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| {{Adams | | {{Adams |
| | number = ML23312A183 | | | number = ML24022A189 |
| | issue date = 11/14/2023 | | | issue date = 01/23/2024 |
| | title = Integrated Inspection Report 05000382/2023003 and Notice of Violation | | | title = Acknowledgment of Reply to a Notice of Violation NRC Inspection Report 05000382/2023003 |
| | author name = Dixon J | | | author name = Warnick G |
| | author affiliation = NRC/RGN-IV/DORS/PBD | | | author affiliation = NRC/RGN-IV/DRSS/DIOR |
| | addressee name = Sullivan J | | | addressee name = Sullivan J |
| | addressee affiliation = Entergy Operations, Inc | | | addressee affiliation = Entergy Operations, Inc |
| | docket = 05000382 | | | docket = 05000382 |
| | license number = NPF-038 | | | license number = NPF-038 |
| | contact person = Sanchez A | | | contact person = |
| | document report number = IR 2023003 | | | document report number = IR 2023003 |
| | document type = Inspection Report, Letter, Notice of Violation | | | document type = Inspection Report, Letter |
| | page count = 26 | | | page count = 2 |
| }} | | }} |
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| =Text= | | =Text= |
| {{#Wiki_filter:November 14, 2023 | | {{#Wiki_filter: |
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| ==SUBJECT:==
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| WATERFORD STEAM ELECTRIC STATION, UNIT 3 - INTEGRATED INSPECTION REPORT 05000382/2023003 AND NOTICE OF VIOLATION
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| ==Dear Joseph Sullivan:==
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| On September 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Waterford Steam Electric Station, Unit 3. On October 16, 2023, the NRC inspectors discussed the results of this inspection with you and other members of your staff.
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| The results of this inspection are documented in the enclosed inspection report.
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| The enclosed report discusses a violation associated with a finding of very low safety significance (Green). The NRC evaluated this violation in accordance with Section 2.3.2 of the NRC Enforcement Policy, which can be found at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The violation is cited in Enclosure 1, Notice of Violation (Notice). The violation did not meet the criteria to be treated as a non-cited violation because Entergy Operations, Inc. (licensee) failed to periodically calibrate and process radiation monitors in a timely manner to restore compliance from the previous non-cited violation.
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| Specifically, the licensee failed to ensure that instruments (33 area and radiation monitors) and equipment used for quantitative radiation measurements were calibrated periodically for the radiation measured.
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| You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response. The NRCs review of your response will also determine whether further enforcement action is necessary to ensure your compliance with regulatory requirements.
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| If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
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| Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Waterford Steam Electric Station, Unit 3. If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at Waterford Steam Electric Station, Unit 3.
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| This letter, its enclosures, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
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| Sincerely, Signed by Dixon, John on 11/14/23 John L. Dixon, Jr., Chief Reactor Projects Branch D Division of Operating Reactor Safety Docket No. 05000382 License No. NPF-38
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| ===Enclosures:===
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| 1) Notice of Violation 2) Inspection Report 05000382/2023003
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| ==Inspection Report==
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| Docket No. 05000382 License No. NPF-38 Report No. 05000382/2023003 Enterprise Identifier: I-2023-003-0009 Licensee: Entergy Operations, Inc.
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| Facility: Waterford Steam Electric Station, Unit 3 Location: Killona, LA 70057 Inspection Dates: July 1, 2023, to September 30, 2023 Inspectors: C. Alldredge, Health Physicist D. Childs, Resident Inspector C. Harrington, Operations Engineer S. Hedger, Sr Emergency Preparedness Inspector J. O'Donnell, Senior Health Physicist A. Patz, Senior Resident Inspector H. Strittmatter, Emergency Preparedness Inspector T. Weir, Physical Security Inspector D. You, Operations Engineer Approved By: John L. Dixon, Jr., Chief Reactor Projects Branch D Division of Operating Reactor Safety Enclosure 2
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| =SUMMARY=
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| 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.
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| ===List of Findings and Violations===
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| Failure to Periodically Calibrate Radiation Monitors Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [P.3] - 71124.05 Radiation Safety NOV 05000382/2023003-01 Resolution Open The inspectors identified a violation (Green) of 10 CFR 20.1501(c) for failure to periodically calibrate area, process, and effluent radiation monitoring equipment used to perform (e.g.,
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| dose rate and effluent monitoring) measurements. Specifically, on or around July 2006, the licensee began changing the periodic calibrations of process, effluent, and area radiation monitors without proper technical justification or documented bases.
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| ===Additional Tracking Items===
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| Type Issue Number Title Report Section Status LER 05000382/2022-001-02 Non-Compliance with 71153 Closed Technical Specifications Due to Incorrect Procedural Guidance for Radiation Monitors LER 05000382/2022-001-01 Non-Compliance with 71153 Closed Technical Specifications Due to Incorrect Procedural Guidance for Radiation Monitors LER 05000382/2022-001-00 Non-Compliance with 71153 Closed Technical Specifications Due to Incorrect Conversion Factors in Three Gaseous Radiation Monitors E2-2
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| =PLANT STATUS=
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| Unit 3 operated at or near rated thermal power for the entire inspection period.
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| ==INSPECTION SCOPES==
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| Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
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| ==REACTOR SAFETY==
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| ==71111.04 - Equipment Alignment==
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| ===Partial Walkdown Sample (IP Section 03.01) (2 Samples)===
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| The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
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| : (1) emergency diesel generator B during emergency diesel generator A planned outage from August 7-8, 2023
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| : (2) auxiliary component cooling water train B and component cooling water train B following unplanned failure of auxiliary component cooling water pump A on August 31, 2023
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| ==71111.05 - Fire Protection==
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| ===Fire Area Walkdown and Inspection Sample (IP Section 03.01) (1 Sample)===
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| The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
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| : (1) fire area RAB-22-001, elevation +21.00' reactor auxiliaries building drumming station (hot tool room) on August 4, 2023
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| ==71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance==
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| ===Requalification Examination Results (IP Section 03.03) (1 Sample)===
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| : (1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered on June 19, to July 20, 2023.
