF3-AS-041722-0238, taken on April 17,
2022, was not evaluated under circumstances reasonable to determine the extent and
magnitude of airborne radioactivity levels which resulted in a failure to post and control an
airborne radioactivity area.
Inadequate Radiological Work Permit Procedure to Address Respirator Controls During Work
Activities.
Cornerstone Significance Cross-Cutting Report
Aspect Section
Occupational Green [H.14] - 71124.03
Radiation Safety NCV 05000382/2022002-06 Conservative
Open/Closed Bias
The inspectors identified a Green, non-cited violation of Technical Specification 6.8.1(a) for an
inadequate radiological work permit (RWP) procedure to address respirator controls during
work activities. Specifically, licensee procedure EN-RP-105, Radiological Work Permits,
revision 19, contained procedural steps outlining the process for removing respiratory controls
while an attachment to this procedure bypassed completion of an RWP revision and a total
effective dose equivalent (TEDE)/as low as (is) reasonably achievable (ALARA) evaluation
when changing respiratory protection controls.
3
Failure to Ensure Proper Phase Rotation for FLEX Equipment
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.13] - 71152A
Systems NCV 05000382/2022002-07 Consistent
Open/Closed Process
A self-revealed Green finding and associated non-cited violation (NCV) of 10 CFR 50.155(c),
Mitigation of beyond-design-basis events, was identified when the licensee failed to ensure
equipment relied upon for the mitigation strategies for beyond-design basis external events
had the capability to perform the required functions. Specifically, the licensee failed to ensure
that required Diverse and Flexible Coping Strategies (FLEX) electrical receptacles had the
same electrical phase rotation as the FLEX N and N+1 core cooling pump motors such that
the core cooling pumps would operate as expected.
Inadequate Design of Differential Pressure Sensor Ambient Sensing Line
Cornerstone Significance Cross-Cutting Report
Aspect Section
Barrier Integrity Green None (NPP) 71153
Open/Closed
The inspectors reviewed a self-revealed Green finding and associated non-cited violation of
10 CFR Part 50, Appendix B, Criterion III, Design Control, when the licensee failed to
appropriately verify the adequacy of the shield building ventilation design. Specifically, a failed
stroke time test for shield building ventilation valve 114B on October 18, 2021, showed that an
ambient pressure sensing line failed to provide proper input since August 29, 2021. This
discovery revealed that train B of the shield building ventilation system and train B of the
controlled area ventilation system were inoperable for approximately 50 days. This condition
is prohibited by technical specifications and resulted in the issuance of a licensee event report
because the time these systems were inoperable exceeded the technical specification allowed
outage time.
Additional Tracking Items
None.
4
PLANT STATUS
Unit 3 entered the inspection period in power coast down at approximately 95 percent reactor
power. On April 2, 2022, the unit was shut down for refueling outage 24. On June 18, 2022, the
reactor was made critical following completion of the refueling outage and returned to full power
on June 23, 2022. On June 24, 2022, the unit experienced an unplanned trip due to the
automatic closing of main steam isolation valve 2. The plant was restarted on June 27, 2022,
and returned to full power on June 29, 2022, where it remained for the remainder of the
inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
complete when the IP requirements most appropriate to the inspection activity were met
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors performed activities described in IMC 2515,
Appendix D, Plant Status, observed risk-significant activities, and completed onsite portions of
IPs. 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
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to
the onset of seasonal extreme rain and wind for the following systems: component
cooling water, auxiliary component cooling water, startup transformers, and
emergency diesel generators on June 2, 2022.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) emergency feedwater system following a valid actuation of the system on
June 27, 2022
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
(1) The inspectors evaluated system configurations during a complete walkdown of the
safety injection system on May 6, 2022.
5
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a
walkdown and performing a review to verify program compliance, equipment functionality,
material condition, and operational readiness of the following fire areas:
(1) fire area RAB 19-001, elevation +21.00' component cooling water pump room A on
April 20, 2022
(2) fire area RAB 18-001, elevation +21.00' component cooling water heat exchanger
room A on May 14, 2022
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
(1) component cooling water B heat exchanger on May 27, 2022.
71111.08P - Inservice Inspection Activities (PWR)
PWR Inservice Inspection Activities Sample (IP Section 03.01) (1 Sample)
(1) The inspectors verified that the reactor coolant system boundary, steam generator
tubes, reactor vessel internals, risk-significant piping system boundaries, and
containment boundary are appropriately monitored for degradation and that repairs
and replacements were appropriately fabricated, examined and accepted by
reviewing the following activities from April 7, 2022 to May 13, 2022:
03.01.a - Nondestructive Examination and Welding Activities.
Dye Penetrant Test Examination, Report No.: BOP-PT-22-012. Field Weld
FW-1 Seal Weld. Component ID: EFWMVAAA204A/B.
Ultrasonic Test Examination, Report No.: BOP-UT-22-001. Pipe to
Valve SI-512A. Component ID: SI-512A (ISI-V2507) FW-7. Safety Injection
System.
Ultrasonic Test Examination, Report No.: BOP-UT-22-002. Valve SI-512A to
Pipe. Component ID: SI-512A (ISI-C2507) FW-8. Safety Injection System.
Ultrasonic Test Examination, Report No.: W-ISI-UT-22-004. 4" Pip to Elbow
Weld. Component ID: 25-026, Reactor Coolant System.
Ultrasonic Test Examination, Report No.: W-ISI-UT-22-005. Elbow to 4: Pipe
Weld. Component ID: 25-027, Reactor Coolant System.
Ultrasonic Test Examination, Report No.: W-ISI-UT-22-001. Valve to 20" Pipe
Weld. Component ID: 45-008, Feedwater System.
Ultrasonic Test Examination, Report No.: W-ISI-UT-22-002. 20" Pipe to Valve
Weld. Component ID: 45-010, Feedwater System.
Ultrasonic Test Examination, Report No.: W-ISI-UT-22-003. Valve to 20" Pipe
Weld. Component ID: 46-006, Feedwater System.
6
Visual Test Examination - VT-1, Report No.: W-ISI-VT-22-028. Rigid Restraint
Attachment Weld. Component ID: FWRR-0283A, Emergency Feedwater
System.
Visual Test Examination - VT-3, Report No.: W-ISI-VT-22-029. Rigid Restraint.
Component ID: FWRR-0283, Emergency Feedwater System.
Radiograph Test Examination, Report No.: BOP-RT-22-001. Field Weld FW-7
Pipe to Valve SI-512A. Component ID: SI-512A. Safety Injection System.
Radiograph Test Examination, Report No.: BOP-RT-22-002. Field Weld FW-8
Valve SI-512A to Pipe. Component ID: SI-512A. Safety Injection System.
Phased Array Ultrasonic Test Examination of Previously Identified relevant
indications accepted for continued service. Report W-ISI-VE-22-001. 2" Drain
Nozzle to Safe-End Weld. Component ID: 07-009-WOL. Reactor Coolant
System.
Phased Array Ultrasonic Test Examination of Previously Identified relevant
indications accepted for continued service. Report W-ISI-VE-22-002. 2" Drain
Nozzle to Safe-End Weld. Component ID: 11-007-WOL. Reactor Coolant
System.
Welding associated with full replacement of the Safety Injection valve SI-512
A (ISI-V2507). Gas Tungsten Arc Welding. Work Order No. 527322-01. Field
Weld No. 7.
Welding associated with full replacement of the Safety Injection valve SI-512
A (ISI-V2507). Gas Tungsten Arc Welding. Work Order No. 527322-01. Field
Weld No. 8.
03.01.b - Pressurized-Water Reactor Vessel Upper Head Penetration Examination
Activities.
Visual Test Examination - Bare Metal Visual, Report No.: W-ISI-VT-22-042.
Reactor Vessel Closure Head RVCH CEDM Nozzles 1-87. Component
ID: 02-N-01X1 thru 02-N-87X1. Reactor Pressure Vessel.
Visual Test Examination - Bare Metal Visual, Report No.: W-ISI-VT-22-043.
Reactor Vessel Closure Head RVCH Vent Line. Component ID: 02-N2-01X1.
Visual Test Examination - Bare Metal Visual, Report No.: W-ISI-VT-22-044.
Reactor Vessel Closure Head RVCH CEDM Nozzles92-101. Component
ID: 02-N-92X1 thru 02-N-101X1. Reactor Pressure Vessel.
03.01.c - Pressurized-Water Reactor Boric Acid Corrosion Control Activities.
Boric Acid Evaluation No. 19-WF3-0004, Condition Report CR-WF3-2019-
00140
Boric Acid Evaluation No. 19-WF3-0012, Condition Report CR-WF3-2019-
01063
Boric Acid Evaluation No. 19-WF3-0019, Condition Report CR-WF3-2019-
03032
Boric Acid Evaluation No. 19-WF3-0020, Condition Report CR-WF3-2019-
03053
Boric Acid Evaluation No. 19-WF3-0021, Condition Report CR-WF3-2019-
03302
Boric Acid Evaluation No. 19-WF3-0022, Condition Report CR-WF3-2019-
03311
7
Boric Acid Evaluation No. 19-WF3-0023, Condition Report CR-WF3-2019-
04894
Boric Acid Evaluation No. 19-WF3-0025, Condition Report CR-WF3-2019-
06358
Boric Acid Evaluation No. 19-WF3-0026, Condition Report CR-WF3-2019-
06379
Boric Acid Evaluation No. 19-WF3-0028, Condition Report CR-WF3-2019-
06373
Boric Acid Evaluation No. 20-WF3-0001, Condition Report CR-WF3-2020-
01131
Boric Acid Evaluation No. 20-WF3-0016, Condition Report CR-WF3-2020-
04595
Boric Acid Evaluation No. 21-WF3-0001, Condition Report CR-WF3-2021-
00085
Boric Acid Evaluation No. 21-WF3-0020, Condition Report CR-WF3-2021-
05655
Boric Acid Evaluation No. 21-WF3-0022, Condition Report CR-WF3-2021-
05516
Boric Acid Evaluation No. 21-WF3-0026, Condition Report CR-WF3-2021-
05559
03.01.d - Pressurized-Water Reactor Steam Generator Tube Examination Activities.
Per the licensee's current requirement, they were not required to perform any
Steam Generator tube inspections this outage.
The licensee did install a modification to the Steam Generators feed rings to
reduce harmonic vortexing that they have experienced since the installation of
the replacement Steam Generators in 2013.
Problem Identification and Resolution. Review of Inservice Inspection items.
(Inspection Procedure 71152 - Problem Identification and Resolution)
The inspector evaluated a sample of 29 condition reports associated with
inservice inspection activities. No findings or violations of more than minor
significance were identified.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
(1 Sample)
(1) The inspectors observed and evaluated licensed operator performance in the control
room during plant startup following a refueling outage on June 18-19, 2022.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1) The inspectors observed and evaluated licensee simulator-based just-in-time training
for a reactor startup followed by training involving a rapid downpower with steam line
break inside containment on June 27, 2022.
8
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated the accuracy and completeness of risk assessments for the
following planned and emergent work activities to ensure configuration changes and
appropriate work controls were addressed:
(1) elevated Green risk while restarting Unit 3 and bringing reactor to 100 percent power
following unplanned main steam isolation valve closure from June 27 to 29, 2022
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1) shutdown cooling train operability following loss of auxiliary component cooling water
pump B on May 9, 2022
(2) emergency feedwater pump AB operability following surveillance with less than
allowed differential pressure on June 11, 2022
(3) auxiliary component cooling water pump B operability following identification of raised
bearing temperatures on June 18, 2022
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
(2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
(1) auxiliary component cooling water pump B motor was replaced with the component
cooling water pump AB motor on June 5, 2022
(2) reactor coolant system 1B cold leg resistance temperature detector thermowell was
plugged and existing core operating limit supervisory system detector used for
safety-related inputs on June 19, 2022
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system
operability and/or functionality:
(1) component cooling water pump B testing after relay maintenance performed on
May 19, 2022
(2) reactor coolant system integrity checks following leaks from core element drive vent
valves on May 28, 2022
(3) auxiliary component cooling water pump B testing following replacement with
component cooling water pump AB on June 5, 2022
9
(4) engineered safety features actuation system testing for steam generator isolation
after relay replacement on June 27, 2022
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
(1) The inspectors evaluated refueling outage 24 activities from April 2 to June 20, 2022.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability
and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (3 Samples)
(1) emergency diesel generator B surveillance test on May 12, 2022
(2) control elements drop testing on June 18, 2022
(3) main turbine electronic and physical trip testing on June 19, 2022
Inservice Testing (IP Section 03.01) (1 Sample)
(1) main steam isolation valves A and B inservice test on April 2, 2022
Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
(1) leak rate test containment isolation valve, LRT-109, at penetration 63 and blind flange
on May 14, 2022
FLEX Testing (IP Section 03.02) (1 Sample)
(1) FLEX N+1 diesel generator 3-year preventative maintenance and 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> run loaded
at 360 KW on May 11, 2022
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
(1) The inspectors evaluated how the licensee identifies the magnitude and extent of
radiation levels and the concentrations and quantities of radioactive materials and
how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
(1) The inspectors evaluated how the licensee instructs workers on plant-related
radiological hazards and the radiation protection requirements intended to protect
workers from those hazards.
10
Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and
controlling contamination and radioactive material:
(1) licensee surveys of potentially contaminated material leaving the radiological
controlled area.
(2) workers exiting containment and the radiologically controlled area during the refueling
outage.
