IR 05000382/2018004: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(Created page by program invented by StriderTol)
 
(5 intermediate revisions by the same user not shown)
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:February 5, 2019
{{#Wiki_filter:ary 5, 2019


==SUBJECT:==
==SUBJECT:==
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED INSPECTION REPORT 05000382/201 8 00 4
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED INSPECTION REPORT 05000382/2018004


Dear Mr. Dinelli
==Dear Mr. Dinelli:==
: On December 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford Steam Electric Station, Unit On January 15, 2019
On December 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford Steam Electric Station, Unit 3. On January 15, 2019, the NRC inspectors discussed the results of this inspection with you and other members of your staff.
, the NRC inspectors discussed the results of this inspection with you and other members of your staf The results of this inspection are documented in the enclosed repor NRC inspectors documented one finding of very low safety significance (Green) in this repor This finding involved a violation of NRC requirement The NRC is treating this violation as non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Polic If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Waterford Steam Electric Station, Unit If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 3 0 days of the date of this inspection report, with the basis for your disagreement, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Waterford Steam Electric Station, Unit J. Dinelli 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 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding.


"
The results of this inspection are documented in the enclosed report.
 
NRC inspectors documented one finding of very low safety significance (Green) in this report.
 
This finding involved a violation of NRC requirements. The NRC is treating this violation as non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
 
If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Waterford Steam Electric Station, Unit 3.
 
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Waterford Steam Electric Station, Unit 3. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.


Sincerely,
Sincerely,
/RA/ Neil O'Keefe, Chief Project Branch D Division of Reactor Projects Docket No. 50-382 License No. NPF-38 Enclosure:
/RA/
Neil OKeefe, Chief Project Branch D Division of Reactor Projects Docket No. 50-382 License No. NPF-38 Enclosure:
Inspection Report 05000382/2018004 w/Attachment:
Inspection Report 05000382/2018004 w/Attachment:
Documents Reviewed
Documents Reviewed


Enclosure U.S. NUCLEAR REGULATORY COMMISSION
U.S. NUCLEAR REGULATORY COMMISSION


==Inspection Report==
==Inspection Report==
Docket Number:
Docket Number: 05000382 License Number: NPF-38 Report Number: 05000382/2018004 Enterprise Identifier: I-2018-004-002 Licensee: Entergy Operations, Inc.
05000382 License Number:
NPF-38 Report Number:
05000382/201800 4 Enterprise Identifier:
I-2018-004-002 Licensee: Entergy Operations, In Facility: Waterford Steam Electric Station, Unit 3 Location: Killona, Louisiana Inspection Dates:
October 1, 2018 to December 31, 2018 Inspectors:
F. Ramírez, Senior Resident Inspector C. Speer, Resident Inspector L. Newman, Resident Inspector J. Dixon, Senior Project Engineer Approved By:
Neil O'Keefe Chief , Project Branch D Division of Reactor Projects


2
Facility: Waterford Steam Electric Station, Unit 3 Location: Killona, Louisiana Inspection Dates: October 1, 2018 to December 31, 2018 Inspectors: F. Ramírez, Senior Resident Inspector C. Speer, Resident Inspector L. Newman, Resident Inspector J. Dixon, Senior Project Engineer Approved By: Neil OKeefe Chief, Project Branch D Division of Reactor Projects Enclosure


=SUMMARY=
=SUMMARY=
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensee's performance by conducting an integrated inspection at Waterford Steam Electric Station, Unit in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRC's program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
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 NRC-identified is summarized in the table below.
 
A NRC-identified is summarized in the table below.
 
List of Findings and Violations Failure to Control and Document Traceability for Quality Lubricating Oil for Safety-Related Components Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000382/2018004
-01 Closed H.1- Resources 71111.12- Maintenance Effectiveness The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion II, "Quality Assurance Program," for the licensee's failure to ensure that identification of quality item s be maintained throughout fabrication, erection, installation, and use so that the item can be traced to its documentation.


Specifically, U NT-005-007, "Plant Lubrication Program", which control s the identification of lubricants and hydraulic fluids for plant components, did not contain instructions for controlling and documenting the labelling , addition and storage of lubricating oil for safe ty-related components
List of Findings and Violations Failure to Control and Document Traceability for Quality Lubricating Oil for Safety-Related Components Cornerstone      Significance                                  Cross-cutting      Report Section Aspect Mitigating        Green                                          H.1              71111.12 Systems          NCV 05000382/2018004-01                        Resources          Maintenance Closed                                                            Effectiveness The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B,
.
Criterion II, Quality Assurance Program, for the licensees failure to ensure that identification of quality items be maintained throughout fabrication, erection, installation, and use so that the item can be traced to its documentation. Specifically, UNT-005-007, Plant Lubrication Program, which controls the identification of lubricants and hydraulic fluids for plant components, did not contain instructions for controlling and documenting the labelling, addition and storage of lubricating oil for safety-related components.
3


=PLANT STATUS=
=PLANT STATUS=
Line 65: Line 60:


==INSPECTION SCOPES==
==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
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.
-rm/doc-collections/insp
 
-manual/inspection
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. [Include for integrated report: The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution.] The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
-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.[Include for integrated report: The inspectors performed plant status activities described in IMC 2515 Appendix D, "Plant Status" and conducted routine reviews using IP 71152, "Problem Identification and Resolution."] The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.


==REACTOR SAFETY==
==REACTOR SAFETY==


==71111.04 - Equipment Alignment==
===71111.04Equipment Alignment     Partial Walkdown ===
 
===Partial Walkdown===
{{IP sample|IP=IP 71111.04|count=4}}
{{IP sample|IP=IP 71111.04|count=4}}
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
Line 84: Line 74:
: (4) Emergency feedwater pump AB following realignment on December 22, 2018
: (4) Emergency feedwater pump AB following realignment on December 22, 2018


==71111.05AQ - Fire Protection Annual/Quarterly==
===71111.05AQFire Protection Annual/Quarterly     Quarterly Inspection ===
 
{{IP sample|IP=IP 71111.05|count=4}}
===Quarterly Inspection===
{{IP sample|IP=IP 71111.05AQ|count=4}}
The inspectors evaluated fire protection program implementation in the following selected areas:
The inspectors evaluated fire protection program implementation in the following selected areas:
: (1) Fire area RAB 8B, switchgear room B on October 20, 2018
: (1) Fire area RAB 8B, switchgear room B on October 20, 2018
: (2) Fire Area RAB 2
: (2) Fire Area RAB 2-001, heating ventilation and air conditioning mechanical room on October 31, 2018
-001 , heating ventilation and air conditioning mechanical room on October 31, 2018
: (3) Fire area RAB 3, heating ventilation and air conditioning equipment room on November 26, 2018
: (3) Fire area RAB 3, heating ventilation and air conditioning equipment room on   November 26, 2018
: (4) Fire area RAB 8C, switchgear room AB on November 26, 2018
: (4) Fire area RAB 8C, switchgear room AB on November 26, 2018


==71111.06 - Flood Protection Measures==
===71111.06Flood Protection Measures   Internal Flooding ===
{{IP sample|IP=IP 71111.06|count=1}}
The inspectors evaluated internal flooding mitigation protection features in internal flooding zone 5, -35 hallways and open rooms on November 15, 2018.


===Internal Flooding===
===71111.11Licensed Operator Requalification Program and Licensed Operator Performance    Operator Requalification ===
{{IP sample|IP=IP 71111.06|count=1}}
{{IP sample|IP=IP 71111.11|count=1}}
The inspectors evaluated internal flooding mitigation protection features in internal flooding zone 5, -35 hallways and open rooms on November 15, 2018
The inspectors observed and evaluated simulator training scenario on shutting down the plant for a refueling outage on November 20, 2018.
.


==71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance==
===Operator Performance (1 Sample)===
The inspectors observed and evaluated control room operator response to the failure of wet cooling tower fans 5-8 during an elevated risk condition on October 11, 2018.


===Operator Requalification===
The inspectors observed and evaluated a high (yellow) risk evolution of swapping safety-related AB bus from train A to train B power on October 19, 2018.
{{IP sample|IP=IP 71111.11|count=1}}
The inspectors observed and evaluated simulator training scenario on shutting down the plant for a refueling outage on November 20, 2018. Operator Performance (1 Sample) The inspectors observed and evaluated control room operator response to the failure of wet cooling tower fans 5
-8 during an elevated risk condition on October 11, 2018
. The inspectors observed and evaluated a high (yellow) risk evolution of swapping safety
-related AB bus from train A to train B power on October 19, 2018.


The inspectors observed and evaluated observation of control room operator performance during turbine valve testing on December 7, 2018.
The inspectors observed and evaluated observation of control room operator performance during turbine valve testing on December 7, 2018.


==71111.12 - Maintenance Effectiveness==
===71111.12Maintenance Effectiveness   Quality Control ===
 
===Quality Control===
{{IP sample|IP=IP 71111.12|count=1}}
{{IP sample|IP=IP 71111.12|count=1}}
The inspectors evaluated maintenance and quality control activities associated with the following equipment performance issues:
The inspectors evaluated maintenance and quality control activities associated with the following equipment performance issues:
: (1) Traceability of lubricating oil in safety
: (1) Traceability of lubricating oil in safety-related components on October 25
-related components on October 25
 
==71111.13 - Maintenance Risk Assessments and Emergent Work Control==


======
===71111.13Maintenance Risk Assessments and Emergent Work Control ===
{{IP sample|IP=IP 71111.13|count=4}}
{{IP sample|IP=IP 71111.13|count=4}}
The inspectors evaluated the risk assessments for the following planned and emergent work activities
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
:
: (1) Emergent work and risk assessment for unplanned cycling of wet cooling tower fans on October 11, 2018
: (1) Emergent work and risk assessment for unplanned cycling of wet cooling tower fans on October 11, 2018
: (2) Planned yellow risk due to work on auxiliary component cooling water train B on November 13, 2018
: (2) Planned yellow risk due to work on auxiliary component cooling water train B on November 13, 2018
Line 132: Line 110:
: (4) Emergent work and risk assessment for failed stroke time testing of normal outside air intake upstream isolation valve on December 20, 2018
: (4) Emergent work and risk assessment for failed stroke time testing of normal outside air intake upstream isolation valve on December 20, 2018


==71111.15 - Operability Determinations and Functionality Assessments==
===71111.15Operability Determinations and Functionality Assessments ===
 