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| E2-3
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| ==71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance==
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| ===Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)===
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| : (1) Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on June 28, 2023.
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| Annual Requalification Operating Tests The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.
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| Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.
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| Requalification Examination Security The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.
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| Remedial Training and Re-examinations The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.
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| Operator License Conditions The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.
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| Control Room Simulator The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.
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| Problem Identification and Resolution The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.
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| E2-4
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| ==71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance==
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| Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
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| (1 Sample)
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| : (1) The inspectors observed and evaluated licensed operator performance in the control room during reactor trip circuit breaker testing and during preparations for a planned outage of emergency diesel generator A on August 6, 2023.
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| ===Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)===
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| : (1) The inspectors observed and evaluated licensed operator simulator training involving a component cooling water pump room fire and a faulted steam generator tube rupture general emergency on August 15, 2023.
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| ==71111.13 - Maintenance Risk Assessments and Emergent Work Control==
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| ===Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)===
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| The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
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| : (1) elevated green risk due to a planned emergency diesel generator A outage from August 7-9, 2023
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| : (2) yellow risk due to heavy work in the Waterford switchyard concurrent with safety-related equipment surveillances from August 14-18, 2023
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| : (3) yellow risk due to unplanned failure of component cooling water cross-connect valve between pump A and pump AB from September 20-21, 2023
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| ==71111.15 - Operability Determinations and Functionality Assessments==
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| ===Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)===
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| The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
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| : (1) high pressure safety injection train A operability following high leakage during testing on July 11, 2023
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| : (2) containment spray pump A operability following identification of low component cooling water flow on July 25, 2023
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| : (3) reactor protection system operability following identification of errors in the steam generator narrow range reactor trip setpoint on August 9, 2023
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| : (4) startup transformers A and B following failure and isolation of multiple 230 kV breakers in the Waterford switchyard on September 14, 2023 E2-5
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| ==71111.18 - Plant Modifications==
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| Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
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| (1 Sample)
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| The inspectors evaluated the following temporary or permanent modifications:
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| : (1) auxiliary component cooling water pump A motor was replaced with the component cooling water pump AB motor on September 4, 2023
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| ==71111.24 - Testing and Maintenance of Equipment Important to Risk==
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| The inspectors evaluated the following testing and maintenance activities to verify system
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| ===operability and/or functionality: Post-Maintenance Testing (PMT) (IP Section 03.01)===
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| {{IP sample|IP=IP 71111.24|count=8}}
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| : (1) control room air conditioning train B following unplanned failure to start of air handler AH-12B on July 20, 2023
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| : (2) high pressure safety injection pump A following relief valve replacement on July 27, 2023
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| : (3) dry cooling tower fan 11B after planned maintenance on August 16, 2023
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| : (4) emergency diesel generator B after planned maintenance on August 23, 2023
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| : (5) auxiliary component cooling water pump A following failure of motor on September 4, 2023
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| : (6) containment particulate radiation monitors following failure on September 25, 2023
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| : (7) containment fan cooling train B following failure of temperature control valve on September 26, 2023
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| : (8) spent fuel pool pump B following pump replacement on September 28, 2023
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| ===Surveillance Testing (IP Section 03.01) (3 Samples)===
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| : (1) high pressure safety injection pump B on July 26, 2023
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| : (2) reactor trip circuit breaker testing on August 6, 2023
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| : (3) emergency diesel generator A overspeed testing on August 10, 2023
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| ===Reactor Coolant System Leakage Detection Testing (IP Section 03.01) (1 Sample)===
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| : (1) reactor coolant system leakage calculation on July 20, 2023
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| ==71114.01 - Exercise Evaluation==
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| ===Inspection Review (IP Section 02.01-02.11) (1 Sample)===
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| : (1) The inspectors evaluated the biennial emergency plan exercise conducted on June 21, 2023. The exercise scenario simulated a reactor coolant pump seal failure followed by a loss of coolant accident, increasing plant and containment radiation levels, multiple failures in high pressure safety injection sub-systems, followed by continued escalating containment radiation levels coupled with a loss of containment spray function. This scenario was complicated later with a penetration failure in containment, involving a simulated radiological release offsite. The licensee E2-6
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| completed its critique process for the exercise on July 10, 2023, and the inspectors subsequently evaluated the effectiveness of the critique process to identify performance weaknesses and deficiencies to ensure they were entered into the corrective action program for resolution.
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| This documents completion of this inspection sample which was documented as a partial sample in Inspection Report 05000382/2023002 (ADAMS Accession No.
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| ML23216A106).