(3) licensee surveys of potentially contaminated material leaving containment.
Radiological Hazards Control and Work Coverage (IP Section 03.04) (5 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following
radiological work:
(1) radiation work permit (RWP) 2022-0606, Minor Maintenance Activities
(2) RWP 2022-0610, Erect/Dismantle Scaffolding in the Reactor Containment Building
(3) RWP 2022-0635, Radiography including Radiation Protection Boundary Guards
(4) RWP 2022-0805, Tours and Inspections Outside the Reactor Containment Building
(5) RWP 2022-0708, Remove and Replace InCore Instruments (ICIs)
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (5 Samples)
The inspectors evaluated licensee controls of the following high radiation areas and very
(1) spent resin tank room
(2) lock on cable for Tri-Nuke filter in the spent fuel building, +46' fuel handling building
(3) pre-concentrator filter cubicles
(4) fuel pool filter cubicle
(5) keys controlled at the access to the radiologically controlled areas by radiation
protection for high radiation areas and locked high radiation areas
Radiation Worker Performance and Radiation Protection Technician Proficiency
(IP Section 03.06) (1 Sample)
(1) The inspectors evaluated radiation worker and radiation protection technician
performance as it pertains to radiation protection requirements.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (2 Samples)
The inspectors evaluated the configuration of the following permanently installed ventilation
systems:
(1) control room ventilation system emergency filtration unit train A
(2) controlled ventilation areas filter unit train B
11
Temporary Ventilation Systems (IP Section 03.02) (1 Sample)
The inspectors evaluated the configuration of the following temporary ventilation systems:
(1) high efficiency particulate air filter setup for the cutting, grinding, and welding
associated with RWP 2022-0627
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
(1) The inspectors evaluated the licensees use of respiratory protection devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
(1) The inspectors evaluated the licensees use and maintenance of self-contained
breathing apparatuses.
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Walkdowns and Observations (IP Section 03.01) (4 Samples)
The inspectors evaluated the following radioactive effluent systems during walkdowns:
(1) reactor main condenser evacuation system
(2) turbine gland sealing system
(3) discharge structure to the Mississippi River
(4) reactor gaseous waste management system
Sampling and Analysis (IP Section 03.02) (3 Samples)
Inspectors evaluated the following effluent samples, sampling processes and compensatory
samples:
(1) weekly liquid effluent sampling of the circulating water discharge outfall
(2) weekly sampling of dry cooling tower sump No. 2 outfall
(3) weekly turbine building/yard oil separator outfall
Dose Calculations (IP Section 03.03) (2 Samples)
The inspectors evaluated the following dose calculations:
(1) cumulative dose and dose rate summary for gaseous effluent release associated with
gaseous effluent release permit No. W3GB2019-005
(2) cumulative doses details for liquid effluent release associated with liquid effluent
release permit No. W3LB2019-009
Abnormal Discharges (IP Section 03.04) (1 Sample)
The inspectors evaluated the following abnormal discharges:
(1) There were no abnormal discharges identified during the inspection period.
12
71124.07 - Radiological Environmental Monitoring Program
Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)
(1) The inspectors evaluated environmental monitoring equipment and observed
collection of environmental samples.
Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)
(1) The inspectors evaluated the implementation of the licensees radiological
environmental monitoring program.
GPI Implementation (IP Section 03.03) (1 Sample)
(1) The inspectors evaluated the licensees implementation of the Groundwater
Protection Initiative program to identify incomplete or discontinued program elements.
There were no incomplete or discontinued program elements identified.
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (1 Sample)
(1) Unit 3 (April 1, 2021, through March 30, 2022)
MS06: Emergency AC Power Systems (IP Section 02.05) (1 Sample)
(1) Unit 3 (April 1, 2021, through March 30, 2022)
MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)
(1) Unit 3 (April 1, 2021, through March 30, 2022)
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
(1) Unit 3 (January 1, 2021, through March 31, 2022)
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual
Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample
(IP Section 02.16) (1 Sample)
(1) Unit 3 (January 1, 2021, through March 31, 2022)
13
71152A - Annual Follow-up Problem Identification and Resolution
Annual Follow-up of Selected Issues (Section 03.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issues:
(1) phase rotation reversal of AB FLEX core cooling pump power receptacle on
May 5, 2022
71153 - Follow Up of Events and Notices of Enforcement Discretion
Personnel Performance (IP Section 03.03) (1 Sample)
(1) The inspectors evaluated the licensee response to an unplanned closure of main
steam isolation valve 2 and main feed isolation valve 2 and licensees performance
on June 24, 2022.
INSPECTION RESULTS
Failure to Adequately Plan and Control Worker Exposures As Low As (is) Reasonably
Achievable (ALARA) During the Removal of Pressurizer Heaters Resulting in Worker
Uptakes.
Cornerstone Significance Cross-Cutting Report
Aspect Section
Occupational Green [P.5] - 71124.01
Radiation Safety NCV 05000382/2022002-02 Operating
Open/Closed Experience
The inspectors identified a finding of very low safety significance (Green) for the licensee
having unplanned and unintended occupational internal radiation exposure because of
deficiencies in the licensees work planning and work control program. Specifically, the
licensee failed to appropriately implement aspects of EN-RP-105, Radiological Work
Permits (RWP), to maintain doses ALARA. Four workers (two radiation protection
technicians and two contract workers) received an uptake of airborne radioactive material
during the removal of pressurizer heaters. The highest internal uptake was 13 mrem
committed effective dose equivalent (CEDE).
Description: On April 18, 2022, two radiation protection technicians and two contract workers
(laborers) received uptakes from airborne radioactive materials during the replacement of
pressurizer heaters. The uptakes occurred as the pressurizer heaters were removed and
transported from the pressurizer shroud, through the shroud openings (several windows and
a door), and out through the pressurizer cubicle to a shielded storage container. During a
previous shift of this work evolution, a survey of the pressurizer shroud and two removed
heaters confirmed the Alpha Level 2, high contamination area conditions of the work area
(WF3-2204-00608). Two of the four laborers, those inside the pressurizer shroud and
removing the pressurizer heaters from the pressurizer, were wearing powered air purifying
respirators. The other workers, those outside the shroud but inside the pressurizer cubicle,
were not in powered air purifying respirators. The two laborers, outside pressurizer shroud,
did not enter the shroud. A radiation protection technician, providing job coverage, partially
entered the shroud as they surveyed the old pressurizer heaters being removed and were
placed into transport sleeves. Another radiation protection technician entered the high
14
contamination area of the pressurizer cubicle to remove radioactive trash at the end of the
job. These workers were identified with personnel contamination when exiting the
radiologically controlled area. The workers were sent for a whole body count to determine if
the workers received uptakes of radioactive material. The four workers working inside the
cubicle, but outside the shroud, received unintended uptakes of unanticipated airborne
radioactive material.
The licensees procedures required the creation of plans to minimize the exposure to workers
and to use radiological data and lessons learned from previous work.
Procedure EN-RP-105, Radiological Work Permits (RWP), revision 19, step 5.3.7 of the
RWP Planning Process states, in part, the licensee is to perform more rigorous planning for
work where contamination levels and the type of work to be performed results in a higher
potential for workers to be exposed to airborne alpha radioactivity during the work by:
- Using relevant job history files
- Understanding the physical characteristics and limitations of the work area
- Planning for minimizing or eliminating spread of alpha contamination
- Planning for minimizing or eliminating generation of airborne radioactivity
The inspectors compared the ALARA plans and results for the 2015 and 2022 pressurizer
heater replacement evolution and their associated radiological surveys. The inspectors were
unable to identify in either ALARA plan a specific plan or controls for the workers outside of
the shroud to minimize their exposures from the spread of alpha contamination when items
were removed from the shroud and any unanticipated alpha airborne radioactivity area.
The prior work history in the 2015 ALARA post-job review identified the contamination inside
of the shroud as an Alpha Level 2, high contamination area and an alpha airborne radiation
area. The plan provided no additional protective measures to the workers not working directly
inside the shroud, even though the removed pressurizer heaters were passed through the
openings of the shroud for transport out of the cubicle. The air sampler for the pressurizer
heater removal evolution was located near the work area inside the shroud. While a high
efficiency particulate air (HEPA) unit provided an engineering control through one shroud
opening to reduce the spread of airborne contamination, there were other large openings in
the shroud to the pressurizer cubicle and other areas above and below the pressurizer
shroud. These openings were present through which airborne radioactivity could spread. The
RWP was planned with misting, wetting, decontamination, and wrapping as critical steps to
reduce contamination levels and minimize the airborne hazard. In addition, the ALARA plan
and RWP considered the dose rates from the old pressurizer heaters to have the largest
impact on worker exposures. Dose rates on contact with the pressurizer heaters ranged from
80 millirem per hour (mR/hr) to 2,600 mR/hr and 30 mR/hr to 700 mR/hr at a foot. Therefore,
RWP 2015-0615 specified the old pressurizer heaters were to be removed from the
pressurizer cubicle as soon as practical while the additional measures to reduce exposure to
contamination (wetting, wrapping, etc.), seen as increasing exposure time to the higher dose
rates of the pressurizer heaters, were not used though planned.
The removed heaters were transported from under the shroud in capped polyvinyl chloride
sleeves to reduce the spread of alpha contamination and function as a carrying tool to move
the heaters to their storage location. The potential for contamination spread from the
transport sleeves was considered low. On November 13, 2015, a worker was documented
with facial contamination from transporting an old pressurizer heater in a transport sleeve and
15
the event was determined to not be attributed to poor radiation worker behavior (CR-WF3-
2015-08222). In response to this facial contamination, face shields were instituted for the
workers outside the shroud. No additional protective measures were considered for workers
not directly interfacing with the reactor coolant system boundary.
The 2022 ALARA plan was similar to the 2015 ALARA plan and evaluated the exposures for
the workers inside the shroud to the current and postulated radiological conditions as they
interfaced directly with reactor coolant system components. As in the 2015 ALARA plan, the
workers outside the shroud would not be interfacing with the reactor coolant system boundary
and their risk to additional hazards, such as exposures to alpha contamination and alpha
airborne radioactivity, was considered minimal. These workers had no specified protective
measures to minimize their exposure to alpha contamination or alpha airborne radioactivity
areas other than protective clothing for high contamination areas in the ALARA plan or RWP.
Similarly, in the 2015 ALARA plan and RWP, it directed the use of a HEPA hose to contain
radioactive material as the pressurizer heaters were removed from the pressurizer to
minimize contamination and powered air purifying respirators for the workers inside the
shroud. The air sampler for the pressurizer heater removal evolution was located near the
work area inside the shroud and the continuous air monitor placed outside the pressurizer
cubicle door.
For the current heater removal evolution, a survey of the first two removed heaters and
shroud areas supported an Alpha Level 2, high contamination area posting (WF3-2204-
00608) and the prior shift of pressurizer heater removals, air sample WF3-AS-041722-0238
indicated an airborne radioactivity area within the shroud at 0.518 derived air concentration
(DAC). An airborne radioactivity area is designated at 0.3 DAC. During the heater removal
which resulted in the four worker uptakes, air sample WF3-AS-041822-0303 indicated an
airborne radioactivity area inside the shroud of 5.4 DAC (2.62 DAC-beta/gamma and 2.78
DAC-alpha).
In addition, the dose rates of the removed heaters were known to affect the continuous air
monitor (an AMS-4) and challenge its ability to provide accurate air sample results. The
current dose rates for the pressurizer heaters in 2022 ranged from 120 mR/hr on contact to
2,400 mR/hr on contact. This situation led to the continuous air monitor being placed outside
the pressurizer cubicle door and created the inability to adequately assess or alert workers to
the changing airborne conditions in the pressurizer cubicle so they could minimize their dose.
The operating experience and lessons learned from the 2015 facial contamination event and
the resulting protective measures were not carried forward to the 2022 pressurizer heater
replacement in RWP 2022-0615. Further, no assessment was made for the potential
migration of airborne radioactivity from inside the shroud through the shroud openings into
the pressurizer cubicle. In the 2015 or 2022 ALARA plans, the plans and control measures
did not adequately inform or reduce the pressurizer cubicle workers exposure to the spread
of alpha contamination or airborne radioactivity. The licensee failed to learn from their
previous experience and include this in the 2022 pressurizer heater replacement.
Corrective Actions: The licensee entered the issue into their corrective action program to
evaluate the ALARA planning and control measures for the pressurizer replacement activities
for all personnel involved.
Corrective Action References: CR-WF3-2022-02805 and CR-WF3-2022-04924
16
Performance Assessment:
Performance Deficiency: The failure to adequately plan to control worker exposures ALARA
is a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Program and Process attribute of the Occupational
Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the
adequate protection of the worker health and safety from exposure to radiation from
radioactive material during routine civilian nuclear reactor operation. Specifically, the failure to
plan and control worker exposures ALARA during the pressurizer heater removal evolution
resulted in unplanned internal dose with the highest CEDE of 13 mrem. In addition,
Inspection Manual Chapter 0612, appendix E, example 6.h states a performance deficiency is
more than minor if the performance deficiency resulted in inadequately controlled radiological
conditions such that the worker received or was likely to receive greater than 10 mrem CEDE.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix C, Occupational Radiation Safety SDP. The inspectors determined the finding to
be of very low safety significance (Green) because it was: (1) not associated with as low as
reasonably achievable (ALARA) planning or work controls, (2) there was no overexposure,
(3) there was no substantial potential for an overexposure, and (4) the ability to assess dose
was not compromised.
