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WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED INSPECTION REPORT 05000382/2018001 | |||
==Dear Mr. Dinelli:== | ==Dear Mr. Dinelli:== | ||
Line 27: | Line 26: | ||
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. | 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. | From April 2017 to April 2018, the NRC issued three Severity Level IV traditional enforcement violations associated with impacting the ability of the NRC to perform its regulatory oversight function. This includes the one Severity Level IV violation documented in this report. However, the NRC will not conduct Inspection Procedure 92723, Follow Up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period, because one of the violations occurred in 2006 and is not representative of present performance. | ||
If you contest the violation or significance of this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Waterford Steam Electric Station, Unit 3. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding. | |||
If you contest the violation or significance of | |||
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, | |||
Sincerely, | Sincerely, | ||
/RA/ Geoffrey Miller , Branch Chief Project Branch D Division of Reactor Projects Docket No. 50-382 License No. NPF-38 | /RA/ | ||
Geoffrey Miller, Branch Chief Project Branch D Division of Reactor Projects Docket No. 50-382 License No. NPF-38 | |||
===Enclosure:=== | ===Enclosure:=== | ||
Inspection Report 05000382/2018001 w/ | Inspection Report 05000382/2018001 w/ Attachments: | ||
1. Documents Reviewed 2. O | |||
==Inspection Report== | ==Inspection Report== | ||
Docket Number: | Docket Number: 05000382 License Number: NPF-38 Report Number: 05000382/2018001 Enterprise Identifier: I-2018-001-0002 Licensee: Entergy Operations, Inc. | ||
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: | Facility: Waterford Steam Electric Station, Unit 3 Location: 17265 River Road Killona, LA 70057 Inspection Dates: January 1, 2018, to March 31, 2018 Inspectors: F. Ramírez, Senior Resident Inspector C. Speer, Resident Inspector J. Choate, Project Engineer J. Dixon, Senior Project Engineer N. Greene, PhD, Senior Health Physicist S. Money, Health Physicist J. ODonnell, CHP, Health Physicist Approved By: G. Miller, Chief Enclosure | ||
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. | |||
G. Miller , Chief | |||
=SUMMARY= | =SUMMARY= | ||
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the | The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Waterford Steam Electric Station, Unit 3, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. An NRC-identified violation and additional items are summarized in the tables below. | ||
, Unit 3 , in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the | |||
-01 Closed | List of Findings and Violations Failure to Obtain NRC Staff Authorization Prior to Changing a Procedure that Impacts Implementation of Technical Specifications Cornerstone Significance Cross-cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 71152 NCV 05000382/2018001-01 Closed The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.59, Changes, | ||
Tests, and Experiments, Section (c)(1), for the licensees failure to submit and obtain authorization prior to implementation procedures described in the Final Safety Analysis Report. | |||
Additional Tracking | Additional Tracking Items Type Issue number Title Report Status Section LER 05000382/2017-002-00 Automatic Reactor Scram 71153 Closed due to the Failure of Fast Bus Transfer Relays to Automatically Transfer Station Loads to Off-site Power on a Main Generator Trip | ||
-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 | |||
=PLANT STATUS= | =PLANT STATUS= | ||
Line 63: | Line 55: | ||
Waterford Steam Electric Station Unit 3 operated at or near 100 percent rated thermal power for the entire inspection period. | Waterford Steam Electric Station Unit 3 operated at or near 100 percent rated thermal power for the entire inspection period. | ||
==INSPECTION | ==INSPECTION SCOPES== | ||
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards. | |||
-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, | |||
-Water Reactor Inspection Program - Operations Phase. | |||
==REACTOR SAFETY== | ==REACTOR SAFETY== | ||
