IR 05000382/2018001

Waterford Steam Electric Station, Unit 3 - NRC Integrated Inspection Report 05000382/2018001

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

Text

May 8, 2018

Mr. John Dinelli Site Vice President Entergy Operations, Inc.

17265 River Road Killona, LA 70057-0751

SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED INSPECTION REPORT 05000 382/2018001

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 includ es 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 th is 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/ Attachment s: 1. Documents Reviewed 2. Occupational Radiation Safety Inspection Request for Information

Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 05000 382 License Number: NPF-38 Report Number: 05000 382/2018001 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. O'Donnell, CHP, Health Physicist Approved By:

G. Miller , Chief 2

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensee's performance by conducting an integrated inspection at Waterford Steam Electric Station

, Unit 3 , in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRC's program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. An NRC-identified violation and additional items are summarized in the table s below. List of Findings and Violations Failure to Obtain NRC Staff Authorization Prior to Changing a Procedure that Impacts Implementation of Technical Specification s Cornerstone Significance Cross-cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000382/2018001

-01 Closed Not Applicable 71152 The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.59, "Changes, Tests, and Experiments," Section (c)(1), for the licensee's failure to submit and obtain authorization prior to implementation procedures described in the Final Safety Analysis Report.

Additional Tracking Item s Type Issue number Title Report Section Status 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 71153 Closed 3

PLANT STATUS

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

INSPECTION SCOPE S 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 Sample s) The inspectors evaluated system configuration s 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 r oom 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

5 (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 cro ss-conne ct valve solenoid valve replacement on March 8, 2018 (6) Component cooling water pump B to AB discharge cross

-conne ct valve solenoid valve replacement on March 8, 2018 (7) Low pressure safety injection pump B on March 14, 2018 6 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 SAFET Y 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

.

7 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 licensee's 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 Issue s (1 Sample) The inspectors reviewed the licensee's 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)050003 82/201 7-00 2-00 , Automatic Reactor Scram due to the Failure of Fast Bus Transfer Relays to Automatically Transfer S tation Loads to Off-site Power on a Main Generator Trip

, on July 17, 2017 8 INSPECTION RESULTS Failure to Obtain NRC Staff Authorization Prior to Changing a Procedure that Impacts Implementation of Technical Specifications Cornerstone Significance Cross-cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000382/2018001

-01 Closed Not Applicable 71152 The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.59, "Changes, Tests, and Experiments," Section (c)(1), for the licensee's 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 , i f 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 i f Procedure OP-100-014, Revision 337, would have been implemented as written, it would 9 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 201 8, 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 201 8. 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-WF3-201 8-02111 Performance Assessment

Performance Deficiency

The licensee's 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 ROP's 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 NRC's 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 10 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 licensee's 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 Report (Closed) 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 05000382/2017 00 71153 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.

11 EXIT MEETING S AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report

. On January 25 , 2018, the inspector s 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 inspector s 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

OP-901-521 Severe Weather and Flooding

25 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

71111.05 - Fire Protection

Miscellaneous Documents

Number Title Revision RAB1A-B-C-D-001 Control Room Proper, H&V Room, Emergency Living Quarters, and Computer Room

RAB8B-E-F-001 Switchgear B

RAB 17-001 Component Cooling Water Heat Exchanger "B"

RAB 19-001 Component Cooling Water Pump Room "A"

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

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

OP-901-404 High Airborne Activity in FHB

OP-901-405 Fuel Handling Incident

OP-901-513 Spent Fuel Pool Cooling Malfunction

OP-902-002 Loss of Coolant Accident Recovery

71111.12 - Maintenance Effectiveness

Miscellaneous Documents Number Title Revision 910163-001 PCI Quality Assurance Traveler

- FOST A1 Fabrication

EC-53943 Station Battery B Cell Lid Cracking

EC-57534 Station Battery A Cell Lid Cracks

QPP-205 Graham, Visual Inspection

QPP-205 Addenda Graham, Visual Inspection addenda

WDT-0528 PCI Welding EDG Supplemental Fuel Oil Storage Tank

WF3-FOST-DN-021 Deviation Notice for Waterford 3 Fuel

Oil Storage Tank, Tank A1 - Rust and Arc Strikes on

Shell 1 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

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 ADV Leakages 1 EC-75901 Component Cooling Water Heat Exchanger Degraded Performance