Cross-Cutting Aspect: P.5 - Operating Experience: The organization systematically and
effectively collects, evaluates, and implements relevant internal and external operating
experience in a timely manner. Operating experience is used to support daily work functions
with emphasis on the possibility that it could happen here, or it could happen again.
Specifically, the licensee failed to learn from their own history when planning this work and
include the lessons learned from 2015 in the 2022 pressurizer heater replacement evolution.
Enforcement:
Violation: Technical Specification 6.8.1(a) requires, in part, that written procedures shall be
established, implemented, and maintained covering applicable procedures recommended in
NRC Regulatory Guide 1.33, revision 2, appendix A, dated February 1978. Section 7.e of
Regulatory Guide 1.33, appendix A, requires radiation protection procedures for the
implementation of an ALARA program. The licensee established procedure EN-RP-105,
Radiological Work Permits, revision 19, to implement the ALARA program.
Procedure EN-RP-105, step 5.3.7. states, in part, the licensee is to perform more rigorous
planning for work where contamination levels and the type of work to be performed results in
a higher potential for workers to be exposed to airborne alpha radioactivity.
Contrary to the above, on April 18, 2022, the licensee failed to implement procedure
EN-RP-105 to perform more rigorous planning for work where contamination levels and the
type of work to be performed results in a higher potential for workers to be exposed to
airborne alpha radioactivity. Specifically, the ALARA planning and controls for the workers in
the pressurizer cubicle were inadequate, which resulted in the uptakes to two laborers and
two radiation protection technicians during the 2022 pressurizer heater replacement
evolution.
17
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Failure to Follow Procedures with an Improper Entry into a High Radiation Area
Cornerstone Significance Cross-Cutting Report
Aspect Section
Occupational Green [H.11] - 71124.01
Radiation Safety NCV 05000382/2022002-01 Challenge the
Open/Closed Unknown
The inspectors reviewed a self-revealed Green non-cited violation of Technical Specification
6.8.1.a for a worker's failure to follow procedures resulting in an improper entry to a high
radiation area. Specifically, on April 8, 2022, an operator worker received a dose rate alarm
as he entered into a high radiation area that he had not been made aware of the radiological
conditions and was not briefed for prior to entry.
Description: On April 8, 2022, an operator worker entered a high radiation area (HRA) on the
4-foot elevation of the reactor containment building while logged onto radiation work
permit (RWP) 2022-0702, "Reactor Disassembly Activities," task 5. The individual entered the
reactor containment building tasked to secure the shutdown cooling vacuum priming when
required. Instead, as the operator entered the area, he was called by another worker to
observe the local reactor coolant system (RCS) level. Observing the RCS level required the
worker to climb a ladder to the reactor containment building sump platform. This area was
posted and controlled as an HRA, and the posting stated a requirement for a briefing by
radiation protection (RP) prior to entry. The change in work scope was not discussed or
authorized by RP prior to entry on the sump platform; thus, the worker was not briefed on the
radiological dose rates for entry. Upon ducking beneath the HRA barrier and posting and
traversing the ladder to the top of the sump platform, the operator received a dose rate alarm
on the alarming self-reading dosimeter (SRD) of 355 millirem per hour. This alarm was based
on a dose rate setpoint of 302 millirem per hour on his SRD. The dose rates the worker was
briefed for by RP for his assigned job were less than HRA conditions, based on
Survey WF3-2204-00087, dated April 3, 2022.
Procedure EN-RP-100, "Radiation Worker Expectations," revision 13, section 5.3, requires, in
part, that individuals with access to radiologically controlled areas (RCAs): [3] have no entry
to areas above seven feet without prior permission from RP; [6] observe and obey
radiological postings; [7] shall read, understand, and obey the RWP; and [9] know the
radiological conditions in their planned work area AND travel paths. Section 5.5[15] of
EN-RP-100 states, "If you receive an SRD dose rate alarm, THEN (a) back out of the affected
area, (b) notify others in the work area, and (c) immediately contact RP for direction."
RWP 2022-0702 instructed the worker to stop work if a dose rate alarm is received that is not
anticipated/discussed in the job brief. It then instructs the worker to place the job in a safe
condition, inform co-workers, exit the area, and notify RP. Discussions with RP while onsite,
informed the NRC that RP instructed the worker to immediately leave the RCA once they
were alerted to his dose rate alarm. However, the worker did not leave the RCA until
approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> later based on the SRD histogram reviewed.
Additionally, attachment 8 to EN-RP-101, "Access Controls for Radiologically Controlled
Areas," revision 16, requires, in part, workers entering a HRA to (1) be logged onto an RWP
that allows access to the area, (2) be briefed and knowledgeable of radiological conditions in
the work area and travel path, and (3) only enter areas they have been briefed on.
18
Therefore, the NRC determined that the worker failed to comply with licensee procedures by
failing to obey the HRA radiological posting, traversing a ladder and path to an area with
radiological conditions he was not briefed for, not following the RWP he logged onto, and
failing to leave the area and the RCA immediately as instructed by RP.
Corrective Actions: The licensee assessed this issue and implemented multiple immediate
corrective actions, which included restricting the worker's access to the RCA, coaching, and
requiring a reverse brief from radiation workers to include scope of work, radiological
conditions, and travel paths to the work location.
Corrective Action References: CR-WF3-2022-02217
Performance Assessment:
Performance Deficiency: The failure to follow a licensee's procedural requirements for entry
into an HRA was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Program & Process attribute of the Occupational
Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the
adequate protection of the worker health and safety from exposure to radiation from
radioactive material during routine civilian nuclear reactor operation. Specifically, the failure to
follow requirements involving radiological controls had the potential to increase the worker's
dose. The failure to follow procedural requirements by making an improper entry into an HRA
for which the worker was not briefed resulted in an increase to worker exposure of radiation
dose rates greater than the general area dose rates for which the worker was briefed.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix C, Occupational Radiation Safety SDP. The inspectors determined the finding to
be of very low safety significance (Green) because it was: (1) not associated with as low as
reasonably achievable (ALARA) planning or work controls, (2) there was no overexposure,
(3) there was no substantial potential for an overexposure, and (4) the ability to assess dose
was not compromised.
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with
uncertain conditions. Risks are evaluated and managed before proceeding. Specifically, the
worker failed to stop, contact RP, and assess the radiological conditions for the change in
work scope, as required, prior to entry on the sump platform. The worker was not briefed for
the dose rates in this area and was therefore unaware of the radiological hazard.
Enforcement:
Violation: Technical Specification 6.8.1(a) requires, in part, the written procedures be
established, implemented, and maintained covering the applicable RP procedures
recommended in appendix A to Regulatory Guide 1.33, section 7.e(1), for access control to
radiation areas including a radiation work permit system. The licensee established procedure
EN-RP-101, "Access Controls for Radiologically Controlled Areas," in part, to control access
to radiation areas which includes requirements for following a radiation work permit system.
Attachment 8 to EN-RP-101, revision 16, requires, in part, workers entering a HRA to (1) be
logged onto an RWP that allows access to the area, (2) be briefed and knowledgeable of
radiological conditions in the work area and travel path, and (3) only enter areas they have
19
been briefed on.
Contrary to the above, on April 8, 2022, a worker failed to implement and follow procedure
EN-RP-101 for entry into a HRA. Specifically, a worker failed to follow attachment 8, which
required the worker to follow the RWP that allows access to the work area, be briefed and
knowledgeable of radiological conditions in the work area and travel path, and only enter
areas they have been briefed for. As a result, the worker received a dose rate alarm on the
assigned SRD and failed to exit the RCA immediately as instructed by RP.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Failure to Follow Procedures Regarding the Use of Lapel Air Sample Results
Cornerstone Significance Cross-Cutting Report
Aspect Section
Occupational Green [H.13] - 71124.03
Radiation Safety NCV 05000382/2022002-03 Consistent
Open/Closed Process
The inspectors identified a Green, non-cited violation of Technical Specification 6.8.1(a) for
the licensees failure to follow written radiation procedure, EN-RP-131, Air Sampling,
revision 17. Specifically, the licensee failed to follow section 5.1.12 for a lapel air sample
which indicated an intake could occur greater than four derived air concentration hours
(DAC-hrs) in an area that was not posted and controlled as an airborne radioactivity area.
This step required, in part, the licensee stop work; evacuate workers, collect grab samples,
and identify the source; inform workers in the area without respiratory protection that airborne
radioactivity was measured, and potential exposures would be evaluated; and if the
conditions causing the airborne radioactivity may still exist or are unknown, then immediately
post and control the area as an airborne radioactivity area.
Description: On April 17, 2022, during refueling outage 24, workers were cutting welds in
preparation for removing the pressurizer heaters from the bottom of the pressurizer. The work
was conducted in the pressurizer shroud, inside the pressurizer cubicle, on the 21-foot
elevation of containment. The workers were partially cutting the welds that connected the
pressurizer heaters to the pressurizer heater sleeves. This allowed the heaters to be easily
removed during the next portion of the work activity. As part of the radiological work permit
requirements, the workers wore lapel air samplers to monitor potential internal exposures in
the work area.
The NRC inspectors reviewed lapel air sample WF3-AS-041722-0246 taken on
April 17, 2022. This lapel air sample was from a workers breathing zone when they worked in
the pressurizer cubicle. The lapel air sample was collected at 2:40 pm, analyzed, and initially
assigned a dose of 13.94 mrem or 5.58 DAC-hrs. The lapel air sample was counted on an
iSolo alpha/beta counting system at 9:06 pm which was a 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 26 minutes delay from
the sample collection time. The sample was counted again after 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> post collection
resulting in 12.78 mrem or 5.11 DAC-hrs. The sample was counted on an instrument (iSolo)
that compensated for and corrected the results for radon daughters, i.e., performs radon
discrimination.
According to the licensees procedure, EN-RP-131, Air Sampling, section 5.1.12, it stated, in
part, if a lapel air sample results indicated an intake could occur at greater than 4 DAC-hrs, in
20
an area that is not posted and controlled as an airborne radioactivity area, and radon
discriminating analysis was complete then:
Stop work,
Evacuate workers from the affected area, collect grab samples to determine if
airborne concentrations are sustained, and to identify the source if unknown,
Inform workers in the area without respiratory protection that airborne radioactivity
was measured, and potential exposures will be evaluated, and
If the conditions causing the airborne radioactivity may still exist or are unknown, then
immediately post and control the area as an airborne radioactivity area.
Procedure EN-RP-131, attachment 4, was used to document the results of lapel air samples.
For lapel air sample WF3-AS-041722-0246, the box was checked in attachment 4 stating that
the net activity was less than an activity corresponding to 10 mrem committed effective dose
equivalent (CEDE), or 4 DAC-hrs, and no further action was required. However, the sample
results indicated 13.94 mrem exposure at the initial count time with 6.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> delay post
collection and 12.78 mrem after 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> post collection, which are both greater than
10 mrem CEDE.
In addition, procedure EN-RP-131, step 5.2.8 provided instructions on how to analyze a lapel
air sample. The instructions focused strictly on the internal dose assessment to a worker
based on the sample results. This step did not reference back or make note of step 5.1.12 to
use the lapel air sample results to post and control an airborne radioactivity area. The
separation of this information in the analysis and decision-making sections led workers to not
recognize occurrences when lapel air sample results indicated an airborne radioactivity area
and that additional actions were required.
The license failed to follow procedure steps to stop work; evacuate the workers, obtain grab
samples, and identify the source; inform the workers in the area without respiratory protection
that airborne radioactivity was measured, and potential exposures will be evaluated; and post
and control the area as an airborne radioactivity area.
Corrective Actions: The licensee has entered the performance deficiency into their corrective
action program to determine appropriate actions.
Corrective Action References: CR-WF3-2022-04922
Performance Assessment:
Performance Deficiency: The failure to follow procedures regarding the use of lapel air
sample results was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Program & Process attribute of the Occupational
Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the
adequate protection of the worker health and safety from exposure to radiation from
radioactive material during routine civilian nuclear reactor operation. Specifically, the licensee
did not follow their procedure to stop work; evacuate the workers, obtain grab samples, and
identify the source; inform the workers in the area without respiratory protection that airborne
radioactivity was measured, and potential exposures will be evaluated; and post and control
the area as an airborne radioactivity area. Additionally, the finding was similar to Inspection
21
Manual Chapter 0612, Power Reactor Inspection Reports - Examples of Minor Issues,
appendix E, example 6(h). This example states a performance deficiency was more than
minor if the performance deficiency results in a failure of radiological controls that could result
or resulted in an exposure equal to or greater than 10 mrem CEDE. In this case, the failure to
follow procedural steps after receiving lapel air sample results greater than 4 DAC-hrs
(10 mrem CEDE), resulted in workers being in an unknown airborne radioactivity area with
exposures greater than 10 mrem CEDE, specifically 13.94 mrem and 12.78 mrem CEDE.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix C, Occupational Radiation Safety SDP. The inspectors determined the finding had
very low safety significance (Green) because: (1) it was not associated with ALARA planning
and work controls, (2) it was not an overexposure, (3) there was no substantial potential for
overexposure, and (4) the ability to assess dose was not compromised.