==71111.01 - Adverse Weather Protection== | ==71111.01 - Adverse Weather Protection Impending Severe Weather== | ||
{{IP sample|IP=IP 71111.01|count=1}} | |||
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. | 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== | ==71111.04 - Equipment Alignment Partial Walkdown== | ||
{{IP sample|IP=IP 71111.04|count=3}} | |||
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains: | |||
: | |||
: (1) Emergency feedwater train A following maintenance on January 12, 2018 | : (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 | : (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 | : (3) Low pressure safety injection train A with train B out of service for maintenance on March 13, 2018 | ||
==71111.05 - Fire Protection== | ==71111.05 - Fire Protection Quarterly Inspection== | ||
{{IP sample|IP=IP 71111.05|count=5}} | |||
The inspectors evaluated fire protection program implementation in the following selected areas: | The inspectors evaluated fire protection program implementation in the following selected areas: | ||
: (1) Shutdown cooling heat exchanger rooms A and B, Fire Area RAB 33 , on January 4, 2018 | : (1) Shutdown cooling heat exchanger rooms A and B, Fire Area RAB 33, on January 4, 2018 | ||
: (2) Switchgear | : (2) Switchgear room B, Fire Area RAB 8B, E, and F on February 12, 2018 | ||
: (3) Control room, Fire Area RAB 1A, B, C, and D on February 12, 2018 | : (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 | : (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 | : (5) Component cooling water pump room A, Fire Area RAB 19 on March 14, 2018 | ||
==71111.07 - Heat Sink Performance== | ==71111.07 - Heat Sink Performance Heat Sink== | ||
{{IP sample|IP=IP 71111.07|count=1}} | |||
The inspectors evaluated the ultimate heat sink performance test on January 23, 2018. | The inspectors evaluated the ultimate heat sink performance test on January 23, 2018. | ||
==71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance== | ==71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification== | ||
{{IP sample|IP=IP 71111.11|count=1}} | |||
The inspectors observed and evaluated operator performance in the simulator during an evaluated emergency plan exercise on February 21, 2018. | |||
The inspectors observed and evaluated operator performance in the simulator during an evaluated emergency plan exercise on February 21 | |||
== | ===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== | ||
{{IP sample|IP=IP 71111.12|count=3}} | {{IP sample|IP=IP 71111.12|count=3}} | ||
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions | |||
: | 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 | : (1) Component cooling water on January 25, 2018 | ||
: (2) 125 Vdc distribution system on March 12, 2018 | : (2) 125 Vdc distribution system on March 12, 2018 | ||
: (3) Plant protection system on March 28, 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 | : (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== | ==71111.13 - Maintenance Risk Assessments and Emergent Work Control== | ||
{{IP sample|IP=IP 71111.13|count=3}} | |||
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 | : (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 | : (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 | : (3) Control element assembly emergency work and unexpected limiting condition for operation on February 6, 2018 | ||
==71111.15 - Operability Determinations and Functionality Assessments | ==71111.15 - Operability Determinations and Functionality Assessments== | ||
{{IP sample|IP=IP 71111. | {{IP sample|IP=IP 71111.15|count=6}} | ||
The inspectors evaluated the following operability determinations and functionality assessments: | The inspectors evaluated the following operability determinations and functionality assessments: | ||
: (1) Core element assembly calculator 2 unexpected trend on January 2, 2018 | : (1) Core element assembly calculator 2 unexpected trend on January 2, 2018 | ||
Line 140: | Line 128: | ||
==71111.18 - Plant Modifications== | ==71111.18 - Plant Modifications== | ||
{{IP sample|IP=IP 71111.18|count=1}} | |||
The inspectors evaluated the following temporary or permanent modifications: | |||