{{IP sample|IP=IP 71111.15|count=4}}
===(4 Sample s) The inspectors evaluated the following operability determinations and functionality assessments:
The inspectors evaluated the following operability determinations and functionality assessments:
: (1) Operability of low pressure safety injection system following leak rate failure of the auto vent system valve on October 24, 2018
: (1) Operability of low pressure safety injection system following leak rate failure of the auto vent system valve on October 24, 2018
: (2) Operability of dry cooling tower fans trains A and B after fan 14B's drain plug was found damaged on November 19, 2018
: (2) Operability of dry cooling tower fans trains A and B after fan 14Bs drain plug was found damaged on November 19, 2018
: (3) Operability of main steam isolation valve 1 with low nitrogen accumulator pressure on December 11, 2018
: (3) Operability of main steam isolation valve 1 with low nitrogen accumulator pressure on December 11, 2018
: (4) Operability of the high pressure injection system due to potential single failure of a safety-related electrical bus on December 18, 2018
: (4) Operability of the high pressure injection system due to potential single failure of a safety-related electrical bus on December 18, 2018


==71111.19 - Post Maintenance Testing=====
===71111.19Post Maintenance Testing ===
{{IP sample|IP=IP 71111.15|count=2}}
{{IP sample|IP=IP 71111.19|count=2}}
The inspectors evaluated the following post-maintenance tests:
The inspectors evaluated the following post-maintenance tests:
: (1) Steam generator 1 main steam atmospheric dump valve following replacement of volume boosters on October 9, 2018
: (1) Steam generator 1 main steam atmospheric dump valve following replacement of volume boosters on October 9, 2018
: (2) Emergency diesel generator B following replacement of low pressure safety injection pump sequencer relay on October 22, 2018
: (2) Emergency diesel generator B following replacement of low pressure safety injection pump sequencer relay on October 22, 2018


==71111.22 - Surveillance Testing==
===71111.22Surveillance Testing The inspectors evaluated the following surveillance tests:   Routine ===
 
===The inspectors evaluated the following surveillance tests:
Routine===
{{IP sample|IP=IP 71111.22|count=3}}
{{IP sample|IP=IP 71111.22|count=3}}
: (1) Auxiliary component cooling water pump A operability run on October 4, 2018
: (1) Auxiliary component cooling water pump A operability run on October 4, 2018
: (2) Component cooling water make up pump B operability run on October 15, 2018
: (2) Component cooling water make up pump B operability run on October 15, 2018
: (3) Emergency feedwater pump B operability run on December 19, 2018 Containment Isolation Valve (1 Sample)
: (3) Emergency feedwater pump B operability run on December 19, 2018
: (1) Atmospheric dump valve A and B stroke test on October 1 9,


==OTHER ACTIVITIES
===Containment Isolation Valve (1 Sample)===
- BASELINE==
: (1) Atmospheric dump valve A and B stroke test on October 19,
71151-Performance Indicator Verification (2 Samples) The inspectors verified licensee performance indicators submittals listed below:
: (1) BI01:  Reactor Coolant System (RCS) Specific Activity Sample (10/01/2017
-09/30/2018)
: (2) BI02:  RCS Leak Rate Sample (10/01/2017
-09/30/2018
)


==71152 - Problem Identification and Resolution==
==OTHER ACTIVITIES - BASELINE==


===Semiannual Trend Review===
===71151Performance Indicator Verification ===
{{IP sample|IP=IP 71151|count=2}}
The inspectors verified licensee performance indicators submittals listed below:
: (1) BI01: Reactor Coolant System (RCS) Specific Activity Sample (10/01/2017-09/30/2018)
: (2) BI02: RCS Leak Rate Sample (10/01/2017-09/30/2018)
 
===71152Problem Identification and Resolution      Semiannual Trend Review ===
{{IP sample|IP=IP 71152|count=1}}
{{IP sample|IP=IP 71152|count=1}}
The inspectors reviewed the licensees corrective action program for trends in operability determinations that might be indicative of a more significant safety issue. The inspectors made an observation related to technical specification surveillances and operability determinations that is documented in the Inspection Results section below.


The inspectors reviewed the licensee's corrective action program for trends in operability determinations that might be indicative of a more significant safety issue.
===Annual Follow-up of Selected Issues (1 Sample)===
 
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
The inspectors made an observation related to technical specification surveillances and operability determinations that is documented in the Inspection Results section below.
: (1) Emergency feedwater pump AB turbine lubrication oil filtration system on December 31, 2018 The inspectors made an observation related to the filtration of lubrication oil for safety-related components that is documented in the Inspection Results section below.
 
Annual Follow
-up of Selected Issue s (1 Sample) The inspectors reviewed the licensee's implementation of its corrective action program related to the following issues:
: (1) Emergency feedwater pump AB turbine lubrication oil filtration system on December 31, 2018 The inspectors made an observation related to the filtration of lubrication oil for safety-related components that is documented in the Inspection Results section below.


==INSPECTION RESULTS==
==INSPECTION RESULTS==
Failure to Control and Document Traceability for Quality Lubricating Oil for Safety
Failure to Control and Document Traceability for Quality Lubricating Oil for Safety-Related Components Cornerstone       Significance                                     Cross-cutting Report Section Aspect Mitigating         Green                                            H.1              71111.12 Systems           NCV 05000382/2018004-01                         Resources        Maintenance Closed                                                             Effectiveness The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion II, Quality Assurance Program, for the licensees failure to ensure that identification of quality items be maintained throughout fabrication, erection, installation, and use so that the item can be traced to its documentation. Specifically, procedure UNT-005-007, Plant Lubrication Program, which controls the identification of lubricants and hydraulic fluids for plant components, did not contain instructions for controlling and documenting the labelling, addition and storage of lubricating oil for safety-related components.
-Related Components Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000382/2018004
-01 Closed H.1- Resources


==71111.12 - Maintenance Effectiveness==
=====Description:=====
As part of a maintenance effectiveness quality control inspection, the inspectors reviewed Waterfords processes for adding lubrication oil to safety-related components. At Waterford, lubrication oil is commercially procured and later quality dedicated in accordance with licensee procedure EN-DC-306, Acceptance of Commercial-Grade Items/Services in Safety-Related Applications, Revision 7. The now-quality oil is then placed in a 55-gallon drum, labeled as quality material and stored in the lubrication oil storage area. When lubrication oil is needed for equipment in the plant, Operations personnel fill small oil containers (about 1 gallon in size) from the 55-gallon drums and then transport it inside the plant where its added to the plant component. The unused oil remaining in the small oil container is stored in oil storage lockers throughout the plant which are used by Operations and Maintenance personnel. Operations personnel would continue to use the oil in that small container until it was depleted and then refill from the 55-gallon drums in the lubrication storage area as necessary without being able to verify the oil was quality oil.


The inspectors identified a Green, non
The inspectors noted that no work orders or any other tracking method were used to document the issuing of safety-related oil during this process. The licensees oil lubrication program didnt require the source information from the 55-gallon drum to be annotated for historical documentation. Information such as batch or lot numbers, part numbers, expiration dates, age, purchase order information, trace number or other information that would help trace the oil to its source was not recorded as it was added to a particular component, thereby losing the ability to trace the oil added to a particular safety-related component.
-cited violation of 10 CFR Part 50, Appendix B, Criterion II, "Quality Assurance Program," for the licensee's failure to ensure that identification of quality items be maintained throughout fabrication, erection, installation, and use so that the item can be traced to its documentation. Specifically, procedure UNT-005-007, "Plant Lubrication Program", which controls the identification of lubricants and hydraulic fluids for plant components, did not contain instructions for controlling and documenting the labelling, addition and storage of lubricating oil for safety-related components.


Description
Procedure UNT-005-007 directs the person adding oil to record all component lubricant consumption on the components Plant Lube Manual (PLM) Lube Info Sheet. It also directs the performer to document the amount of oil added on attachment 7.2. The procedure only allows Operations personnel to add oil during off normal hours when a low level could cause equipment damage. However, the inspectors identified that the oil added to safety-related components is not documented per attachment 7.2, and is mostly added to plant equipment by Operations personnel. Instead, Operations personnel generated condition reports to document the addition of oil to equipment. The inspectors noted that the information contained in the condition reports mainly included the oil type and the quantity that was added to the safety-related component.
:  As part of a maintenance effectiveness quality control inspection, the inspectors reviewed Waterford's processes for adding lubrication oil to safety
-related components. At Waterford, lubrication oil is commercially procured and later quality dedicated in accordance with licensee procedure EN
-DC-306, "Acceptance of Commercial
-Grade Items/Services in Safety
-Related Applications," Revision 7. The now
-quality oil is then placed in a 55
-gallon drum, labeled as quality material and stored in the lubrication oil storage area. When lubrication oil is needed for equipment in the plant, Operations personnel fill small oil containers (about 1 gallon in size) from the 55-gallon drums and then transport it inside the plant where it's added to the plant component. The unused oil remaining in the small oil container is stored in oil storage lockers throughout the plant which are used by Operations and Maintenance personnel. Operations personnel would continue to use the oil in that small container until it was depleted and then refill from the 55
-gallon drums in the lubrication storage area as necessary without being able to verify the oil was quality oil
. The inspectors noted that no work orders or any other tracking method were used to document the issuing of safety
-related oil during this process.


The licensee's oil lubrication program didn't require the source information from the 55-gallon drum to be annotated for historical documentation. Information such as batch or lot numbers , part numbers, expiration dates, age, purchase order information, trace number or other information that would help trace the oil to its source was not recorded as it was added to a particular component, thereby losing the ability to trace the oil added to a particular safety
However, the information did not have sufficient detail to document and trace the source of the oil or demonstrate that quality oil was added. Further, interviews with plant staff indicated Operations personnel routinely replenished oil containers in the Operations oil lockers, creating the potential for mixed oil (quality and non-quality or two different types of oil). In addition, the lockers were storing small containers with both quality and non-quality oil. This failure to segregate the oil types could have caused the inadvertent addition of non-quality oil to safety-related components.
-related component
.