Cross-Cutting Aspect: H.13 - Consistent Process: Individuals use a consistent, systematic
approach to make decisions. Risk insights are incorporated as appropriate. Specifically, the
procedure had disjointed analysis and decision-making sections which did not allow a worker
to consistently process lapel air samples which may require decisions for stopping work,
evacuating workers, providing additional sampling, informing workers of the airborne
radioactivity areas, and resulting exposures, and posting and controlling airborne radioactivity
areas when the criteria was reached.
Enforcement:
Violation: Technical Specifications 6.8.1(a) requires, in part, that written procedures shall be
established, implemented, and maintained covering the procedures recommended in
Regulatory Guide 1.33, revision 2, appendix A, dated February 1978. Regulatory Guide 1.33,
appendix A, section 7.e. requires procedures for Airborne Radioactivity Monitoring. The
licensee established procedure EN-RP-131, Air Sampling, revision 17, to provide standard
instructions for obtaining radiological air samples and for determining the concentration of
airborne particulate, iodine, tritium, and noble gas radioactivity.
Procedure EN-RP-131, Air Sampling, revision 17, section 5.1.12 states, in part, that if lapel
air sample results indicated an intake could occur at greater than 4 DAC-hrs, in an area that
is not posted and controlled as an airborne radioactivity area, and radon discriminating
analysis was complete, the licensee will: stop work; evacuate workers from the affected area,
collect grab samples to determine if airborne concentrations are sustained and to identify the
source if unknown; inform workers in the area without respiratory protection that airborne
radioactivity was measured and potential exposures will be evaluated; and if the conditions
causing the airborne radioactivity may still exist or are unknown, then immediately post and
control the area as an airborne radioactivity area.
Contrary to the above, on April 17, 2022, the licensee failed to follow procedure EN-RP-131,
Air Sampling, revision 17, section 5.1.12, when lapel air sample results indicated an intake
could occur at greater than 4 DAC-hrs, in an area that is not posted and controlled as an
airborne radioactivity area, and radon discrimination was complete. Specifically, the licensee
did not stop work; evacuate workers from the affected area, collect grab samples to
determine if airborne concentrations are sustained, and to identify the source if unknown;
inform workers in the area without respiratory protection that airborne radioactivity was
measured and potential exposures will be evaluated; and if the conditions causing the
airborne radioactivity may still exist or are unknown, then immediately post and control the
area as an airborne radioactivity area.
22
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Failure to Follow a Radiological Work Permit Requirement
Cornerstone Significance Cross-Cutting Report
Aspect Section
Occupational Green [H.5] - Work 71124.03
Radiation Safety NCV 05000382/2022002-04 Management
Open/Closed
The inspectors identified a Green, non-cited violation of Technical Specification 6.8.1(a) for
the licensees failure to follow radiation procedure, EN-RP-100, Radiation Worker
Expectations, revision 13, steps to follow the requirements set forth within a radiological work
permit (RWP). Specifically, workers failed to follow RWP 2022-0615, task 2, Removal of old
pressurizer heaters (includes cutting/grinding and all supporting activities), revision 2, which
required a continuous air monitor be located within the pressurizer cubicle during work
evolutions which have the potential for generating airborne activity.
Description: On April 18, 2022, during refueling outage 24, two pipefitters (laborers) and two
radiation protection technicians were contaminated during the removal of pressurizer heaters.
The primary pressurizer heater removal work took place inside the pressurizer shroud, in the
pressurizer cubicle, on the 21-foot elevation of containment. This work was conducted under
the requirements of RWP 0615, task 2. Two laborers, located inside the shroud, removed the
pressurizer heaters, placed them in transport sleeves, then passed them through an opening
in the shroud to two additional laborers inside the cubicle. These two laborers then passed
the pressurizer heaters from the pressurizer cubicle to other workers for storage. The
laborers inside the shroud wore powered air purifying respirators while the rest of the workers
wore standard anticontamination apparel.
Upon removing the J-1 pressurizer heater from its location, a blackish sludge came out of the
hole with some of the material landing on a laborer. Due to the remaining dose margin and
the presence of the unknown sludge, the radiation protection technician decided to stop the
job and have everyone exit the area.
When the workers attempted to exit the radiologically controlled area, the workers performing
work in the pressurizer cubicle alarmed the personnel contamination monitors. The workers
were sent for whole body counts to identify any intake of radioactive material to the workers.
Unknown to the workers while they were removing the pressurizer heaters, airborne
radioactivity levels had increased in the pressurizer cubicle. As a result, four workers, those
working in the pressurizer cubicle, received intakes of airborne radioactive material.
NRC inspectors reviewed the event and identified an RWP 0615, task 2 requirement was not
met. Specifically, the licensee did not implement the requirement that a continuous air
monitor be in the pressurizer cubicle during work evolutions which have the potential for
generating airborne activity. The location of the continuous air monitor during the activity was
outside the pressurize cubicle near the entranceway to the cubicle. This location was not
representative of the actual work area and did not allow the continuous air monitor to alert
workers of changing airborne radioactivity levels within the cubicle.
Corrective Actions: The licensee entered the issue into the corrective action program to
determine appropriate actions.
23
Corrective Action References: CR-WF3-2022-04924, CR-WF3-2022-03171
Performance Assessment:
Performance Deficiency: The failure to follow a radiological work permit requirement was a
performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Human Performance attribute of the Occupational
Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the
adequate protection of the worker health and safety from exposure to radiation from
radioactive material during routine civilian nuclear reactor operation. Specifically, workers
within the pressurizer cubicle received unintended internal exposures from unanticipated
airborne radioactive material. Additionally, the finding was similar to Inspection Manual
Chapter 0612, Power Reactor Inspection Reports - Examples of Minor Issues, appendix E,
example 6(h). This example states that a performance deficiency was more than minor if it
results in a failure of radiological controls which could result or resulted in an exposure equal
to or greater than 10 mrem committed effective dose equivalent (CEDE). In this case, the
failure to have the continuous air monitor located in the work area resulted in a workers
unintended exposure of 13 mrem CEDE.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix C, Occupational Radiation Safety SDP. The inspectors determined the finding had
very low safety significance (Green) because: (1) it was not associated with ALARA planning
and work controls, (2) it was not an overexposure, (3) there was no substantial potential for
overexposure, and (4) the ability to assess dose was not compromised.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of
planning, controlling, and executing work activities such that nuclear safety is the overriding
priority. The work process includes the identification and management of risk commensurate
to the work and the need for coordination with different groups or job activities. Specifically,
the possibility of generating airborne radioactivity was an identified risk for this work and a
continuous air monitor in operation was required within the associated RWP to protect the
workers within the cubicle and mitigate this risk. However, upon execution of the RWP, this
requirement was not met.
Enforcement:
Violation: Technical Specifications 6.8.1(a) requires, in part, that written procedures shall be
established, implemented, and maintained covering applicable procedures recommended in
NRC Regulatory Guide 1.33, revision 2, appendix A, dated February 1978. Regulatory
Guide 1.33, appendix A, section 7.e. requires procedures for Access Control to Radiation
Areas Including a Radiation Work Permit (RWP) System. The licensee established
procedure EN-RP-100, Radiation Worker Expectations, revision 12, which established basic
radiation protection requirements and expectations for radiation workers engaged in
radiological work that included the use of radiological work permits.
Procedure EN-RP-100, section 5.3 states, in part, the RWP shall be read, understood, and
obeyed when workers are to enter a radiologically controlled area. The workers were
assigned RWP 2022-0615, task 2, Removal of old pressurizer heaters (includes
cutting/grinding and all supporting activities), revision 2, which required a continuous air
monitor be located in the pressurizer cubicle during work evolutions that have the potential for
24
generating airborne activity.
Contrary to the above, on April 18, 2022, workers failed read, understand, and obey the
RWP 2022-0615, task 2, revision 2 requirement to locate a continuous air monitor in the
pressurizer cubicle during work evolutions that had the potential for generating airborne
radioactivity. Specifically, there was no continuous air monitor in the cubicle to alert workers
of a generated airborne radioactivity area when removing the pressurizer heaters from the
pressurizer. This resulted in a worker receiving an unintended exposure of 13 mrem CEDE.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Failure to Survey for an Airborne Radioactivity Area.
Cornerstone Significance Cross-Cutting Report
Aspect Section
Occupational Green [H.14] - 71124.03
Radiation Safety NCV 05000382/2022002-05 Conservative
Open/Closed Bias
The inspectors identified a Green, non-cited violation of 10 CFR 20.1501(a) for the licensees
failure to reasonably evaluate surveys under the circumstances to identify and post an
airborne radioactivity area in accordance with 10 CFR 20.1902(d). Specifically, air sample
survey WF3-AS-041722-0238, taken on April 17, 2022, was not evaluated under
circumstances reasonable to determine the extent and magnitude of airborne radioactivity
levels which resulted in a failure to post and control an airborne radioactivity area.
Description: On April 17, 2022, during Waterford-3s refueling outage, pipefitters were
conducting work to prepare for the removal of heaters from the bottom of the pressurizer.
This work was taking place within the pressurizer shroud, inside the pressurizer cubicle, on
the 21-foot elevation of containment. The workers were partially cutting the welds that
connected the pressurizer heaters to their heater sleeves. This job allowed the welds to be
broken in a later work activity so that the pressurizer heaters could be removed from the
pressurizer.
In association with this job, the inspectors identified air sample survey WF3-AS-041722-0238,
taken on April 17, 2022, was not evaluated in a reasonable time period to post the area as an
airborne radioactivity area and inform workers of the conditions. The air sample was collected
from 9:15 a.m. to 10:40 a.m. The sample was counted on an iSolo alpha/beta counting
system at 12:16 p.m., an hour and 36 minutes after its collection. The resulting count
determined a total derived air concentration (DAC) for beta/alpha airborne radioactivity of 0.8.
This value is roughly 2.5 times over the threshold for posting an airborne radioactivity area at
0.3 DAC.
Licensee procedure EN-RP-131, Air Sampling, revision 17, contained the requirements for
posting of airborne radioactivity areas in accordance with 10 CFR 20.1902(d). Section 5.1.12
of this procedure stated, in part, that if air sample results indicate total airborne concentration
greater than or equal to 0.3 DAC, in an area that is not posted and controlled as an airborne
radioactivity area, the licensee will post and control the area as an airborne radioactivity area.
The sample was counted on an instrument (iSolo) that compensated and corrected the
activity for radon daughter products, i.e., discriminated radon from the total activity.
Procedure EN-RP-304, Operation of Counting Equipment, revision 6, section 6.3.8, step 8,
25
stated if a sample count time is within six hours of the sample stop time, then the
compensated value may be used. However, the licensee attributed the initial high count to
radon daughter products with no documented justification or discussion for this conclusion.
The licensee decided to conduct follow-up counts to factor out the radon daughter products.
They conducted additional counts at 7.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and 17.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> post collection of the sample.
The resulting counts were a total DAC of 0.657 and 0.518, respectively. Neither of these
results are below the threshold for posting an airborne radioactivity area. The licensee
attributed these results to radon daughter products and did not consider the counting
equipment discriminated radon daughter from the resulting activity.
Because the licensee did not evaluate this survey in a timely manner, the area was not
posted as an airborne radioactivity area in accordance with 10 CFR 20.1902(d), work
continued within the location, and workers were not informed of the changing radiological
conditions.
Corrective Actions: The licensee entered the performance deficiency into their corrective
action program to determine appropriate actions.
Corrective Action References: CR-WF3-2022-03296, CR-WF3-2022-03297, CR-WF3-2022-
04921
Performance Assessment:
Performance Deficiency: Failure to evaluate a survey as required by 10 CFR 20.1501(a) in
the work area of the pressurizer cubicle to identify and post an airborne radioactivity area in
accordance with 10 CFR 20.1902(d) was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Program & Process attribute of the Occupational
Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the
adequate protection of the worker health and safety from exposure to radiation from
radioactive material during routine civilian nuclear reactor operation. This resulted in workers
unknowingly being exposed to an unidentified airborne radioactivity area and receiving
additional unintended exposures.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix C, Occupational Radiation Safety SDP. The inspectors determined the finding had
very low safety significance (Green) because: (1) it was not associated with ALARA planning
and work controls, (2) it was not an overexposure, (3) there was no substantial potential for
overexposure, and (4) the ability to assess dose was not compromised.
Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision making-practices
that emphasize prudent choices over those that are simply allowable. A proposed action is
determined to be safe in order to proceed, rather than unsafe in order to stop. Specifically,
individuals involved in the counting of the air sample assumed radon daughter products were
contributing to the results instead of recognizing the equipment used compensated for radon
daughters. This caused the licensee to not identify and post the area as an airborne
radioactivity area.
Enforcement:
26
Violation: Title 10 CFR 20.1501(a), states in part, each licensee shall make or cause to be
made surveys of areas that may be necessary for the licensee to comply with the regulations
in this part and are reasonable under the circumstances to evaluate the magnitude and extent
of radiation levels and the potential radiological hazards of the radiation levels and residual
radioactivity detected.
Title 10 CFR 20.1902(d) states, in part, the licensee shall post each airborne radioactivity
area with a conspicuous sign bearing the radiation symbol and the words "Caution, Airborne
Radioactivity Area." The licensee implemented 10 CFR 20.1902(d) requirements through
procedure EN-RP-131, Air Sampling, revision 17. Section 5.1.12 stated, in part, that if air
sample results indicate total airborne concentration greater than or equal to 0.3 DAC, in an
area that is not posted and controlled as an airborne radioactivity area, the licensee will post
and control the area as an airborne radioactivity area.
