IR 05000382/2023002

Integrated Inspection Report 05000382/2023002

ML23216A106
Person / Time
Site:	Waterford
Issue date:	08/08/2023
From:	John Dixon NRC/RGN-IV/DORS/PBD
To:	Sullivan J Entergy Operations
References
IR 2023002
Download: ML23216A106 (1)

Text

August 08, 2023

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 - INTEGRATED INSPECTION REPORT 05000382/2023002

Dear Joseph Sullivan:

On June 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Waterford Steam Electric Station, Unit 3. On July 31, 2023, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

No NRC-identified or self-revealing findings were identified during this inspection.

A licensee-identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as a non-cited violation (NCV)

consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Waterford Steam Electric Station, Unit 3. 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 08/08/23 John L. Dixon, Jr., Chief Reactor Projects Branch D Division of Operating Reactor Safety Docket No. 05000382 License No. NPF-38

Enclosure:

As stated

Inspection Report

Docket Number: 05000382 License Number: NPF-38 Report Number: 05000382/2023002 Enterprise Identifier: I-2023-002-0009 Licensee: Entergy Operations, Inc.

Facility: Waterford Steam Electric Station, Unit 3 Location: Killona, LA 70057 Inspection Dates: April 1, 2023, to June 30, 2023 Inspectors: D. Childs, Resident Inspector S. Hedger, Sr Emergency Preparedness Inspector A. Patz, Senior Resident Inspector H. Strittmatter, Sr Emergency Preparedness Inspector T. Weir, Physical Security Inspector Approved By: John L. Dixon, Jr., Chief Reactor 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. A licensee-identified non-cited violation is documented in report section: 71111.0

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000382/2022-003-00 Operation Prohibited by 71153 Closed Technical Specifications Due to Radiation Monitor Calibration Error LER 05000382/2022-004-00 Regarding Operation 71153 Closed Prohibited by Technical Specifications Due to Inadequate Radiation Monitor Calibration Procedures LER 05000382/2022-006-00 Non-Compliance with 71153 Closed Technical Specifications Due to Incorrect Conversion Factors in Plant Stack and Fuel Handling Building Radiation Monitors LER 05000382/2023-001-00 Non-Compliance with 71153 Closed Technical Specifications Due to pico-ammeter circuit board fluctuations in Containment High Range Radiation Monitor B

PLANT STATUS

Unit 3 operated at or near rated thermal power for the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

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 hurricane season for the following systems: emergency diesel generator system, ultimate heat sink, emergency feedwater system, and startup transformers on May 5, 2023.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) startup transformer A and associated electrical equipment following unplanned loss of startup transformer B on April 6, 2023

(2) emergency diesel generator A while emergency diesel generator B was inoperable due to planned maintenance on May 23, 2023

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 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 16A-001, emergency diesel fuel oil feed tank A space on April 20, 2023

(2) fire areas RAB 15-001 and RAB 16-001, emergency diesel generator A and B rooms on April 24, 2023

(3) fire areas RAB 8A-001 and RAB 8B-001, switchgear A and switchgear B rooms on May 8, 2023

(4) fire area RAB 40-001, diesel storage tank A space on May 25, 2023

(5) fire area RAB 41-001, diesel storage tank B space on May 25, 2023

(6) fire area RAB 23-001, corridor, concentrators, and hold-up rooms on June 12, 2023

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire drill in the +55.00' elevation of the reactor auxiliary building involving a cable tray fire in electrical penetration room B on June 13, 2023

71111.06 - Flood Protection Measures

Flooding Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated internal flooding mitigation protections in:

Zone 11 - emergency diesel generator room B Zone 37 - diesel fuel oil feed tank room A Zone 38 - diesel fuel oil feed tank room B

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 emergency diesel generator overspeed testing on May 24, 2023.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated a licensed operator requalification exam on May 1, 2023.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) component cooling water train A following failure of dry cooling tower fan 9B due to water in-leakage into motor bearing on April 4, 2023