Procedure UNT-005-007 directs the person adding oil to record all component lubricant consumption on the component's Plant Lube Manual (PLM) Lube Info Sheet. It also directs the performer to document the amount of oil added on attachment 7.2. The procedure only allows Operations personnel to add oil during off normal hours when a low level could cause equipment damage. However, the inspectors identified that the oil added to safety
The Licensee Quality Assurance Program Manual, Revision 34, states that identification of each item is maintained throughout fabrication, erection, installation, and use so that the item can be traced to its documentation. The Quality Assurance Program Manual further states that traceability is maintained to an extent consistent with the items importance to safety. The licensees program to control the addition of lubrication oil to safety-related plant components, which was written to satisfy the Quality Assurance Program Manual requirements, was governed by licensee Procedure UNT-005-007, Plant Lubrication Program, Revision 304.
-related components is not documented per attachment 7.2, and is mostly added to plant equipment by Operations personnel. Instead, Operations personnel generated condition reports to document the addition of oil to equipment. The inspectors noted that the information contained in the condition report s mainly included the oil type and the quantity that was added to the safety
-related component. However, the information did not have sufficient detail to document and trace the source of the oil or demonstrate that quality oil was added. Further, interviews with plant staff indicated Operations personnel routinely replenished oil containers in the Operations oil lockers, creating the potential for mixed oil (quality and non
-quality or two different types of oil)
. In addition, the lockers were storing small containers with both quality and non
-quality oil. This failure to segregate the oil types could have caused the inadvertent addition of non
-quality oil to safety
-related components.


The Licensee Quality Assurance Program Manual, Revision 34, states that identification of each item is maintained throughout fabrication, erection, installation, and use so that the item can be traced to its documentation. The Quality Assurance Program Manual further states that traceability is maintained to an extent consistent with the item's importance to safety. The licensee's program to control the addition of lubrication oil to safety
The inspectors concluded that, as a result of the programmatic deficiencies described above, the licensee did not control and document the oil additions from dedication until plant use to confirm they added the correct oil to safety-related components, could not determine the age of the oil added to ensure shelf-life requirements were met, and could not consistently trend oil types and amounts added to safety-related components. Additionally, because containers with unused quality oil were not segregated from non-quality oil in the lockers, they were at risk of inadvertently adding non-quality oil to safety-related components. As a result they did not meet the requirements of the Quality Assurance Program Manual.
-related plant components, which was written to satisfy the Quality Assurance Program Manual requirements, was governed by licensee Procedure UNT 007, "Plant Lubrication Program," Revision 304.
 
The inspectors concluded that, as a result of the programmatic deficiencies described above, the licensee did not control and document the oil additions from dedication until plant use to confirm they added the correct oil to safety
-related components, could not determine the age of the oil added to ensure shelf
-life requirements were met, and could not consistently trend oil types and amounts added to safety
-related components. Additionally, because containers with unused quality oil were not segregated from non
-quality oil in the lockers, they were at risk of inadvertently adding non
-quality oil to safety
-related components. As a result they did not meet the requirements of the Quality Assurance Program Manual.


There were no cases identified by the inspectors where the incorrect oil had been added to a safety-related component.
There were no cases identified by the inspectors where the incorrect oil had been added to a safety-related component.


Corrective Actions: The licensee entered this issue in to corrective action program and implemented fleet procedure EN
Corrective Actions: The licensee entered this issue in to corrective action program and implemented fleet procedure EN-DC-303, Lubrication Program. Future corrective actions include ensuring that the control and documentation traceability requirements are addressed in the new fleet procedure.
-DC-303, "Lubrication Program."


Future corrective actions include ensuring that the control and documentation traceability requirements are addressed in the new fleet procedure.
Corrective Action References: Condition Reports CR-HQN-2018-02301, CR-WF3-2018-05303, and CR-WF3-2018-05885.


Corrective Action References:  Condition Reports CR
=====Performance Assessment:=====
-HQN-2018-02301, CR-WF3-2018-05303, and CR-WF3-2018-05885. Performance Assessment
Performance Deficiency: The licensees failure to control and document traceability of quality lubricating oil for safety-related applications as required by the Quality Assurance Program Manual, Revision 34, was a performance deficiency.
: Performance Deficiency: The licensee's failure to control and document traceability of quality lubricating oil for safety
-related applications as required by the Quality Assurance Program Manual, Revision 34, was a performance deficiency.


Screening: The performance deficiency was more than minor, and therefore a finding, because if left uncorrected, it had the potential to lead to a more significant safety concern. Specifically, the programmatic failure to control and document the transfer of safety related oil from the point of dedication as quality material to oil containers and then into plant equipment leaves the licensee at risk of adding incorrect oil to equipment which could affect the availability and reliability of safety related systems. This performance deficiency is also similar to Example J of Appendix E to Inspection Manual Chapter 0612, because significant programmatic deficiencies were identified with the issue that could lead to errors if uncorrected.
Screening: The performance deficiency was more than minor, and therefore a finding, because if left uncorrected, it had the potential to lead to a more significant safety concern. Specifically, the programmatic failure to control and document the transfer of safety related oil from the point of dedication as quality material to oil containers and then into plant equipment leaves the licensee at risk of adding incorrect oil to equipment which could affect the availability and reliability of safety related systems. This performance deficiency is also similar to Example J of Appendix E to Inspection Manual Chapter 0612, because significant programmatic deficiencies were identified with the issue that could lead to errors if uncorrected.


Significance: Using Inspection Manual Chapter 0609, Attachment 4, "Initial Characterization of Findings," and Appendix A, "The Significance Determination Process (SDP) for Findings At-Power," Exhibit 2, "Mitigating Systems Screening Questions," dated June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green) because
Significance: Using Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green) because
: (1) the finding was not a deficiency affecting the design or qualification of a mitigating system;
: (1) the finding was not a deficiency affecting the design or qualification of a mitigating system;
: (2) the finding did not represent a loss of system and/or function;
: (2) the finding did not represent a loss of system and/or function;
: (3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and
: (3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and
: (4) the finding does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety
: (4) the finding does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensee's maintenance rule program for greater than 24 hours.
-significant in accordance with the licensee's maintenance rule program for greater than 24 hours.


Cross-cutting Aspect: The finding had a cross
Cross-cutting Aspect: The finding had a cross-cutting aspect in the area of human performance associated with resources because licensee leadership failed to ensure that personnel, equipment, procedures, and other resources were available and adequate to support nuclear safety [H.1]. Specifically, the licensees plant lubrication program did not provide sufficient detailed instructions to ensure adequate control and traceability of lubricating oil for safety-related components.
-cutting aspect in the area of human performance associated with resources because licensee leadership failed to ensure that personnel, equipment, procedures, and other resources were available and adequate to support nuclear safety [H.1]. Specifically, the licensee's plant lubrication program did not provide sufficient detailed instructions to ensure adequate control and traceability of lubricating oil for safety
-related components.


Enforcement
=====Enforcement:=====
Violation: Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion II, "Quality Assurance Program," requires in part that the applicant shall establish a quality assurance program which complies with the requirements of Appendix B. The licensee established the Entergy Quality Assurance Program Manual, Revision 34, to meet this requirement. The Entergy Quality Assurance Program Manual, Section B.6, requires that identification of each item be maintained throughout fabrication, erection, installation, and use so that the item can be traced to its documentation. Procedure UNT 007, "Plant Lubrication Program," Revision 304, intended to meet this requirement for lubricating oil, controls the identification of lubricants and hydraulic fluids for plant safety
Violation: Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion II, Quality Assurance Program, requires in part that the applicant shall establish a quality assurance program which complies with the requirements of Appendix B. The licensee established the Entergy Quality Assurance Program Manual, Revision 34, to meet this requirement. The Entergy Quality Assurance Program Manual, Section B.6, requires that identification of each item be maintained throughout fabrication, erection, installation, and use so that the item can be traced to its documentation. Procedure UNT-005-007, Plant Lubrication Program, Revision 304, intended to meet this requirement for lubricating oil, controls the identification of lubricants and hydraulic fluids for plant safety-related components.
-related components.


Contrary to the above, prior to November 2018, the licensee failed to ensure the identification of each quality item be maintained through installation and use so that the item can be traced to its documentation. Specifically, for lubricants and hydraulic fluids for plant safety
Contrary to the above, prior to November 2018, the licensee failed to ensure the identification of each quality item be maintained through installation and use so that the item can be traced to its documentation. Specifically, for lubricants and hydraulic fluids for plant safety-related components, the licensee
-related components, the licensee (1)failed to control oil by batch or lot from dedication until plant use,
: (1) failed to control oil by batch or lot from dedication until plant use,
: (2) failed to adequately and consistently mark containers with source information at the point of issue and
: (2) failed to adequately and consistently mark containers with source information at the point of issue and
: (3) failed to record the source information in maintenance records after adding it to safety-related components
: (3) failed to record the source information in maintenance records after adding it to safety-related components.
. Enforcement Action:  This violation is being treated as a non
-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.


Observation Semiannual Trend Review
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.


==71152 - Problem Identification and Resolution==
Observation                                  71152 Problem Semiannual Trend Review                              Identification and Resolution The inspectors identified a potential adverse trend involving operability determinations and technical specification surveillances. Technical Specification 4.0.1 requires that failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO.


The inspectors identified a potential adverse trend involving operability determinations and technical specification surveillances. Technical Specification 4.0.1 requires that "failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO.The inspectors reviewed multiple instances where the licensee identified degraded equipment conditions, but did not consider the impact the conditions would have on the ability to surveillances required by technical specifications in the associated operability determination.
The inspectors reviewed multiple instances where the licensee identified degraded equipment conditions, but did not consider the impact the conditions would have on the ability to surveillances required by technical specifications in the associated operability determination.
* Condition Reports CR-WF3-2018-00983 - The licensee identified that Technical Specification 4.0.1 was not appropriately applied to several instances of containment area radiation monitors being inoperable. The radiation monitors were required to perform technical specification surveillances associated with containment isolation valves CAP 103 (Containment Purge Inlet Inside Annulus), CAP-104 (Containment Purge Inlet Inside Containment), and CAR-200B (Containment Atmospheric Release Exhaust Header B Pressure Control Inlet). The licensee did not declare the associated equipment inoperable despite the inability to successfully complete the required technical specification surveillance. The licensee reported these conditions to the NRC as LER 2018-001-00. The NRC documented an associated licensee identified violation in Inspection Report 05000382/2018002.
* Condition Reports CR-WF3-2018-02007 - During the extent-of-cause review for CR-WF3-2018-00983, the licensee identified that Technical Specification 4.0.1 was not appropriately applied to several instances of control room outside air intake radiation monitors being inoperable. The radiation monitors were required to perform technical specification surveillances on the control room emergency filtration system, but the licensee did not declare the associated trains of control room emergency filtration system inoperable despite the inability to successfully complete the required technical specification surveillances. The licensee reported these conditions to the NRC as LERs 2018-002-00 and 2018-002-01.
* Condition Reports CR-WF3-2016-06410, CR-WF3-2016-00170, and CR-WF3-2017-04552 - The licensee identified the differential pressure monitoring points associated with the controlled ventilation area system were degraded. The differential pressure monitoring points were required to perform technical specification surveillances for the system, but their degradation and impact on the licensees ability to successfully complete the surveillances was not considered during the operability determination. Following inspector questioning, the licensee ultimately determined that the technical specification surveillances could successfully be performed using alternate monitoring points that were available to assess the same parameter but were not previously evaluated or approved for this use. Based on this new evaluation, the licensee concluded that the associated equipment remained operable.
* Condition Report CR-WF3-2018-03124 - The licensee found an emergency feedwater flow loop instrument out of tolerance. The instrument is required to perform technical specification surveillances for the system, but the degradation and impact on the licensees ability to successfully complete the surveillances was not considered during the operability determination. Following inspector questioning, the licensee performed an engineering evaluation that demonstrated that the technical specification surveillances could successfully be performed with the as-found instrument conditions and so the associated equipment remained operable.