Contrary to the above, on April 17, 2022, the licensee failed to make or cause to be made
surveys of areas that may be necessary for the licensee to comply with the regulations in this
part and are reasonable under the circumstances to evaluate the magnitude and extent of
radiation levels and the potential radiological hazards of the radiation levels and residual
radioactivity detected. Consequently, the licensee failed to post and control an airborne
radioactivity area when air sample results indicated a total airborne concentration of greater
than or equal to 0.3 DAC.
Specifically, air sample survey WF3-AS-041722-0238 was taken and the counting of the
sample was delayed such that the results were not evaluated for over 58 hours6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br /> while work
continued within the area. This resulted in a failure to post and control this area as an
airborne radioactivity area.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Inadequate Radiological Work Permit Procedure to Address Respirator Controls During Work
Activities.
Cornerstone Significance Cross-Cutting Report
Aspect Section
Occupational Green [H.14] - 71124.03
Radiation Safety NCV 05000382/2022002-06 Conservative
Open/Closed Bias
The inspectors identified a Green, non-cited violation of Technical Specification 6.8.1(a) for
an inadequate radiological work permit (RWP) procedure to address respirator controls
during work activities. Specifically, licensee procedure EN-RP-105, Radiological Work
Permits, revision 19, contained procedural steps outlining the process for removing
respiratory controls while an attachment to this procedure bypassed completion of an RWP
revision and a total effective dose equivalent (TEDE)/as low as (is) reasonably achievable
(ALARA) evaluation when changing respiratory protection controls.
Description: On April 17, 2022, during the refueling outage, workers were performing
preparatory work for the removal of the pressurizer heaters from the bottom of the
pressurizer. This job was performed in the pressurizer shroud, inside the pressurizer cubicle,
on the 21-foot elevation of containment. The workers were to partially cut the welds that
connected the heaters to their heater sleeves.
27
The inspectors reviewed RWP 2022-0615, task 2, Removal of Old Pressurizer Heaters
(includes cutting/grinding and all supporting activities), revision 2, and its supporting
documentation, such as surveys and TEDE/ALARA evaluations. TEDE/ALARA evaluation
number 2022-0615-02, Removal of Old Pressurizer Heater, required the use of powered air
purifying respirators (PAPRs) during the work performed on this task with potential airborne
radioactivity levels approaching 0.38 derived air concentrations. However, documentation
showed that during the weld cutting for this job, the workers did not wear PAPRs. The
licensee used procedure EN-RP-105, attachments 5, RWP Field Change, to document their
in-field change decision to remove respirator use for this job.
Procedure EN-RP-105, step 5.7.1, described the scope of RWP field changes and stated, in
part, that an RWP field change may be used to change protective requirements on a case-by-
case basis for a particular entry or specific evolution within the job (for example, allowing
scaffold builders to wear double gloves instead of double protective clothing when supporting
a valve rebuild). Inspectors reviewed the in-field change document and noted that the
respiratory protection requirement was removed for the entire length of the weld cutting job
and was not changed for a specific portion of the job., e.g., setting up the cutting equipment
at the cut location.
Procedure EN-RP-105, attachment 5, was internally inconsistent with section 5.7 of the
procedure which described the scope of in-field changes. Specifically, attachment 5 included
language that stated ALARA/Supervisor approval is required for field changes involving:
changing respiratory protection requirements and changing the TEDE/ALARA evaluations.
This specific language in attachment 5 created a new criterion, new allowance, to the in-field
change process which was not contained in section 5.7.1 of the procedure.
In addition, procedure EN-RP-105, step 5.8.1, RWP Revision, stated, in part, the licensee
was to revise RWPs for conditions involving changes in work scope which make the RWP
controls insufficient and which do not meet the criteria for a field change as described in
section 5.7, and for changes in radiological protective requirements for the duration of the job.
These two criteria indicated a revision to the RWP was required for a change in respiratory
protection requirements; specifically relaxing the requirement to wear PAPRs for the duration
of the cutting job.
Further, step 5.8.2.d, stated, if respiratory protection requirements are changed, then
perform a TEDE/ALARA evaluation according to procedure EN-RP-503, Selection, Issue and
Use of Respiratory Protection Equipment. This procedural step was to ensure workers were
adequately protected for changes of respirator requirements within a work area. The in-field
change did not reflect a reevaluated TEDE/ALARA evaluation to relax the respiratory
requirement for workers to use PAPRs.
After reviewing procedure EN-RP-105, Radiological Work Permit, the inspectors determined
the procedural steps 5.7.1, 5.8.1, and 5.8.2.d conflicted with attachment 5. The language in
attachment 5 of the procedure allowed workers to understand the relaxing of respiratory
requirements was an acceptable action that could be performed in the field without additional
required actions. Due to this inconsistency, a worker did not adhere to the other procedural
steps, such as performing an RWP revision and a TEDE/ALARA evaluation, when removing
respiratory protection controls for a job. These steps are important to ensure workers are
adequately protected while maintaining their doses ALARA within the work area.
28
Corrective Actions: The licensee has entered the performance deficiency into their corrective
action program to determine appropriate actions.
Corrective Action References: CR-WF3-2022-04923
Performance Assessment:
Performance Deficiency: Inadequate RWP procedure to address respirator controls during
work activities was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Program & Process attribute of the Occupational
Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the
adequate protection of the worker health and safety from exposure to radiation from
radioactive material during routine civilian nuclear reactor operation. The inconsistent process
within procedure EN-RP-105 created performance gaps when evaluating, assessing, and
controlling worker exposures from unintended and unanticipated sources and maintaining
doses ALARA.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix C, Occupational Radiation Safety SDP. The inspectors determined the finding had
very low safety significance (Green) because: (1) the performance deficiency was associated
with ALARA planning or work controls and (2) the average collective dose was less than
135 person-rem for the pressurized-water reactor.
Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision making-practices
that emphasize prudent choices over those that are simply allowable. A proposed action is
determined to be safe in order to proceed, rather than unsafe in order to stop. Specifically,
field changes were made to radiological controls for a job via an in-field change form with
multiple levels of supervisory approval that did not question if the decision to remove
respiratory protection might require a more rigorous process or if other procedural steps
applied to this decision (RWP revision and TEDE/ALARA evaluation).
Enforcement:
Violation: Technical Specifications 6.8.1(a), requires, in part, that written procedures shall be
established, implemented, and maintained covering applicable procedures recommended in
NRC Regulatory Guide 1.33, revision 2, appendix A, dated February 1978. Appendix A,
section 7.e. requires procedures for Access Control to Radiation Areas Including a Radiation
Work Permit (RWP) System. The licensee established procedure EN-RP-105, Radiological
Work Permits, revision 19, to implement a radiological work permit system.
Procedure EN-RP-105, step 5.8.1, RWP Revision, stated, in part, the licensee was to revise
RWPs for conditions involving changes in work scope which make the RWP controls
insufficient and which do not meet the criteria for a field change as described in section 5.7,
and for changes in radiological protective requirements for the duration of the job. In addition,
step 5.8.2.d, stated, if respiratory protection requirements are changed, then perform a
TEDE/ALARA evaluation according to procedure EN-RP-503, Selection, Issue and Use of
Respiratory Protection Equipment.
Procedure EN-RP-105, attachment 5, stated, in part, ALARA/Supervisor approval is required
for field changes involving: changing respiratory protection requirements and changing the
TEDE/ALARA evaluations.
29
Contrary to the above, on April 17, 2022, the use of procedure EN-RP-105, attachment 5,
which was internally inconsistent, resulted in the licensees failure to follow the requirements
in procedure EN-RP-105, step 5.8.1, RWP Revision, for a revision to RWPs for conditions
involving changes in work scope which make the RWP controls insufficient and which do not
meet the criteria for a field change as described in section 5.7, and for changes in radiological
protective requirements for the duration of the job. In addition, step 5.8.2.d, required that if
respiratory protection requirements are changed, then perform a TEDE/ALARA evaluation
according to procedure EN-RP-503, Selection, Issue and Use of Respiratory Protection
Equipment. Specifically, workers used attachment 5 to change respiratory protection
requirements in the field without adhering to additional requirements within the procedure
such as performing an RWP revision and reassessing the associated TEDE/ALARA
evaluation.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Failure to Ensure Proper Phase Rotation for FLEX Equipment
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.13] - 71152A
Systems NCV 05000382/2022002-07 Consistent
Open/Closed Process
A self-revealed Green finding and associated non-cited violation (NCV) of 10 CFR 50.155(c),
Mitigation of beyond-design-basis events, was identified when the licensee failed to ensure
equipment relied upon for the mitigation strategies for beyond-design basis external events
had the capability to perform the required functions. Specifically, the licensee failed to ensure
that required Diverse and Flexible Coping Strategies (FLEX) electrical receptacles had the
same electrical phase rotation as the FLEX N and N+1 core cooling pump motors such that
the core cooling pumps would operate as expected.
Description: As part of the licensees Phase 2 strategies as required by NRC Order
EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies
for Beyond-Design-Basis External Events, the licensee committed to the guidance described
in NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,
revision 0. NRC Order EA-12-049 has since been codified by 10 CFR 50.155(c), Mitigation
of beyond-design-basis events.
Specifically for FLEX core cooling capabilities, the licensee developed strategies that
incorporate the use of the permanently installed charging pumps along with FLEX N and N+1
core cooling pumps. The FLEX N core cooling pump is permanently mounted on the -35
elevation of the reactor auxiliaries building. The FLEX N+1 core cooling pump is stored in the
FLEX N+1 building in the owner-controlled area of the site. Either pump can be implemented
to provide water to either the reactor coolant system (RCS) or to a steam generator.
One of the licensees strategies for core cooling includes powering one FLEX core cooling
pump and one charging pump using a FLEX diesel generator through a permanently installed
charging pump circuit. One of the two FLEX diesel generators would provide power into an
existing 480V safety-related bus. The AB swing bus would be aligned to the powered bus.
The two busses would then separately power the charging pump and the FLEX core cooling
pump. In this situation, the FLEX core cooling pump would not have worked because the AB
30
receptacle was wired incorrectly and provided electricity with a reverse phase rotation.
During installation of FLEX equipment in 2015, the licensee tested the FLEX electrical
receptacles that are routed from the charging pump breakers. One individual tested FLEX
receptacles A and B while another individual tested the AB receptacle. All receptacles were
signed off as passing the phase rotation test, but when the FLEX N core cooling pump was
energized by the B FLEX receptacle the pump turned counterclockwise, or backwards from
the required direction for the pump to work properly. The licensee then swapped leads on the
FLEX N core cooling pump which then passed the rotation test on November 25, 2015.
On March 29, 2020, the licensee performed a rotation check of the FLEX N+1 core cooling
pump when also powered from the B receptacle; the pump rotated in the wrong direction. The
licensee then swapped the leads for the FLEX N+1 core cooling pump ensuring that it would
also rotate in the correct direction when plugged into the B FLEX receptacle, exactly like the
FLEX N core cooling pump.
On June 1, 2021, the licensee powered the FLEX N core cooling pump from the AB
receptacle and again the pump spun in the reverse direction. The licensee found through
troubleshooting that the FLEX A and B electrical receptacles as well as the FLEX N and N+1
core cooling pumps were all wired opposite from the initial installation requirements; however,
they all worked correctly when used together. The FLEX AB electrical receptacle was still
installed in accordance with initial installation requirements and would therefore cause
reverse rotation. On June 2, 2021, the licensee swapped the leads for the FLEX AB
receptacle to bring all the FLEX receptacles and FLEX core cooling pumps in alignment so
they would all work properly when used together.
Per the licensees FLEX strategy requirements for FLEX fluid and electrical connections
found in Technical Requirements Manual (TRM) 3.13.3, Table 3.13-2, FLEX Connections
that Directly Perform a FLEX Mitigation Strategy for the Key Safety Functions, the FLEX AB
electrical receptacle, FLEXEDSC31AB-4C1, is required in Modes 1 through 4 along with
either the FLEX B receptacle for the primary connection point or the FLEX A receptacle for
the secondary connection point. Note 2 of Table 3.13-2 states that FLEX AB electrical
receptacle is required to be operable to support the core cooling strategy and is not
dependent upon which FLEX core cooling pump power source has been selected for FLEX
implementation.
From November 25, 2015, until March 29, 2020, only the FLEX N core cooling pump would
have rotated correctly when powered by the FLEX A or B electrical receptacles from the
charging pump breakers. For this period, the FLEX N+1 core cooling pump would only have
rotated correctly if using the FLEX AB receptacle. From March 29, 2020, until June 2, 2021,
FLEX N and N+1 core cooling pumps would have rotated correctly and performed their
function when powered by the FLEX A and B receptacles, but not when powered by the AB
receptacle.
Corrective Actions: The licensee swapped the leads for FLEX electrical receptacle AB so the
phase rotation matched FLEX receptacles A and B as well as FLEX N and N+1 core cooling
pump motors. The licensee updated drawings to reflect the new phase rotation of the
receptacles and pump motors that matched what was installed. The licensee also performed
an extent of condition to verify the phase rotation of all three FLEX electrical receptacles from
the charging pump electrical junction boxes as well as the phase rotation of the FLEX N and
31
N+1 core cooling pump motors to ensure they would work together. The licensee also verified
the phase rotation of the FLEX N and N+1 diesel generators.