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| ==71114.06 - Drill Evaluation==
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| Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)
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| (1 Sample)
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| : (1) The inspectors evaluated an emergency preparedness drill involving an earthquake and spent fuel pool loss of coolant inventory on August 30, 2023
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| ===Drill/Training Evolution Observation (IP Section 03.02) (2 Samples)===
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| The inspectors evaluated:
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| : (1) simulator based training for a loss of reactor coolant accident on August 29, 2023
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| : (2) simulator based training for a security threat and automatic failure to shut down the reactor on September 6,
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| ==RADIATION SAFETY==
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| ==71124.05 - Radiation Monitoring Instrumentation==
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| ===Walkdowns and Observations (IP Section 03.01) (8 Samples)===
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| The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
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| : (1) portable survey instruments ready for use at the west side access to the radiologically controlled area
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| : (2) portable survey instruments in storage, but available for use in the instrument lab
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| : (3) area radiation monitors in auxiliary building
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| : (4) process radiation monitors in the auxiliary building
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| : (5) effluent radiation monitors in the auxiliary building
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| : (6) personnel contamination monitors at the exit(s) to the radiologically controlled area (east and west)
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| : (7) chemistry count room instruments (gamma spectroscopy and liquid scintillation)
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| : (8) portal monitors and friskers at the exit to the protected area
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| ===Calibration and Testing Program (IP Section 03.02) (12 Samples)===
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| The inspectors evaluated the calibration and testing of the following radiation detection instruments:
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| : (1) Ludlum Model 177, CHP-CR-192, frisker E2-7
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| : (2) Ludlum Model 3030, CHP-C-060, scaler
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| : (3) Thermo Scientific AMS-4, HP-RD-264, continuous air sampler
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| : (4) Mirion TelePole II, CHP-TEL173, wide range telescopic survey meter
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| : (5) Ludlum Model 9-3, CHP-Dr-400, ion chamber
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| : (6) Ludlum Model 12-4, CHP-MF-154, neutron dose rate
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| : (7) Mirion iSolo, HP-CS-020, scaler
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| : (8) Mirion GEM-5, HP-DS-094, gamma exit monitor
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| : (9) Mirion ARGOS-5AB, HP-DS-103, personnel contamination monitor
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| : (10) Mirion CRONOS, HP-DS-110, tool/equipment monitor
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| : (11) General Atomic ARMIR0300,2, fuel handling building airborne isolation radiation monitor
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| : (12) General Atomic ARMIR5500-A, main steam line radiation monitor Effluent Monitoring Calibration and Testing Program Sample (IP Section 03.03) (2 Samples)
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| The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
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| : (1) PRMIR0647, waste condensate and laundry waste discharge radiation monitor
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| : (2) PRMIR5700, component cooling water loop return header radiation monitor
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| ==71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &==
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| Transportation
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| ===Radioactive Material Storage (IP Section 03.01)===
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| {{IP sample|IP=IP 71124.08|count=3}}
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| The inspectors evaluated the licensees performance in controlling, labeling, and securing the following radioactive materials:
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| : (1) intermodal containers containing oil drums, dry active waste, and outage supplies and shielding of boxes and refuel equipment in the west yard and south yard
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| : (2) source storage lockers and J.L. Shepherd calibrator in primary chemistry lab.
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| : (3) two process shields for resin and one process shield for filter in the solidification building
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| ===Radioactive Waste System Walkdown (IP Section 03.02) (1 Sample)===
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| The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:
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| : (1) liquid waste management system and portions of the resin waste management system
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| ===Waste Characterization and Classification (IP Section 03.03) (3 Samples)===
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| The inspectors evaluated the following characterization and classification of radioactive waste:
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| : (1) reactor coolant system 2023 10 CFR Part 61 waste stream
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| : (2) liquid waste management 2023 Part 61 waste stream
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| : (3) resin waste management 2022 Part 61 waste stream E2-8
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| Shipment Preparation (IP Section 03.04)
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| No shipment was available for observation during this inspection.
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| ===Shipping Records (IP Section 03.05) (4 Samples)===
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| The inspectors evaluated the following non-excepted radioactive material shipments through a record review:
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| : (1) RSN-22-1010 dry active waste/metal, May 19, 2022
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| : (2) RSN-22-1017 CVC resin, July 28, 2022
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| : (3) RSN-23-1001 dry active waste/metal, April 5, 2023
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| : (4) RSN-23-2048 reactor coolant pump seal, September 7,
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| ==OTHER ACTIVITIES - BASELINE==
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| ===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
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| MS08: Heat Removal Systems (IP Section 02.07) ===
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| {{IP sample|IP=IP 71151|count=1}}
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| : (1) Unit 3 (July 1, 2022, through June 30, 2023)
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| ===MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)===
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| : (1) Unit 3 (July 1, 2022, through June 30, 2023)
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| ===MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)===
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| : (1) Unit 3 (July 1, 2022, through June 30, 2023)
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| ===71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02) ===
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| {{IP sample|IP=IP 71152|count=1}}
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| : (1) The inspectors reviewed the licensees corrective action program for potential adverse trends that might be indicative of a more significant safety issue. The inspectors performed an in-depth review of repeat equipment failures. During this review, the inspectors noted an adverse trend in the number of issues that fail at least twice. This trend is detailed in an observation in the results section of this report. No more than minor concerns were identified.
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| ===71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP section 03.02) ===
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| {{IP sample|IP=IP 71153|count=1}}
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| The inspectors evaluated the following licensee event reports (LERs):
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| E2-9
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| : (1) LER 05000382/2022-001-00, 05000382/2022-001-01, and 05000382/2022-001-02, Non-Compliance with Technical Specifications Due to Incorrect Procedural Guidance for Radiation Monitors (ADAMS Accession No. ML23053A354). The inspection conclusions associated with this LER and two updates are documented in Inspection Report 05000382/2023040. An additional inspection conclusion regarding reporting timeliness is documented in this report under Inspection Results Section 71153. This LER and updates are closed.
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| ==INSPECTION RESULTS==
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| Failure to Periodically Calibrate Radiation Monitors Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [P.3] - 71124.05 Radiation Safety NOV 05000382/2023003-01 Resolution Open The inspectors identified a violation (Green) of 10 CFR 20.1501(c) for failure to periodically calibrate area, process, and effluent radiation monitoring equipment used to perform (e.g.,
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| dose rate and effluent monitoring) measurements. Specifically, on or around July 2006, the licensee began changing the periodic calibrations of process, effluent, and area radiation monitors without proper technical justification or documented bases.