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:

(1) emergency diesel generator B from May 22 to May 25, 2023

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) yellow risk due to an offsite electrical grid spike isolating startup transformer B and generator output breaker B on April 6, 2023

(2) elevated green risk due to a load-balancing authority declaration of conservative operations to ensure grid stability on May 16, 2023

(3) yellow risk due to planned outage of auxiliary feedwater pump and heavy switchyard work from June 12-15, 2023

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (1 Sample)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) emergency diesel generator B following blown fuse replacement on May 26, 2023

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

(1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) temporary modification EC54002032 to decrease core protection calculator A sensitivity due to degrading excore nuclear instrument on May 24, 2023

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system

operability and/or functionality: Post-Maintenance Testing (PMT) (IP Section 03.01)

(1) containment spray pump A following planned maintenance on April 12, 2023

(2) emergency feedwater pump A after motor oil change and calibration of pressure discharge sensor on April 13, 2023

(3) inlet damper hydramotor to the train A control room air handling unit after motor refurbishment on May 9, 2023

(4) containment fan coolers A and C following corrective maintenance on train A temperature control valve on May 11, 2023

(5) shield building ventilation train B and reactor auxiliary building normal ventilation train B following post-maintenance test failures on May 18, 2023

Surveillance Testing (IP Section 03.01) (1 Sample)

(1) emergency diesel generator B overspeed trip testing on May 24, 2023

Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)

(1) operational testing of the FLEX N and N+1 diesel fuel oil transfer pumps on May 16, 2023

71114.01 - Exercise Evaluation

Inspection Review (IP Section 02.01-02.11) (1 Partial)

(1) (Partial)

The inspectors evaluated the biennial emergency plan exercise conducted on June 21, 2023. However, as of the end of the 2nd quarter 2023, the licensee had not completed its critique process for the exercise. As such, the inspectors had not completed the full evaluation of the exercise and the critique process. The inspectors will complete the inspection in the 3rd quarter, and the results of the inspection will be documented in NRC Inspection Report 05000382/2023003.

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors evaluated changes to the Alert/Notification System (ANS) Design Report, revision 9 (effective February 13, 2023). This involved review of a selection of additional licensee screening and evaluation documentation. These evaluations and reviews do not constitute NRC approval.

71114.08 - Exercise Evaluation - Scenario Review

Inspection Review (IP Section 02.01 - 02.04) (1 Sample)

(1) The inspectors reviewed the licensee's preliminary exercise scenario that was submitted to the NRC on April 24, 2023 (ML23114A222), for the exercise scheduled to occur on June 21, 2023. The inspectors discussed the preliminary scenario with J. Lewis, Manager, Emergency Preparedness, and other members of the emergency preparedness staff on May 18, 2023. The inspectors' review does not constitute NRC approval of the scenario.

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) April 1, 2022, through March 31, 2023

MS06: Emergency AC Power Systems (IP Section 02.05) (1 Sample)

(1) April 1, 2022, through March 31, 2023

MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)

(1) April 1, 2022, through March 31, 2023

EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)

(1) October 1, 2022, through March 31, 2023 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13)

(1 Sample)

(1) October 1, 2022, through March 31, 2023 EP03: Alert and Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)

(1) October 1, 2022, through March 31, 2023

71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP section 03.02)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 05000382/2022-003-00, Operation Prohibited by Technical Specifications Due to Radiation Monitor Calibration Error (ADAMS Accession No. ML22164B005)

LER 05000382/2022-004-00, Operation Prohibited by Technical Specifications Due to Inadequate Radiation monitor Calibration Procedures (ADAMS Accession No.