Corrective Action References: CR-WF3-2021-02879
Performance Assessment:
Performance Deficiency: The licensee failed to ensure equipment relied upon for the
mitigation strategies for beyond-design basis external events had sufficient capability to
perform the required functions.
Screening: The inspectors determined the performance deficiency was more-than-minor
because it was associated with the design control attribute of the mitigating systems
cornerstone and adversely affected the cornerstone objective to ensure the availability,
reliability, and capability of systems that respond to initiating events to prevent undesirable
consequences. Specifically, the licensee failed to ensure that required FLEX electrical
receptacles had the same electrical phase rotation as the FLEX N and N+1 core cooling
pump motors such that the core cooling pumps would operate as expected.
Significance: The inspectors assessed the significance of the finding using NRC Inspection
Manual Chapter 0609 Appendix A, The Significance Determination Process (SDP) for
Findings At-Power. Using Exhibit 2, Mitigating Systems Screening Questions, Section E,
the inspectors determined the finding to be of very low safety significance (Green), because
the performance deficiency was associated with equipment not solely purposed for spent fuel
pool instrumentation or for containment venting, but it was associated with equipment
credited in a Phase 2 FLEX strategy such that all FLEX functions could still be completed in
accordance with existing plant procedures within the time allotted.
Cross-Cutting Aspect: H.13 - Consistent Process: Individuals use a consistent, systematic
approach to make decisions. Risk insights are incorporated as appropriate. Specifically, the
leads for FLEX N core cooling pump were swapped after it spun backwards during the initial
bump check in 2015. The licensee did not ensure the use of a systematic process was used
during installation of equipment or during troubleshooting unexpected as-found conditions.
Enforcement:
Violation: Title 10 CFR 50.155(b)(1), states, in part, strategies and guidelines to mitigate
beyond-design-basis events from natural phenomena must be capable of being implemented
site-wide and must include maintaining or restoring core cooling capabilities.
Title 10 CFR 50.155(c), states, in part, equipment relied on for the mitigation strategies and
guidelines required by paragraph (b)(1) of this section must have sufficient capability to
perform the functions to perform the functions required by paragraph (b)(1).
Contrary to the above, from November 25, 2015, until June 2, 2021, the licensee failed to
ensure equipment relied upon for restoring core cooling capabilities had sufficient capability
to perform the required functions. Specifically, the licensee failed to ensure that required
FLEX electrical receptacles had the same electrical phase rotation as the FLEX N and N+1
core cooling pump motors such that the core cooling pumps would operate as expected.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
32
Inadequate Design of Differential Pressure Sensor Ambient Sensing Line
Cornerstone Significance Cross-Cutting Report
Aspect Section
Barrier Integrity Green None (NPP) 71153
Open/Closed
The inspectors reviewed a self-revealed Green finding and associated non-cited violation of
10 CFR Part 50, Appendix B, Criterion III, Design Control, when the licensee failed to
appropriately verify the adequacy of the shield building ventilation design. Specifically, a
failed stroke time test for shield building ventilation valve 114B on October 18, 2021,
discovered that an ambient pressure sensing line failed to provide proper input since
August 29, 2021. This discovery revealed that train B of the shield building ventilation system
and train B of the controlled area ventilation system were inoperable for approximately
50 days. This condition is prohibited by technical specifications and resulted in the issuance
of a licensee event report because the time these systems were inoperable exceeded the
technical specification allowed outage time.
Description: The shield building ventilation system is an engineered safety feature charcoal
filtration system and is not normally in operation. It is designed to maintain the shield building
to reactor building annulus in a -8.0 INWC (inches water column) negative pressure and
preclude any contaminated air leakage through the shield building during a design basis
accident that causes a safety injection actuation signal. Shield building ventilation system air
is filtered through high efficiency particulate air filters and charcoal beds to reduce the
radiological dose to the general public. The shield building ventilation system has two basic
flow paths used for two phases of operation: the exhaust phase and the recirculation phase.
The shield building ventilation system shifts between the exhaust and recirculation phases of
operation to maintain vacuum using input from the ambient pressure sensing line until the
safety injection actuation signal is removed.
The controlled area ventilation system is an engineered safety feature charcoal filtration
system, and it is designed to maintain select rooms in the reactor auxiliary building at a
negative pressure. Select rooms include the A and B safeguards rooms, the -4 and -35 wing
areas, the shutdown heat exchanger rooms, the A and B valve galleries, and the -4 reactor
auxiliary building pipe penetration area. Controlled area ventilation system air is filtered
through high efficiency particulate air filters and charcoal beds to reduce the radiological dose
to the general public during a design basis accident. The controlled area ventilation system
uses ambient differential pressure to control damper positions to regulate the amount of
makeup air allowed into the suction of the air handling units.
On August 29, 2021, high winds and rain during Hurricane Ida allowed water intrusion into an
ambient pressure sensing line that provides input into differential pressure sensors
SBVIDPT5054B (shield building ventilation annulus to ambient differential pressure) and
HVRIDPT5272B (-4 reactor auxiliary building pipe penetration to ambient differential
pressure). Although not identified at the time, past plant computer data point trends indicate
that the erratic pressure readings began the day Hurricane Ida passed over Waterford 3. This
condition was only discovered on October 18, 2021, when the licensee was troubleshooting a
failed valve stroke time test. These differential pressure data points are not observed on a
regular basis.
After this condition was discovered, the licensee declared the shield building ventilation
33
system inoperable and entered technical specification 3.7.7 on October 18, 2021, at 0200.
Later the next day, it was discovered the suspect ambient sensing line also provides ambient
pressure input to HVRIDPT5272B and the controlled area ventilation system was declared
inoperable at 1000 on October 19, 2021. The sensing line was purged with air to remove the
water and post-maintenance testing was performed on both systems. Operability was
restored to the controlled area ventilation system at 2128 on October 19, 2021, and
operability was restored to the shield building ventilation system at 0316 on October 21,
2021. Shield building ventilation system train B and controlled area ventilation system train B
were inoperable for approximately 50 days; this period of inoperability exceeded their 7-day
allowed outage time in technical specification 3.7.7. Licensee Event Report 50-382/2021-003-
00, Non-Compliance with Technical Specifications due to Failed Ambient Pressure Input, was
submitted to the NRC on December 16, 2021.
Corrective Actions: The licensee plans to modify the subject sensing line to eliminate the
potential for water intrusion. The licensee also plans to generate a new calculated computer
point that compares the opposite train differential pressure transmitter SBVIDPT5054A with
SBVIDPT5054B values which will alarm in the control room when the error between these
two points exceeds a reasonable value continuously for a selected period of time.
Additionally, preventive maintenance will be revised to include draining the ambient sensing
line.
Corrective Action References: CR-WF3-2021-5760
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensee failed to appropriately
verify the adequacy of a pressure sensing line design that impacts shield building and
controlled area ventilation was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor, and
therefore a finding, because it was associated with the Design Control attribute of the Barrier
Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable
assurance that physical design barriers protect the public from radionuclide releases caused
by accidents or events. Specifically, the licensee failed to recognize that the design of the
ambient sensing line allowed it to fill with water and prevent train B of the shield building
ventilation system and train B of the controlled area ventilation system from being able to
perform their designed functions.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix A, The Significance Determination Process (SDP) for Findings At-Power.
Specifically, using Exhibit 3, Barrier Integrity Screening Questions, the inspectors
determined that this finding is of very low safety significance (Green), because the finding
only represented a degradation of the radiological barrier function provided for the control
room, auxiliary building, reactor building, or spent fuel pool.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to
this finding because the inspectors determined the finding did not reflect present licensee
performance.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part,
that design control measures shall be established to assure that applicable regulatory
34
requirements and the design bases are correctly translated into specifications, drawings,
procedures, and instructions.
Contrary to the above, prior to October 19, 2021, the licensee failed to ensure that the
ambient pressure sensing line in question was adequately designed to assure that applicable
regulatory requirements and the design bases are correctly translated into specifications,
drawings, procedures, and instructions to ensure that the installed equipment was protected
from inclement weather within the design bases. Specifically, the licensee failed to ensure
that the sensing line was protected against water intrusion and retention during periods of
severe inclement weather. This failure resulted in a condition prohibited by technical
specifications and an associated licensee event report because the time these systems were
inoperable exceeded the technical specification allowed outage time.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On June 16, 2022, the inspectors presented the radiation safety inspection results to Mr.
J. Ferrick, Site Vice President, and other members of the licensee staff.
On June 23, 2022, the inspectors presented the inservice inspection results to
Mr. J. Ferrick, Site Vice President and other members of the licensee staff.
On June 24, 2022, the inspectors presented the radiation safety inspection results to Mr.
J. Ferrick, Site Vice President, and other members of the licensee staff.
On July 19, 2022, the inspectors presented the integrated inspection results to
Mr. M. Lewis, General Manager of Plant Operations, and other members of the licensee
staff.
35
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.01 Procedures EN-FAP-EP-010 Severe Weather Response 9
71111.01 Procedures OP-901-521 Severe Weather and Flooding 338
71111.04 Miscellaneous SD-SI Safety Injection 19
71111.04 Procedures OP-009-003 Emergency Feedwater 312
71111.04 Procedures OP-009-008 Safety Injection System 47
71111.05 Fire Plans RAB 18-001 Component Cooling Water Heat Exchanger A 9
71111.05 Fire Plans RAB 19-001 Component Cooling Water Pump A 8
71111.05 Procedures EN-DC-161 Control of Combustibles 24
71111.07A Miscellaneous W3-DBD-004 Component Cooling Water Auxiliary Component Cooling 306
Water
71111.07A Work Orders 52944799
71111.08P Corrective Action Condition Reports CR-WF3-2022-02400, CR-WF3-2022-02459,
Documents CR-WF3-2022-02468, CR-WF3-2022-02472,
CR-WF3-2022-02644, CR-WF3-2022-02658,
CR-WF3-2022-02665, CR-WF3-2022-02682,
CR-WF3-2022-01929, CR-WF3-2022-01949,
CR-WF3-2022-01977, CR-WF3-2022-01978,
CR-WF3-2022-01979, CR-WF3-2022-01993,
CR-WF3-2022-02011, CR-WF3-2022-02012,
CR-WF3-2022-02013, CR-WF3-2022-02014,
CR-WF3-2022-02015, CR-WF3-2022-02016,
CR-WF3-2022-02017, CR-WF3-2022-02030,
CR-WF3-2022-02057, CR-WF3-2022-02755,
CR-WF3-2022-02768, CR-WF3-2022-02823,
CR-WF3-2022-02444, CR-WF3-2022-02633,
71111.08P Drawings E-2803, IC-1130 Safety Injection, Dravo Corporation, Pipe Fabrication 7
Division
71111.08P Drawings E-3029LW3CC43 Essential Cooling Water, Dravo Corporation, Pipe 6
Fabrication Department
71111.08P Drawings E-3029LW3CC51 Essential Cooling Water, Dravo Corporation, Pipe 6
Fabrication Division
36
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.08P Engineering DECP REPLACE SI-512A WITH A SWING CHECK VALVE 0
Changes 0000083354
71111.08P Engineering EC 0000081552 Disposition of Active Leak Indications Found on Reactor 000
Changes
71111.08P Engineering EC 000073452 Steam Generator Feedring Modification (Child SG1 - 0
Changes Feedring)
71111.08P Engineering EC 000073453 Steam Generator Feedring Modification (Child SG2 - 0
Changes Feedring)
71111.08P Engineering EC-0000083354 Replace SI-512A with a Swing Check Valve 0
Changes
71111.08P Miscellaneous CEP-PT-001 ASME Section XI Pressure Test (PT) Program, Entergy 311
Nuclear Engineering Programs
71111.08P Miscellaneous Code Case N- Alternative Examination Requirements for PWR Reactor 03/03/2016
729-6 Vessel Upper Heads with Nozzles having Pressure-
Retaining Partial-Penetration Welds,Section XI, Division 1
71111.08P Miscellaneous EN-DC-319 Boric Acid Corrosion Control Program (BACCP) 12
71111.08P Miscellaneous EPID L-2018- WATERFORD STEAM ELECTRIC STATION, UNIT 3- 10/18/2018
LLR-0025 PROPOSED ALTERNATIVE TO ASME CODE, SECTION
XI, REGARDING CHARGING PIPE VISUAL INSPECTION
71111.08P Miscellaneous Purchase Order: Certified Material Test Report, Welding Rods, ER308/308L, 06/05/2012
10323632 GTAW, 3/32 inch diameter, Austenitic Steel Rod.
71111.08P Miscellaneous Purchase Order: Certified Material Test Report - Welding Rod, ER308/308L, 10/17/2017
10323632 GTAW, 1/8 inch diameter, Austenitic Steel
71111.08P Miscellaneous SEP-BAC-WF3- Waterford 3 Boric Acid Corrosion Control Program (BACC) 003
001 Program Section
71111.08P Miscellaneous SEP-CISI-104 Program Section for ASME Section XI, Division 1 WF3 5
Containment Inservice Inspection Program
71111.08P Miscellaneous SEP-ISI-104 Program Section for ASME Section XI, Division 1 WF3 11
Inservice Inspection Program
71111.08P Miscellaneous SEP-PT-WF3-001 Waterford 3 Inservice Inspection Pressure Testing (PT) 000
Program Section
71111.08P Miscellaneous W3F1-2008-0060 Request for Alternative W3-\Sl-006, Proposed Alternative to 09/18/2008
Extend the Second 10-Year lnservice Inspection Interval for
37
Inspection Type Designation Description or Title Revision or
Procedure Date
Reactor Vessel Internal Weld Examinations Waterford
Steam Electric Station, Unit 3, Docket No. 50-382, License
No. NPF-38
71111.08P Miscellaneous W3F1-2009-0006 RAJ Response to Request for Alternative W3-ISl-006 To 03/19/2009
Extend the Second 10 Year AMSE Code ISI and License
Amendment Request, NPF-38-280 To Support Request for
Alternative W3-ISl-006, Waterford Steam Electric Station,
Unit 3 (Waterford 3), Docket No. 50-382, License No.
