IR 05000382/2018001

NRC Integrated Inspection Report 05000382/2018001

ML18128A066
Person / Time
Site:	Waterford
Issue date:	05/08/2018
From:	Geoffrey Miller NRC/RGN-IV/DRP/RPB-D
To:	Dinelli J Entergy Operations
Miller G
References
IR 2018001
Download: ML18128A066 (29)

Text

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED INSPECTION REPORT 05000382/2018001

Dear Mr. Dinelli:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford Steam Electric Station, Unit 3. On April 12, 2018, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented one Severity Level IV violation with no associated finding. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

From April 2017 to April 2018, the NRC issued three Severity Level IV traditional enforcement violations associated with impacting the ability of the NRC to perform its regulatory oversight function. This includes the one Severity Level IV violation documented in this report. However, the NRC will not conduct Inspection Procedure 92723, Follow Up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period, because one of the violations occurred in 2006 and is not representative of present performance.

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

Sincerely,

/RA/

Geoffrey Miller, Branch Chief Project Branch D Division of Reactor Projects Docket No. 50-382 License No. NPF-38

Enclosure:

Inspection Report 05000382/2018001 w/ Attachments:

1. Documents Reviewed 2. O

Inspection Report

Docket Number: 05000382 License Number: NPF-38 Report Number: 05000382/2018001 Enterprise Identifier: I-2018-001-0002 Licensee: Entergy Operations, Inc.

Facility: Waterford Steam Electric Station, Unit 3 Location: 17265 River Road Killona, LA 70057 Inspection Dates: January 1, 2018, to March 31, 2018 Inspectors: F. Ramírez, Senior Resident Inspector C. Speer, Resident Inspector J. Choate, Project Engineer J. Dixon, Senior Project Engineer N. Greene, PhD, Senior Health Physicist S. Money, Health Physicist J. ODonnell, CHP, Health Physicist Approved By: G. Miller, Chief 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. An NRC-identified violation and additional items are summarized in the tables below.

List of Findings and Violations Failure to Obtain NRC Staff Authorization Prior to Changing a Procedure that Impacts Implementation of Technical Specifications Cornerstone Significance Cross-cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 71152 NCV 05000382/2018001-01 Closed The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.59, Changes,

Tests, and Experiments, Section (c)(1), for the licensees failure to submit and obtain authorization prior to implementation procedures described in the Final Safety Analysis Report.

Additional Tracking Items Type Issue number Title Report Status Section LER 05000382/2017-002-00 Automatic Reactor Scram 71153 Closed due to the Failure of Fast Bus Transfer Relays to Automatically Transfer Station Loads to Off-site Power on a Main Generator Trip

PLANT STATUS

Waterford Steam Electric Station Unit 3 operated at or near 100 percent rated thermal power for the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.01 - Adverse Weather Protection Impending Severe Weather

The inspectors evaluated readiness for impending adverse weather conditions prior to the onset of and during extreme low temperatures for the area on January 16, 2018.

71111.04 - Equipment Alignment Partial Walkdown

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

(1) Emergency feedwater train A following maintenance on January 12, 2018

(2) Component cooling water train A with train B out of service for maintenance on January 24, 2018

(3) Low pressure safety injection train A with train B out of service for maintenance on March 13, 2018

71111.05 - Fire Protection Quarterly Inspection

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

(1) Shutdown cooling heat exchanger rooms A and B, Fire Area RAB 33, on January 4, 2018

(2) Switchgear room B, Fire Area RAB 8B, E, and F on February 12, 2018

(3) Control room, Fire Area RAB 1A, B, C, and D on February 12, 2018

(4) Component cooling water heat exchanger B, Fire Area RAB 17 on March 13, 2018

(5) Component cooling water pump room A, Fire Area RAB 19 on March 14, 2018

71111.07 - Heat Sink Performance Heat Sink

The inspectors evaluated the ultimate heat sink performance test on January 23, 2018.

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification

The inspectors observed and evaluated operator performance in the simulator during an evaluated emergency plan exercise on February 21, 2018.

Operator Performance (1 Sample)

The inspectors observed and evaluated control room operator performance during main turbine governor valve testing on January 19, 2018.

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Component cooling water on January 25, 2018

(2) 125 Vdc distribution system on March 12, 2018

(3) Plant protection system on March 28, 2018

Quality Control (1 Sample)

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

(1) Fuel oil storage tank A1 vendor and licensee quality documents related to receipt of segments from vendor and associated welding on March 7, 2018

71111.13 - Maintenance Risk Assessments and Emergent Work Control

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

(1) Risk assessment associated with maintenance on boric acid makeup tanks A and B on January 3, 2018

(2) Risk assessment and risk management actions associated with maintenance on emergency diesel generator A on January 31, 2018

(3) Control element assembly emergency work and unexpected limiting condition for operation on February 6, 2018

71111.15 - Operability Determinations and Functionality Assessments

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Core element assembly calculator 2 unexpected trend on January 2, 2018

(2) Atmospheric dump valve A leakage on February 8, 2018

(3) Component cooling water heat exchanger B failed performance test on February 9, 2018

(4) Reactor coolant pump 2A oil leak on March 8, 2018

(5) Core protection calculator Channel C failure on March 26, 2018

(6) Ultimate heat sink on March 28, 2018

71111.18 - Plant Modifications

The inspectors evaluated the following temporary or permanent modifications:

(1) Dry cooling tower train A recirculation barrier installation, Phase 3, on March 16, 2018

71111.19 - Post Maintenance Testing

The inspectors evaluated the following post maintenance tests:

(1) Reactor trip circuit breaker 6 on January 9, 2018

(2) High pressure safety injection train B on January 23, 2018

(3) Emergency diesel generator A on February 3, 2018

(4) Auxiliary component cooling water train B on February 21, 2018

(5) Component cooling water pump B to AB suction cross-connect valve solenoid valve replacement on March 8, 2018

(6) Component cooling water pump B to AB discharge cross-connect valve solenoid valve replacement on March 8, 2018

(7) Low pressure safety injection pump B on March 14, 2018

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

(1) Emergency diesel generator A monthly surveillance on January 8, 2018

(2) Safety Channel A nuclear instrumentation functional test on January 24, 2018

(3) Functional test of plant protective system Channel C on February 23, 2018

71114.06 - Drill Evaluation Emergency Planning Drill

The inspectors evaluated a site emergency plan drill on February 21,

71124.01 - Radiological Hazard Assessment and Exposure Controls Radiological Hazard Assessment

===The inspectors evaluated radiological hazards assessments and controls.

Instructions to Workers===

The inspectors evaluated worker instructions.

Contamination and Radioactive Material Control (1 Sample)

The inspectors evaluated contamination and radioactive material controls.

Radiological Hazards Control and Work Coverage (1 Sample)

The inspectors evaluated radiological hazards control and work coverage.

High Radiation Area and Very High Radiation Area Controls (1 Sample)

The inspectors evaluated risk-significant high radiation area and very high radiation area controls.

Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample)

The inspectors evaluated radiation worker performance and radiation protection technician proficiency.

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation Engineering Controls

The inspectors evaluated airborne controls and monitoring.

Use of Respiratory Protection Devices

The inspectors evaluated respiratory protection.

Self-Contained Breathing Apparatus for Emergency Use (1 Sample)

The inspectors evaluated the licensees self-contained breathing apparatus program.

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

The inspectors verified licensee performance indicator submittals listed below:

(1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (January 1, 2017, through December 31, 2017)

(2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample (January 1, 2017, through December 31, 2017)

(3) IE04: Unplanned Scrams with Complications (USwC) Sample (January 1, 2017, through December 31, 2017)

(4) OR01: Occupational Exposure Control Effectiveness Sample (April 1, 2017, through December 31, 2017)

(5) PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (April 1, 2017, through December 31, 2017)

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues

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

(1) Implementation of change to technical specification and technical requirements compliance procedure

71153 - Follow-up of Events and Notices of Enforcement Discretion Licensee Event Reports

The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) Licensee Event Report (LER) 05000382/2017-002-00, Automatic Reactor Scram due to the Failure of Fast Bus Transfer Relays to Automatically Transfer Station Loads to Off-site Power on a Main Generator Trip, on July 17,

INSPECTION RESULTS

Failure to Obtain NRC Staff Authorization Prior to Changing a Procedure that Impacts Implementation of Technical Specifications Cornerstone Significance Cross-cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 71152 NCV 05000382/2018001-01 Closed The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.59, Changes, Tests, and Experiments, Section (c)(1), for the licensees failure to submit and obtain authorization prior to implementation procedures described in the Final Safety Analysis Report.

Description:

Waterford Technical Specification 3.7.4, states, in part, that two independent trains of ultimate heat sink cooling towers shall be Operable in Modes 1, 2, 3, and 4. Each train consists of a dry cooling tower and a wet cooling tower and its associated water basin.