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| =====Description:=====
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| As a result of the previous radiation safety inspection conducted in November 2021, the licensee was issued a non-cited violation (NCV) for failure to ensure monitors used for quantitative radiation measurements were calibrated periodically for the radiation measured. The failure to periodically calibrate area, process, and effluent radiation monitors was documented in inspection report 05000382/2021004 as NCV 05000382/2021004-01, Failure to Periodically Calibrate Radiation Monitors, (ADAMS Accession Number ML22028A000). The original violation documented 29 of 41 radiation monitors as being overdue on their required calibration frequencies. This NCV was entered into the licensees corrective action program as condition report CR-WF3-2022-00851.
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| There were two aspects to the prior NCV:
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| : (1) the changing of the calibration frequencies without technical justification and
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| : (2) the failure to periodically calibrate the radiation monitors themselves. During the onsite inspection, July 24-28, 2023, the inspectors determined the aspect of changing the calibration frequencies without a technical justification was addressed by the licensee. The licensees Final Safety Analysis Report in chapter 11, section 2.5.2 specified an 18-month calibration frequency for process and effluent monitors. The inspectors reviewed several change requests, dated October 21, 2021, to remove the unjustified extension of the calibration frequencies, specifically the 6.75-year and 9-year frequencies.
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| These change requests were more encompassing and included more than the 41 radiation monitors as described in the prior NCV. The change requests were submitted through the licensees preventive maintenance program which included a work order process to schedule the calibrations at specified frequencies. However, the inspectors determined that the licensee had not periodically calibrated the radiation monitors within their specified frequencies.
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| The NRC Enforcement Policy (Accession Number ML22336A179), section 2.3.2.a described the conditions that allow the NRC to issue NCVs to licensees with credited corrective action programs. Section 2.3.2.a.2 states, in part, that the licensee must restore compliance (or demonstrate objective evidence of plans to restore compliance) within a reasonable period E2-10
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| after a violation has been identified.
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| Since November 2021, the licensee had not demonstrated progress toward restoring compliance by calibrating the overdue radiation monitors. The inspectors determined approximately 68 percent of the 41 radiation monitors were outside their new calibration frequencies. In addition, the information requested by the inspectors showed that only one of the 29 radiation monitors had been calibrated since the previous inspection.
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| During the review of the licensees progress toward restoring compliance, the licensee provided information on the calibration status of 44 area and process radiation monitors not specifically covered by technical specifications, technical requirements manual, or the offsite dose calculation manual. Of the 44 radiation monitors described, 33 were shown as past due for the new calibration frequencies, with three additional radiation monitor calibrations due within two months after the inspection. This information also showed that 20 of the 33 monitors were already beyond the 6.75-year frequency. Of these 20, three exceeded the 9-year frequency and six were simply identified as greater than 8 years.
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| The licensees preventive maintenance program and work order process failed to adequately schedule and complete the radiation monitor calibrations in a timely manner to restore compliance. The prior violation had identified 29 radiation monitors overdue at the time of that inspection. Of the 29 radiation monitors, four were process radiation monitors that required repair prior to calibration. The inspectors observed two of these process radiation monitors not functioning (turned off) during one of the walkdowns (plant tours). In the 20 months since the previous inspection, the calibration of process radiation monitors should have been conducted at least once with an 18-month calibration frequency.
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| Corrective Actions: The prior NCV's corrective action focused on correcting the calibration frequency in the work management process. At the conclusion of the current inspection, the licensee had calibrated only one radiation monitor as identified in the previous NCV within the last 20 months (since November 2021). The licensee has entered this repetitive issue in their corrective action program to create a plan to restore compliance with 10 CFR 20.1501(c).
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| Corrective Action References: CR-WF3-2023-14818
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| =====Performance Assessment:=====
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| Performance Deficiency: Failure to periodically calibrate area and process radiation monitors in accordance with license commitments and regulatory requirements.
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| Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Plant Facilities/Equipment and Instrumentation attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation.
| |
| | |
| Specifically, an ineffective radiation program barrier was identified when radiation monitors were observed to be non-functional (i.e., turned off).
| |
| | |
| Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix C, Occupational Radiation Safety SDP. The inspectors determined the finding had a very low safety significance (Green) because:
| |
| : (1) it was not associated with ALARA planning and work controls,
| |
| : (2) it was not an overexposure,
| |
| : (3) there was no potential for an overexposure; and
| |
| : (4) the ability to assess dose was not compromised.
| |
| | |
| E2-11
| |
| | |
| Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to address issues in a timely manner commensurate with their safety significance. Specifically, the licensee failed to schedule and perform timely calibrations of radiation monitors to restore compliance from a previous NCV documented in CR-WF3-2022-00851.
| |
| | |
| =====Enforcement:=====
| |
| Violation: Title 10 CFR 20.1501(c) states, in part, that the licensee shall ensure that instruments and equipment used for quantitative radiation measurements are calibrated periodically for the radiation measured.
| |
| | |
| Contrary to the above, from November 2021 to September 30, 2023, the licensee failed to ensure that instruments (radiation monitors) and equipment used for quantitative radiation measurements were calibrated periodically for the radiation measured. Specifically, the licensee failed to periodically calibrate 33 area and process radiation monitors.
| |
| | |
| Enforcement Action: This violation is being cited because the licensee failed to restore compliance within a reasonable period after the violation was identified consistent with Section 2.3.2 of the Enforcement Policy.
| |
| | |
| Observation: 71152S The inspectors reviewed the licensees corrective action program to identify performance trends that might indicate the existence of a more significant safety issue The inspectors noted a trend in human performance. Specifically, the inspectors noted six events in which the licensee had repeat issues that significantly impacted plant operations over the last cycle, from May 2022 to October 2023. Examples include:
| |
| * CR-WF3-2022-04112: Auxiliary component cooling water pump B failed due to a bearing high temperature on May 8, 2022. The bearing was repaired and failed again on May 23, 2022.
| |
| * CR-WF3-2022-05956: Control element assembly 45 caused an alarm in the control room for high voltage on December 9, 2021. The assembly was returned to normal service and the issue repeated on August 18, 2022.