: (1) Dry cooling tower train A recirculation barrier installation, Phase 3, on March 16, 2018 | : (1) Dry cooling tower train A recirculation barrier installation, Phase 3, on March 16, 2018 | ||
==71111.19 - Post Maintenance Testing | ==71111.19 - Post Maintenance Testing== | ||
{{IP sample|IP=IP 71111. | {{IP sample|IP=IP 71111.19|count=7}} | ||
The inspectors evaluated the following post maintenance tests: | The inspectors evaluated the following post maintenance tests: | ||
: (1) Reactor trip circuit breaker 6 on January 9, 2018 | : (1) Reactor trip circuit breaker 6 on January 9, 2018 | ||
Line 151: | Line 141: | ||
: (3) Emergency diesel generator A on February 3, 2018 | : (3) Emergency diesel generator A on February 3, 2018 | ||
: (4) Auxiliary component cooling water train B on February 21, 2018 | : (4) Auxiliary component cooling water train B on February 21, 2018 | ||
: (5) Component cooling water pump B to AB suction | : (5) Component cooling water pump B to AB suction cross-connect valve solenoid valve replacement on March 8, 2018 | ||
: (6) Component cooling water pump B to AB discharge cross | : (6) Component cooling water pump B to AB discharge cross-connect valve solenoid valve replacement on March 8, 2018 | ||
- | : (7) Low pressure safety injection pump B on March 14, 2018 | ||
: (7) Low pressure safety injection pump B on March 14, 2018 | |||
==71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: | ==71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Routine== | ||
{{IP sample|IP=IP 71111.22|count=3}} | {{IP sample|IP=IP 71111.22|count=3}} | ||
: (1) Emergency diesel generator A monthly surveillance on January 8, 2018 | : (1) Emergency diesel generator A monthly surveillance on January 8, 2018 | ||
Line 164: | Line 151: | ||
: (3) Functional test of plant protective system Channel C on February 23, 2018 | : (3) Functional test of plant protective system Channel C on February 23, 2018 | ||
==71114.06 - Drill Evaluation== | ==71114.06 - Drill Evaluation Emergency Planning Drill== | ||
{{IP sample|IP=IP 71114.06|count=1}} | |||
The inspectors evaluated a site emergency plan drill on February 21, | |||
The inspectors evaluated a site emergency plan drill on February 21, | |||
==71124.01 - Radiological Hazard Assessment and Exposure Controls== | ==RADIATION SAFETY== | ||
==71124.01 - Radiological Hazard Assessment and Exposure Controls Radiological Hazard Assessment== | |||
{{IP sample|IP=IP 71124.01|count=1}} | |||
=== | ===The inspectors evaluated radiological hazards assessments and controls. | ||
Instructions to Workers=== | |||
{{IP sample|IP=IP 71124.01|count=1}} | {{IP sample|IP=IP 71124.01|count=1}} | ||
==71124.03 - In-Plant Airborne Radioactivity Control and Mitigation== | 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== | |||
{{IP sample|IP=IP 71124.03|count=1}} | |||
The inspectors evaluated airborne controls and monitoring. | |||
=== | ===Use of Respiratory Protection Devices=== | ||
{{IP sample|IP=IP 71124.03|count=1}} | {{IP sample|IP=IP 71124.03|count=1}} | ||
The inspectors evaluated respiratory protection. | |||
Self-Contained Breathing Apparatus for Emergency Use (1 Sample) | |||
The inspectors evaluated the licensees self-contained breathing apparatus program. | |||
===Annual Follow | ==OTHER ACTIVITIES - BASELINE== | ||
-up of Selected | |||
===71151 - Performance Indicator Verification === | |||
{{IP sample|IP=IP 71151|count=5}} | |||
The inspectors verified licensee performance indicator submittals listed below: | |||
: (1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (January 1, 2017, through December 31, 2017) | |||
: (2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample (January 1, 2017, through December 31, 2017) | |||
: (3) IE04: Unplanned Scrams with Complications (USwC) Sample (January 1, 2017, through December 31, 2017) | |||
: (4) OR01: Occupational Exposure Control Effectiveness Sample (April 1, 2017, through December 31, 2017) | |||
: (5) PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (April 1, 2017, through December 31, 2017) | |||
==71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues== | |||
{{IP sample|IP=IP 71152|count=1}} | {{IP sample|IP=IP 71152|count=1}} | ||
The inspectors reviewed the | |||
: (1) Implementation of change to technical specification and technical requirements compliance procedure 71153 - Follow-up of Events and Notices of Enforcement Discretion Licensee Event Reports | The inspectors reviewed the licensees implementation of its corrective action program related to the following issue: | ||