Condition Reports CR-WF3-2018-00983 - The licensee identified that Technical Specification 4.0.1 was not appropriately applied to several instances of containment area radiation monitors being inoperable. The radiation monitors were required to perform technical specification surveillances associated with containment isolation valves CAP 103 (Containment Purge Inlet Inside Annulus), CAP
The inspectors raised their concerns with licensee personnel about the apparent trend of not considering the impact of degraded conditions on the ability to perform technical specification surveillances during operability determinations to ensure compliance with Technical Specification 4.0.1. The licensee initiated CR-WF3-2018-05569 to document the concerns and evaluate any additional guidance or training is needed to ensure that Technical Specification 4.0.1 is applied appropriately.
-104 (Containment Purge Inlet Inside Containment), and CAR
-200B (Containment Atmospheric Release Exhaust Header 'B' Pressure Control Inlet).


The licensee did not declare the associated equipment inoperable despite the inability to successfully complete the required technical specification surveillance. The licensee reported these conditions to the NRC as LER 2018 00. The NRC documented an associated licensee identified violation in Inspection Report 05000382/2018002.
Observation                                    71152  Problem Annual Follow-up of Selected Issues                        Identification and Resolution The inspectors reviewed the licensees process to provide quality lubrication oil to the emergency feedwater system AB pump turbine. The inspection focused on the licensees method for filtering the oil used to lubricate the emergency feedwater AB pump turbine governor. The inspectors noted that the lubrication oil was commercially procured and later quality dedicated in accordance with licensee Procedure EN-DC-306, Acceptance of Commercial-Grade Items/Services in Safety-Related Applications, Revision 7. The now-quality oil was then placed in the lubrication storage area, labeled as quality, kept separate from the commercial-grade version, and issued as needed to refill the pumps turbine and governor. The inspectors identified several process deficiencies, which are discussed below:
* The inspectors noted that oil filtration to specific particulate size was not listed as a critical characteristic used in the commercial-grade dedication process. The emergency feedwater system Terry Steam Turbine vendor manual, licensee Procedure MM-006-026, EFW Turbine Maintenance Procedure, Revision 8, and Plant Lube Manual, all specify the need to pre-filter the Terry Turbine oil to less than five microns.
* The inspectors noted that the licensee filters the oil, but does not use a quality-related filtration rig, does not control how often the filter is changed, and does not perform an analysis after filtration to ensure the particulate specification is met.
* The inspectors also noticed that the licensee does not have a consistent quality process to ensure that the oil being added to the pump turbine meets filtration requirements. The requirement to filter to less than five microns is listed in the document sources listed above, however, there is no established procedures or work instructions to govern this activity.


Condition Reports CR
In response to inspector concerns, the licensee collected and analyzed oil samples of the Terry Turbines oil, and confirmed that the oil currently in the pumps turbine was meeting the particulate specification requirements. In addition, the inspectors did not identify any instances where oil with out-of-specification particulate content had been added to safety-related components. Title 10 CFR 50, Appendix B, Criterion III, Design Control, requires in part, that applicable regulatory requirements and the design basis, as defined in §50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies, are correctly translated into specifications, drawings, procedures, and instructions. However, since there was no safety impact to any safety-related systems, the inspectors considered the failure to correctly translate applicable regulatory requirements and the design basis for emergency feedwater system as a minor violation.
-WF3-2018-02007 - During the extent
-of-cause review for CR
-WF3-2018-00983, the licensee identified that Technical Specification 4.0.1 was not appropriately applied to several instances of control room outside air intake radiation monitors being inoperable. The radiation monitors were required to perform technical specification surveillances on the control room emergency filtration system, but the licensee did not declare the associated trains of control room emergency filtration system inoperable despite the inability to successfully complete the required technical specification surveillances. The licensee reported these conditions to the NRC as LERs 201 8-002-00 and 2018 01.


Condition Reports CR
This issue was entered into the licensees corrective action program as CR-WF3-2018-06323.
-WF3-2016-06410, CR-WF3-2016-00170, and CR-WF3-2017-04552 - The licensee identified the differential pressure monitoring points associated with the controlled ventilation area system were degraded. The differential pressure monitoring points were required to perform technical specification surveillances for the system, but their degradation and impact on the licensee's ability to successfully complete the surveillances was not considered during the operability determination. Following inspector questioning, the licensee ultimately determined that the technical specification surveillances could successfully be performed using alternate monitoring points that were available to assess the same parameter but wer e not previously evaluated or approved for this use. Based on this new evaluation, the licensee concluded that the associated equipment remained operable.
 
Condition Report CR
-WF3-2018-03124 - The licensee found an emergency feedwater flow loop instrument out of tolerance. The instrument is required to perform technical specification surveillances for the system, but the degradation and impact on the licensee's ability to successfully complete the surveillances was not considered during the operability determination. Following inspector questioning, the licensee performed an engineering evaluation that demonstrated that the technical specification surveillances could successfully be performed with the as
-found instrument conditions and so the associated equipment remained operable.
 
The inspectors raised their concerns with licensee personnel about the apparent trend of not considering the impact of degraded conditions on the ability to perform technical specification surveillances during operability determinations to ensure compliance with Technical Specification 4.0.1. The licensee initiated CR
-WF3-2018-05569 to document the concerns and evaluate any additional guidance or training is needed to ensure that Technical Specification 4.0.1 is applied appropriately.
 
Observation Annual Follow
-up of Selected Issues
 
==71152 - Problem Identification and Resolution==
 
The inspectors reviewed the licensee's process to provide quality lubrication oil to the emergency feedwater system AB pump turbine. The inspection focused on the licensee's method for filtering the oil used to lubricate the emergency feedwater AB pump turbine governor. The inspectors noted that the lubrication oil was commercially procured and later quality dedicated in accordance with licensee Procedure EN
-DC-306, "Acceptance of Commercial
-Grade Items/Services in Safety
-Related Applications," Revision 7. The now-quality oil was then placed in the lubrication storage area, labeled as quality, kept separate from the commercial
-grade version, and issued as needed to refill the pump's turbine and governor. The inspectors identified several process deficiencies, which are discussed below:
The inspectors noted that oil filtration to specific particulate size was not listed as a critical characteristic used in the commercial
-grade dedication process.
 
The emergency feedwater system Terry Steam Turbine vendor manual, licensee Procedure MM-006-026, "EFW Turbine Maintenance Procedure
," Revision 8, and Plant Lube Manual
, all specify the need to pre
-filter the Terry Turbine oil to less than five microns.
 
The inspectors noted that the licensee filters the oil, but does not use a quality
-related filtration rig, does not control how often the filter is changed, and does not perform an analysis after filtration to ensure the particulate specification is met.
 
The inspectors also noticed that the licensee does not have a consistent quality process to ensure that the oil being added to the pump turbine meets filtration requirements. The requirement to filter to less than five microns is listed in the document sources listed above, however, there is no established procedures or work instructions to govern this activity.
 
In response to inspector concerns, the licensee collected and analyzed oil samples of th e Terry Turbine's oil, and confirmed that the oil currently in the pump's turbine was meeting the particulate specification requirements. In addition, the inspectors did not identify any instances where oil with out-of-specification particulate content had been added to safety
-related components. Title 10 CFR 50, Appendix B, Criterion III, "Design Control," requires in part, that applicable regulatory requirements and the design basis, as defined in §50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies
, are correctly translated into specifications, drawings, procedures, and instructions.
 
However, since there was no safety impact to any safety
-related systems, the inspectors considered the failure to correctly translate applicable regulatory requirements and the design basis for emergency feedwater system as a minor violation.
 
This issue was entered into the licensee's corrective action program as CR-WF3-2018-06323.


==EXIT MEETINGS AND DEBRIEFS==
==EXIT MEETINGS AND DEBRIEFS==
On January 15, 2019, the inspector s presented the quarterly resident inspector inspection results to Mr. John Dinelli, Site Vice President, and other members of the licensee staff.
On January 15, 2019, the inspectors presented the quarterly resident inspector inspection results to Mr. John Dinelli, Site Vice President, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report.
 
The inspectors verified no proprietary information was retained or documented in this report.