| |
| * CR-WF3-2022-06302: Plant protection system power supply 28 tripped on overvoltage on April 1, 2021. The licensee attempted to identify the cause during the subsequent refueling outage. The power supply tripped again on overvoltage on September 6, 2022.
| |
| * CR-WF3-2023-15308: One of the two let down pressure control valves failed on August 27, 2023. The licensee identified water in the compressed air line and returned the valve to service. The valve caused another transient on August 31, 2023.
| |
| * CR-WF3-2023-15909: Spent fuel pool pump B experienced leakage issues on March 24, 2023. The reworked pump was brought back onsite after 6 months and had similar issues on September 28, 2023.
| |
| * CR-WF3-2023-15947: The train B containment fan cooler flow control valve was not providing adequate flow rates on September 19, 2023. The valve was returned to service and exhibited issues again on October 2, 2023.
| |
| | |
| The inspectors did not identify any findings or more-than-minor violations. The licensee identified and performed initial corrective actions as well as follow-up corrective actions for all E2-12
| |
| | |
| these issues. In response to this observation, the licensee documented the trend in CR-WF3-2023-16108.
| |
| | |
| Minor Violation 71153 Minor Violation Minor Violation: All safety-related radiation monitors were being examined as part of an extent of condition review beginning in January 2022 following identification of incorrect engineering conversion factors for multiple wide range gas monitors. These issues were first described in Licensee Event Report 05000382/2022-001-00, Non-Compliance with Technical Specifications Due to Incorrect Conversion Factors in Three Gaseous Radiation Monitors.
| |
| | |
| These issues were dispositioned by the NRC as a White finding in inspection report 05000382/2022090 (ADAMS Accession Number ML22241A143) and reviewed via a supplemental inspection in accordance with Inspection Procedure 95001 in inspection report 05000382/2023040 (ADAMS Accession Number ML23145A227).
| |
| | |
| On November 16, 2022, as part of the extent of condition review, the licensee identified that three component cooling water radiation monitors had incorrect engineering correction factors. These monitors check for radiation that leaks from connecting systems into the normally clean, closed-circuit CCW system. The correction factors were based on the detectors response to cobalt-60 instead of cesium-137, causing the sensitivity of the detectors to be approximately 46 percent lower than the expected response. The licensee recalibrated the CCW radiation monitors on November 17, 2022. The CCW radiation monitors were found to have been incorrectly calibrated for longer than the allowed outage time in technical specification 3.3.3.1 and therefore required an LER in accordance with 10 CFR 50.73(a)(2)(i)(B). The licensee provided this information to the NRC in LER 05000382/2022-001-02 on February 22, 2023, or about 98 days after identification of the issue. This delay does not meet the requirements of 10 CFR 50.73(a)(1) to submit a Licensee Event Report within 60 days of discovery of the event.
| |
| | |
| Screening: The inspectors determined the violation was minor. The failure to submit a LER in accordance with 10 CFR 50.73 is an example of a Severity Level IV violation in accordance with section 6.9 of the NRC Enforcement Policy. However, the event report was submitted by the licensee before NRC identification and did not impact the ability of the NRC to perform its regulatory oversight function. Therefore, the violation is considered minor in accordance with section 2.2.1 of the NRC Enforcement Policy.
| |
| | |
| =====Enforcement:=====
| |
| This failure to comply with 10 CFR 50.73(a)(1) constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. This minor violation, in addition to inspection report 05000382/2023040 (ADAMS Accession No.
| |
| | |
| ML23192A764), closes LER 05000382/2022-001-02.
| |
| | |
| E2-13
| |
| | |
| ==EXIT MEETINGS AND DEBRIEFS==
| |
| The inspectors verified no proprietary information was retained or documented in this report.
| |
| * On June 29, 2023, the inspectors presented the exam technical debrief inspection results to Robbie Ledet, Operations Director, and other members of the licensee staff.
| |
| * On July 12, 2023, the inspectors presented the emergency preparedness exercise inspection results to John Ferrick, Site Vice President, and other members of the licensee staff.
| |
| * On August 7, 2023, the inspectors presented the public radiation safety inspection results to Joseph Sullivan, Site Vice President, and other members of the licensee staff.
| |
| * On August 14, 2023, the inspectors presented the exam exit meeting inspection results to Joseph Sullivan, Site Vice President, and other members of the licensee staff.
| |
| * On October 16, 2023, the inspectors presented the integrated inspection results to Joseph Sullivan, Site Vice President, and other members of the licensee staff.