71111.08P Miscellaneous W3F1-2010-0002 Request for NRC Alternative to ASME IWE-5521 Regarding 02/09/2010
Post Repair Testing of Waterford 3s Steel Containment
Vessel Opening Waterford Steam, Electric Station, Unit 3,
Docket No. 50-382, License No. NPF-38
71111.08P Miscellaneous W3F1-2011-0041 Request for Alternative to ASME IWE-5221 Regarding Post 07/27/2011
Repair Testing of Waterford 3s Steel Containment Vessel
Opening Waterford Steam Electric Station, Unit 3, Docket
No. 50-382
71111.08P Miscellaneous W3F1-2013-0044 Waterford 3 Request for Alternative W3-ISI-023, ASME 09/26/2013
Code Case N-770-1 Successive Examinations, Waterford
Steam Electric Station, Unit 3/ Docket No. 50-382, License
No. NPF-38
71111.08P Miscellaneous W3F1-2018-0008 Request for NRC Alternative to ASME IWA-5211 Regarding 02/20/2018
Charging Pipe Visual Inspection, Relief Request W3-ISI-030,
Waterford Steam Electric Station, Unit 3 (Waterford 3),
Docket No. 50-382, License No. NPF-38
71111.08P Miscellaneous W3F1-2018-0067 Response to NRC Request for Additional Information 11/19/2018
Regarding Request for Alternative to ASME Code Case
N-770-2, Successive Examinations, Relief Request
W3-ISI-031
71111.08P Miscellaneous W3F1-2019-0017 Closure of Commitment Associated with Inservice Inspection 02/14/2019
Program Alternative WF3-RR-19-1 for Application of
Dissimilar Metal Weld Full Structural Weld Overlay -
Reactor Coolant System Cold Leg Drain Nozzles
71111.08P Miscellaneous Work Order: Single Weld Datasheet (Weld Traveler) for Valve SI-512A 04/20/2022
38
Inspection Type Designation Description or Title Revision or
Procedure Date
528322-01, Map (ISI-V2507), Field Weld FW-7, EC 83354
No. WF3-
528322-01-01
71111.08P Miscellaneous Work Order: Single Weld Datasheet (Weld Traveler) for Valve SI-512A 04/20/2022
528322-01, Map (ISI-V2507), Field Weld FW-8
No. WF3-
5273220-01-01
71111.08P NDE Reports BOP-VE-19-002 Nozzle to Safe-End Circumferential Weld - Weld Overlay 02/07/2019
71111.08P NDE Reports BOP-VE-19-003 Nozzle to Safe-End Circumferential Weld - Weld Overlay 02/07/2019
71111.08P NDE Reports BOP-VE-19-004 Safe End to 2" Pipe Weld - Weld Overlay 02/07/2019
71111.08P NDE Reports BOP-VE-19-005 Safe-End to 2" Pipe Weld - Weld Overlay 02/07/2019
71111.08P NDE Reports BOP-VT-19-005 Reactor Vessel Closure Head Control Element Drive 02/02/2019
Mechanism Nozzles
71111.08P NDE Reports BOP-VT-21-004 Socket Weld CCW Line 3CC1 1/2-46 09/14/2021
71111.08P NDE Reports ISI-VT-17-132 Reactor Vessel Closure Head Control Element Drive 05/15/2017
Mechanism Nozzles 1-87
71111.08P Procedures CEP-BAC-001 Boric Acid Corrosion Control (BACC) Program Plan 2
71111.08P Procedures CEP-NDE-0100 Administration and Control of NDE, Entergy Nuclear 16
Engineering Programs
71111.08P Procedures CEP-NDE-0404 Manual Ultrasonic Examination of Ferritic Piping Welds 9
(ASME XI)
71111.08P Procedures CEP-NDE-0423 Manual Ultrasonic Examination of Austenitic Piping Welds 9
(ASME XI)
71111.08P Procedures CEP-NDE-0493 Manual Ultrasonic Examination of Reactor Coolant Pump 4
Flywheel
71111.08P Procedures CEP-NDE-0641 Liquid Penetrant Examination (PT) for ASME Section XI 9
71111.08P Procedures CEP-NDE-0901 VT-1 Examination, Entergy Nuclear Engineering Programs 6
71111.08P Procedures CEP-NDE-0902 VT-2 Examination, Entergy Nuclear Engineering Programs 10
71111.08P Procedures CEP-NDE-0903 VT-3 Examination, Entergy Nuclear Engineering Programs 6
71111.08P Procedures CEP-NDE-0955 Visual Examination (VE) of Bare-Metal Surfaces, Entergy 308
Nuclear Engineering Programs
71111.08P Procedures CEP-WP-002, Welding Procedure, Specification WPS-SS-8/8-B, Manual 0
Gas Tungsten Arc Welding (GTAW) of P-No. 8 stainless
steels
39
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.08P Procedures CEP-WP-GWS-1 General Welding Standard, ASME/ANSI 6
71111.08P Procedures CEP-WP-IGP-1 Internal Gas Purging 1
71111.08P Procedures EPRI-WOL-PA-1 Procedure for Manual Phased Array Ultrasonic Examination 4
of Weld Overlaid Similar and Dissimilar Metal Welds
71111.08P Procedures EPRI-WOL-PA-1, Procedure for Manual Phased Array Ultrasonic Examination 09/12/2014
Table 1 of Weld Overlaid Similar and Dissimilar Metal Welds
71111.08P Procedures EPRI-WOL-PA-1, Procedure for Manual Phased Array Ultrasonic Examination 09/12/2014
Table 2 of Weld Overlaid Similar and Dissimilar Metal Welds
71111.08P Procedures LMT-07-PAUT- Performance of Phased Array Instrument Screen Height and 1
005 Amplitude Control Linearity Checks
71111.08P Procedures LMT-08-EPRI- Procedure for Manual Phased Array Ultrasonic Examination 0
WOL-1 of Weld Overlaid Similar and Dissimilar Metal Welds
71111.08P Procedures LMT-08-PAUT- 5 Performance of Phased Array Instrument Screen Height and 0
Amplitude Control Linearity Checks
71111.08P Procedures LMT-21-PAUT- Encoded Phased Array Ultrasonic Examination of Small 0
029 Bore Austenitic and Ferritic Socket Welds (= 2.0 OD NPS)
71111.08P Procedures PQR 107 Procedure Qualification Record - Manual Gas Tungsten & 1
Shielded Metal Arc Welding
71111.08P Procedures PQR-170 Procedure Qualification Record - Manual Gas Tungsten & 1
Shielded Metal Arc Welding
71111.08P Self-Assessments LO-HQNLO- 2022 Welding Program Assessment 02/17/2022
2021-19
71111.08P Self-Assessments LO-WLO-2021- Pre-NRC RF24 ISI Activities Self-Assessment Report 10/14/2021
0033 CA-2
71111.08P Work Orders 527322 EC 83354 - REPLACE VALVE SI-512A 04/08/2022
71111.11Q Procedures EN-TQ-100 Operations Training Program Description 1
71111.11Q Procedures OP-010-003 Plant Startup 360
71111.11Q Procedures OP-010-003 Power Operations 341
71111.11Q Procedures OP-901-220 Loss of Condenser Vacuum 305
71111.11Q Procedures OP-901-221 Secondary System Transient 11
71111.11Q Procedures OP-902-000 Standard Post Trip Actions 17
71111.13 Corrective Action CR-WF3-YYYY- 2022-04969
Documents NNNN
Resulting from
40
Inspection Type Designation Description or Title Revision or
Procedure Date
Inspection
71111.13 Procedures OP-010-003 Plant Startup 361
71111.13 Procedures OP-010-004 Power Operations 341
71111.15 Corrective Action CR-WF3-YYYY- 2022-03704, 2022-04112, 2022-04542, 2022-04759
Documents NNNN
71111.15 Engineering EC 93200 Input for Emergency Feedwater Pump AB Differential 06/11/2022
Changes Pressure
71111.15 Engineering EC-92951 Availability of Shutdown Cooling in Modes 5 & 6 05/11/2022
Changes
71111.18 Corrective Action CR-WF3-YYYY- 2022-3704, 2022-4283, 2022-4299, 2022-4314
Documents NNNN
71111.18 Engineering EC 91881 Substitute Core Protection Calculator D RTD Input 03/02/2022
Changes
71111.18 Engineering EC 92952 Temporary Plug for Thermowell 05/17/2022
Changes
71111.18 Engineering EC 93024 Extend EC-91881 until Refuel 25 06/16/2022
Changes
71111.18 Engineering EC 93139 ACCEMTR3B-6 Motor Comparison and Evaluation 06/05/2022
Changes
71111.18 Work Orders 580731
71111.19 Procedures OP-903-033 Cold Shutdown IST Valve Tests 060
71111.19 Procedures OP-903-050 Component Cooling Water and Auxiliary Component Cooling 44
Water Pump and Valve Operability Test
71111.19 Procedures OP-903-092 Main Steam Isolation Actuation Signal Test 302
71111.19 Procedures OP-903-095 ESFAS Subgroup Relay Test - Shutdown 016
71111.19 Work Orders 581904, 581916, 580585
71111.20 Procedures EN-OP-119 Protected Equipment Postings 16
71111.20 Procedures EN-OU-108 Shutdown Safety Management Program (SSMP) 11
71111.20 Procedures OP-010-005 Plant Shutdown 341
71111.20 Procedures OP-010-006 Outage Operations 340
71111.20 Work Orders 52945451, 52962777, 572188
71111.22 Corrective Action CR-WF3-YYYY- 2022-03491, 2022-03799, 2022-1852
Documents NNNN
41
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.22 Procedures OP-903-033 Cold Shutdown IST Valve Tests 59
71111.22 Procedures OP-903-092 Main Steam Isolation Actuation Signal Test 302
71111.22 Procedures OP-903-116 Train B Integrated Emergency Diesel Generator/Engineering 56
Safety Features Test
71111.22 Procedures SEP-APJ-005 Waterford 3 Primary Containment Leakage Rate Testing 10
71111.22 Procedures STA-001-004 Local Leak Rate Test (LLRT) 319
71111.22 Procedures STA-001-006 Leak Rate Testing 305
71111.22 Work Orders 52952716, 52951975
71124.01 Corrective Action CR-WF3-YYYY- 2021-00608, 2021-00636, 2021-01493, 2021-03064,
Documents XXXX 2021-04681, 2021-04685, 2021-04952, 2021-05400,
2021-06456
71124.01 Corrective Action CR-WF3-YYYY- 2022-00556, 2022-01496, 2022-01953, 2022-02217,
Documents XXXX 2022-02542
71124.01 Corrective Action CR-WF3-YYYY- 2022-03170, 2022-03171, 2022-03174, 2022-03226,
Documents XXXX 2022-03290, 2022-03293, 2022-03295, 2022-03296,
Resulting from 2022-03297, 2022-03298, 2022-04917, 2022-04918,
Inspection 2022-04920, 2022-04921, 2022-04922, 2022-04923,
2022-04924
71124.01 Miscellaneous Nuclear Daily Report 04/12/2022
71124.01 Miscellaneous Hot Spot Tracking Log 04/13/2022
71124.01 Miscellaneous Attachment 5 to LHRA/VHRA Key Log 04/12/2022
71124.01 Miscellaneous HP-SM-076 +46 Fuel Handling Building Spent Fuel Pool Inventory 03/24/2022
71124.01 Procedures EN-RP-100 Radiation Worker Expectations 12
71124.01 Procedures EN-RP-101 Access Control for Radiologically Controlled Areas 15
71124.01 Procedures EN-RP-102 Radiological Control 7
71124.01 Procedures EN-RP-104 Personnel Contamination Events 11
71124.01 Procedures EN-RP-105 Radiological Work Permits 19
71124.01 Procedures EN-RP-106 Radiological Survey Documentation 7
71124.01 Procedures EN-RP-110 ALARA Program 14
71124.01 Procedures EN-RP-121 Radioactive Material Control 17
71124.01 Procedures EN-RP-123 Radiological Controls for Highly Radioactive Objects 1
71124.01 Procedures EN-RP-143 Source Control 14
42
Inspection Type Designation Description or Title Revision or
Procedure Date
71124.01 Radiation WF3-2203-00161 +15 OA - Low Level Radwaste Storage Building 03/22/2022
Surveys
71124.01 Radiation WF3-2204-00087 -4 Reactor Containment Building 04/03/2022
Surveys
71124.01 Radiation WF3-2204-00206 Refuel 24 RP Bi-Weekly Survey +21 Reactor Containment 04/06/2022
Surveys Building
71124.01 Radiation WF3-2204-00209 Bi-Weekly -4 Reactor Containment Building 04/06/2022
Surveys
71124.01 Radiation WF3-2204-00234 -11 Reactor Containment Building Overhead Scaffold 04/07/2022
Surveys Support
71124.01 Radiation WF3-2204-00367 -4 Reactor Containment Building 04/11/2022
Surveys
71124.01 Radiation WF3-2204-00385 +21 Reactor Containment Building Pressurizer 04/11/2022
Surveys
71124.01 Radiation Work RWP 2021-0002 Operations Personnel to Perform Various Activities in 1
Permits (RWPs) Radiologically Controlled Areas
71124.01 Radiation Work RWP 2021-0054 Safety Injection Tank Sampling, Personnel/Escape Interlock 1