=DOCUMENTS REVIEWED=
=DOCUMENTS REVIEWED=


71111.04 - Equipment Alignment
71111.04 Equipment Alignment
Condition Reports
Condition Reports
CR-WF3-2018-06495 CR-WF3-2018-06395 CR-WF3-2018-06078 CR-WF3-2018-05008 CR-WF3-2018-04366 CR-WF3-2018-04351 CR-WF3-2018-04333 CR-WF3-2018-04274 Procedures Number Title Revision OP-009-003 Emergency Feedwater
CR-WF3-2018-06495       CR-WF3-2018-06395     CR-WF3-2018-06078     CR-WF3-2018-05008
309 OP-003-014 Control Room Heating and Ventilation (HVC)
CR-WF3-2018-04366       CR-WF3-2018-04351     CR-WF3-2018-04333     CR-WF3-2018-04274
307 OP-002-001 Auxiliary Component Cooling Water
Procedures
Drawings Number Title Revision G-853 Sheet 22
Number             Title                                                         Revision
HVAC Air Flow Diagram Control Room
OP-009-003         Emergency Feedwater                                           309
G-853 Sheet 23
OP-003-014         Control Room Heating and Ventilation (HVC)                   307
HVAC Air Flow Diagram Control Room
OP-002-001         Auxiliary Component Cooling Water                             312
G-160 Sheet 5
Drawings
Flow Diagram Component Closed Cooling Water System
Number             Title                                                         Revision
71111.05 - Fire Protection
G-853 Sheet 22     HVAC Air Flow Diagram Control Room                           6
Procedures Number Title Revision EN-DC-161 Control of Combustibles
G-853 Sheet 23     HVAC Air Flow Diagram Control Room                           26
FP-001-018 Pre-Fire Strategies, Development and Revision
G-160 Sheet 5       Flow Diagram Component Closed Cooling Water System           22
304  Miscellaneous
71111.05 Fire Protection
Documents Number   Title   Revision RAB 2-001 Waterford  
Procedures
- 3 S.E.S Prefire
Number             Title                                                         Revision
Strategy Elev. +46.00' RAB (RCA) H&V Mechanical Room
EN-DC-161           Control of Combustibles                                       18
RAB 3-001 Waterford  
FP-001-018         Pre-Fire Strategies, Development and Revision                 304
- 3 S.E.S Prefire Strategy Elev. +46.00' RAB HVAC Equipment Room
Miscellaneous
RAB 8C-001 Waterford  
Documents
- 3 S.E.S Prefire Strategy Switchgear Room "A/B"
Number           Title                                                           Revision
RAB 8B, E, F
RAB 2-001       Waterford - 3 S.E.S Prefire Strategy Elev. +46.00 RAB (RCA)     13
-001 Waterford  
H&V Mechanical Room
- 3 S.E.S Prefire Strategy Switchgear Room "B"
RAB 3-001       Waterford - 3 S.E.S Prefire Strategy Elev. +46.00 RAB HVAC     8
Equipment Room
RAB 8C-001       Waterford - 3 S.E.S Prefire Strategy Switchgear Room A/B       11
RAB 8B, E, F-   Waterford - 3 S.E.S Prefire Strategy Switchgear Room B         12
001
Calculations
Calculations
Number Title Revision ECF14-008 WF3 Fire Safety Analysis  
Number             Title                                                         Revision
- Fire Area RAB 2
ECF14-008         WF3 Fire Safety Analysis - Fire Area RAB 2                   1
ECF91-010 Combustible Loading Calculation for Fire Area RAB 8
ECF91-010         Combustible Loading Calculation for Fire Area RAB 8           3
71111.06 - Flood Protection Measures
71111.06 Flood Protection Measures
Miscellaneous
Miscellaneous
Documents Number   Title   Revision MNQ3-5 Flooding Analysis Outside Containment
Documents
ECM15-004 Waterford 3 FLEX Internal Flooding Calculation
Number               Title                                                       Revision
PRA-W3-01-002 W3 Internal Flooding Analysis
MNQ3-5               Flooding Analysis Outside Containment                       5
WF3-CS-15-00010 Waterford Steam Electric Station Unit 3 Fukushima Flood Hazard Re-evaluation Report
ECM15-004           Waterford 3 FLEX Internal Flooding Calculation             0
71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance
PRA-W3-01-002       W3 Internal Flooding Analysis                               3
Procedures Number Title Revision OP-903-007 Turbine Inlet Valve Cycling Test
WF3-CS-15-00010     Waterford Steam Electric Station Unit 3 Fukushima Flood     0
71111.12 - Maintenance Effectiveness
Hazard Re-evaluation Report
Condition Reports (CR) CR-WF3-2018-06323 CR-WF3-2018-05885 CR-HQN-2018-02301 CR-WF3-2018-05303 CR-WF3-2018-01197 CR-WF3-2018-04575 CR-WF3-2018-05580 CR-WF3-2018-06557 Work Orders
71111.11 Licensed Operator Requalification Program and Licensed Operator Performance
2682377 52783397       Procedures Number Title Revision UNT-005-007 Plant Lubrication Program
Procedures
304 MM-006-026 EFW Turbine Maintenance Procedure
Number             Title                                                       Revision
MM-006-026 EFW Turbine Maintenance Procedure
OP-903-007         Turbine Inlet Valve Cycling Test                             17
EN-MP-115 Material Issues and Returns
71111.12 Maintenance Effectiveness
EN-DC-306 Acceptance of Commercial
Condition Reports (CR)
-Grade Items/Services in
CR-WF3-2018-06323       CR-WF3-2018-05885     CR-HQN-2018-02301 CR-WF3-2018-05303
Procedures Number Title Revision Safety-Related Applications
CR-WF3-2018-01197       CR-WF3-2018-04575     CR-WF3-2018-05580     CR-WF3-2018-06557
Vendor Documents Number   Title   Revision TD-T147.0025 Terry Steam Turbine Instruction Manual
Work Orders
71111.13 - Maintenance Risk and Emergent Work
2682377     52783397
Procedures
Number             Title                                                       Revision
UNT-005-007         Plant Lubrication Program                                   304
MM-006-026         EFW Turbine Maintenance Procedure                           7
MM-006-026         EFW Turbine Maintenance Procedure                           8
EN-MP-115           Material Issues and Returns                                 7
EN-DC-306           Acceptance of Commercial-Grade Items/Services in             7
Procedures
Number           Title                                                       Revision
Safety-Related Applications
Vendor
Documents
Number           Title                                                       Revision
TD-T147.0025     Terry Steam Turbine Instruction Manual                     2
71111.13 Maintenance Risk and Emergent Work
Condition Reports
Condition Reports
CR-WF3-2018-07285 CR-WF3-2018-07325 CR-WF3-2018-07326   Procedures Number Title Revision EN-WM-104 On Line Risk Assessment
CR-WF3-2018-07285     CR-WF3-2018-07325     CR-WF3-2018-07326
OI-037-000 Operations Risk Assessment Guideline
Procedures
313  Miscellaneous
Number           Title                                                       Revision
Documents Number   Title   Date Protected Equipment List for ACC Train B
EN-WM-104         On Line Risk Assessment                                     18
11/13/2018
OI-037-000       Operations Risk Assessment Guideline                       313
71111.15 - Operability Determination and Functionality Assessments
Miscellaneous
Documents
Number           Title                                               Date
Protected Equipment List for ACC Train B             11/13/2018
71111.15 Operability Determination and Functionality Assessments
Condition Reports
Condition Reports
CR-WF3-2018-06982 CR-WF3-2018-5973 CR-WF3-2018-5995 CR-WF3-2018-7253 CR-WF3-20187188 CR-WF3-2018-4793 CR-WF3-2018-7188 CR-WF3-2018-8014 CR-WF3-2018-3856     Procedures Number Title Revision EN-OP-104 Operability Determination Process
CR-WF3-2018-06982     CR-WF3-2018-5973     CR-WF3-2018-5995     CR-WF3-2018-7253
Drawings Number Title Revision PD91480 Hydraulic Schematic MSIV
CR-WF3-20187188       CR-WF3-2018-4793     CR-WF3-2018-7188     CR-WF3-2018-8014
B424 Sheet E1646
CR-WF3-2018-3856
Control Wiring Diagram
Procedures
St eam Line 1 Isolation VA 2MS
Number           Title                                                       Revision
-V602A 6
EN-OP-104         Operability Determination Process                           16
Drawings Number Title Revision B424 Sheet 1646
Drawings
Control Wiring Diagram
Number           Title                                                       Revision
Stm Line 1 Isolation VA 2MS
PD91480           Hydraulic Schematic MSIV                                   5
-V602A Sh 1 16 B424 Sheet 1647
B424 Sheet E1646 Control Wiring Diagram Steam Line 1 Isolation VA 2MS-V602A   6
Control Wiring Diagram
Drawings
Stm Line 1 Isolation VA 2MS
Number             Title                                                       Revision
-V602A Sh 2 21 G-167 Sheet 2
B424 Sheet 1646   Control Wiring Diagram Stm Line 1 Isolation VA 2MS-V602A     16
Safety Injection System Flow Diagram
Sh 1
B424 Sheet 1647   Control Wiring Diagram Stm Line 1 Isolation VA 2MS-V602A     21
Sh 2
G-167 Sheet 2     Safety Injection System Flow Diagram                         53
Miscellaneous
Miscellaneous
Documents Number   Title   Revision EC-I01-006 Determination of Secondary Systems Measurement Channel Functional Safety Significance
Documents
EC-M00-009 Closure Time Analysis for Main Steam Isolation Valves MS
Number         Title                                                           Revision
-124 A & B 1 EM-M98-004 Design Basis
EC-I01-006     Determination of Secondary Systems Measurement Channel           1
Review for Main Steam Isolation Valves MS
Functional Safety Significance
-124 A & B 1 EM-M98-004 Design Basis Review for Main Steam Isolation Valves MS
EC-M00-009     Closure Time Analysis for Main Steam Isolation Valves MS-124 A & 1
-124 A & B 0 EC-10516 Evaluate Widening the MSIV Operating Pressure B
B
and/Operability
EM-M98-004     Design Basis Review for Main Steam Isolation Valves MS-124 A &   1
Limits to Minimize the Frequency of
B
Nitrogen Pressure Adjustments
EM-M98-004     Design Basis Review for Main Steam Isolation Valves MS-124 A &   0
EC-I00-002 Main Steam Isolation Valve Nitrogen Dome Pressure
B
EC-M97-031 Train A Safeguards Pump Room Temperature Raise
EC-10516       Evaluate Widening the MSIV Operating Pressure Band/Operability   0
ER-W3-2002-0352-002 Modification to Safety Injection System
Limits to Minimize
71111.19 - Post Maintenance Testing
the Frequency of Nitrogen Pressure Adjustments
EC-I00-002     Main Steam Isolation Valve Nitrogen Dome Pressure               0
EC-M97-031     Train A Safeguards Pump Room Temperature Raise                   2
ER-W3-2002-     Modification to Safety Injection System                         0
0352-002
71111.19 Post Maintenance Testing
Procedures
Procedures
Number Title Revision OP-903-068 Emergency Diesel Generator and Subgroup Relay Operability Verification
Number             Title                                                       Revision
2 STA-001-005 Leakage Testing of Air and Nitrogen Accumulators for Safety Relief Valves
OP-903-068         Emergency Diesel Generator and Subgroup Relay Operability   322
20
Verification
71111.22 - Surveillance Testing
STA-001-005       Leakage Testing of Air and Nitrogen Accumulators for Safety 320
Procedures Number Title Revision OP-903-046 Emergency Feedwater Pump Operability Check
Relief Valves
2 STA-001-005 Leakage Testing of Air and Nitrogen Accumulators for Safety Relief Valves
71111.22 Surveillance Testing
20 OP-903-050 Component Cooling Water and Auxiliary Component Cooling Water Pump and
Procedures
Valve Operability Test
Number               Title                                                       Revision
71151 - Performance Indicator Verification
OP-903-046           Emergency Feedwater Pump Operability Check                   322
Procedures Number Title Revision EN-LI-114 Regulatory Performance Indicator Process
STA-001-005         Leakage Testing of Air and Nitrogen Accumulators for Safety 320
Relief Valves
OP-903-050           Component Cooling Water and Auxiliary Component Cooling     41
Water Pump and Valve Operability Test
71151 Performance Indicator Verification
Procedures
Number               Title                                                       Revision
EN-LI-114           Regulatory Performance Indicator Process                     11
Miscellaneous
Miscellaneous
Documents Number   Title   Date W3F1-2018-004 NRC Performance Indicator (PI) Data  
Documents
- 4 th Quarter 2017 Data
Number               Title                                                         Date
Jan 9, 2018 W3F1-2018-024 NRC Performance Indicator (PI) Data  
W3F1-2018-004       NRC Performance Indicator (PI) Data - 4 Quarter 2017 Data
- 1 st Quarter 2018 Data
th
Apr 12, 2018 W3F1-2018-042 NRC Performance Indicator (PI) Data  
Jan 9,
- 2 nd Quarter 2018 Data
2018
Jul 13, 2018 W3F1-2018-066 NRC Performance Indicator (PI) Data  
W3F1-2018-024       NRC Performance Indicator (PI) Data - 1st Quarter 2018 Data   Apr 12,
- 3 rd Quarter 2018 Data
2018
Oct 21, 2018  71152 - Identification & Resolution of Problems
W3F1-2018-042       NRC Performance Indicator (PI) Data - 2nd Quarter 2018 Data   Jul 13,
2018
W3F1-2018-066       NRC Performance Indicator (PI) Data - 3rd Quarter 2018 Data   Oct 21,
2018
71152 Identification & Resolution of Problems
Condition Reports
Condition Reports
CR-WF3-2018-04575 CR-WF3-2018-05580 CR-WF3-2018-06557 CR-WF3-2018-05569 CR-WF3-2018-03124 CR-WF3-2018-00983 CR-WF3-2018-02007   Procedures Number Title Revision MM-006-026 EFW Turbine Maintenance Procedure
CR-WF3-2018-04575         CR-WF3-2018-05580     CR-WF3-2018-06557     CR-WF3-2018-05569
MM-006-026 EFW Turbine Maintenance Procedure
CR-WF3-2018-03124         CR-WF3-2018-00983     CR-WF3-2018-02007
EN-DC-306 Acceptance of Commercial
Procedures
-Grade Items/Services in Safety-Related Applications
Number               Title                                                       Revision
MM-006-026           EFW Turbine Maintenance Procedure                           7
MM-006-026           EFW Turbine Maintenance Procedure                           8
EN-DC-306           Acceptance of Commercial-Grade Items/Services in             7
Safety-Related Applications
Miscellaneous
Miscellaneous
Documents Number   Title   Date Lubriport Laboratories Inc. Oil Sample Results for EFW AB Pump Turbine
Documents
November 2018  
Number       Title                                                     Date
Lubriport Laboratories Inc. Oil Sample Results for EFW AB November
Pump Turbine                                             2018