| |
| | |
| E2-14
| |
| | |
| =DOCUMENTS REVIEWED=
| |
| | |
| Inspection Type Designation Description or Title Revision or
| |
| Procedure Date
| |
| 71111.04 Procedures OP-002-001 Auxiliary Component Cooling Water 320
| |
| 71111.04 Procedures OP-002-003 Component Cooling Water 322
| |
| 71111.04 Procedures OP-009-002 Emergency Diesel Generator 360
| |
| 71111.05 Drawings G-FP-0021 Fire Detection System Raceway & Equipment Layout 0
| |
| Reactor Auxiliary Building EL +21.00'
| |
| 71111.05 Fire Plans RAB 22-001 Drumming Station (Hot Tool Room) 7
| |
| 71111.11B Corrective Action CR-WF3-YYYY- 2021-04665, 2022-03323, 2022-05400, 2022-06858
| |
| Documents NNNN
| |
| 71111.11B Miscellaneous Waterford Credit for Standing Watch Logs (8/1/21 to
| |
| 5/25/23)
| |
| 71111.11B Miscellaneous Checklist for Upgrading from Inactive to Active Status 314
| |
| 71111.11B Miscellaneous 2023 Week 2 SRO/RO Written Exam
| |
| 71111.11B Miscellaneous Waterford Operator Medical Records
| |
| 71111.11B Miscellaneous Waterford 2023 Week 1 and 2 Scenarios and JPMs
| |
| 71111.11B Miscellaneous SBT Package - 2022 NRC Initial Exam Scenario 3 11/28/2021
| |
| 71111.11B Miscellaneous Post-Event Simulator Test - April 12, 2023, and August 2,
| |
| 22
| |
| 71111.11B Miscellaneous Simulator Baseline Testing Data 06/20/2023
| |
| 71111.11B Miscellaneous Tracking Tool Prevent Overlap Written Exam - 2023
| |
| Written Exam Worksheet
| |
| 71111.11B Miscellaneous Tracking Tool Prevent Overlap Operating Test - 2023
| |
| Annual Exam Tracking and 2023 JPM Matrix
| |
| 71111.11B Miscellaneous 2021 Biennial Written SRO Remedial Exam
| |
| 71111.11B Miscellaneous DR 17-0193
| |
| 71111.11B Miscellaneous DR 21-0096
| |
| 71111.11B Miscellaneous DR 23-0004
| |
| 71111.11B Miscellaneous DR 23-0025
| |
| 71111.11B Miscellaneous DR 23-0031
| |
| 71111.11B Miscellaneous DR 23-0042
| |
| 71111.11B Miscellaneous DR 23-0059
| |
| 71111.11B Miscellaneous DR-23-0055
| |
| E2-15
| |
| Inspection Type Designation Description or Title Revision or
| |
| Procedure Date
| |
| 71111.11B Miscellaneous TQF-202-SRB Simulator Review Board (SRB) Meeting Minutes 02/01/2023
| |
| 71111.11B Miscellaneous WSIM-DIR-003 Simulator Operability Testing - Cycle 25 11/23/2022
| |
| 71111.11B Procedures Simulator Differences List 06/20/2023
| |
| 71111.11B Procedures EN-NS-112 Medical Program 23
| |
| 71111.11B Procedures EN-OP-115-06 Activation and Deactivation of Licenses, and Maintaining 3
| |
| Active License Status
| |
| 71111.11B Procedures EN-TQ-100 Operations Training Program Description 3
| |
| 71111.11B Procedures EN-TQ-202 Simulator Configuration Control 12
| |
| 71111.11B Procedures EN-TQ-210 Conduct of Simulator Training 17
| |
| 71111.11B Procedures EN-TQ-217 Exam Security 12
| |
| 71111.11B Procedures TQF-210-CC01 Crew Critique
| |
| 71111.11B Procedures WTRN-OPS- Site Simulator Exam Security Checklist 1
| |
| SIMEXAMSECURITY
| |
| 71111.11Q Procedures EN-OP-115 Conduct of Operations 31
| |
| 71111.11Q Procedures EP-001-001 Recognition and Classification of Emergency Conditions 37
| |
| 71111.11Q Procedures OP-903-006 Reactor Trip Circuit Breaker Test 16
| |
| 71111.11Q Work Orders 53036043, 54006929
| |
| 71111.12 Miscellaneous TD G080.0095 General Electric Switchgear Magne Blast Breakers 6
| |
| 71111.12 Procedures EN-DC-205 Maintenance Rule Monitoring 9
| |
| 71111.12 Procedures ME-004-115 4.16/6.9 kV G.E. Magne-Blast Breaker Overhaul 6
| |
| 71111.12 Work Orders 527902555, 00517244
| |
| 71111.13 Procedures EN-WM-101 On-Line Work Management Process 25
| |
| 71111.13 Procedures EN-WM-104 On-Line Risk Assessment 27
| |
| 71111.15 Calculations ECI92-019 Plant Protection System Setpoint Uncertainty Calculation 5
| |
| 71111.15 Corrective Action CR-WF3-YYYY- 2023-14217, 2023-14854, 2023-14895, 2023-15179,
| |
| Documents NNNN 2023-15245, 2023-15993, 2023-15602, 2023-15603,
| |
| 23-15604, 2023-15605
| |
| 71111.15 Corrective Action OP-903-030 Safety Injection Pump Operability Verification 41
| |
| Documents
| |
| 71111.15 Corrective Action CR-WF3-YYYY- 2023-14746, 2023-14747
| |
| Documents NNNN
| |
| Resulting from
| |
| Inspection
| |
| E2-16
| |
| Inspection Type Designation Description or Title Revision or
| |
| Procedure Date
| |
| 71111.15 Procedures PE-004-024 309
| |
| 71111.18 Corrective Action CR-WF3-YYYY- 2023-15311
| |
| Documents NNNN
| |
| 71111.18 Engineering EC 54046818 ACCEMTR3A-3 Motor Comparison and EQ Evaluation 09/03/2023
| |
| Changes
| |
| 71111.24 Corrective Action CR-WF3-YYY-NNNN 2023-15594, 2023-15671, 2023-15909, 2023-14384,
| |
| Documents 2023-14396
| |
| 71111.24 Engineering EC 54056366 Containment PIG 09/25/2023
| |
| Evaluations