Permits (RWPs) Door Tests, Minor Maintenance, Inspections and Valve-Line
Ups, Radiation Protection Job Coverage into posted Locked
71124.01 Radiation Work RWP 2022-0610 Erect/Dismantle Scaffolding in the Reactor Containment 0
Permits (RWPs) Building
71124.01 Radiation Work RWP 2022-0627 Maintenance Valve Work Inside the Reactor Containment 0
Permits (RWPs) Building
71124.01 Radiation Work RWP 2022-0635 Radiography including Radiation Protection Boundary 0
Permits (RWPs) Guards
71124.01 Radiation Work RWP 2022-0702 Reactor Disassembly Activities 0
Permits (RWPs)
71124.01 Radiation Work RWP 2022-0708 Remove and Replace ICIs 0
Permits (RWPs)
71124.01 Radiation Work RWP 2022-0805 Tours and Inspections Outside the Reactor Containment 0
Permits (RWPs) Building
71124.01 Self-Assessments LO-WLO-2021- Radiological Hazard Assessment and Exposure Controls (IP 11/29/2021
00019 71124.01)
43
Inspection Type Designation Description or Title Revision or
Procedure Date
71124.03 Corrective Action CR-WF3-YYYY- 2021-00537, 2021-00657, 2021-02666, 2021-04975,
Documents XXXX 2021-05769, 2021-05898, 2021-06399, 2021-07131
71124.03 Corrective Action CR-WF3-YYYY- 2022-00421
Documents XXXX
71124.03 Miscellaneous Inspection and Maintenance of Respiratory Protection 03/10/2021
Equipment - March 2021
71124.03 Miscellaneous Inspection and Maintenance of Respiratory Protection 01/27/2022
Equipment - January 2022
71124.03 Miscellaneous Inspection and Maintenance of Respiratory Protection 12/30/2021
Equipment - December 2021
71124.03 Miscellaneous Watford 3 Personnel- FireHawk Respirator Qualifications 03/23/2022
71124.03 Miscellaneous EN-RP-502, Annual Respiratory Protection Equipment Inventory & 12/12/2021
Attachment 9.5 Inspection - 2021
71124.03 Miscellaneous EN-RP-503, Total Effective Dose Equivalent/ALARA Evaluation for RWP 12/31/2021
Attachment 9.11 2022-0615
71124.03 Miscellaneous EN-RP-503, Total Effective Dose Equivalent/ALARA Evaluation for RWP 12/31/2021
Attachment 9.12 2022-0627
71124.03 Miscellaneous EN-RP-503, Annual Respiratory Protection Equipment Inventory & 12/12/2021
Attachment 9.5 Inspection - Security 2021
71124.03 Procedures EN-RP-131 Air Sampling 17
71124.03 Procedures EN-RP-203 Dose Assessment 10
71124.03 Procedures EN-RP-501 Respiratory Protection Program 7
71124.03 Procedures EN-RP-502 Inspection and Maintenance of Respiratory Protection 10
Equipment
71124.03 Procedures EN-RP-502-01 FireHawk M7 SCBA 3
71124.03 Procedures EN-RP-502-03 AirHawk II SCBA 0
71124.03 Procedures EN-RP-503 Selection, Issue and Use of Respiratory Protection 8
Equipment
71124.03 Procedures EN-RP-504 Breathing Air 4
71124.03 Procedures EN-RP-505 PortaCount Respirator Fit Testing 9
71124.03 Procedures HP-002-603 Inspection and Use of Control Room EBA Filtration Panel 12
71124.03 Procedures MM-003-045 Control Room Air Conditioning System Surveillance 316
71124.03 Procedures MM-003-046 Controlled Ventilation Area System Surveillance 311
71124.03 Procedures MM-007-034 RAB Normal Ventilation System Exhaust Filter Test 4
44
Inspection Type Designation Description or Title Revision or
Procedure Date
71124.03 Radiation WF3-2204-00447 +46 foot elevation- Reactor Containment Building - survey 04/13/2022
Surveys performed for welders to grind out and remove RCSV-3184,
RCSV-1017, RCSV-1014, & RCSV-1015
71124.03 Radiation WF3-2204-00468 +46 foot elevation- Reactor Containment Building- survey of 04/13/2022
Surveys pipe tent on south west wall of cavity
71124.03 Radiation WF3-2204-00481 +46 foot elevation- Reactor Containment Building - survey 04/13/2022
Surveys performed to down post fire protection tent
71124.03 Radiation WF3-2204-00489 +46 foot elevation - Reactor Containment Building - survey 04/13/2022
Surveys performed for completion of grinding before weld of new
valves for RCS line takes place
71124.03 Radiation WF3-AS-041322- Air sample for RWP 2022-0627 during the removal & grind 04/13/2022
Surveys 0103 out valve: RCISV 1014, RCISV 1015, RCISV 1017
71124.03 Radiation WF3-AS-041322- Air sample for RWP 2022-0627 during grind out valves: RC- 04/13/2022
Surveys 0105 1014, RC-1015, RC-1017, RC-3184
71124.03 Radiation WF3-AS-041322- Air sample for RWP 2022-0627 during removal/replace RC 04/13/2022
Surveys 0110 valves
71124.03 Radiation WF3-AS-041722- Pzr Room - cut out heaters 04/17/2022
Surveys 0238
71124.03 Radiation WF3-AS-041722- Lapel air sample data 04/17/2022
Surveys 0246
71124.03 Radiation WF3-AS-042222- Validation of A/S PZR Cut out heater 04/22/2022
Surveys 0581
71124.03 Radiation Work RWP 2022-0615 Refuel 24 - Remove/Replace Pressurizer Heaters 0, 1, 2, 3, 4,
Permits (RWPs) 5
71124.03 Radiation Work RWP 2022-0627 Refuel 24 - Maintenance Valve Work inside the Reactor 0
Permits (RWPs) Containment Building
71124.04 Calculations Internal Dose Assessment Models for 2 worker uptakes 04/27/2022
71124.04 Calculations Internal Dose Assessment Model for 2 worker uptakes 04/21/2022
71124.04 Miscellaneous Whole Body Counts for 8 workers 04/19/2022
71124.04 Miscellaneous Whole Body Counts for 5 workers 04/20/2022
71124.04 Miscellaneous Whole Body Counts for 4 workers 04/21/2022
71124.04 Miscellaneous Whole Body Counts for 3 workers 04/22/2022
71124.04 Miscellaneous Whole Body Counts for 1 worker 04/23/2022
71124.04 Miscellaneous Whole Body Counts for 2 workers 04/24/2022
45
Inspection Type Designation Description or Title Revision or
Procedure Date
71124.04 Miscellaneous Apex-InVivo Nuclide Library Report: STDNPPNA.NLB -
Basic NaI NPP and PeakSearch.NLB (STDNPPGE.NLB) -
71124.04 Miscellaneous Whole Body Counts for 8 workers 04/18/2022
71124.04 Miscellaneous LIMS L95908 Teledyne Brown Engineering - Environmental Services: 05/05/2022
Report of Analysis
71124.06 Calculations EN-RW-104, 10 CFR Part 61 Waste Stream Screening and Evaluation 03/22/2021
Attachment 9.1
71124.06 Corrective Action Condition Report 2019-07276, 2019-08771, 2020-00424, 2020-01397,
Documents (CR-WF3-XXXX- 2020-01459, 2020-01747, 2020-01806, 2020-02513,
XXXXX) 2020-03066, 2020-03450, 2020-05459, 2020-05891,
2020-06860, 2021-01378, 2021-02435, 2021-03399,
2021-03399, 2021-04183, 2021-04525, 2021-05562,
2021-05563, 2021-06329, 2021-06506, 2022-00374,
2022-01581, 2022-02066, 2022-02145
71124.06 Miscellaneous Annual Dose Summary for 2019, 2020, and 2021 N/A
71124.06 Miscellaneous Annual Release Summary for 2019, 2020, and 2021 N/A
71124.06 Procedures CE-002-016 Maintaining Gaseous Waste Management System 310
71124.06 Procedures CE-002-018 Monitoring Liquid Waste Management 007
71124.06 Procedures CE-003-300 Preparation of Liquid Samples for Radiological Chemical 013
Analysis
71124.06 Procedures CE-003-509 Routine Filter Replacement and Grab Sampling on 309
Particulate Iodine Gas Monitors and Wide Range Gas
Monitors
71124.06 Procedures CE-003-510 Technical Specification Action Statement Compliance 014
71124.06 Procedures CE-003-512 Liquid Radioactive Waste Release Permit (Manual) 002
71124.06 Procedures CE-003-513 Gaseous Radioactive Waste Release Permit (Manual) 304
71124.06 Procedures CE-003-514 Liquid Radioactive Waste Release Permit 304
71124.06 Procedures CE-003-515 Gaseous Radioactive Waste Release Permit 305
71124.06 Procedures CE-003-700 General Grab Sampling Techniques 319
71124.06 Procedures UNT-005-014 Offsite Dose Calculation Manual 308
71124.06 Self-Assessments QA-2/6-2021-W3- Quality Assurance Audit Report: Combined Chemistry, 10/05/2021
1 Effluents, and Environmental Monitoring
71124.07 Corrective Action Condition Report 2019-07315, 2019-07322, 2019-08536, 2019-08995,
46
Inspection Type Designation Description or Title Revision or
Procedure Date
Documents (CR-WF3-XXXX- 2020-00249, 2020-01272, 2020-02019, 2020-03175,
XXXXX) 2020-04335, 2020-06097, 2020-06639, 2020-07123,
2021-00851, 2021-00958, 2021-02095, 2021-03665,
2021-03668, 2021-04115, 2021-04534, 2022-00086,
2022-00306, 2022-03045, 2022-04529
71124.07 Miscellaneous Energy Nuclear / Waterford-3 Station Groundwater 06/12/2019
Protection Plan
71124.07 Miscellaneous 2020 Land Use Census Data 10/12/2020
71124.07 Miscellaneous Annual Quality Assurance Status Report 03/16/2022
71124.07 Miscellaneous CR-WF3-2020- 10 CFR 50.75(g)(1) Leak/Spill Record - West Side of 10/24/2020
06097 Service Building Warehouse
71124.07 Miscellaneous CR-WF3-2021- 10 CFR 50.75(g)(1) Leak/Spill Record - Fire Protection Pit 07/08/2021
03668 17
71124.07 Miscellaneous W3F1-2020-0025 2019 Annual Radiological Environmental Operating Report 04/27/2020
71124.07 Miscellaneous W3F1-2020-0026 2019 Annual Radioactive Effluent Release Report 04/27/2020
71124.07 Miscellaneous W3F1-2021-0036 2020 Annual Radiological Environmental Operating Report 04/29/2021
71124.07 Miscellaneous W3F1-2021-0037 2020 Annual Radioactive Effluent Release Report 04/29/2021
71124.07 Miscellaneous W3F1-2022-0027 2021 Annual Radioactive Effluent Release Report 04/26/2022
71124.07 Miscellaneous W3F1-2022-0028 2021 Annual Radiological Environmental Operating Report 04/28/2022
71124.07 Procedures CE-003-522 Meteorological Data Collection and Processing 7
71124.07 Procedures CE-003-523 Meteorological Monitoring Program 2
71124.07 Procedures EN-CY-108 Monitoring of Nonradioactive Systems 7
71124.07 Procedures EN-CY-111 Radiological Groundwater Protection Program 12
71124.07 Procedures EN-CY-127 Land Use Census 2
71124.07 Procedures EN-CY-130 Radiological Environmental Monitoring Program 0
71124.07 Procedures EN-CY-132 Annual Radiological Environmental Operating Report 1
71124.07 Procedures EN-RP-113 Response to Contaminated Spills/Leaks 11
71124.07 Procedures OP-903-001 Technical Specification Surveillance Logs 98
71124.07 Procedures UNT-005-014 Offsite Dose Calculation Manual 309
71124.07 Procedures UNT-005-014 Offsite Dose Calculation Manual 308
71124.07 Self-Assessments LO-HQNLO- Groundwater Protection Program Self-Assessment 10/27/2021
2021-00024
71124.07 Self-Assessments LO-WLO-2021- Pre-NRC Assessment of Radiation Safety Inspection Criteria 11/03/2021
47
Inspection Type Designation Description or Title Revision or
Procedure Date
00018
71124.07 Work Orders WF3-398323-01 EM MTWR0001-A, Primary Met Tower 09292015
71124.07 Work Orders WF3-52977514- Calibrate Primary Met Tower IAW MI-003-395 01/27/2022
01/02
71151 Procedures EN-LI-114 Regulatory Performance Indicator Process 19
71152A Corrective Action CR-WF3-YYYY- 2021-02879
Documents NNNN
71152A Drawings G309 Phasing and Voltage Vector Diagram 4
71152A Engineering EC 41846 Isolated Phase Bus Transition 02/07/2013
Changes
71152A Work Orders 52910298, 563568, 563628, 563629, 563631
48