Action c of Technical Specification 3.7.4 states that with a tornado watch in effect, all nine dry cooling tower fans under the missile protected portion of the dry cooling tower shall be Operable. If the number of Operable fans is less than required, restore the inoperable fan(s)to Operable status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, or be in at least Hot Standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Hot Shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The licensee established Procedure OP-100-014, Technical Specification and Technical Requirements Compliance, Revision 336, to provide guidance for determining Operability of equipment and ensuring compliance with the technical specifications and technical requirements manual. Procedure OP-100-014, Attachment 6.6, Specific System Guidelines, provides guidelines on actions when declaring a system inoperable. One of the systems listed and discussed is the ultimate heat sink and its associated Technical Specification 3.7.4.

The Process Applicability Determination process is a method for determining which plant licensing basis documents and processes are affected by a proposed activity and must be revised to reflect that activity. The licensee revised Procedure OP-100-014, Revision 336, using a Process Applicability Determination Evaluation [PAD-OP-100-014, Revision 337] to provide additional guidance on implementation of Technical Specification 3.7.4.

Procedure OP-100-014, Revision 337, was implemented in February 2017 with an added note stating, in part, if the dry cooling tower fans are declared inoperable solely due to wet cooling tower fans being out of service (cascading technical specification), then Technical Specification 3.7.4.c does not need to be applied upon a tornado watch/warning. The licensee performed a technical analysis and concluded that the missile-protected dry cooling tower fans were to be considered Operable for the tornado event because wet cooling tower fan operation is not credited in the tornado event analysis.

The licensee used Procedure EN-LI-100, Process Applicability Determination, to evaluate the change in licensing basis documents. When answering the question, does the proposed activity affect, invalidate, or render incorrect, OR have the potential to affect, invalidate, or render incorrect, information contained in any of the following Licensing Basis Documents?

the licensee answered no for impact on Operating License/Technical Specifications.

However, the inspectors determined that this addition to the site procedure could adversely impact the bases for the acceptability to ultimate heat sink design and operations. As a result, that question should have been answered yes and the licensee would have had to prepare a licensing basis document change request. The inspectors concluded that if Procedure OP-100-014, Revision 337, would have been implemented as written, it would have constituted a change affecting an evaluation that demonstrates the function of the ultimate heat sink.

The inspectors confirmed that between February 2017 and January 2018, there were no tornado watches that coincided with ultimate heat sink system work windows. Therefore, during the time this note was in the procedure, the licensee did not invoke the provision.

Corrective Action(s): The licensee removed the note from Procedure OP-100-014, and corrected the interpretation of the technical specification. Procedure OP-100-014, Revision 342, which removed the note, became effective January 2018. Therefore, if the wet cooling tower fans are inoperable, and there is a simultaneous tornado watch/warning, the licensee will implement Technical Specification 3.7.4, Action c.

Corrective Action Reference(s): CR-WF3-2018-02111

Performance Assessment:

Performance Deficiency: The licensees failure to submit a licensing basis document change request when performing a change impacting technical specifications in accordance with Procedure EN-LI-100, Process Applicability Determination, was a performance deficiency.

Specifically, Procedure EN-LI-100 states that if proposed activities affect, invalidate, or render incorrect information contained in Licensing Basis Documents such as the Operating License/Technical Specifications, then the proper regulatory reviews are performed. The procedure instructs the licensee to prepare a licensing basis document change request in accordance with the licensing basis document change process.

Screening: The inspectors determined the performance deficiency was of minor significance because the licensee did not implement this procedure change and as a result, did not incur a violation of technical specifications. However, because 10 CFR 50.59 violations could potentially impede or impact the regulatory process, the inspectors processed this performance deficiency using the traditional enforcement process and the examples in Section 6.1 of the Enforcement Policy.

Enforcement:

Severity: The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter noncompliance. This violation was more than minor because there was a reasonable likelihood the change would require NRC review and approval prior to implementation, similar to violations assessed in Section 2.1.3 of the NRC Enforcement Manual. The inspectors determined the violation to be a Severity Level IV violation similar to violation Example 6.1.d.2 in the NRC Enforcement Policy.

Violation: As stated, in part, in 10 CFR 50.59, Changes, Tests, and Experiments, Section (c)(1), a licensee may make changes in the facility as described in the final safety analysis report (as updated), make changes in the procedure as described in the final safety analysis report (as updated), and conduct tests or experiments not described in the final safety analysis report (as updated) without obtaining a license amendment pursuant to Sec. 50.90 only if:

(i) a change to the Technical Specifications incorporated in the license is not required. The licensee established Procedure EN-LI-100, Process Applicability Determination, Revision 19, to comply with this requirement. Attachment 9.1 of Procedure EN-LI-100 states, in part, to prepare a licensing basis document change request if a proposed activity affects, invalidates, or renders incorrect, information contained in Technical Specifications.

Contrary to the above requirements, from February 2017, until December 2017, the licensee completed an activity that affected Technical Specifications and did not prepare a licensing basis document change request. Specifically, the licensee implemented a change to Technical Specification 3.7.4, Action c, through the implementation of Procedure OP-100-014, Technical Specification and Technical Requirements Compliance, Revision 337, by adding a note that instructed Operations personnel to not enter Technical Specification 3.7.4.c in the event of a tornado watch/warning if the dry cooling tower fans were declared inoperable solely due to wet cooling tower fans being out of service. This action was inconsistent with the current licensing basis and would have constituted a violation of technical specifications.

Enforcement Action: Because this violation was not repetitive or willful, and was entered into the licensees corrective action program as CR-WF3-2018-02111, this violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy.

Licensee Event Automatic Reactor Scram due to the Failure of Fast Bus 71153 Report Transfer Relays to Automatically Transfer Station Loads to (Closed) Off-site Power on a Main Generator Trip 05000382/2017-002-00

Description:

The NRC conducted a special inspection to better understand the facts and circumstances surrounding this event. The results and findings of that inspection are documented in NRC Inspection Report 05000382/2017011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17354A690). The inspectors did not identify any new deficiencies as a result of this review. This LER is closed.

EXIT MEETINGS AND DEBRIEFS

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

On January 25, 2018, the inspectors presented the radiation safety inspection results to Mr. J. Dinelli, Site Vice President, and other members of the licensee staff.

On April 12, 2018, the resident inspectors presented the quarterly resident inspector inspection results to Mr. J. Dinelli, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

71111.01 - Adverse Weather Protection

Procedures

Number Title Revision

OP-002-007 Freeze Protection and Temperature Maintenance 25

OP-901-521 Severe Weather and Flooding 325

Condition Reports (CRs)

CR-WF3-2017-09668 CR-WF3-2018-00004 CR-WF3-2018-00082 CR-WF3-2018-00098

CR-WF3-2018-00436

71111.04 - Equipment Alignment

Procedures

Number Title Revision

OP-002-003 Component Cooling Water 317

OP-009-003 Emergency Feedwater 309

OP-009-008 Safety Injection System 41

71111.05 - Fire Protection

Miscellaneous Documents

Number Title Revision

RAB1A-B-C-D- Control Room Proper, H&V Room, Emergency Living 10

001 Quarters, and Computer Room

RAB8B-E-F-001 Switchgear B 12

RAB 17-001 Component Cooling Water Heat Exchanger B 8

RAB 19-001 Component Cooling Water Pump Room A 7

RAB 33-001 Shutdown Cooling Heat Exchanger Rooms A and B 8

Procedures

Number Title Revision

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

71111.11 - Licensed Operator Requalification Program and Licensed Operator

Performance

Procedures

Number Title Revision

OP-901-111 Reactor Coolant System Leak 303

OP-901-403 High Airborne Activity in Containment 4

OP-901-404 High Airborne Activity in FHB 2

OP-901-405 Fuel Handling Incident 8

OP-901-513 Spent Fuel Pool Cooling Malfunction 21

OP-902-002 Loss of Coolant Accident Recovery 20

71111.12 - Maintenance Effectiveness

Miscellaneous Documents

Number Title Revision

910163-001 PCI Quality Assurance Traveler - FOST A1 Fabrication 1

EC-53943 Station Battery B Cell Lid Cracking 0

EC-57534 Station Battery A Cell Lid Cracks 0

QPP-205 Graham, Visual Inspection 17

QPP-205 Graham, Visual Inspection addenda 1

Addenda

WDT-0528 PCI Welding EDG Supplemental Fuel Oil Storage Tank 0

WF3-FOST-DN- Deviation Notice for Waterford 3 Fuel Oil Storage Tank, 1

21 Tank A1 - Rust and Arc Strikes on Shell

Procedures

Number Title Revision

ME-003-200 Station Battery Bank and Charger (Weekly) 314

Condition Reports (CRs)

CR-WF3-2014-05777 CR-WF3-2014-06375 CR-WF3-2014-06378 CR-WF3-2015-00842

CR-WF3-2015-01802 CR-WF3-2015-04849 CR-WF3-2015-04850 CR-WF3-2015-04854

CR-WF3-2017-03566 CR-WF3-2017-03607 CR-WF3-2017-06789 CR-WF3-2017-08771

CR-WF3-2017-08845 CR-WF3-2017-09167

Work Orders

446024

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Procedures

Number Title Revision

OP-903-005 Control Element Assembly Operability Check 14

71111.15 - Operability Determinations and Functionality Assessments

Miscellaneous Documents

Number Title Revision/Date

Protected Equipment List January 31,

2018

EC-40444 Revised Impact AST Dose Analyses to Address MSSV and 1

ADV Leakages

EC-75901 Component Cooling Water Heat Exchanger Degraded 1

Performance

ECM95-008 Ultimate Heat Sink Design Basis 3

ECS05-13 Ultimate Head Sink Containment Heat Loads 1

MNQ9-2 Component Cooling Water System 2

MNQ9-50 ACCW System Resistance 2

TD-G080.0495 General Electric Spare Reactor Coolant Pump Motor 1

Drawings

WF3-ME-16- Meteorological Parameters and Parameter Relationships for 0

00001 Design and Operability of the Waterford 3 Ultimate Heat

Sink

Procedures

Number Title Revision

OP-001-002 Reactor Coolant Pump Operation 22

PE-004-021 CCW Heat Exchanger Performance Test 5

Condition Reports (CRs)