: | : (1) Implementation of change to technical specification and technical requirements compliance procedure | ||
: (1) Licensee Event Report (LER) | |||
, on July 17, | ===71153 - Follow-up of Events and Notices of Enforcement Discretion Licensee Event Reports === | ||
{{IP sample|IP=IP 71153|count=1}} | |||
The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx: | |||
: (1) Licensee Event Report (LER) 05000382/2017-002-00, Automatic Reactor Scram due to the Failure of Fast Bus Transfer Relays to Automatically Transfer Station Loads to Off-site Power on a Main Generator Trip, on July 17, | |||
==INSPECTION RESULTS== | ==INSPECTION RESULTS== | ||
Failure to Obtain NRC Staff Authorization Prior to Changing a Procedure that Impacts Implementation of Technical Specifications Cornerstone Significance Cross-cutting Aspect | Failure to Obtain NRC Staff Authorization Prior to Changing a Procedure that Impacts Implementation of Technical Specifications Cornerstone Significance Cross-cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 71152 NCV 05000382/2018001-01 Closed The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.59, Changes, Tests, and Experiments, Section (c)(1), for the licensees failure to submit and obtain authorization prior to implementation procedures described in the Final Safety Analysis Report. | ||
-01 Closed | |||
=====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. | |||
One of the systems listed and discussed is the ultimate heat sink and its associated Technical Specification 3.7.4 | 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 hour, 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 licensee revised Procedure OP-100-014, Revision 336, using a Process Applicability Determination Evaluation [ | 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. | ||
PAD-OP-100-014, Revision 337] to provide additional guidance on implementation of Technical Specification 3.7.4 | |||
Procedure OP-100-014, Revision 337, was implemented in February 2017 with an added note stating, in part, if the dry cooling tower fans are declared inoperable solely due to wet cooling tower fans being out of service (cascading technical specification), then Technical Specification 3.7.4.c does not need to be applied upon a tornado watch/warning. The licensee performed a technical analysis and concluded that the missile-protected dry cooling tower fans were to be considered Operable for the tornado event because wet cooling tower fan operation is not credited in the tornado event analysis. | |||
, | |||
The licensee used Procedure EN-LI-100, Process Applicability Determination, to evaluate the change in licensing basis documents. When answering the question, does the proposed activity affect, invalidate, or render incorrect, OR have the potential to affect, invalidate, or render incorrect, information contained in any of the following Licensing Basis Documents? | |||
the licensee answered no for impact on Operating License/Technical Specifications. | |||
As a result, that question should have been answered | However, the inspectors determined that this addition to the site procedure could adversely impact the bases for the acceptability to ultimate heat sink design and operations. As a result, that question should have been answered yes and the licensee would have had to prepare a licensing basis document change request. The inspectors concluded that if Procedure OP-100-014, Revision 337, would have been implemented as written, it would have constituted a change affecting an evaluation that demonstrates the function of the ultimate heat sink. | ||
The inspectors confirmed that between February 2017 and January | The inspectors confirmed that between February 2017 and January 2018, there were no tornado watches that coincided with ultimate heat sink system work windows. Therefore, during the time this note was in the procedure, the licensee did not invoke the provision. | ||
Corrective Action(s): The licensee removed the note from Procedure OP-100-014, and corrected the interpretation of the technical specification. Procedure OP-100-014, Revision 342, which removed the note, became effective January 2018. Therefore, if the wet cooling tower fans are inoperable, and there is a simultaneous tornado watch/warning, the licensee will implement Technical Specification 3.7.4, Action c. | |||