ECM95-008 Ultimate Heat Sink Design Basis

ECS05-13 Ultimate Head Sink Containment Heat Loads

MNQ9-2 Component Cooling Water System

MNQ9-50 ACCW System Resistance

TD-G080.0495 General Electric Spare Reactor Coolant Pump Motor Drawings 1 WF3-ME-16-00001 Meteorological Parameters and Parameter Relationships for

Design and Operability of the

Waterford 3 Ultimate Heat Sink 0 Procedures

Number Title Revision OP-001-002 Reactor Coolant Pump Operation

PE-004-021 CCW Heat Exchanger Performance Test

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 Tower Outside Missile Protection

ECM95-008 Ultimate Heat Sink Design Basis

MNQ9-52 Ultimate Heat Sink Performance based on data

WF3-ME-16-00001 Meteorological Parameters and Parameter Relationships for

Design and Operability of the Waterford 3 Ultimate Heat Sink 0 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 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

OP-903-050 Component Cooling Water and Auxiliary Component Cooling Water Pump and Valve Operational Test

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

OP-903-121 Safety System Quarterly IST Valve Tests

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 System Safety Channel Operation and Maintenance Manual

April, 1985

Procedures

Number Title Revision MI-003-002 Safety Channel Nuclear Instrumentation Functional Test

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

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

2 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

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-02112017-013 Sluice CVC IX A

February 11, 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-05162017-561 Alpha Air

- Top of UGS

May 16, 2017

Audits and Self

-Assessments

Number Title Date LO-WLO-2017-00068 CA-00005 Pre-NRC Self-Assessment Radiation Safety

- IP 71124.01 November 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 Radiation Protection Instrument, Revision

September 21, 2017 Review of Smears Taken for Alpha Characterization During RF21 September 19, 2017 Spent Fuel Pool Inventory

October 25, 2017 Update to the Review of the Capabilities of Our Passive Monitoring Program to Detect Intakes at Waterford

-3 October 4, 2017 2017-2018 Entergy Waterford 3 Radiation Protection Department Respiratory Improvement Plan

August 10, 2017 Att. 9.6 to EN

-RP-101 LHRA/VHRA Key Log

January 23

-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 Pool 3 EN-RP-100 Radiation Worker Expectations

EN-RP-101 Access Control for Radiologically Controlled Areas

EN-RP-102 Radiological Control

EN-RP-104 Personnel Contamination Events

EN-RP-105 Radiological Work Permits

EN-RP-106 Radiological Survey Documentation

EN-RP-108 Radiation Protection Posting

EN-RP-109 Hot Spot Program

EN-RP-121 Radioactive Material Control

EN-RP-122 Alpha Monitoring

EN-RP-143 Source Control

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

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 Canal 1 2017-0509 RF21 Remove/Replace Steam Generator Primary Manways/Diaphragms

2017-0510 Install/Remove Steam Generator Nozzle Dams, Pin Verification and Closure

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

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

WestDyne (ROSA) and a Submarine

2018-0004 Maintenance Activities in all Radiologically Controlled Areas

2018-0007 Perform Various Decon and Housekeeping Activities in all 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-WTWF3-2017-00273

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-2017-00068 Pre-NRC Assessment IP 71124.03 In

-Plant Airborne Radioactivity Control and Mitigation

November 23, 2017 Filtration Testing Results

Number Title Date 5257571 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 Equipment

- Face Piece Inspection Log

December 27, 2017 Inspection and Maintenance of Respiratory Protection Equipment

- SCBA Inspection Log

December 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 Continuous Air Monitor

EN-RP-501 Respiratory Protection Program

Procedures

Number Title Revision EN-RP-502 Inspection and Maintenance of Respiratory Protection Equipment 10 EN-RP-502-01 Fire Hawk M7 SCBA

EN-RP-503 Selection, Issue And Use Of Respiratory Protection Equipment 7 EN-RP-504 Breathing Air

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-2017-00068 Radiation Safety 71151 OR01 Occupational Exposure Control Effectiveness

November 29, 2017 Miscellaneous Documents

Number Title Date W3F1-2017-0036 NRC Performance Indicator (PI) Data

- 1 st Quarter 2017 ROP Data April 12, 2017

W3F1-2017-0058 NRC Performance Indicator (PI) Data

- 2 nd Quarter 2017 ROP Data July 13, 2017

Miscellaneous Documents

Number Title Date W3F1-2017-0076 NRC Performance Indicator (PI) Data

- 3 rd Quarter 2017 ROP Data October 6, 2017 W3F1-2018-0004 NRC Performance Indicator (PI) Data

- 4 th Quarter 2017 ROP Data January 9, 2018 Procedures

Number Title Revision EN-LI-114 Regulatory Performance Indicator Process

71152 - Problem Identification and Resolution

Miscellaneous Documents

Number Title Date White Paper

Cascading Technical Specifications During Emergency Diesel Generator Outages

February, 2018 Procedures

Number Title Revision EN-LI-100 Process Applicability Determination Form

OP-100-014 Technical Specification and Technical Requirements Compliance

336, 337, 340

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 71124.0

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.