ML19036A873
ML19036A873
SUNSI Review
SUNSI Review             Non-Sensitive            Publicly Available            Keyword:
By: NFO/rdr3 Non-Sensitive Sensitive  Publicly Available
By: NFO/rdr3               Sensitive                 Non-Publicly Available       NRC-002
Non-Publicly Available
OFFICE         SRI:DRP/D RI:DRP/D     RI:DRP/D     TL:DRS/IPAT         BC:DRS/EB1 BC:DRS/EB BC:DRS/PSB2
Keyword: NRC-002 OFFICE SRI:DRP/D RI:DRP/D RI:DRP/D TL:DRS/IPAT
NAME           FRamirez CSpeer       LNewman     RKellar             VGaddy     FRamirez HGepford
BC:DRS/EB1
SIGNATURE       FCR       CAS           LN           RLK                 vgg       FCR       hjg
BC:DRS/EB 2 BC:DRS/PSB2
DATE           1/29/2019 1/28/19       1/29/19     1/29/2019           1/29/19   1/29/2019 2/1/19
NAME FRamirez CSpeer LNewman RKellar VGaddy FRamirez HGepford SIGNATURE FCR CAS LN RLK vgg FCR hjg DATE 1/29/2019 1/28/19 1/29/19 1/29/2019 1/29/19 1/29/2019 2/1/19 OFFICE BC:DRS/OB BC:DRP/D     NAME GWerner NO'Keefe      SIGNATURE JCK for NFO     DATE 2/4/2019 2/5/19
OFFICE         BC:DRS/OB BC:DRP/D
NAME           GWerner   NOKeefe
SIGNATURE       JCK for   NFO
DATE           2/4/2019 2/5/19
}}
}}

Latest revision as of 15:15, 18 December 2019

NRC Integrated Inspection Report 05000382/2018004
ML19036A873
Person / Time
Site: Waterford Entergy icon.png
Issue date: 02/05/2019
From: O'Keefe C
NRC/RGN-IV/DRP/RPB-D
To: Dinelli J
Entergy Operations
O'Keefe C
References
IR 2018004
Download: ML19036A873 (20)


Text

ary 5, 2019

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED INSPECTION REPORT 05000382/2018004

Dear Mr. Dinelli:

On December 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford Steam Electric Station, Unit 3. On January 15, 2019, the NRC inspectors discussed the results of this inspection with you and other members of your staff.

The results of this inspection are documented in the enclosed report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. The NRC is treating this violation as non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Waterford Steam Electric Station, Unit 3.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the Waterford Steam Electric Station, Unit 3. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Neil OKeefe, Chief Project Branch D Division of Reactor Projects Docket No. 50-382 License No. NPF-38 Enclosure:

Inspection Report 05000382/2018004 w/Attachment:

Documents Reviewed

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number: 05000382 License Number: NPF-38 Report Number: 05000382/2018004 Enterprise Identifier: I-2018-004-002 Licensee: Entergy Operations, Inc.

Facility: Waterford Steam Electric Station, Unit 3 Location: Killona, Louisiana Inspection Dates: October 1, 2018 to December 31, 2018 Inspectors: F. Ramírez, Senior Resident Inspector C. Speer, Resident Inspector L. Newman, Resident Inspector J. Dixon, Senior Project Engineer Approved By: Neil OKeefe Chief, Project Branch D Division of Reactor Projects 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 NRC-identified is summarized in the table below.

List of Findings and Violations Failure to Control and Document Traceability for Quality Lubricating Oil for Safety-Related Components Cornerstone Significance Cross-cutting Report Section Aspect Mitigating Green H.1 71111.12 Systems NCV 05000382/2018004-01 Resources Maintenance Closed Effectiveness The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B,

Criterion II, Quality Assurance Program, for the licensees failure to ensure that identification of quality items be maintained throughout fabrication, erection, installation, and use so that the item can be traced to its documentation. Specifically, UNT-005-007, Plant Lubrication Program, which controls the identification of lubricants and hydraulic fluids for plant components, did not contain instructions for controlling and documenting the labelling, addition and storage of lubricating oil for safety-related components.

PLANT STATUS

The plant 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. [Include for integrated report: The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution.] The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.04Equipment Alignment Partial Walkdown

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

(1) Auxiliary component cooling water train B while train A is out of service for heat exchanger performance test on November 1, 2018
(2) Emergency feedwater train B following maintenance on November 20, 2018
(3) Control room heating and ventilation train A following maintenance on December 2, 2018
(4) Emergency feedwater pump AB following realignment on December 22, 2018

71111.05AQFire Protection Annual/Quarterly Quarterly Inspection

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Fire area RAB 8B, switchgear room B on October 20, 2018
(2) Fire Area RAB 2-001, heating ventilation and air conditioning mechanical room on October 31, 2018
(3) Fire area RAB 3, heating ventilation and air conditioning equipment room on November 26, 2018
(4) Fire area RAB 8C, switchgear room AB on November 26, 2018

71111.06Flood Protection Measures Internal Flooding

The inspectors evaluated internal flooding mitigation protection features in internal flooding zone 5, -35 hallways and open rooms on November 15, 2018.

71111.11Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification

The inspectors observed and evaluated simulator training scenario on shutting down the plant for a refueling outage on November 20, 2018.

Operator Performance (1 Sample)

The inspectors observed and evaluated control room operator response to the failure of wet cooling tower fans 5-8 during an elevated risk condition on October 11, 2018.

The inspectors observed and evaluated a high (yellow) risk evolution of swapping safety-related AB bus from train A to train B power on October 19, 2018.

The inspectors observed and evaluated observation of control room operator performance during turbine valve testing on December 7, 2018.

71111.12Maintenance Effectiveness Quality Control

The inspectors evaluated maintenance and quality control activities associated with the following equipment performance issues:

(1) Traceability of lubricating oil in safety-related components on October 25

71111.13Maintenance Risk Assessments and Emergent Work Control

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Emergent work and risk assessment for unplanned cycling of wet cooling tower fans on October 11, 2018
(2) Planned yellow risk due to work on auxiliary component cooling water train B on November 13, 2018
(3) Risk assessment for planned work window on equipment in the transformer yard on December 17, 2018
(4) Emergent work and risk assessment for failed stroke time testing of normal outside air intake upstream isolation valve on December 20, 2018

71111.15Operability Determinations and Functionality Assessments

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Operability of low pressure safety injection system following leak rate failure of the auto vent system valve on October 24, 2018
(2) Operability of dry cooling tower fans trains A and B after fan 14Bs drain plug was found damaged on November 19, 2018
(3) Operability of main steam isolation valve 1 with low nitrogen accumulator pressure on December 11, 2018
(4) Operability of the high pressure injection system due to potential single failure of a safety-related electrical bus on December 18, 2018

71111.19Post Maintenance Testing

The inspectors evaluated the following post-maintenance tests:

(1) Steam generator 1 main steam atmospheric dump valve following replacement of volume boosters on October 9, 2018
(2) Emergency diesel generator B following replacement of low pressure safety injection pump sequencer relay on October 22, 2018

71111.22Surveillance Testing The inspectors evaluated the following surveillance tests: Routine

(1) Auxiliary component cooling water pump A operability run on October 4, 2018
(2) Component cooling water make up pump B operability run on October 15, 2018
(3) Emergency feedwater pump B operability run on December 19, 2018

Containment Isolation Valve (1 Sample)

(1) Atmospheric dump valve A and B stroke test on October 19,

OTHER ACTIVITIES - BASELINE

71151Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

(1) BI01: Reactor Coolant System (RCS) Specific Activity Sample (10/01/2017-09/30/2018)
(2) BI02: RCS Leak Rate Sample (10/01/2017-09/30/2018)

71152Problem Identification and Resolution Semiannual Trend Review

The inspectors reviewed the licensees corrective action program for trends in operability determinations that might be indicative of a more significant safety issue. The inspectors made an observation related to technical specification surveillances and operability determinations that is documented in the Inspection Results section below.