Corrective Action Reference(s): CR-WF3-2018-02111 | |||
CR-WF3- | |||
=====Performance Assessment:===== | |||
Performance Deficiency: The licensees failure to submit a licensing basis document change request when performing a change impacting technical specifications in accordance with Procedure EN-LI-100, Process Applicability Determination, was a performance deficiency. | |||
The | 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. | |||
The licensee | =====Enforcement:===== | ||
Severity: The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter noncompliance. This violation was more than minor because there was a reasonable likelihood the change would require NRC review and approval prior to implementation, similar to violations assessed in Section 2.1.3 of the NRC Enforcement Manual. The inspectors determined the violation to be a Severity Level IV violation similar to violation Example 6.1.d.2 in the NRC Enforcement Policy. | |||
Violation: As stated, in part, in 10 CFR 50.59, Changes, Tests, and Experiments, Section (c)(1), a licensee may make changes in the facility as described in the final safety analysis report (as updated), make changes in the procedure as described in the final safety analysis report (as updated), and conduct tests or experiments not described in the final safety analysis report (as updated) without obtaining a license amendment pursuant to Sec. 50.90 only if: | |||
: (i) a change to the Technical Specifications incorporated in the license is not required. The licensee established Procedure EN-LI-100, Process Applicability Determination, Revision 19, to comply with this requirement. Attachment 9.1 of Procedure EN-LI-100 states, in part, to prepare a licensing basis document change request if a proposed activity affects, invalidates, or renders incorrect, information contained in Technical Specifications. | |||
Contrary to the above requirements, from February 2017, until December 2017, the licensee completed an activity that affected Technical Specifications and did not prepare a licensing basis document change request. Specifically, the licensee implemented a change to Technical Specification 3.7.4, Action c, through the implementation of Procedure OP-100-014, Technical Specification and Technical Requirements Compliance, Revision 337, by adding a note that instructed Operations personnel to not enter Technical Specification 3.7.4.c in the event of a tornado watch/warning if the dry cooling tower fans were declared inoperable solely due to wet cooling tower fans being out of service. This action was inconsistent with the current licensing basis and would have constituted a violation of technical specifications. | |||
- | |||
. | |||
Enforcement Action: Because this violation was not repetitive or willful, and was entered into the licensees corrective action program as CR-WF3-2018-02111, this violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy. | |||
Licensee Event Automatic Reactor Scram due to the Failure of Fast Bus 71153 Report Transfer Relays to Automatically Transfer Station Loads to (Closed) Off-site Power on a Main Generator Trip 05000382/2017-002-00 | |||
On April 12, 2018, the resident | =====Description:===== | ||
The NRC conducted a special inspection to better understand the facts and circumstances surrounding this event. The results and findings of that inspection are documented in NRC Inspection Report 05000382/2017011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17354A690). The inspectors did not identify any new deficiencies as a result of this review. This LER is closed. | |||
==EXIT MEETINGS AND DEBRIEFS== | |||
The inspectors verified no proprietary information was retained or documented in this report. | |||
On January 25, 2018, the inspectors presented the radiation safety inspection results to Mr. J. Dinelli, Site Vice President, and other members of the licensee staff. | |||
On April 12, 2018, the resident inspectors presented the quarterly resident inspector inspection results to Mr. J. Dinelli, Site Vice President, and other members of the licensee staff. | |||
=DOCUMENTS REVIEWED= | =DOCUMENTS REVIEWED= | ||