J. Dinelli

WATERFORD STEAM ELECTRIC STATION, UNIT

- NRC INTEGRATED INSPECTION REPORT 05000382/2018001

DATED MAY 8, 2018

DISTRIBUTION

KKennedy, RA

SMorris, DRA

AVegel, DRP

RLantz, DRP

MShaffer, DRS

JClark, DRS

SKirkwood, RC

GMiller, DRP

JDixon, DRP

JChoate, DRP

FRamirez, DRP

CSpeer, DRP

AElam, DRP

JBowen, RIV/OEDO

VDricks, ORA

JWeil, OCA

APulvirenti, NRR

AMoreno, RIV/CAO

BMaier, RSLO

EUribe, IPAT

MHerrera, DRMA

R4Enforcement

ROP Reports

Electronic Distribution for Waterford OFFICIAL RECORD COPY

ADAMS ACCESSION NUMBER: ML18128A066

SUNSI Review

By: JDixon/rdr Non-Sensitive Sensitive Publicly Available

Non-Publicly Available

Keyword: 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

- NRC INTEGRATED INSPECTION REPORT 05000 382/2018001 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 includ es the one Severity Level

IV violation documented in this report. However , the NRC will not conduct Inspection Procedure 2723, "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 th

is 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

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/ Attachment

s: 1. Documents Reviewed

2. Occupational Radiation Safety Inspection

Request for Information

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number: 05000 382 License Number: NPF-38 Report Number: 05000 382/2018001 Enterprise Identifier:

I-2018-001-0002 Licensee: Entergy Operations, Inc.

Facility: Waterford Steam Electric Station, Unit

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. O'Donnell, CHP, Health Physicist

Approved By:

G. Miller, Chief

SUMMARY The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensee's performance by conducting

an integrated

inspection at Waterford Steam Electric Station

, Unit 3 , in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRC's program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html

for more information. An NRC-identified

violation and additional items are summarized in the table

s below. List of Findings and Violations

Failure to Obtain NRC Staff Authorization

Prior to Changing a Procedure that Impacts Implementation of Technical Specification

s Cornerstone

Significance

Cross-cutting Aspect Report Section Not Applicable

Severity Level

IV NCV 05000382/2018001

-01 Closed Not Applicable

71152 The inspectors identified a Severity Level

IV, non-cited violation of 10 CFR 50.59, "Changes, Tests, and Experiments," Section

(c)(1), for the licensee's failure to submit and obtain authorization prior to implementation procedures described in the Final Safety Analysis Report.

Additional Tracking Item s Type Issue number

Title Report Section Status 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 71153 Closed

PLANT STATUS

Waterford Steam Electric Station

Unit 3 operated at or near

100 percent rated thermal power for the entire inspection period.

INSPECTION SCOPE

S 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 Sample s) The inspectors evaluated system configuration

s during partial walkdowns of the following systems/trains

(1) Emergency feedwater train

A following maintenance on January

2, 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

r oom 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

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 cro

ss-conne ct valve solenoid valve replacement on March

8, 2018 (6) Component cooling water pump

B to AB discharge cross

-conne ct 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 SAFET

Y 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 licensee's 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 Issue s (1 Sample) The inspectors reviewed the licensee's 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)

050003 82/201 7-00 2-00 , Automatic Reactor Scram due to the Failure of Fast Bus Transfer Relays to Automatically Transfer S

tation 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 Aspect Report Section Not Applicable

Severity Level

IV NCV 05000382/2018001

-01 Closed Not Applicable

71152 The inspectors identified a Severity Level

IV, non-cited violation of

CFR 50.59, "Changes, Tests, and Experiments," Section

(c)(1), for the licensee's 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

hours and in Hot Shutdown within the following 6

hours. 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 , i f 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 i

f 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 201 8, 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 201 8. 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-WF3-201 8-02111 Performance Assessment

Performance Deficiency

The licensee's 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 ROP's 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 NRC's 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 licensee's

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 Report (Closed) 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 05000382/2017

-002-00 71153 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 MEETING S AND DEBRIEFS

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

. On January 25 , 2018, the inspector

s presented the radiation safety inspection results to M