ML22174A429)

LER 05000382/2022-006-00, Non-Compliance with Technical Specifications Due to Incorrect Conversion Factors in Plant Stack and Fuel Handling Building Radiation Monitors (ADAMS Accession No. ML22311A471)

LER 05000382/2023-001-00, Non-Compliance with Technical Specifications due to pico-ammeter circuit board fluctuations in Containment High Range Radiation Monitor B (ADAMS Accession No. ML23121A120)

The inspection conclusions associated with these LERs are documented in Inspection Report 05000382/2023040 (ADAMS Accession No. ML23192A764).

These LERs are closed.

INSPECTION RESULTS

Licensee-Identified Non-Cited Violation 71111.05 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: The Waterford Steam Electric Station, Unit 3 Renewed Facility Operating License, section 2.C(9), requires that the licensee implement and maintain in effect all provisions of the approved fire protection program. The approved fire protection program as described by procedure EN-DC-161, Control of Combustibles, revision 24, required that continuous administrative fire watches be established prior to the introduction of any non-exempt transient combustible materials into designated Level 1 areas.

Contrary to the above, from March 11 to April 25, 2022, the licensee failed to establish fire watches in accordance with the approved fire protection program. Specifically, the licensee failed to establish continuous administrative fire watches in Level 1 designated areas containing non-exempt transient combustible materials. On April 25, 2022, the licensee entered condition report CR-WF3-2022-03147 into their corrective action program which states none of the required administrative continuous fire watches or hourly fire watches were found on station. These watches were required for transient combustible permits that have been open as early as March 11, 2022, and were still in place that day. The condition report notes four fire areas with Level 1 combustible control zones, as defined in attachment 4 of EN-DC-161, where fire watches were not identified:

- RAB 7, relay room

- RAB 8A, switchgear room A

- RAB 8B, switchgear room B

- RCB, reactor containment building Section 7.5 of EN-DC-161, requires a continuous fire watch to be established in accordance with procedure EN-OP-139, Fire Watch Program, revision 6, as a minimum compensatory action prior to the introduction of any non-exempt transient combustible materials into designated Level 1 areas. The inspectors reviewed this condition report and identified a partial loss of fire detection and suppression from April 14 to 16, 2022, for fire zones RAB 8A and RAB 8B, that did not appear to have appropriate continuous fire watches. The inspectors requested documentation from the licensee to validate that these fire watches were performed. No conclusive documentation was found that demonstrated the fire watches were performed.

Significance/Severity: Green. The inspectors assessed the significance of the finding using IMC 0609.04, Initial Characterization of Findings, and IMC 0609, appendix F, attachment 1, and determined the finding to be of very low safety significance (Green) because the affected areas were protected with automatic detection and suppression.

Corrective Action References: CR-WF3-2022-03147

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On May 18, 2023, the inspectors presented the emergency preparedness exercise scenario inspection results to G. Taylor, Senior Project Manager, Emergency Preparedness, and other members of the licensee staff.

On June 29, 2023, the inspectors presented the EP performance indicator verification and emergency plan change review inspection results to N. Lawless, Director, Maintenance, and other members of the licensee staff.

On July 17, 2023, the inspectors presented the integrated inspection first exit inspection results to J. Sullivan, Site Vice President, and other members of the licensee staff.

On July 31, 2023, the inspectors presented the integrated inspection results to J. Sullivan Site Vice President and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Procedures EN-FAP-EP-010 Severe Weather Response 9