Line 274: | Line 268: | ||
71111.01 - Adverse Weather Protection | 71111.01 - Adverse Weather Protection | ||
Procedures | Procedures | ||
Number Title Revision OP-002-007 Freeze Protection and Temperature Maintenance | Number Title Revision | ||
OP-901-521 Severe Weather and Flooding | OP-002-007 Freeze Protection and Temperature Maintenance 25 | ||
OP-901-521 Severe Weather and Flooding 325 | |||
CR-WF3-2017-09668 CR-WF3-2018-00004 CR-WF3-2018-00082 CR-WF3-2018-00098 CR-WF3-2018-00436 | 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 | Procedures | ||
Number Title Revision OP-002-003 Component Cooling Water | Number Title Revision | ||
OP-002-003 Component Cooling Water 317 | |||
OP-009-003 Emergency Feedwater 309 | |||
OP-009-008 Safety Injection System 41 | |||
71111.05 - Fire Protection | 71111.05 - Fire Protection | ||
Miscellaneous Documents | Miscellaneous Documents | ||
Number Title Revision RAB1A-B-C-D- | Number Title Revision | ||
RAB8B-E-F-001 Switchgear B | RAB1A-B-C-D- Control Room Proper, H&V Room, Emergency Living 10 | ||
RAB 17-001 Component Cooling Water Heat Exchanger | 001 Quarters, and Computer Room | ||
RAB 19-001 Component Cooling Water Pump Room | RAB8B-E-F-001 Switchgear B 12 | ||
RAB 33-001 Shutdown Cooling Heat Exchanger Rooms | RAB 17-001 Component Cooling Water Heat Exchanger B 8 | ||
RAB 19-001 Component Cooling Water Pump Room A 7 | |||
RAB 33-001 Shutdown Cooling Heat Exchanger Rooms A and B 8 | |||
Procedures | Procedures | ||
Number Title Revision FP-001-018 Pre-fire Strategies, Development and Revision | Number Title Revision | ||
304 | FP-001-018 Pre-fire Strategies, Development and Revision 304 | ||
71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance | 71111.11 - Licensed Operator Requalification Program and Licensed Operator | ||
Performance | |||
Procedures | Procedures | ||
Number Title Revision OP-901-111 Reactor Coolant System Leak | Number Title Revision | ||
OP-901-111 Reactor Coolant System Leak 303 | |||
OP-901-404 High Airborne Activity in FHB | OP-901-403 High Airborne Activity in Containment 4 | ||
OP-901-405 Fuel Handling Incident | OP-901-404 High Airborne Activity in FHB 2 | ||
OP-901-513 Spent Fuel Pool Cooling Malfunction | OP-901-405 Fuel Handling Incident 8 | ||
OP-902-002 Loss of Coolant Accident Recovery | OP-901-513 Spent Fuel Pool Cooling Malfunction 21 | ||
OP-902-002 Loss of Coolant Accident Recovery 20 | |||
71111.12 - Maintenance Effectiveness | 71111.12 - Maintenance Effectiveness | ||
Miscellaneous Documents Number Title Revision 910163-001 PCI Quality Assurance Traveler | Miscellaneous Documents | ||
- FOST A1 Fabrication | Number Title Revision | ||
EC-53943 Station Battery B Cell Lid Cracking | 910163-001 PCI Quality Assurance Traveler - FOST A1 Fabrication 1 | ||
EC-57534 Station Battery A Cell Lid Cracks | EC-53943 Station Battery B Cell Lid Cracking 0 | ||
QPP-205 Graham, Visual Inspection | EC-57534 Station Battery A Cell Lid Cracks 0 | ||
QPP-205 | QPP-205 Graham, Visual Inspection 17 | ||
WDT-0528 PCI Welding EDG Supplemental Fuel Oil Storage Tank | QPP-205 Graham, Visual Inspection addenda 1 | ||
WF3-FOST-DN- | Addenda | ||
Oil Storage Tank, Tank A1 - Rust and Arc Strikes on | WDT-0528 PCI Welding EDG Supplemental Fuel Oil Storage Tank 0 | ||
WF3-FOST-DN- Deviation Notice for Waterford 3 Fuel Oil Storage Tank, 1 | |||
Number Title Revision ME-003-200 Station Battery Bank and Charger (Weekly) | 21 Tank A1 - Rust and Arc Strikes on Shell | ||
Procedures | |||
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 | 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 | Work Orders | ||
446024 | 446024 | ||
71111.13 - Maintenance Risk Assessments and Emergent Work Control | |||
Procedures | Procedures | ||
Number Title Revision OP-903-005 Control Element Assembly Operability Check | Number Title Revision | ||
OP-903-005 Control Element Assembly Operability Check 14 | |||
71111.15 - Operability Determinations and Functionality Assessments | 71111.15 - Operability Determinations and Functionality Assessments | ||
Miscellaneous Documents | Miscellaneous Documents | ||
Number Title Revision/Date | Number Title Revision/Date | ||
January 31, 2018 EC-40444 Revised Impact AST Dose Analyses to Address MSSV and ADV Leakages | Protected Equipment List January 31, | ||