CR-WF3-2011-07700 CR-WF3-2012-02332 CR-WF3-2018-00662 CR-WF3-2018-00785

CR-WF3-2018-00948 CR-WF3-2018-00951 CR-WF3-2018-00986 CR-WF3-2018-01225

Condition Reports (CRs)

CR-WF3-2018-01426 CR-WF3-2018-01549 CR-WF3-2018-01559

Work Orders

481333 495770 495771 496893 52348919

71111.18 - Plant Modifications

Miscellaneous Documents

Number Title Revision

6W12CM10 Common Mat Stress Analysis - Cooling Tower Area 2

ECC16-004 Horizontal Air Flow Barrier Roof and Gutters at Dry Cooling 0

Tower Outside Missile Protection

ECM95-008 Ultimate Heat Sink Design Basis 3

MNQ9-52 Ultimate Heat Sink Performance based on data 2

WF3-ME-16- Meteorological Parameters and Parameter Relationships for 0

00001 Design and Operability of the Waterford 3 Ultimate Heat

Sink

Condition Reports (CRs)

CR-WF3-2012-02332

Work Orders

444257

71111.19 - Post-Maintenance Testing

Miscellaneous Documents

Number Title Revision

AR 184566 Replace Solenoid Valve

AR 186060 Align PMRQs for AOV PM Optimization Program

TD A610.0155 ASCO Installation and Maintenance Instructions for 3-Way 0

Solenoid Valves Series 8316

Procedures

Number Title Revision/Date

ME-007-019 ASCO/AVCO/MAC/Parker Hannifin Solenoid Valves 306

Procedures

Number Title Revision/Date

MM-003-041 Six Year Emergency Diesel Engine Inspection February 2,

2018

OP-903-030 Safety Injection Pump Operability Verification 35

OP-903-050 Component Cooling Water and Auxiliary Component 039

Cooling Water Pump and Valve Operational Test

OP-903-118 Primary Auxiliaries Quarterly IST Valve Tests 43

OP-903-121 Safety System Quarterly IST Valve Tests 27

Condition Reports (CRs)

CR-WF3-2017-07146 CR-WF3-2018-00441 CR-WF3-2018-00808 CR-WF3-2018-01498

Work Orders

436357 52649596 52673039 52701091

71111.22 - Surveillance Testing

Miscellaneous Documents

Number Title Date

TD-C490.0485 Combustion Engineering Ex-Core Neutron Flux Monitoring April, 1985

System Safety Channel Operation and Maintenance Manual

Procedures

Number Title Revision

MI-003-002 Safety Channel Nuclear Instrumentation Functional Test 17

OP-903-068 Emergency Diesel Generator and Subgroup Relay 319

Operability Verification

OP-903-107 Plant Protection System Channel C Functional Test 312

Work Orders

2800018 52800019

71114.06 - Drill Evaluation

Procedures

Number Title Revision

EP-001-010 Unusual Event 306

EP-001-020 Alert 309

EP-001-030 Site Area Emergency 308

EP-002-010 Notifications and Communications 315

OP-902-002 Loss of Coolant Accident Recovery 20

Condition Reports (CRs)

CR-WF3-2018-01082 CR-WF3-2018-01083 CR-WF3-2018-01084 CR-WF3-2018-01095

71124.01 - Radiological Hazard Assessment and Exposure Controls

Air Sample Surveys

Number Title Date

OL-011518-002 Pool Purification Pump Shaft Removal January 15,

2018

OL-02112017- Sluice CVC IX A February 11,

013 2017

OL-032717-006 Lapel Air Sample for RWP 2017-0064 March 27,

2017

OL-040417-004 Alpha Air - RAB -35 Safeguards Room A April 4, 2017

OL-072217-0015 Alpha Air - Letdown Valve Gallery July 22, 2017

RF-05162017- Alpha Air - Top of UGS May 16, 2017

561

Audits and Self-Assessments

Number Title Date

LO-WLO-2017- November

Pre-NRC Self-Assessment Radiation Safety - IP 71124.01

00068 CA-00005 30, 2017

Miscellaneous Documents

Number Title Date

NSTS Annual Inventory Reconciliation Report January 4,

2018

Miscellaneous Documents

Number Title Date

Periodic Review of Plant Isotopic Mix Compared to September

Radiation Protection Instrument, Revision 1 21, 2017

Review of Smears Taken for Alpha Characterization During September

RF21 19, 2017

Spent Fuel Pool Inventory October 25,

2017

Update to the Review of the Capabilities of Our Passive October 4,

Monitoring Program to Detect Intakes at Waterford-3 2017

2017-2018 Entergy Waterford 3 Radiation Protection Department August 10,

Respiratory Improvement Plan 2017

Att. 9.6 to EN- LHRA/VHRA Key Log January 23-

RP-101 25, 2018

WO 52734309 Sealed Source Leak Test June 22,

2017

WO 52768769 Semi-Annual Source Inventory December

11, 2017

Procedures

Number Title Revision

EN-RE-220 PWR Control of Miscellaneous Materials in the Spent Fuel 3

Pool

EN-RP-100 Radiation Worker Expectations 12

EN-RP-101 Access Control for Radiologically Controlled Areas 13

EN-RP-102 Radiological Control 5

EN-RP-104 Personnel Contamination Events 9

EN-RP-105 Radiological Work Permits 18

EN-RP-106 Radiological Survey Documentation 7

EN-RP-108 Radiation Protection Posting 19

EN-RP-109 Hot Spot Program 5

EN-RP-121 Radioactive Material Control 13

EN-RP-122 Alpha Monitoring 9

EN-RP-143 Source Control 13

EN-RP-315 Operation and Calibration of the CRONOS Contamination 2

Monitor

Radiation Surveys

Number Title Date

WF3-1704-0537 +46 Pressurizer Cubicle April 18, 2017

WF3-1705-0049 FHB +46 Fuel Handling Area May 1, 2017

WF3-1711-0270 FHB +46 Fuel Handling Area November

30, 2017

WF3-1711-0271 FHB +46 Fuel Handling Area November

30, 2017

WF3-1801-0194 RAB -4 Hallways January 16,

2018

WF3-1801-0213 RAB -35 Hallways January 18,

2018

WF3-1801-0262 RAB -21 Hallways January 24,

2018

Radiation Work Permits

Number Title Revision

2017-0101 Work Activities in the Spent Fuel Pool and the Transfer 1

Canal

2017-0509 RF21 Remove/Replace Steam Generator Primary 1

Manways/Diaphragms

2017-0510 Install/Remove Steam Generator Nozzle Dams, Pin 2

Verification and Closure

2017-0705 RF21 Reassembly of Reactor Head and Associated Work 0

Activities

2017-0727 RF21 Perform Reactor Vessel (ISI) Inspection Using the 2

WestDyne (ROSA) and a Submarine

2018-0004 Maintenance Activities in all Radiologically Controlled Areas 0

2018-0007 Perform Various Decon and Housekeeping Activities in all 0

Radiologically Controlled Areas

Condition Reports (CRs)

CR-WF3-2017-02540 CR-WF3-2017-02718 CR-WF3-2017-02956 CR-WF3-2017-03344

CR-WF3-2017-03349 CR-WF3-2017-03362 CR-WF3-2017-03799 CR-WF3-2017-03872

CR-WF3-2017-03953 CR-WF3-2017-06030 CR-WF3-2017-06758 CR-WF3-2017-07988

CR-WF3-2017-08330 CR-WF3-2018-00506 CR-WF3-2018-00507 WT-WTWF3-2017-

273

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Air Quality Testing Results

Number Title Date

296484-0 Compressed Air/Gas Quality Testing Laboratory Report February 15,

2017

296614-0 Compressed Air/Gas Quality Testing Laboratory Report February 16,

2017

309752-0 Compressed Air/Gas Quality Testing Laboratory Report July 28, 2017

309780-0 Compressed Air/Gas Quality Testing Laboratory Report July 31, 2017

Audits and Self-Assessments

Number Title Date

LO-WLO-2017- Pre-NRC Assessment IP 71124.03 In-Plant Airborne November

00068 Radioactivity Control and Mitigation 23, 2017

Filtration Testing Results

Number Title Date

257571 Charcoal Sample Testing May 31, 2016

2577572 In-Place HEPA Filter Testing June 1, 2016

2704414 In-Place Charcoal Filter Testing November 8,

2017

Miscellaneous Documents

Number Title Date

Inspection and Maintenance of Respiratory Protection December

Equipment - Face Piece Inspection Log 27, 2017

Inspection and Maintenance of Respiratory Protection December

Equipment - SCBA Inspection Log 27, 2017

2017-0702-04 TEDE-ALARA Evaluation November

15, 2016

Procedures

Number Title Revision

EN-RP-310 Operation and Initial Setup of the Eberline AMS-4 4

Continuous Air Monitor

EN-RP-501 Respiratory Protection Program 5

Procedures

Number Title Revision

EN-RP-502 Inspection and Maintenance of Respiratory Protection 10

Equipment

EN-RP-502-01 Fire Hawk M7 SCBA 1

EN-RP-503 Selection, Issue And Use Of Respiratory Protection 7

Equipment

EN-RP-504 Breathing Air 4

SCBA Maintenance Records

Number Title Date

UEM-6123 Posi3 USB Test Results - Complete SCBA Test March 31,

2016

UEM-6123 Posi3 USB Test Results - Complete SCBA Test February 13,

2017

UEM-6259 Posi3 USB Test Results - Complete SCBA Test March 30,

2016

UEM-6259 Posi3 USB Test Results - Complete SCBA Test February 14,

2017

Condition Reports (CRs)