OP-003-024 Sump Pump Operations 320

OP-901-521 Severe Weather and Flooding 341

71111.04 Procedures OP-006-010 TEDG Operations 5

OP-009-002 Emergency Diesel Generator 360

71111.05 Drawings 5817-11881 Fire Detection System Device List 9

G-FP0021 Fire Detection System Raceway and Equipment Layout 0

Reactor Auxiliary Building Elevation Plus 21 Feet

Fire Plans RAB 15-001 Emergency Diesel Generator 3B Room Fire Plan 9

RAB 16-001 Emergency Diesel Generator 3A Room Fire Plan 12

RAB 16A-001 Emergency Diesel Oil Feed Tank A Space Fire Plan 6

RAB 23-001 Corridor, Concentrators, and Hold-up Rooms 9

RAB 40-001 Diesel Storage Tank A 6

RAB 41-001 Diesel Storage Tank B 6

RAB 5-001 Electrical Penetration Room B 10

RAB 8A-001 Switchgear Room A 13

RAB 8B-001 Switchgear Room B 14

71111.06 Engineering MNQ3-5 Flooding Analysis Outside Containment 6

Evaluations

71111.11Q Procedures ME-004-021 Emergency Diesel Generator 40

OP-009-002 Emergency Diesel Generator 360

OP-901-111 Reactor Coolant System Leak 307

OP-901-112 Charging or Letdown Malfunction 11

OP-902-000 Standard Post Trip Actions 17

71111.12 Corrective Action CR-WF3-YYYY- 2023-01697, 2023-01772, 2023-01788

Documents NNNN

Procedures ME-004-021 Emergency Diesel Generator 40

Work Orders 541972, 564250, 565306, 567406, 571240, 52987991,

2993356

71111.13 Corrective Action CR-WF3-YYYY- 2023-13734

Documents NNNN

Inspection Type Designation Description or Title Revision or

Procedure Date

Procedures EN-WM-104 On Line Risk Assessment 26

71111.15 Corrective Action CR-WF3-YYYY- 2023-13411

Documents NNNN

71111.18 Corrective Action CR-WF3-YYYY- 2023-02209, 2023-02238, 2023-13225

Documents NNNN

Engineering EC 54002032 ENI Channel A Middle Detector Database Update 0

Changes EC 54002750 ENI Channel A Subchannel Gain Change 0

Procedures NE-002-012 Linear Power Single Channel Adjustment for Excore 2

Detector Drift

NE-006-001 Addressable Constant Administrative Controls 304

71111.24 Corrective Action CR-WF3-YYYY- 2023-01874, 2023-02124, 2023-13169, 2023-13192,

Documents NNNN 2023-13265, 2023-13293

Corrective Action CR-WF3-YYYY- 2023-01859, 2023-01909, 2023-01979

Documents NNNN

Resulting from

Inspection

Procedures FIG-001 FLEX Implementing Guideline - Extended Loss of AC Power 9

FSG-005 Initial Assessment and FLEX Equipment Staging 15

ME-004-021 Emergency Diesel Generator 39

MM-007-029 Hydramotors Model NH96 B1 308

OP-008-008 Shield Building Ventilation 12

OP-903-035 Containment Spray Pump Operability Check 34

OP-903-046 Emergency Feed Pump Operability Check 325

Work Orders 594839, 54002015, 582788, 53026685, 52939414

71114.01 Corrective Action CR-WF3-YYYY- 2021-02170, 2021-05108, 2022-01454, 2022-01513,

Documents NNNN 2022-03563, 2022-07220, 2023-01506, 2023-02182,

23-02225, 2023-13669, 2023-13671

Procedures EN-EP-313 Offsite Dose Assessment using the Unified RASCAL 4

Interface

EN-EP-603 Emergency Notifications 1

EN-EP-609 Emergency Operations Facility (EOF) Operations 7

EN-EP-613 Declared Emergency Recovery and Re-entry 1

EP-001-001 Recognition and Classification of Emergency Conditions 36

Inspection Type Designation Description or Title Revision or

Procedure Date

EP-001-020 Alert 311

EP-002-010 Notifications and Communications 317

EP-002-050 Offsite Dose Assessment 309

EP-002-052 Protective Action Guidelines 27