ECM95-008 Ultimate Heat Sink Design Basis | 2018 | ||
ECS05-13 Ultimate Head Sink Containment Heat Loads | EC-40444 Revised Impact AST Dose Analyses to Address MSSV and 1 | ||
MNQ9-2 Component Cooling Water System | ADV Leakages | ||
MNQ9-50 ACCW System Resistance | EC-75901 Component Cooling Water Heat Exchanger Degraded 1 | ||
TD-G080.0495 General Electric Spare Reactor Coolant Pump Motor Drawings | Performance | ||
Design and Operability of the | ECM95-008 Ultimate Heat Sink Design Basis 3 | ||
Waterford 3 Ultimate Heat Sink | ECS05-13 Ultimate Head Sink Containment Heat Loads 1 | ||
Number Title Revision OP-001-002 Reactor Coolant Pump Operation | MNQ9-2 Component Cooling Water System 2 | ||
PE-004-021 CCW Heat Exchanger Performance Test | MNQ9-50 ACCW System Resistance 2 | ||
TD-G080.0495 General Electric Spare Reactor Coolant Pump Motor 1 | |||
Drawings | |||
WF3-ME-16- Meteorological Parameters and Parameter Relationships for 0 | |||
00001 Design and Operability of the Waterford 3 Ultimate Heat | |||
Sink | |||
Procedures | |||
Number Title Revision | |||
OP-001-002 Reactor Coolant Pump Operation 22 | |||
PE-004-021 CCW Heat Exchanger Performance Test 5 | |||
Condition Reports (CRs) | 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 | 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) | Condition Reports (CRs) | ||
CR-WF3-2018-01426 CR-WF3-2018-01549 CR-WF3-2018-01559 | CR-WF3-2018-01426 CR-WF3-2018-01549 CR-WF3-2018-01559 | ||
481333 495770 495771 496893 52348919 | Work Orders | ||
481333 495770 495771 496893 52348919 | |||
71111.18 - Plant Modifications | |||
Miscellaneous Documents | Miscellaneous Documents | ||
Number Title Revision 6W12CM10 Common Mat Stress Analysis | Number Title Revision | ||
- Cooling Tower Area 2 ECC16-004 Horizontal Air Flow Barrier Roof and Gutters at Dry Cooling Tower Outside Missile Protection | 6W12CM10 Common Mat Stress Analysis - Cooling Tower Area 2 | ||
ECM95-008 Ultimate Heat Sink Design Basis | ECC16-004 Horizontal Air Flow Barrier Roof and Gutters at Dry Cooling 0 | ||
MNQ9-52 Ultimate Heat Sink Performance based on data | Tower Outside Missile Protection | ||
WF3-ME-16- | ECM95-008 Ultimate Heat Sink Design Basis 3 | ||
Design and Operability of the Waterford 3 Ultimate Heat Sink | MNQ9-52 Ultimate Heat Sink Performance based on data 2 | ||
CR-WF3-2012-02332 | WF3-ME-16- Meteorological Parameters and Parameter Relationships for 0 | ||
444257 | 00001 Design and Operability of the Waterford 3 Ultimate Heat | ||
Miscellaneous Documents Number Title Revision AR 184566 Replace Solenoid Valve | Sink | ||
AR 186060 Align PMRQs for AOV PM Optimization Program | Condition Reports (CRs) | ||
TD A610.0155 | CR-WF3-2012-02332 | ||
ASCO Installation and Maintenance Instructions for 3 | Work Orders | ||
-Way Solenoid Valves Series 8316 | 444257 | ||
71111.19 - Post-Maintenance Testing | |||
Miscellaneous Documents | |||
Number Title Revision | |||
AR 184566 Replace Solenoid Valve | |||
AR 186060 Align PMRQs for AOV PM Optimization Program | |||
TD A610.0155 ASCO Installation and Maintenance Instructions for 3-Way 0 | |||
Solenoid Valves Series 8316 | |||
Procedures | Procedures | ||
Number Title Revision/Date ME-007-019 ASCO/AVCO/MAC/Parker Hannifin Solenoid Valves | Number Title Revision/Date | ||
306 | ME-007-019 ASCO/AVCO/MAC/Parker Hannifin Solenoid Valves 306 | ||
Procedures | Procedures | ||
Number Title Revision/Date MM-003-041 Six Year Emergency Diesel Engine Inspection | Number Title Revision/Date | ||
February 2, 2018 OP-903-030 Safety Injection Pump Operability Verification | MM-003-041 Six Year Emergency Diesel Engine Inspection February 2, | ||
OP-903-050 Component Cooling Water and Auxiliary Component Cooling Water Pump and Valve Operational Test | 2018 | ||
OP-903-030 Safety Injection Pump Operability Verification 35 | |||
OP-903-121 Safety System Quarterly IST Valve Tests | OP-903-050 Component Cooling Water and Auxiliary Component 039 | ||
Cooling Water Pump and Valve Operational Test | |||
OP-903-118 Primary Auxiliaries Quarterly IST Valve Tests 43 | |||
OP-903-121 Safety System Quarterly IST Valve Tests 27 | |||
Condition Reports (CRs) | Condition Reports (CRs) | ||
CR-WF3-2017-07146 CR-WF3-2018-00441 CR-WF3-2018-00808 CR-WF3-2018-01498 | CR-WF3-2017-07146 CR-WF3-2018-00441 CR-WF3-2018-00808 CR-WF3-2018-01498 | ||