CR-WF3-2016-03044 CR-WF3-2017-00011 CR-WF3-2017-00375 CR-WF3-2017-00678

CR-WF3-2017-04253 CR-WF3-2017-05533 CR-WF3-2017-06536 CR-WF3-2017-06758

71151 - Performance Indicator Verification

Audits and Self-Assessments

Number Title Date

LO-WLO-2017- Radiation Safety 71151 OR01 Occupational Exposure November

00068 Control Effectiveness 29, 2017

Miscellaneous Documents

Number Title Date

W3F1-2017- NRC Performance Indicator (PI) Data - 1st Quarter 2017 April 12, 2017

0036 ROP Data

W3F1-2017- NRC Performance Indicator (PI) Data - 2nd Quarter 2017 July 13, 2017

0058 ROP Data

Miscellaneous Documents

Number Title Date

W3F1-2017- NRC Performance Indicator (PI) Data - 3rd Quarter 2017 October 6,

0076 ROP Data 2017

W3F1-2018- NRC Performance Indicator (PI) Data - 4th Quarter 2017 January 9,

0004 ROP Data 2018

Procedures

Number Title Revision

EN-LI-114 Regulatory Performance Indicator Process 9

71152 - Problem Identification and Resolution

Miscellaneous Documents

Number Title Date

White Paper Cascading Technical Specifications During Emergency February,

Diesel Generator Outages 2018

Procedures

Number Title Revision

EN-LI-100 Process Applicability Determination Form 19

OP-100-014 Technical Specification and Technical Requirements 336, 337, 340

Compliance

Condition Reports (CRs)

CR-WF3-2017-00780 CR-WF3-2017-00785

Occupational Radiation Safety Inspection

Waterford-3

Dates of Inspection: January 22 - 26, 2018

Integrated Inspection Report 2018001

Inspection areas are listed in the attachments below.

Please provide the requested information on or before January 5, 2018.

Please submit this information using the same lettering system as below. For example, all

contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled

1- A, applicable organization charts in file/folder 1- B, etc.

If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at

least 30 days later than the onsite inspection dates, so the inspectors will have access to the

information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed

below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the

entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear

to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which

file the information can be found.

If you have any questions or comments, please contact Natasha Greene at (817) 200-1154 or

Natasha.Greene@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget,

control number 3150-0011.

1. Radiological Hazard Assessment and Exposure Controls (71124.01) and

Performance Indicator Verification (71151)

Date of Last Inspection: 4/24/2017

A. List of contacts and telephone numbers for the Radiation Protection Organization Staff

and Technicians

B. Applicable organization charts

C. Audits, self-assessments, and LERs written since 4/24/2017, related to this inspection

area

D. Procedure indexes for the radiation protection procedures

E. Please provide procedures related to the following areas noted below. Additional

procedures may be requested by number after the inspector reviews the procedure

indexes.

1. Radiation Protection Program

2. Radiation Protection Conduct of Operations, if not included in #1.

3. Personnel Dosimetry

4. Posting of Radiological Areas

5. High Radiation Area Controls

6. RCA Access Controls and Radiation Worker Instructions

7. Conduct of Radiological Surveys

8. Radioactive Source Inventory and Control

F. List of corrective action documents (including corporate and sub-tiered systems) since

4/24/2017.

a. Initiated by the radiation protection organization

b. Assigned to the radiation protection organization

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that

the inspector can perform word searches.

G. List of radiologically significant work activities scheduled to be conducted during the

inspection period. (If the inspection is scheduled during an outage, please also include a

list of work activities greater than 1 rem, scheduled during the outage with the dose

estimate for the work activity.)

H. List of active radiation work permits

I. Radioactive source inventory list all radioactive sources that are required to be leak

tested. Indicate which sources are 10 CFR Part 20, Appendix E, Category 1 or Category

2. Please indicate the radioisotope, initial and current activity (w/assay date), and

storage location for each applicable source.

J. The last two leak test results for the Category 1 or 2 radioactive sources and any other

radioactive source(s) that have failed its leak test within the last two years

K. A list of any non-fuel items stored in the spent fuel pools, and if available, their

appropriate dose rates (Contact / @ 30cm)

L. A list of radiological controlled area entries greater than 100 millirem since 4/24/2017.

The list should include the date of entry, some form of worker identification, the radiation

work permit used by the worker, dose accrued by the worker, and the electronic

dosimeter dose alarm set-point used during the entry (for Occupational Radiation Safety

Performance Indicator verification in accordance with IP 71151).

3. In-Plant Airborne Radioactivity Control and Mitigation (71124.03)

Date of Last Inspection: 3/21/2016

A. List of contacts and telephone numbers for the following areas:

1. Respiratory Protection Program

2. Self-contained breathing apparatus

B. Applicable organization charts

C. Copies of audits, self-assessments, vendor or NUPIC audits for contractor support

(SCBA), and LERs, written since 3/21/2016 related to:

1. Installed air filtration systems

2. Self-contained breathing apparatuses

D. Procedure index for:

1. Use and operation of continuous air monitors

2. Use and operation of temporary air filtration units

3. Respiratory protection

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures may be requested by number after the inspector reviews

the procedure indexes.

1. Respiratory protection program

2. Use of self-contained breathing apparatuses

3. Air quality testing for SCBAs

4. Use of installed plant systems, such as containment purge, spent fuel pool

ventilation, and auxiliary building ventilation

F. A summary list of corrective action documents (including corporate and sub-tiered

systems) written since 3/21/2016, related to the Airborne Monitoring program including:

1. Continuous air monitors

2. Self-contained breathing apparatuses

3. Respiratory protection program

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that

the inspector can perform word searches.

G. List of SCBA qualified personnel - reactor operators and emergency response personnel

H. Inspection records for self-contained breathing apparatuses (SCBAs) staged in the plant

for use since 3/21/2016.

I. SCBA training and qualification records for control room operators, shift supervisors,

STAs, and OSC personnel for the last year.

A selection of personnel may be asked to demonstrate proficiency in donning, doffing,

and performance of functionality check for respiratory devices

J. List of respirators (available for use) by type (APR, SCBA, PAPR, etc.), manufacturer,

and model.

ML18128A066

SUNSI Review Non-Sensitive Publicly Available Keyword:

By: JDixon/rdr Sensitive Non-Publicly Available NRC-002

OFFICE SRI:DRP/D RI:DRP/D PE:DRP/D BC:DRS/EB1 BC:DRS/EB2 BC:DRS/PSB2

NAME FRamirez CSpeer JChoate TFarnholtz JDrake HGepford

SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/

DATE 5/7/18 5/4/18 5/7/18 5/3/2018 5/3/18 5/3/18

OFFICE BC:DRS/OB TL:DRS/IPAT SPE:DRP/D BC:DRP/D

NAME VGaddy GGeorge JDixon GMiller

SIGNATURE /RA/ /RA/ /RA/ /RA/

DATE 5/7/18 5/3/18 5/3/18 5/8/18

May 8, 2018

Mr. John Dinelli

Site Vice President

Entergy Operations, Inc.

265 River Road

Killona, LA 70057-0751

SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED

INSPECTION REPORT 05000382/2018001

Dear Mr. Dinelli:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at your Waterford Steam Electric Station, Unit 3. On April 12, 2018, the NRC inspectors

discussed the results of this inspection with you and other members of your staff. The results of

this inspection are documented in the enclosed report.

NRC inspectors documented one Severity Level IV violation with no associated finding. The

NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of

the Enforcement Policy.

From April 2017 to April 2018, the NRC issued three Severity Level IV traditional enforcement

violations associated with impacting the ability of the NRC to perform its regulatory oversight

function. This includes the one Severity Level IV violation documented in this report. However,

the NRC will not conduct Inspection Procedure 92723, Follow Up Inspection for Three or More

Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period,

because one of the violations occurred in 2006 and is not representative of present

performance.

If you contest the violation or significance of this NCV, you should provide a response within

days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with

copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the

NRC resident inspector at the Waterford Steam Electric Station, Unit 3.