EP-002-102 Emergency Operations Facility (EOF) Activation, Operation, 310

and Deactivation

OP-901-130 Reactor Coolant Pump Malfunction 12

OP-901-510 Component Cooling Water System Malfunction 306

OP-902-000 Standard Post Trip Actions 17

OP-902-002 Loss of Coolant Accident Recovery 21

OP-902-009 Standard Appendices 323

Work Orders Work Order 560193

Number

71114.04 Corrective Action CR-WF3-YYYY- 2023-13931

Documents NNNN

Resulting from

Inspection

Miscellaneous 10CFR50.54(Q)(2) Review for EN-EP-609 Revision 7 04/24/2023

10CFR50.54(Q)(2) Review for EPP-424 Revision 22 04/13/2023

10CFR50.54(Q)(2) Review for EPP-422 Revision 16 04/13/2023

10CFR50.54(Q)(3) Screening for Alert/Notification System 02/13/2023

Design Report, Revision 9

W3F1-2023-0019 Emergency Preparedness Updated Alert/Notification 02/20/2023

System (ANS) Design Report, Revision 9, September 2022;

Waterford Steam Electric Station, Unit 3; Docket No. 50-382;

Renewed Facility Operating License No. NPF-38

Procedures Updated Alert/Notification System Design Report 9

EN-EP-305 Emergency Planning 10CFR50.54(q) Review Program 8

EN-EP-609 Emergency Operations Facility (EOF) Operations 7

EN-EP-609 Emergency Operations Facility (EOF) Operations 6

EPP-422 Siren and Helicopter Warning System Maintenance 15, 16

EPP-424 Siren Testing and Siren System Administrative Controls 21, 22

71114.08 Miscellaneous W3F1-2019-0072 Emergency Preparedness Full Participation Exercise 09/19/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

Scenario, Waterford Steam Electric Station, Unit 3

(Waterford 3); Docket No. 50-382; Renewed Facility

Operating License No. NPF-38

W3F1-2021-0062 Emergency Preparedness Full Participation Exercise 08/24/2021

Scenario, Waterford Steam Electric Station, Unit 3

(Waterford 3); Docket No. 50-382; Renewed Facility

Operating License No. NPF-38

W3F1-2023-0034 Emergency Preparedness Full Participation Exercise 04/24/2023

Scenario, Waterford Steam Electric Station, Unit 3; Docket

No. 50-382; Renewed Facility Operating License No. NPF-

Procedures EN-EP-603 Emergency Notifications 1

EN-EP-604 Emergency Classifications 1

EP-001-001 Recognition and Classification of Emergency Conditions 36

EP-002-052 Protective Action Guidelines 27

71151 Corrective Action

Documents CR-WF3-YYYY- 2022-07880, 2023-00128, 2023-0738

NNNN

Corrective Action

Documents CR-WF3-YYYY- 2023-13798, 2023-14046

Resulting from NNNN

Inspection

Miscellaneous Entergy Operations, Inc., Waterford-3 Steam Electric 9

Station, Updated Alert/Notification System Design Report

1st Quarter 2023 Red Team EOF Tabletop, 02/01/2023 02/08/2023

1st Quarter 2023 Orange Team EOF Tabletop, 02/08/2023 02/09/2023

1st Quarter 2023 Blue Team EOF Tabletop, 02/15/2023 02/16/2023

WF3 03-21-23 Orange Team Site Drill - DEP Package 03/27/2023

WF3 (Red Team) 2nd 4th Quarter 2022 EOF Tabletop, 11/10/2022

11/09/2022

WF3 2022 2nd 4th Quarter (Orange Team) EOF Tabletop, 11/17/2022

11/16/2022

WSXM-LOR- 2022 Cycle 5 EP DEP Evaluation 0

25DEP

Inspection Type Designation Description or Title Revision or

Procedure Date

WSXM-LOR-231 2023 Cycle 1 Simulator Exam 0

EXM

Procedures EN-FAP-EP-005 Emergency Preparedness Performance Indicators 17

EN-LI-114 Regulatory Performance Indicator Process 21

EPP-424 Siren Testing and Siren System Administrative Controls 22

14