Annual Follow-up of Selected Issues (1 Sample)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Emergency feedwater pump AB turbine lubrication oil filtration system on December 31, 2018 The inspectors made an observation related to the filtration of lubrication oil for safety-related components that is documented in the Inspection Results section below.

INSPECTION RESULTS

Failure to Control and Document Traceability for Quality Lubricating Oil for Safety-Related Components Cornerstone Significance Cross-cutting Report Section Aspect Mitigating Green H.1 71111.12 Systems NCV 05000382/2018004-01 Resources Maintenance Closed Effectiveness The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion II, Quality Assurance Program, for the licensees failure to ensure that identification of quality items be maintained throughout fabrication, erection, installation, and use so that the item can be traced to its documentation. Specifically, procedure UNT-005-007, Plant Lubrication Program, which controls the identification of lubricants and hydraulic fluids for plant components, did not contain instructions for controlling and documenting the labelling, addition and storage of lubricating oil for safety-related components.

Description:

As part of a maintenance effectiveness quality control inspection, the inspectors reviewed Waterfords processes for adding lubrication oil to safety-related components. At Waterford, lubrication oil is commercially procured and later quality dedicated in accordance with licensee procedure EN-DC-306, Acceptance of Commercial-Grade Items/Services in Safety-Related Applications, Revision 7. The now-quality oil is then placed in a 55-gallon drum, labeled as quality material and stored in the lubrication oil storage area. When lubrication oil is needed for equipment in the plant, Operations personnel fill small oil containers (about 1 gallon in size) from the 55-gallon drums and then transport it inside the plant where its added to the plant component. The unused oil remaining in the small oil container is stored in oil storage lockers throughout the plant which are used by Operations and Maintenance personnel. Operations personnel would continue to use the oil in that small container until it was depleted and then refill from the 55-gallon drums in the lubrication storage area as necessary without being able to verify the oil was quality oil.

The inspectors noted that no work orders or any other tracking method were used to document the issuing of safety-related oil during this process. The licensees oil lubrication program didnt require the source information from the 55-gallon drum to be annotated for historical documentation. Information such as batch or lot numbers, part numbers, expiration dates, age, purchase order information, trace number or other information that would help trace the oil to its source was not recorded as it was added to a particular component, thereby losing the ability to trace the oil added to a particular safety-related component.

Procedure UNT-005-007 directs the person adding oil to record all component lubricant consumption on the components Plant Lube Manual (PLM) Lube Info Sheet. It also directs the performer to document the amount of oil added on attachment 7.2. The procedure only allows Operations personnel to add oil during off normal hours when a low level could cause equipment damage. However, the inspectors identified that the oil added to safety-related components is not documented per attachment 7.2, and is mostly added to plant equipment by Operations personnel. Instead, Operations personnel generated condition reports to document the addition of oil to equipment. The inspectors noted that the information contained in the condition reports mainly included the oil type and the quantity that was added to the safety-related component.

However, the information did not have sufficient detail to document and trace the source of the oil or demonstrate that quality oil was added. Further, interviews with plant staff indicated Operations personnel routinely replenished oil containers in the Operations oil lockers, creating the potential for mixed oil (quality and non-quality or two different types of oil). In addition, the lockers were storing small containers with both quality and non-quality oil. This failure to segregate the oil types could have caused the inadvertent addition of non-quality oil to safety-related components.

The Licensee Quality Assurance Program Manual, Revision 34, states that identification of each item is maintained throughout fabrication, erection, installation, and use so that the item can be traced to its documentation. The Quality Assurance Program Manual further states that traceability is maintained to an extent consistent with the items importance to safety. The licensees program to control the addition of lubrication oil to safety-related plant components, which was written to satisfy the Quality Assurance Program Manual requirements, was governed by licensee Procedure UNT-005-007, Plant Lubrication Program, Revision 304.

The inspectors concluded that, as a result of the programmatic deficiencies described above, the licensee did not control and document the oil additions from dedication until plant use to confirm they added the correct oil to safety-related components, could not determine the age of the oil added to ensure shelf-life requirements were met, and could not consistently trend oil types and amounts added to safety-related components. Additionally, because containers with unused quality oil were not segregated from non-quality oil in the lockers, they were at risk of inadvertently adding non-quality oil to safety-related components. As a result they did not meet the requirements of the Quality Assurance Program Manual.

There were no cases identified by the inspectors where the incorrect oil had been added to a safety-related component.

Corrective Actions: The licensee entered this issue in to corrective action program and implemented fleet procedure EN-DC-303, Lubrication Program. Future corrective actions include ensuring that the control and documentation traceability requirements are addressed in the new fleet procedure.

Corrective Action References: Condition Reports CR-HQN-2018-02301, CR-WF3-2018-05303, and CR-WF3-2018-05885.

Performance Assessment:

Performance Deficiency: The licensees failure to control and document traceability of quality lubricating oil for safety-related applications as required by the Quality Assurance Program Manual, Revision 34, was a performance deficiency.

Screening: The performance deficiency was more than minor, and therefore a finding, because if left uncorrected, it had the potential to lead to a more significant safety concern. Specifically, the programmatic failure to control and document the transfer of safety related oil from the point of dedication as quality material to oil containers and then into plant equipment leaves the licensee at risk of adding incorrect oil to equipment which could affect the availability and reliability of safety related systems. This performance deficiency is also similar to Example J of Appendix E to Inspection Manual Chapter 0612, because significant programmatic deficiencies were identified with the issue that could lead to errors if uncorrected.

Significance: Using Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green) because

(1) the finding was not a deficiency affecting the design or qualification of a mitigating system;
(2) the finding did not represent a loss of system and/or function;
(3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and
(4) the finding does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensee's maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Cross-cutting Aspect: The finding had a cross-cutting aspect in the area of human performance associated with resources because licensee leadership failed to ensure that personnel, equipment, procedures, and other resources were available and adequate to support nuclear safety [H.1]. Specifically, the licensees plant lubrication program did not provide sufficient detailed instructions to ensure adequate control and traceability of lubricating oil for safety-related components.

Enforcement:

Violation: Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion II, Quality Assurance Program, requires in part that the applicant shall establish a quality assurance program which complies with the requirements of Appendix B. The licensee established the Entergy Quality Assurance Program Manual, Revision 34, to meet this requirement. The Entergy Quality Assurance Program Manual, Section B.6, requires that identification of each item be maintained throughout fabrication, erection, installation, and use so that the item can be traced to its documentation. Procedure UNT-005-007, Plant Lubrication Program, Revision 304, intended to meet this requirement for lubricating oil, controls the identification of lubricants and hydraulic fluids for plant safety-related components.

Contrary to the above, prior to November 2018, the licensee failed to ensure the identification of each quality item be maintained through installation and use so that the item can be traced to its documentation. Specifically, for lubricants and hydraulic fluids for plant safety-related components, the licensee

(1) failed to control oil by batch or lot from dedication until plant use,
(2) failed to adequately and consistently mark containers with source information at the point of issue and
(3) failed to record the source information in maintenance records after adding it to safety-related components.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Observation 71152 Problem Semiannual Trend Review Identification and Resolution The inspectors identified a potential adverse trend involving operability determinations and technical specification surveillances. Technical Specification 4.0.1 requires that failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO.

The inspectors reviewed multiple instances where the licensee identified degraded equipment conditions, but did not consider the impact the conditions would have on the ability to surveillances required by technical specifications in the associated operability determination.

  • Condition Reports CR-WF3-2018-00983 - The licensee identified that Technical Specification 4.0.1 was not appropriately applied to several instances of containment area radiation monitors being inoperable. The radiation monitors were required to perform technical specification surveillances associated with containment isolation valves CAP 103 (Containment Purge Inlet Inside Annulus), CAP-104 (Containment Purge Inlet Inside Containment), and CAR-200B (Containment Atmospheric Release Exhaust Header B Pressure Control Inlet). The licensee did not declare the associated equipment inoperable despite the inability to successfully complete the required technical specification surveillance. The licensee reported these conditions to the NRC as LER 2018-001-00. The NRC documented an associated licensee identified violation in Inspection Report 05000382/2018002.
  • Condition Reports CR-WF3-2016-06410, CR-WF3-2016-00170, and CR-WF3-2017-04552 - The licensee identified the differential pressure monitoring points associated with the controlled ventilation area system were degraded. The differential pressure monitoring points were required to perform technical specification surveillances for the system, but their degradation and impact on the licensees ability to successfully complete the surveillances was not considered during the operability determination. Following inspector questioning, the licensee ultimately determined that the technical specification surveillances could successfully be performed using alternate monitoring points that were available to assess the same parameter but were not previously evaluated or approved for this use. Based on this new evaluation, the licensee concluded that the associated equipment remained operable.
  • Condition Report CR-WF3-2018-03124 - The licensee found an emergency feedwater flow loop instrument out of tolerance. The instrument is required to perform technical specification surveillances for the system, but the degradation and impact on the licensees ability to successfully complete the surveillances was not considered during the operability determination. Following inspector questioning, the licensee performed an engineering evaluation that demonstrated that the technical specification surveillances could successfully be performed with the as-found instrument conditions and so the associated equipment remained operable.

The inspectors raised their concerns with licensee personnel about the apparent trend of not considering the impact of degraded conditions on the ability to perform technical specification surveillances during operability determinations to ensure compliance with Technical Specification 4.0.1. The licensee initiated CR-WF3-2018-05569 to document the concerns and evaluate any additional guidance or training is needed to ensure that Technical Specification 4.0.1 is applied appropriately.