J. Dinelli 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.

Sincerely,

/RA/

Geoffrey Miller, Branch Chief

Project Branch D

Division of Reactor Projects

Docket No. 50-382

License No. NPF-38

Enclosure:

Inspection Report 05000382/2018001

w/ Attachments:

1. Documents Reviewed

2. Occupational Radiation Safety Inspection

Request for Information

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number: 05000382

License Number: NPF-38

Report Number: 05000382/2018001

Licensee: Entergy Operations, Inc.

Facility: Waterford Steam Electric Station, Unit 3

Location: 17265 River Road

Killona, LA 70057

Inspection Dates: January 1, 2018, to March 31, 2018

Inspectors:

F. Ramírez, Senior Resident Inspector

C. Speer, Resident Inspector

J. Choate, Project Engineer

J. Dixon, Senior Project Engineer

N. Greene, PhD, Senior Health Physicist

S. Money, Health Physicist

J. ODonnell, CHP, Health Physicist

Approved By:

G. Miller, Chief

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees

performance by conducting an integrated inspection at Waterford Steam Electric Station, Unit 3,

in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the

NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer

to https://www.nrc.gov/reactors/operating/oversight.html for more information. An

NRC-identified violation and additional items are summarized in the tables below.

List of Findings and Violations

Failure to Obtain NRC Staff Authorization Prior to Changing a Procedure that Impacts

Implementation of Technical Specifications

Cornerstone Significance Cross-cutting Report

Aspect Section

Not Applicable Severity Level IV Not Applicable 71152

NCV 05000382/2018001-01

Closed

The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.59, Changes,

Tests, and Experiments, Section (c)(1), for the licensees failure to submit and obtain

authorization prior to implementation procedures described in the Final Safety Analysis Report.

Additional Tracking Items

Type Issue number Title Report Status

Section

LER 05000382/2017-002-00 Automatic Reactor Scram 71153 Closed

due to the Failure of Fast Bus

Transfer Relays to

Automatically Transfer

Station Loads to Off-site

Power on a Main Generator

Trip

PLANT STATUS

Waterford Steam Electric Station Unit 3 operated at or near 100 percent rated thermal power for

the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in

effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with

their attached revision histories are located on the public website at http://www.nrc.gov/reading-

rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared

complete when the IP requirements most appropriate to the inspection activity were met

consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection

Program - Operations Phase. The inspectors performed plant status activities described in

IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem

Identification and Resolution. The inspectors reviewed selected procedures and records,

observed activities, and interviewed personnel to assess licensee performance and compliance

with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.01 - Adverse Weather Protection

Impending Severe Weather (1 Sample)

The inspectors evaluated readiness for impending adverse weather conditions prior to the

onset of and during extreme low temperatures for the area on January 16, 2018.

71111.04 - Equipment Alignment

Partial Walkdown (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1) Emergency feedwater train A following maintenance on January 12, 2018

(2) Component cooling water train A with train B out of service for maintenance on

January 24, 2018

(3) Low pressure safety injection train A with train B out of service for maintenance on

March 13, 2018

71111.05 - Fire Protection

Quarterly Inspection (5 Samples)

The inspectors evaluated fire protection program implementation in the following selected

areas:

(1) Shutdown cooling heat exchanger rooms A and B, Fire Area RAB 33, on

January 4, 2018

(2) Switchgear room B, Fire Area RAB 8B, E, and F on February 12, 2018

(3) Control room, Fire Area RAB 1A, B, C, and D on February 12, 2018

(4) Component cooling water heat exchanger B, Fire Area RAB 17 on March 13, 2018

(5) Component cooling water pump room A, Fire Area RAB 19 on March 14, 2018

71111.07 - Heat Sink Performance

Heat Sink (1 Sample)

The inspectors evaluated the ultimate heat sink performance test on January 23, 2018.

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 Sample)

The inspectors observed and evaluated operator performance in the simulator during an

evaluated emergency plan exercise on February 21, 2018.

Operator Performance (1 Sample)

The inspectors observed and evaluated control room operator performance during main turbine

governor valve testing on January 19, 2018.

71111.12 - Maintenance Effectiveness

Routine Maintenance Effectiveness (3 Samples)

The inspectors evaluated the effectiveness of routine maintenance activities associated

with the following equipment and/or safety significant functions:

(1) Component cooling water on January 25, 2018

(2) 125 Vdc distribution system on March 12, 2018

(3) Plant protection system on March 28, 2018

Quality Control (1 Sample)

The inspectors evaluated maintenance and quality control activities associated with the

following equipment performance issues:

(1) Fuel oil storage tank A1 vendor and licensee quality documents related to receipt of

segments from vendor and associated welding on March 7, 2018

71111.13 - Maintenance Risk Assessments and Emergent Work Control (3 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent

work activities:

(1) Risk assessment associated with maintenance on boric acid makeup tanks A and B on

January 3, 2018

(2) Risk assessment and risk management actions associated with maintenance on

emergency diesel generator A on January 31, 2018

(3) Control element assembly emergency work and unexpected limiting condition for

operation on February 6, 2018

71111.15 - Operability Determinations and Functionality Assessments (6 Samples)

The inspectors evaluated the following operability determinations and functionality

assessments:

(1) Core element assembly calculator 2 unexpected trend on January 2, 2018

(2) Atmospheric dump valve A leakage on February 8, 2018

(3) Component cooling water heat exchanger B failed performance test on February 9, 2018

(4) Reactor coolant pump 2A oil leak on March 8, 2018

(5) Core protection calculator Channel C failure on March 26, 2018

(6) Ultimate heat sink on March 28, 2018

71111.18 - Plant Modifications (1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) Dry cooling tower train A recirculation barrier installation, Phase 3, on March 16, 2018

71111.19 - Post Maintenance Testing (7 Samples)

The inspectors evaluated the following post maintenance tests:

(1) Reactor trip circuit breaker 6 on January 9, 2018

(2) High pressure safety injection train B on January 23, 2018

(3) Emergency diesel generator A on February 3, 2018

(4) Auxiliary component cooling water train B on February 21, 2018

(5) Component cooling water pump B to AB suction cross-connect valve solenoid valve

replacement on March 8, 2018

(6) Component cooling water pump B to AB discharge cross-connect valve solenoid valve

replacement on March 8, 2018

(7) Low pressure safety injection pump B on March 14, 2018

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine (3 Samples)

(1) Emergency diesel generator A monthly surveillance on January 8, 2018

(2) Safety Channel A nuclear instrumentation functional test on January 24, 2018

(3) Functional test of plant protective system Channel C on February 23, 2018

71114.06 - Drill Evaluation

Emergency Planning Drill (1 Sample)

The inspectors evaluated a site emergency plan drill on February 21, 2018.

RADIATION SAFETY

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (1 Sample)

The inspectors evaluated radiological hazards assessments and controls.

Instructions to Workers (1 Sample)

The inspectors evaluated worker instructions.

Contamination and Radioactive Material Control (1 Sample)

The inspectors evaluated contamination and radioactive material controls.

Radiological Hazards Control and Work Coverage (1 Sample)

The inspectors evaluated radiological hazards control and work coverage.

High Radiation Area and Very High Radiation Area Controls (1 Sample)

The inspectors evaluated risk-significant high radiation area and very high radiation area

controls.

Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample)

The inspectors evaluated radiation worker performance and radiation protection technician

proficiency.

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Engineering Controls (1 Sample)

The inspectors evaluated airborne controls and monitoring.

Use of Respiratory Protection Devices (1 Sample)

The inspectors evaluated respiratory protection.

Self-Contained Breathing Apparatus for Emergency Use (1 Sample)

The inspectors evaluated the licensees self-contained breathing apparatus program.

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification (5 Samples)

The inspectors verified licensee performance indicator submittals listed below:

(1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (January 1, 2017, through

December 31, 2017)

(2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample (January 1, 2017,

through December 31, 2017)

(3) IE04: Unplanned Scrams with Complications (USwC) Sample (January 1, 2017,

through December 31, 2017)

(4) OR01: Occupational Exposure Control Effectiveness Sample (April 1, 2017, through

December 31, 2017)

(5) PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation

Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent

Occurrences Sample (April 1, 2017, through December 31, 2017)

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (1 Sample)

The inspectors reviewed the licensees implementation of its corrective action program

related to the following issue:

(1) Implementation of change to technical specification and technical requirements

compliance procedure

71153 - Follow-up of Events and Notices of Enforcement Discretion

Licensee Event Reports (1 Sample)

The inspectors evaluated the following licensee event reports which can be accessed at

https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) Licensee Event Report (LER) 05000382/2017-002-00, Automatic Reactor Scram due to

the Failure of Fast Bus Transfer Relays to Automatically Transfer Station Loads to

Off-site Power on a Main Generator Trip, on July 17, 2017

INSPECTION RESULTS

Failure to Obtain NRC Staff Authorization Prior to Changing a Procedure that Impacts

Implementation of Technical Specifications

Cornerstone Significance Cross-cutting Report

Aspect Section

Not Applicable Severity Level IV Not Applicable 71152

NCV 05000382/2018001-01

Closed

The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.59, Changes,

Tests, and Experiments, Section (c)(1), for the licensees failure to submit and obtain

authorization prior to implementation procedures described in the Final Safety Analysis

Report.