| |
| 71111.24 Procedures ME-004-021 Emergency Diesel Generator 40
| |
| 71111.24 Procedures ME-007-006 480 VAC and Less Squirrel Cage Induction Motors 22
| |
| 71111.24 Procedures MI-003-377 Containment Atmospheric Particulate and Gaseous 318
| |
| Radiation Monitor
| |
| 71111.24 Procedures OI-040-000 Reactor Coolant System Leakage Monitoring 18
| |
| 71111.24 Procedures OP-002-003 Component Cooling Water 322
| |
| 71111.24 Procedures OP-002-006 Fuel Pool Cooling and Purification 331
| |
| 71111.24 Procedures OP-003-014 Control Room Heating and Ventilation 311
| |
| 71111.24 Procedures OP-009-002 Emergency Diesel Generator 360
| |
| 71111.24 Procedures OP-009-008 Safety Injection System 48
| |
| 71111.24 Procedures OP-903-002 Emergency Diesel Generator and Subgroup Relay 327
| |
| Operability Verification
| |
| 71111.24 Procedures OP-903-006 Reactor Trip Circuit Breaker Test 16
| |
| 71111.24 Procedures OP-903-008 Reactor Coolant System Isolation Leakage Test 26
| |
| 71111.24 Procedures OP-903-024 Reactor Coolant System Water Inventory Balance 26
| |
| 71111.24 Procedures OP-903-030 Safety Injection Pump Operability Verification 41
| |
| 71111.24 Procedures OP-903-037 Containment Cooling Fan Operability Verification 7
| |
| 71111.24 Procedures OP-903-050 Auxiliary Component Cooling Water Pump and Valve 47
| |
| Operability Test
| |
| 71111.24 Work Orders 52950139, 52988195, 54017890, 54026996
| |
| 71114.01 Corrective Action Condition Reports 13881, 13921, 13922, 13931, 13932, 13951, 13952,
| |
| Documents (CR-WF3-) 13960, 13961, 13962, 13964, 13965, 13967, 13969,
| |
| 13970, 13971, 14019, 14046, 14049, 14053, 14249
| |
| 71114.01 Miscellaneous Management Debrief, 6/21/23 NRC/FEMA Evaluated 07/10/2023
| |
| E2-17
| |
| Inspection Type Designation Description or Title Revision or
| |
| Procedure Date
| |
| Exercise
| |
| 71114.06 Procedures EP-001-001 Recognition and Classification of Emergency Conditions 37
| |
| 71114.06 Procedures OP-901-111 Reactor Coolant System Leak 307
| |
| 71114.06 Procedures OP-901-403 High Airborne Activity in Containment 4
| |
| 71114.06 Procedures OP-901-405 Fuel Handling Incident 8
| |
| 71114.06 Procedures OP-901-525 Security Threat 20
| |
| 71114.06 Procedures OP-902-000 Standard Post Trip Actions 17
| |
| 71114.06 Procedures OP-902-002 Loss of Coolant Accident Recovery 21
| |
| 71114.06 Procedures OP-902-009 Standard Appendices 323
| |
| 71124.05 Calibration 52982382-01 ARMIR5400-B Calibrate Radiation Monitor Electronics 06/13/2023
| |
| Records
| |
| 71124.05 Calibration 52993552-01 AMIR5500-B Main Steam Line Radiation Monitor Chanel 06/25/2023
| |
| Records Calibration
| |
| 71124.05 Calibration CHP-ARM046 Portable Instrumentation Calibration Data Sheet 10/10/2022
| |
| Records Amp-100, area radiation monitor
| |
| 71124.05 Calibration CHP-CR-227 Portable Instrumentation Calibration Data Sheet 03/07/2022
| |
| Records LM-177, Frisker
| |
| 71124.05 Calibration CHP-DR-664 Portable Instrumentation Calibration Data Sheet 07/19/2022
| |
| Records Model 9-3, ion chamber
| |
| 71124.05 Calibration Detector 4 - 125 mL Efficiency Verification Worksheet 06/19/2023
| |
| Records Charcoal 125 milliliter charcoal bottles for Detector 4
| |
| 71124.05 Calibration Detector 6 - 1 L Efficiency Verification Worksheet 09/15/2022
| |
| Records Marinelli 1 Liter Marinelli container for Detector 6
| |
| 71124.05 Calibration Detector 6 - Filter Efficiency Verification Worksheet 09/27/2022
| |
| Records 47-millimeter glass fiber filter for Detector 6
| |
| 71124.05 Calibration FastScan Calibration of the Dosimetry FastScan Whole-Body 03/08/2023
| |
| Records Counting System
| |
| 71124.05 Calibration HP-RD-300 Portable Instrumentation Calibration Data Sheet 07/20/2022
| |
| Records AMS-4, airborne particulate detector
| |
| 71124.05 Calibration Source 87-CS-S-117 Confirmation of J.L. Shephard Model 78-2M 03/30/2023
| |
| Records 400 Curie Cs-137 Source
| |
| 71124.05 Calibration Source KR2723 Confirmation of J.L. Shephard Model 78-2M 03/30/2023
| |
| Records 130 millicurie Cs-137 Source
| |
| 71124.05 Corrective Action CR-WF3-YYYY- 2015-00182, 2015-00186, 2016-05176, 2018-01348,
| |
| E2-18
| |
| Inspection Type Designation Description or Title Revision or
| |
| Procedure Date
| |
| Documents XXXXX 2019-04721, 2021-03832, 2022-00851, 2022-00852,
| |
| 22-01430, 2022-01699, 2022-03151, 2022-04636,
| |
| 22-04815, 2022-07729, 2023-01153, 2023-13271,
| |
| 23-13721, 2023-13758, 2023-14157
| |
| 71124.05 Corrective Action CR-WF3-YYYY- 2023-14488, 2023-14540, 2023-14818
| |
| Documents XXXXX
| |
| Resulting from
| |
| Inspection
| |
| 71124.05 Miscellaneous ARMIRE5500-A/B Main Steam Line Radiation Monitor Readout Comparison 07/25/2023