Observation 71152 Problem Annual Follow-up of Selected Issues Identification and Resolution The inspectors reviewed the licensees process to provide quality lubrication oil to the emergency feedwater system AB pump turbine. The inspection focused on the licensees method for filtering the oil used to lubricate the emergency feedwater AB pump turbine governor. The inspectors noted that the lubrication oil was commercially procured and later quality dedicated in accordance with licensee Procedure EN-DC-306, Acceptance of Commercial-Grade Items/Services in Safety-Related Applications, Revision 7. The now-quality oil was then placed in the lubrication storage area, labeled as quality, kept separate from the commercial-grade version, and issued as needed to refill the pumps turbine and governor. The inspectors identified several process deficiencies, which are discussed below:

  • The inspectors noted that oil filtration to specific particulate size was not listed as a critical characteristic used in the commercial-grade dedication process. The emergency feedwater system Terry Steam Turbine vendor manual, licensee Procedure MM-006-026, EFW Turbine Maintenance Procedure, Revision 8, and Plant Lube Manual, all specify the need to pre-filter the Terry Turbine oil to less than five microns.
  • The inspectors noted that the licensee filters the oil, but does not use a quality-related filtration rig, does not control how often the filter is changed, and does not perform an analysis after filtration to ensure the particulate specification is met.
  • The inspectors also noticed that the licensee does not have a consistent quality process to ensure that the oil being added to the pump turbine meets filtration requirements. The requirement to filter to less than five microns is listed in the document sources listed above, however, there is no established procedures or work instructions to govern this activity.

In response to inspector concerns, the licensee collected and analyzed oil samples of the Terry Turbines oil, and confirmed that the oil currently in the pumps turbine was meeting the particulate specification requirements. In addition, the inspectors did not identify any instances where oil with out-of-specification particulate content had been added to safety-related components. Title 10 CFR 50, Appendix B, Criterion III, Design Control, requires in part, that applicable regulatory requirements and the design basis, as defined in §50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies, are correctly translated into specifications, drawings, procedures, and instructions. However, since there was no safety impact to any safety-related systems, the inspectors considered the failure to correctly translate applicable regulatory requirements and the design basis for emergency feedwater system as a minor violation.

This issue was entered into the licensees corrective action program as CR-WF3-2018-06323.

EXIT MEETINGS AND DEBRIEFS

On January 15, 2019, the inspectors presented the quarterly resident inspector inspection results to Mr. John Dinelli, Site Vice President, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report.

DOCUMENTS REVIEWED

71111.04 Equipment Alignment

Condition Reports

CR-WF3-2018-06495 CR-WF3-2018-06395 CR-WF3-2018-06078 CR-WF3-2018-05008

CR-WF3-2018-04366 CR-WF3-2018-04351 CR-WF3-2018-04333 CR-WF3-2018-04274

Procedures

Number Title Revision

OP-009-003 Emergency Feedwater 309

OP-003-014 Control Room Heating and Ventilation (HVC) 307

OP-002-001 Auxiliary Component Cooling Water 312

Drawings

Number Title Revision

G-853 Sheet 22 HVAC Air Flow Diagram Control Room 6

G-853 Sheet 23 HVAC Air Flow Diagram Control Room 26

G-160 Sheet 5 Flow Diagram Component Closed Cooling Water System 22

71111.05 Fire Protection

Procedures

Number Title Revision

EN-DC-161 Control of Combustibles 18

FP-001-018 Pre-Fire Strategies, Development and Revision 304

Miscellaneous

Documents

Number Title Revision

RAB 2-001 Waterford - 3 S.E.S Prefire Strategy Elev. +46.00 RAB (RCA) 13

H&V Mechanical Room

RAB 3-001 Waterford - 3 S.E.S Prefire Strategy Elev. +46.00 RAB HVAC 8

Equipment Room

RAB 8C-001 Waterford - 3 S.E.S Prefire Strategy Switchgear Room A/B 11

RAB 8B, E, F- Waterford - 3 S.E.S Prefire Strategy Switchgear Room B 12

001

Calculations

Number Title Revision

ECF14-008 WF3 Fire Safety Analysis - Fire Area RAB 2 1

ECF91-010 Combustible Loading Calculation for Fire Area RAB 8 3

71111.06 Flood Protection Measures

Miscellaneous

Documents

Number Title Revision

MNQ3-5 Flooding Analysis Outside Containment 5

ECM15-004 Waterford 3 FLEX Internal Flooding Calculation 0

PRA-W3-01-002 W3 Internal Flooding Analysis 3

WF3-CS-15-00010 Waterford Steam Electric Station Unit 3 Fukushima Flood 0

Hazard Re-evaluation Report

71111.11 Licensed Operator Requalification Program and Licensed Operator Performance

Procedures

Number Title Revision

OP-903-007 Turbine Inlet Valve Cycling Test 17

71111.12 Maintenance Effectiveness

Condition Reports (CR)

CR-WF3-2018-06323 CR-WF3-2018-05885 CR-HQN-2018-02301 CR-WF3-2018-05303

CR-WF3-2018-01197 CR-WF3-2018-04575 CR-WF3-2018-05580 CR-WF3-2018-06557

Work Orders

2682377 52783397

Procedures

Number Title Revision

UNT-005-007 Plant Lubrication Program 304

MM-006-026 EFW Turbine Maintenance Procedure 7

MM-006-026 EFW Turbine Maintenance Procedure 8

EN-MP-115 Material Issues and Returns 7

EN-DC-306 Acceptance of Commercial-Grade Items/Services in 7

Procedures

Number Title Revision

Safety-Related Applications

Vendor

Documents

Number Title Revision

TD-T147.0025 Terry Steam Turbine Instruction Manual 2

71111.13 Maintenance Risk and Emergent Work

Condition Reports

CR-WF3-2018-07285 CR-WF3-2018-07325 CR-WF3-2018-07326

Procedures

Number Title Revision

EN-WM-104 On Line Risk Assessment 18

OI-037-000 Operations Risk Assessment Guideline 313

Miscellaneous

Documents

Number Title Date

Protected Equipment List for ACC Train B 11/13/2018

71111.15 Operability Determination and Functionality Assessments

Condition Reports

CR-WF3-2018-06982 CR-WF3-2018-5973 CR-WF3-2018-5995 CR-WF3-2018-7253

CR-WF3-20187188 CR-WF3-2018-4793 CR-WF3-2018-7188 CR-WF3-2018-8014

CR-WF3-2018-3856

Procedures

Number Title Revision

EN-OP-104 Operability Determination Process 16

Drawings

Number Title Revision

PD91480 Hydraulic Schematic MSIV 5

B424 Sheet E1646 Control Wiring Diagram Steam Line 1 Isolation VA 2MS-V602A 6

Drawings

Number Title Revision

B424 Sheet 1646 Control Wiring Diagram Stm Line 1 Isolation VA 2MS-V602A 16

Sh 1

B424 Sheet 1647 Control Wiring Diagram Stm Line 1 Isolation VA 2MS-V602A 21

Sh 2

G-167 Sheet 2 Safety Injection System Flow Diagram 53

Miscellaneous

Documents

Number Title Revision

EC-I01-006 Determination of Secondary Systems Measurement Channel 1

Functional Safety Significance

EC-M00-009 Closure Time Analysis for Main Steam Isolation Valves MS-124 A & 1

B

EM-M98-004 Design Basis Review for Main Steam Isolation Valves MS-124 A & 1

B

EM-M98-004 Design Basis Review for Main Steam Isolation Valves MS-124 A & 0

B

EC-10516 Evaluate Widening the MSIV Operating Pressure Band/Operability 0

Limits to Minimize

the Frequency of Nitrogen Pressure Adjustments

EC-I00-002 Main Steam Isolation Valve Nitrogen Dome Pressure 0

EC-M97-031 Train A Safeguards Pump Room Temperature Raise 2

ER-W3-2002- Modification to Safety Injection System 0

0352-002

71111.19 Post Maintenance Testing

Procedures

Number Title Revision

OP-903-068 Emergency Diesel Generator and Subgroup Relay Operability 322

Verification

STA-001-005 Leakage Testing of Air and Nitrogen Accumulators for Safety 320

Relief Valves

71111.22 Surveillance Testing

Procedures

Number Title Revision

OP-903-046 Emergency Feedwater Pump Operability Check 322

STA-001-005 Leakage Testing of Air and Nitrogen Accumulators for Safety 320

Relief Valves

OP-903-050 Component Cooling Water and Auxiliary Component Cooling 41

Water Pump and Valve Operability Test

71151 Performance Indicator Verification

Procedures

Number Title Revision

EN-LI-114 Regulatory Performance Indicator Process 11

Miscellaneous

Documents

Number Title Date

W3F1-2018-004 NRC Performance Indicator (PI) Data - 4 Quarter 2017 Data

th

Jan 9,

2018

W3F1-2018-024 NRC Performance Indicator (PI) Data - 1st Quarter 2018 Data Apr 12,

2018

W3F1-2018-042 NRC Performance Indicator (PI) Data - 2nd Quarter 2018 Data Jul 13,

2018

W3F1-2018-066 NRC Performance Indicator (PI) Data - 3rd Quarter 2018 Data Oct 21,

2018

71152 Identification & Resolution of Problems

Condition Reports

CR-WF3-2018-04575 CR-WF3-2018-05580 CR-WF3-2018-06557 CR-WF3-2018-05569

CR-WF3-2018-03124 CR-WF3-2018-00983 CR-WF3-2018-02007

Procedures

Number Title Revision

MM-006-026 EFW Turbine Maintenance Procedure 7

MM-006-026 EFW Turbine Maintenance Procedure 8

EN-DC-306 Acceptance of Commercial-Grade Items/Services in 7

Safety-Related Applications

Miscellaneous

Documents

Number Title Date

Lubriport Laboratories Inc. Oil Sample Results for EFW AB November

Pump Turbine 2018

ML19036A873

SUNSI Review Non-Sensitive Publicly Available Keyword:

By: NFO/rdr3 Sensitive Non-Publicly Available NRC-002

OFFICE SRI:DRP/D RI:DRP/D RI:DRP/D TL:DRS/IPAT BC:DRS/EB1 BC:DRS/EB BC:DRS/PSB2

NAME FRamirez CSpeer LNewman RKellar VGaddy FRamirez HGepford

SIGNATURE FCR CAS LN RLK vgg FCR hjg

DATE 1/29/2019 1/28/19 1/29/19 1/29/2019 1/29/19 1/29/2019 2/1/19

OFFICE BC:DRS/OB BC:DRP/D

NAME GWerner NOKeefe

SIGNATURE JCK for NFO

DATE 2/4/2019 2/5/19