Description: Waterford Technical Specification 3.7.4, states, in part, that two independent

trains of ultimate heat sink cooling towers shall be Operable in Modes 1, 2, 3, and 4. Each

train consists of a dry cooling tower and a wet cooling tower and its associated water basin.

Action c of Technical Specification 3.7.4 states that with a tornado watch in effect, all nine dry

cooling tower fans under the missile protected portion of the dry cooling tower shall be

Operable. If the number of Operable fans is less than required, restore the inoperable fan(s)

to Operable status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, or be in at least Hot Standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Hot

Shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The licensee established Procedure OP-100-014,

Technical Specification and Technical Requirements Compliance, Revision 336, to provide

guidance for determining Operability of equipment and ensuring compliance with the technical

specifications and technical requirements manual. Procedure OP-100-014, Attachment 6.6,

Specific System Guidelines, provides guidelines on actions when declaring a system

inoperable. One of the systems listed and discussed is the ultimate heat sink and its

associated Technical Specification 3.7.4.

The Process Applicability Determination process is a method for determining which plant

licensing basis documents and processes are affected by a proposed activity and must be

revised to reflect that activity. The licensee revised Procedure OP-100-014, Revision 336,

using a Process Applicability Determination Evaluation [PAD-OP-100-014, Revision 337] to

provide additional guidance on implementation of Technical Specification 3.7.4.

Procedure OP-100-014, Revision 337, was implemented in February 2017 with an added

note stating, in part, if the dry cooling tower fans are declared inoperable solely due to wet

cooling tower fans being out of service (cascading technical specification), then Technical Specification 3.7.4.c does not need to be applied upon a tornado watch/warning. The

licensee performed a technical analysis and concluded that the missile-protected dry cooling

tower fans were to be considered Operable for the tornado event because wet cooling tower

fan operation is not credited in the tornado event analysis.

The licensee used Procedure EN-LI-100, Process Applicability Determination, to evaluate

the change in licensing basis documents. When answering the question, does the proposed

activity affect, invalidate, or render incorrect, OR have the potential to affect, invalidate, or

render incorrect, information contained in any of the following Licensing Basis Documents?

the licensee answered no for impact on Operating License/Technical Specifications.

However, the inspectors determined that this addition to the site procedure could adversely

impact the bases for the acceptability to ultimate heat sink design and operations. As a

result, that question should have been answered yes and the licensee would have had to

prepare a licensing basis document change request. The inspectors concluded that if

Procedure OP-100-014, Revision 337, would have been implemented as written, it would

have constituted a change affecting an evaluation that demonstrates the function of the

ultimate heat sink.

The inspectors confirmed that between February 2017 and January 2018, there were no

tornado watches that coincided with ultimate heat sink system work windows. Therefore,

during the time this note was in the procedure, the licensee did not invoke the provision.

Corrective Action(s): The licensee removed the note from Procedure OP-100-014, and

corrected the interpretation of the technical specification. Procedure OP-100-014,

Revision 342, which removed the note, became effective January 2018. Therefore, if the wet

cooling tower fans are inoperable, and there is a simultaneous tornado watch/warning, the

licensee will implement Technical Specification 3.7.4, Action c.

Corrective Action Reference(s): CR-WF3-2018-02111

Performance Assessment:

Performance Deficiency: The licensees failure to submit a licensing basis document change

request when performing a change impacting technical specifications in accordance with

Procedure EN-LI-100, Process Applicability Determination, was a performance deficiency.

Specifically, Procedure EN-LI-100 states that if proposed activities affect, invalidate, or render

incorrect information contained in Licensing Basis Documents such as the Operating

License/Technical Specifications, then the proper regulatory reviews are performed. The

procedure instructs the licensee to prepare a licensing basis document change request in

accordance with the licensing basis document change process.

Screening: The inspectors determined the performance deficiency was of minor significance

because the licensee did not implement this procedure change and as a result, did not incur a

violation of technical specifications. However, because 10 CFR 50.59 violations could

potentially impede or impact the regulatory process, the inspectors processed this

performance deficiency using the traditional enforcement process and the examples in

Section 6.1 of the Enforcement Policy.

Enforcement:

Severity: The ROPs significance determination process does not specifically consider the

regulatory process impact in its assessment of licensee performance. Therefore, it is

necessary to address this violation which impedes the NRCs ability to regulate using

traditional enforcement to adequately deter noncompliance. This violation was more than

minor because there was a reasonable likelihood the change would require NRC review and

approval prior to implementation, similar to violations assessed in Section 2.1.3 of the NRC

Enforcement Manual. The inspectors determined the violation to be a Severity Level IV

violation similar to violation Example 6.1.d.2 in the NRC Enforcement Policy.

Violation: As stated, in part, in 10 CFR 50.59, Changes, Tests, and Experiments,

Section (c)(1), a licensee may make changes in the facility as described in the final safety

analysis report (as updated), make changes in the procedure as described in the final safety

analysis report (as updated), and conduct tests or experiments not described in the final

safety analysis report (as updated) without obtaining a license amendment pursuant to

Sec. 50.90 only if: (i) a change to the Technical Specifications incorporated in the license is

not required. The licensee established Procedure EN-LI-100, Process Applicability

Determination, Revision 19, to comply with this requirement. Attachment 9.1 of

Procedure EN-LI-100 states, in part, to prepare a licensing basis document change request if

a proposed activity affects, invalidates, or renders incorrect, information contained in

Technical Specifications.

Contrary to the above requirements, from February 2017, until December 2017, the licensee

completed an activity that affected Technical Specifications and did not prepare a licensing

basis document change request. Specifically, the licensee implemented a change to

Technical Specification 3.7.4, Action c, through the implementation of

Procedure OP-100-014, Technical Specification and Technical Requirements Compliance,

Revision 337, by adding a note that instructed Operations personnel to not enter Technical Specification 3.7.4.c in the event of a tornado watch/warning if the dry cooling tower fans

were declared inoperable solely due to wet cooling tower fans being out of service. This

action was inconsistent with the current licensing basis and would have constituted a violation

of technical specifications.

Enforcement Action: Because this violation was not repetitive or willful, and was entered into

the licensees corrective action program as CR-WF3-2018-02111, this violation is being

treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy.

Licensee Event Automatic Reactor Scram due to the Failure of Fast Bus 71153

Report Transfer Relays to Automatically Transfer Station Loads to

(Closed) Off-site Power on a Main Generator Trip

05000382/2017-002-00

Description: The NRC conducted a special inspection to better understand the facts and

circumstances surrounding this event. The results and findings of that inspection are

documented in NRC Inspection Report 05000382/2017011 (Agencywide Documents Access

and Management System (ADAMS) Accession No. ML17354A690). The inspectors did not

identify any new deficiencies as a result of this review. This LER is closed.

EXIT MEETINGS AND DEBRIEFS

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

On January 25, 2018, the inspectors presented the radiation safety inspection results to

Mr.

J. Dinelli, Site Vice President, and other members of the licensee staff.

On April 12, 2018, the resident inspectors presented the quarterly resident inspector inspection

results to Mr.

J. Dinelli, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

71111.01 - Adverse Weather Protection

Procedures

Number Title Revision

OP-002-007 Freeze Protection and Temperature Maintenance 25

OP-901-521 Severe Weather and Flooding 325

Condition Reports (CRs)

CR-WF3-2017-09668 CR-WF3-2018-00004 CR-WF3-2018-00082 CR-WF3-2018-00098

CR-WF3-2018-00436

71111.04 - Equipment Alignment

Procedures

Number Title Revision

OP-002-003 Component Cooling Water 317

OP-009-003 Emergency Feedwater 309

OP-009-008 Safety Injection System 41

71111.05 - Fire Protection

Miscellaneous Documents

Number Title Revision

RAB1A-B-C-D- Control Room Proper, H&V Room, Emergency Living 10

001 Quarters, and Computer Room

RAB8B-E-F-001 Switchgear B 12

RAB 17-001 Component Cooling Water Heat Exchanger B 8

RAB 19-001 Component Cooling Water Pump Room A 7

RAB 33-001 Shutdown Cooling Heat Exchanger Rooms A and B 8

Procedures

Number Title Revision

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

71111.11 - Licensed Operator Requalification Program and Licensed Operator

Performance

Procedures

Number Title Revision

OP-901-111 Reactor Coolant System Leak 303

OP-901-403 High Airborne Activity in Containment 4

OP-901-404 High Airborne Activity in FHB 2

OP-901-405 Fuel Handling Incident 8

OP-901-513 Spent Fuel Pool Cooling Malfunction 21

OP-902-002 Loss of Coolant Accident Recovery 20

71111.12 - Maintenance Effectiveness

Miscellaneous Documents

Number Title Revision

910163-001 PCI Quality Assurance Traveler - FOST A1 Fabrication 1

EC-53943 Station Battery B Cell Lid Cracking 0

EC-57534 Station Battery A Cell Lid Cracks 0

QPP-205 Graham, Visual Inspection 17

QPP-205 Graham, Visual Inspection addenda 1

Addenda

WDT-0528 PCI Welding EDG Supplemental Fuel Oil Storage Tank 0

WF3-FOST-DN- Deviation Notice for Waterford 3 Fuel Oil Storage Tank, 1

21 Tank A1 - Rust and Arc Strikes on Shell

Procedures

Number Title Revision

ME-003-200 Station Battery Bank and Charger (Weekly) 314

Condition Reports (CRs)