| |
| 71124.05 Miscellaneous PRM+46 Wing PS Plant Stack Process Flow Chart 01/01/2020
| |
| Process 2 Flow through
| |
| 06/01/2023
| |
| 71124.05 Miscellaneous W3F1-2023-0036 Special Report SR-2023-003-01 05/04/2023
| |
| Radiation Monitor Inoperable Greater Than 7 days
| |
| 71124.05 Procedures EN-RP-317-08 Calibration of Portable Scalers 3
| |
| 71124.05 Procedures MI-003-360 Containment High Range Safety Channel A or B Area 317
| |
| Radiation Monitor Calibration
| |
| ARMIR5400 A or ARMIR5400 B
| |
| 71124.05 Procedures MI-003-365 Fuel Handling Building Ventilation Monitor Safety 15
| |
| Channel A or B Calibration
| |
| ARMIR300.1, ARMIR300.2, ARMIR300.3, or
| |
| ARMIR300.4
| |
| 71124.05 Procedures MI-003-389 Main Steam Line Radiation Monitor Channel Calibration 314
| |
| ARMIR5500A or ARMIR5500B
| |
| 71124.05 Procedures MI-003-459 Component Cooling Water Return Header from 307
| |
| Containment Liquid Radiation Monitor
| |
| Channel Calibration PRM-IR-5700
| |
| 71124.05 Procedures MI-005-910 Mobile Airborne Radiation Monitor Calibration, 9
| |
| ARMIR5132, ARMIR5144
| |
| 71124.05 Procedures MI-005-913 Reactor Auxiliary Building Duct Airborne Radiation 307
| |
| Monitor Calibration PRMIR6710 A, B, C, or D
| |
| 71124.05 Procedures MI-005-918 General Atomic High Range Area Radiation Monitor 13
| |
| Assemblies 0359-470
| |
| 71124.05 Procedures MI-005-920 General Atomic Area Radiation Monitor Assemblies 310
| |
| E2-19
| |
| Inspection Type Designation Description or Title Revision or
| |
| Procedure Date
| |
| 0359-3501 and 0359-3502
| |
| 71124.05 Procedures UNT-005-014 Offsite Dose Calculation Manual 309
| |
| 71124.05 Self- LO-WLO-2021-0065 Pre-NRC Self-Assessment, IP71124.05 Radiation 05/31/2023
| |
| Assessments Monitoring Instrumentation
| |
| 71124.05 Self- QA-2/6-2021-W3-1 Quality Assurance Audit Report: 10/05/2021
| |
| Assessments Combined Chemistry, Effluents and Environmental
| |
| Monitoring
| |
| 71124.08 Corrective Action CR-WF3-YYYY- 2021-06506, 2021-06530; 2021-06613, 2022-00853,
| |
| Documents XXXXX 2022-01302, 2022-03092, 2022-03196, 2022-04189,
| |
| 22-05026, 2022-05444, 2022-06079, 2022-06708,
| |
| 22-06969, 2022-07572, 2022-07593, 2022-07668,
| |
| 22-00651, 2022-00916, 2022-00987, 2022-01936,
| |
| 22-01988
| |
| 71124.08 Miscellaneous Annual Radioactive Effluent Release Report CY 2022 04/24/2023
| |
| 71124.08 Miscellaneous EN-RP-143 Semi-Annual Sealed Source Leak Test 05/24/2023
| |
| 71124.08 Miscellaneous IAW EN-RP-143 Semi-Annual Source Inventory 11/02/2022
| |
| 71124.08 Miscellaneous LWM 2023 L97480 Liquid Waste Management Part 61 Analysis 09/14/2022
| |
| 71124.08 Miscellaneous PMID 16018-01 Semi-Annual Sealed Source Leak Test 11/02/2022
| |
| 71124.08 Miscellaneous RCS 2023 L98656-1 RCS 2023 Part 61 Analysis 01/23/2023
| |
| 71124.08 Miscellaneous RWM 22 Apr Resin Waste Management Part 61 Analysis 05/22/2022
| |
| L96067-1
| |
| 71124.08 Procedures EN-RP-121 Radioactive Material Control 18
| |
| 71124.08 Procedures EN-RP-121-01 Receipt of Radioactive Material 7
| |
| 71124.08 Procedures EN-RP-143 Source Control 14
| |
| 71124.08 Procedures EN-RW-102 Radioactive Shipping Procedure 20
| |
| 71124.08 Procedures EN-RW-104 Scaling Factors 14
| |
| 71124.08 Procedures EN-RW-105 Process Control Program 5
| |
| 71124.08 Procedures EN-RW-106 Integrated Transportation Security Plan 7
| |
| 71124.08 Procedures Energy Solutions CS- Bead Resin/Activated Carbon Dewatering Procedure for 2
| |
| OP-PR-010-161017 Energy Solutions 14-215 Or Smaller Liners, Utilizing
| |
| Energy Solutions Self-Engaging Dewatering System
| |
| (SEDS) at Waterford 3
| |
| 71124.08 Self- LO-WLO-2021-00065 Focused Self-Assessment/ Formal Benchmark Report -
| |
| Assessments CA00003 IP 71124.08
| |
| E2-20
| |
| Inspection Type Designation Description or Title Revision or
| |
| Procedure Date
| |
| 71124.08 Shipping Records 22-1010 DAW/Metal 05/19/2022
| |
| 71124.08 Shipping Records 22-1017 CVC Resin 07/28/2022
| |
| 71124.08 Shipping Records 22-3048 RCP Seal Box WF-501 and B-25 09/07/2022
| |
| 71124.08 Shipping Records 23-1003 DAW/Metal 04/05/2023
| |
| 71124.08 Work Orders Quarterly Packaging Inspection 12/13/2021
| |
| 71124.08 Work Orders Quarterly Packaging Inspection 03/30/2022
| |
| 71124.08 Work Orders Quarterly Packaging Inspection 06/15/2023
| |
| 71124.08 Work Orders Quarterly Packaging Inspection 09/14/2022
| |
| 71124.08 Work Orders Quarterly Packaging Inspection 12/01/2022
| |
| 71124.08 Work Orders Quarterly Packaging Inspection 03/02/2023
| |
| 71124.08 Work Orders Quarterly Packaging Inspection 06/14/2023
| |
| E2-21
| |
| }} | | }} |