CR-WF3-2014-05777 CR-WF3-2014-06375 CR-WF3-2014-06378 CR-WF3-2015-00842

CR-WF3-2015-01802 CR-WF3-2015-04849 CR-WF3-2015-04850 CR-WF3-2015-04854

CR-WF3-2017-03566 CR-WF3-2017-03607 CR-WF3-2017-06789 CR-WF3-2017-08771

CR-WF3-2017-08845 CR-WF3-2017-09167

Work Orders

446024

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Procedures

Number Title Revision

OP-903-005 Control Element Assembly Operability Check 14

71111.15 - Operability Determinations and Functionality Assessments

Miscellaneous Documents

Number Title Revision/Date

Protected Equipment List January 31,

2018

EC-40444 Revised Impact AST Dose Analyses to Address MSSV and 1

ADV Leakages

EC-75901 Component Cooling Water Heat Exchanger Degraded 1

Performance

ECM95-008 Ultimate Heat Sink Design Basis 3

ECS05-13 Ultimate Head Sink Containment Heat Loads 1

MNQ9-2 Component Cooling Water System 2

MNQ9-50 ACCW System Resistance 2

TD-G080.0495 General Electric Spare Reactor Coolant Pump Motor 1

Drawings

WF3-ME-16- Meteorological Parameters and Parameter Relationships for 0

00001 Design and Operability of the Waterford 3 Ultimate Heat

Sink

Procedures

Number Title Revision

OP-001-002 Reactor Coolant Pump Operation 22

PE-004-021 CCW Heat Exchanger Performance Test 5

Condition Reports (CRs)

CR-WF3-2011-07700 CR-WF3-2012-02332 CR-WF3-2018-00662 CR-WF3-2018-00785

CR-WF3-2018-00948 CR-WF3-2018-00951 CR-WF3-2018-00986 CR-WF3-2018-01225

Condition Reports (CRs)

CR-WF3-2018-01426 CR-WF3-2018-01549 CR-WF3-2018-01559

Work Orders

481333 495770 495771 496893 52348919

71111.18 - Plant Modifications

Miscellaneous Documents

Number Title Revision

6W12CM10 Common Mat Stress Analysis - Cooling Tower Area 2

ECC16-004 Horizontal Air Flow Barrier Roof and Gutters at Dry Cooling 0

Tower Outside Missile Protection

ECM95-008 Ultimate Heat Sink Design Basis 3

MNQ9-52 Ultimate Heat Sink Performance based on data 2

WF3-ME-16- Meteorological Parameters and Parameter Relationships for 0

00001 Design and Operability of the Waterford 3 Ultimate Heat

Sink

Condition Reports (CRs)

CR-WF3-2012-02332

Work Orders

444257

71111.19 - Post-Maintenance Testing

Miscellaneous Documents

Number Title Revision

AR 184566 Replace Solenoid Valve

AR 186060 Align PMRQs for AOV PM Optimization Program

TD A610.0155 ASCO Installation and Maintenance Instructions for 3-Way 0

Solenoid Valves Series 8316

Procedures

Number Title Revision/Date

ME-007-019 ASCO/AVCO/MAC/Parker Hannifin Solenoid Valves 306

Procedures

Number Title Revision/Date

MM-003-041 Six Year Emergency Diesel Engine Inspection February 2,

2018

OP-903-030 Safety Injection Pump Operability Verification 35

OP-903-050 Component Cooling Water and Auxiliary Component 039

Cooling Water Pump and Valve Operational Test

OP-903-118 Primary Auxiliaries Quarterly IST Valve Tests 43

OP-903-121 Safety System Quarterly IST Valve Tests 27

Condition Reports (CRs)

CR-WF3-2017-07146 CR-WF3-2018-00441 CR-WF3-2018-00808 CR-WF3-2018-01498

Work Orders

436357 52649596 52673039 52701091

71111.22 - Surveillance Testing

Miscellaneous Documents

Number Title Date

TD-C490.0485 Combustion Engineering Ex-Core Neutron Flux Monitoring April, 1985

System Safety Channel Operation and Maintenance Manual

Procedures

Number Title Revision

MI-003-002 Safety Channel Nuclear Instrumentation Functional Test 17

OP-903-068 Emergency Diesel Generator and Subgroup Relay 319

Operability Verification

OP-903-107 Plant Protection System Channel C Functional Test 312

Work Orders

2800018 52800019

71114.06 - Drill Evaluation

Procedures

Number Title Revision

EP-001-010 Unusual Event 306

EP-001-020 Alert 309

EP-001-030 Site Area Emergency 308

EP-002-010 Notifications and Communications 315

OP-902-002 Loss of Coolant Accident Recovery 20

Condition Reports (CRs)

CR-WF3-2018-01082 CR-WF3-2018-01083 CR-WF3-2018-01084 CR-WF3-2018-01095

71124.01 - Radiological Hazard Assessment and Exposure Controls

Air Sample Surveys

Number Title Date

OL-011518-002 Pool Purification Pump Shaft Removal January 15,

2018

OL-02112017- Sluice CVC IX A February 11,

013 2017

OL-032717-006 Lapel Air Sample for RWP 2017-0064 March 27,

2017

OL-040417-004 Alpha Air - RAB -35 Safeguards Room A April 4, 2017

OL-072217-0015 Alpha Air - Letdown Valve Gallery July 22, 2017

RF-05162017- Alpha Air - Top of UGS May 16, 2017

561

Audits and Self-Assessments

Number Title Date

LO-WLO-2017- November

Pre-NRC Self-Assessment Radiation Safety - IP 71124.01

00068 CA-00005 30, 2017

Miscellaneous Documents

Number Title Date

NSTS Annual Inventory Reconciliation Report January 4,

2018

Miscellaneous Documents

Number Title Date

Periodic Review of Plant Isotopic Mix Compared to September

Radiation Protection Instrument, Revision 1 21, 2017

Review of Smears Taken for Alpha Characterization During September

RF21 19, 2017

Spent Fuel Pool Inventory October 25,

2017

Update to the Review of the Capabilities of Our Passive October 4,

Monitoring Program to Detect Intakes at Waterford-3 2017

2017-2018 Entergy Waterford 3 Radiation Protection Department August 10,

Respiratory Improvement Plan 2017

Att. 9.6 to EN- LHRA/VHRA Key Log January 23-

RP-101 25, 2018

WO 52734309 Sealed Source Leak Test June 22,

2017

WO 52768769 Semi-Annual Source Inventory December

11, 2017

Procedures

Number Title Revision

EN-RE-220 PWR Control of Miscellaneous Materials in the Spent Fuel 3

Pool

EN-RP-100 Radiation Worker Expectations 12

EN-RP-101 Access Control for Radiologically Controlled Areas 13

EN-RP-102 Radiological Control 5

EN-RP-104 Personnel Contamination Events 9

EN-RP-105 Radiological Work Permits 18

EN-RP-106 Radiological Survey Documentation 7

EN-RP-108 Radiation Protection Posting 19

EN-RP-109 Hot Spot Program 5

EN-RP-121 Radioactive Material Control 13

EN-RP-122 Alpha Monitoring 9

EN-RP-143 Source Control 13

EN-RP-315 Operation and Calibration of the CRONOS Contamination 2

Monitor

Radiation Surveys

Number Title Date

WF3-1704-0537 +46 Pressurizer Cubicle April 18, 2017

WF3-1705-0049 FHB +46 Fuel Handling Area May 1, 2017

WF3-1711-0270 FHB +46 Fuel Handling Area November

30, 2017

WF3-1711-0271 FHB +46 Fuel Handling Area November

30, 2017

WF3-1801-0194 RAB -4 Hallways January 16,

2018

WF3-1801-0213 RAB -35 Hallways January 18,

2018

WF3-1801-0262 RAB -21 Hallways January 24,

2018

Radiation Work Permits

Number Title Revision

2017-0101 Work Activities in the Spent Fuel Pool and the Transfer 1

Canal

2017-0509 RF21 Remove/Replace Steam Generator Primary 1

Manways/Diaphragms

2017-0510 Install/Remove Steam Generator Nozzle Dams, Pin 2

Verification and Closure

2017-0705 RF21 Reassembly of Reactor Head and Associated Work 0

Activities

2017-0727 RF21 Perform Reactor Vessel (ISI) Inspection Using the 2

WestDyne (ROSA) and a Submarine

2018-0004 Maintenance Activities in all Radiologically Controlled Areas 0

2018-0007 Perform Various Decon and Housekeeping Activities in all 0

Radiologically Controlled Areas

Condition Reports (CRs)

CR-WF3-2017-02540 CR-WF3-2017-02718 CR-WF3-2017-02956 CR-WF3-2017-03344

CR-WF3-2017-03349 CR-WF3-2017-03362 CR-WF3-2017-03799 CR-WF3-2017-03872

CR-WF3-2017-03953 CR-WF3-2017-06030 CR-WF3-2017-06758 CR-WF3-2017-07988

CR-WF3-2017-08330 CR-WF3-2018-00506 CR-WF3-2018-00507 WT-WTWF3-2017-

273

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Air Quality Testing Results

Number Title Date

296484-0 Compressed Air/Gas Quality Testing Laboratory Report February 15,

2017

296614-0 Compressed Air/Gas Quality Testing Laboratory Report February 16,

2017

309752-0 Compressed Air/Gas Quality Testing Laboratory Report July 28, 2017

309780-0 Compressed Air/Gas Quality Testing Laboratory Report July 31, 2017

Audits and Self-Assessments

Number Title Date

LO-WLO-2017- Pre-NRC Assessment IP 71124.03 In-Plant Airborne November

00068 Radioactivity Control and Mitigation 23, 2017

Filtration Testing Results

Number Title Date

257571 Charcoal Sample Testing May 31, 2016

2577572 In-Place HEPA Filter Testing June 1, 2016

2704414 In-Place Charcoal Filter Testing November 8,

2017

Miscellaneous Documents

Number Title Date

Inspection and Maintenance of Respiratory Protection December

Equipment - Face Piece Inspection Log 27, 2017

Inspection and Maintenance of Respiratory Protection December

Equipment - SCBA Inspection Log 27, 2017

2017-0702-04 TEDE-ALARA Evaluation November

15, 2016

Procedures

Number Title Revision

EN-RP-310 Operation and Initial Setup of the Eberline AMS-4 4

Continuous Air Monitor

EN-RP-501 Respiratory Protection Program 5

Procedures

Number Title Revision

EN-RP-502 Inspection and Maintenance of Respiratory Protection 10

Equipment

EN-RP-502-01 Fire Hawk M7 SCBA 1

EN-RP-503 Selection, Issue And Use Of Respiratory Protection 7

Equipment

EN-RP-504 Breathing Air 4

SCBA Maintenance Records

Number Title Date

UEM-6123 Posi3 USB Test Results - Complete SCBA Test March 31,

2016

UEM-6123 Posi3 USB Test Results - Complete SCBA Test February 13,

2017

UEM-6259 Posi3 USB Test Results - Complete SCBA Test March 30,

2016

UEM-6259 Posi3 USB Test Results - Complete SCBA Test February 14,

2017

Condition Reports (CRs)

CR-WF3-2016-03044 CR-WF3-2017-00011 CR-WF3-2017-00375 CR-WF3-2017-00678

CR-WF3-2017-04253 CR-WF3-2017-05533 CR-WF3-2017-06536 CR-WF3-2017-06758

71151 - Performance Indicator Verification

Audits and Self-Assessments

Number Title Date

LO-WLO-2017- Radiation Safety 71151 OR01 Occupational Exposure November

00068 Control Effectiveness 29, 2017

Miscellaneous Documents

Number Title Date

W3F1-2017- NRC Performance Indicator (PI) Data - 1st Quarter 2017 April 12, 2017

0036 ROP Data

W3F1-2017- NRC Performance Indicator (PI) Data - 2nd Quarter 2017 July 13, 2017

0058 ROP Data

Miscellaneous Documents

Number Title Date

W3F1-2017- NRC Performance Indicator (PI) Data - 3rd Quarter 2017 October 6,

0076 ROP Data 2017

W3F1-2018- NRC Performance Indicator (PI) Data - 4th Quarter 2017 January 9,

0004 ROP Data 2018

Procedures

Number Title Revision

EN-LI-114 Regulatory Performance Indicator Process 9

71152 - Problem Identification and Resolution

Miscellaneous Documents

Number Title Date

White Paper Cascading Technical Specifications During Emergency February,

Diesel Generator Outages 2018

Procedures

Number Title Revision

EN-LI-100 Process Applicability Determination Form 19

OP-100-014 Technical Specification and Technical Requirements 336, 337, 340

Compliance

Condition Reports (CRs)

CR-WF3-2017-00780 CR-WF3-2017-00785

Occupational Radiation Safety Inspection

Waterford-3

Dates of Inspection: January 22 - 26, 2018

Integrated Inspection Report 2018001

Inspection areas are listed in the attachments below.

Please provide the requested information on or before January 5, 2018.

Please submit this information using the same lettering system as below. For example, all

contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled

1- A, applicable organization charts in file/folder 1- B, etc.

If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at

least 30 days later than the onsite inspection dates, so the inspectors will have access to the

information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed

below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the

entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear

to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which

file the information can be found.

If you have any questions or comments, please contact Natasha Greene at (817) 200-1154 or

Natasha.Greene@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget,

control number 3150-0011.

1. Radiological Hazard Assessment and Exposure Controls (71124.01) and

Performance Indicator Verification (71151)

Date of Last Inspection: 4/24/2017

A. List of contacts and telephone numbers for the Radiation Protection Organization Staff

and Technicians

B. Applicable organization charts

C. Audits, self-assessments, and LERs written since 4/24/2017, related to this inspection

area

D. Procedure indexes for the radiation protection procedures

E. Please provide procedures related to the following areas noted below. Additional

procedures may be requested by number after the inspector reviews the procedure

indexes.

1. Radiation Protection Program

2. Radiation Protection Conduct of Operations, if not included in #1.

3. Personnel Dosimetry

4. Posting of Radiological Areas

5. High Radiation Area Controls

6. RCA Access Controls and Radiation Worker Instructions

7. Conduct of Radiological Surveys

8. Radioactive Source Inventory and Control

F. List of corrective action documents (including corporate and sub-tiered systems) since

4/24/2017.

a. Initiated by the radiation protection organization

b. Assigned to the radiation protection organization

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that

the inspector can perform word searches.

G. List of radiologically significant work activities scheduled to be conducted during the

inspection period. (If the inspection is scheduled during an outage, please also include a

list of work activities greater than 1 rem, scheduled during the outage with the dose

estimate for the work activity.)

H. List of active radiation work permits

I. Radioactive source inventory list all radioactive sources that are required to be leak

tested. Indicate which sources are 10 CFR Part 20, Appendix E, Category 1 or Category

2. Please indicate the radioisotope, initial and current activity (w/assay date), and

storage location for each applicable source.

J. The last two leak test results for the Category 1 or 2 radioactive sources and any other

radioactive source(s) that have failed its leak test within the last two years

K. A list of any non-fuel items stored in the spent fuel pools, and if available, their

appropriate dose rates (Contact / @ 30cm)

L. A list of radiological controlled area entries greater than 100 millirem since 4/24/2017.

The list should include the date of entry, some form of worker identification, the radiation

work permit used by the worker, dose accrued by the worker, and the electronic

dosimeter dose alarm set-point used during the entry (for Occupational Radiation Safety

Performance Indicator verification in accordance with IP 71151).

3. In-Plant Airborne Radioactivity Control and Mitigation (71124.03)

Date of Last Inspection: 3/21/2016

A. List of contacts and telephone numbers for the following areas:

1. Respiratory Protection Program

2. Self-contained breathing apparatus

B. Applicable organization charts

C. Copies of audits, self-assessments, vendor or NUPIC audits for contractor support

(SCBA), and LERs, written since 3/21/2016 related to:

1. Installed air filtration systems

2. Self-contained breathing apparatuses

D. Procedure index for:

1. Use and operation of continuous air monitors

2. Use and operation of temporary air filtration units

3. Respiratory protection

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures may be requested by number after the inspector reviews

the procedure indexes.

1. Respiratory protection program

2. Use of self-contained breathing apparatuses

3. Air quality testing for SCBAs

4. Use of installed plant systems, such as containment purge, spent fuel pool

ventilation, and auxiliary building ventilation

F. A summary list of corrective action documents (including corporate and sub-tiered

systems) written since 3/21/2016, related to the Airborne Monitoring program including:

1. Continuous air monitors

2. Self-contained breathing apparatuses

3. Respiratory protection program

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that

the inspector can perform word searches.

G. List of SCBA qualified personnel - reactor operators and emergency response personnel

H. Inspection records for self-contained breathing apparatuses (SCBAs) staged in the plant

for use since 3/21/2016.

I. SCBA training and qualification records for control room operators, shift supervisors,

STAs, and OSC personnel for the last year.

A selection of personnel may be asked to demonstrate proficiency in donning, doffing,

and performance of functionality check for respiratory devices

J. List of respirators (available for use) by type (APR, SCBA, PAPR, etc.), manufacturer,

and model.

ML18128A066

SUNSI Review Non-Sensitive Publicly Available Keyword:

By: JDixon/rdr Sensitive Non-Publicly Available NRC-002

OFFICE SRI:DRP/D RI:DRP/D PE:DRP/D BC:DRS/EB1 BC:DRS/EB2 BC:DRS/PSB2

NAME FRamirez CSpeer JChoate TFarnholtz JDrake HGepford

SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/

DATE 5/7/18 5/4/18 5/7/18 5/3/2018 5/3/18 5/3/18

OFFICE BC:DRS/OB TL:DRS/IPAT SPE:DRP/D BC:DRP/D

NAME VGaddy GGeorge JDixon GMiller

SIGNATURE /RA/ /RA/ /RA/ /RA/

DATE 5/7/18 5/3/18 5/3/18 5/8/18