436357 52649596 52673039 52701091 | Work Orders | ||
436357 52649596 52673039 52701091 | |||
71111.22 - Surveillance Testing | |||
Miscellaneous Documents | Miscellaneous Documents | ||
Number Title Date TD-C490.0485 Combustion Engineering Ex | Number Title Date | ||
-Core Neutron Flux Monitoring System Safety Channel Operation and Maintenance Manual | TD-C490.0485 Combustion Engineering Ex-Core Neutron Flux Monitoring April, 1985 | ||
System Safety Channel Operation and Maintenance Manual | |||
Procedures | Procedures | ||
Number Title Revision MI-003-002 Safety Channel Nuclear Instrumentation Functional Test | Number Title Revision | ||
OP-903-068 Emergency Diesel Generator and Subgroup Relay Operability Verification | MI-003-002 Safety Channel Nuclear Instrumentation Functional Test 17 | ||
OP-903-068 Emergency Diesel Generator and Subgroup Relay 319 | |||
Operability Verification | |||
2800018 52800019 | OP-903-107 Plant Protection System Channel C Functional Test 312 | ||
Work Orders | |||
2800018 52800019 | |||
71114.06 - Drill Evaluation | 71114.06 - Drill Evaluation | ||
Procedures | Procedures | ||
Number Title Revision EP-001-010 Unusual Event | Number Title Revision | ||
EP-001-010 Unusual Event 306 | |||
EP-001-020 Alert 309 | |||
EP-001-030 Site Area Emergency 308 | |||
EP-002-010 Notifications and Communications 315 | |||
OP-902-002 Loss of Coolant Accident Recovery 20 | |||
Condition Reports (CRs) | Condition Reports (CRs) | ||
CR-WF3-2018-01082 CR-WF3-2018-01083 CR-WF3-2018-01084 CR-WF3-2018-01095 | 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 | Air Sample Surveys | ||
Number Title Date OL-011518-002 Pool Purification Pump Shaft Removal | Number Title Date | ||
January 15, 2018 OL-02112017- | OL-011518-002 Pool Purification Pump Shaft Removal January 15, | ||
February 11, 2017 OL-032717-006 Lapel Air Sample for RWP 2017 | 2018 | ||
-0064 March 27, 2017 OL-040417-004 Alpha Air | OL-02112017- Sluice CVC IX A February 11, | ||
- RAB -35 Safeguards Room A | 013 2017 | ||
April 4, 2017 | OL-032717-006 Lapel Air Sample for RWP 2017-0064 March 27, | ||
OL-072217-0015 Alpha Air | 2017 | ||
- Letdown Valve Gallery | OL-040417-004 Alpha Air - RAB -35 Safeguards Room A April 4, 2017 | ||
July 22, 2017 | OL-072217-0015 Alpha Air - Letdown Valve Gallery July 22, 2017 | ||
RF-05162017- | RF-05162017- Alpha Air - Top of UGS May 16, 2017 | ||
- Top of UGS | 561 | ||
May 16, 2017 | Audits and Self-Assessments | ||
Audits and Self | Number Title Date | ||
-Assessments | LO-WLO-2017- November | ||
Number Title Date LO-WLO-2017- | Pre-NRC Self-Assessment Radiation Safety - IP 71124.01 | ||
- IP 71124.01 | 00068 CA-00005 30, 2017 | ||
Number Title Date | Miscellaneous Documents | ||
January 4, 2018 | Number Title Date | ||
NSTS Annual Inventory Reconciliation Report January 4, | |||
2018 | |||
Miscellaneous Documents | Miscellaneous Documents | ||
Number Title Date | Number Title Date | ||
Periodic Review of Plant Isotopic Mix Compared to September | |||
October 25, 2017 | Radiation Protection Instrument, Revision 1 21, 2017 | ||
-3 | Review of Smears Taken for Alpha Characterization During September | ||
RF21 19, 2017 | |||
- | Spent Fuel Pool Inventory October 25, | ||
January 23 | 2017 | ||
-25, 2018 WO 52734309 | Update to the Review of the Capabilities of Our Passive October 4, | ||
Sealed Source Leak Test | Monitoring Program to Detect Intakes at Waterford-3 2017 | ||
June 22, 2017 WO 52768769 | 2017-2018 Entergy Waterford 3 Radiation Protection Department August 10, | ||
Semi-Annual Source Inventory | Respiratory Improvement Plan 2017 | ||
Att. 9.6 to EN- LHRA/VHRA Key Log January 23- | |||
Number Title Revision EN-RE-220 PWR Control of Miscellaneous Materials in the Spent Fuel Pool | RP-101 25, 2018 | ||
EN-RP-101 Access Control for Radiologically Controlled Areas | WO 52734309 Sealed Source Leak Test June 22, | ||
EN-RP-102 Radiological Control | 2017 | ||
EN-RP-104 Personnel Contamination Events | WO 52768769 Semi-Annual Source Inventory December | ||
EN-RP-105 Radiological Work Permits | 11, 2017 | ||
EN-RP-106 Radiological Survey Documentation | Procedures | ||
EN-RP-108 Radiation Protection Posting | Number Title Revision | ||
EN-RP-109 Hot Spot Program | EN-RE-220 PWR Control of Miscellaneous Materials in the Spent Fuel 3 | ||
EN-RP-121 Radioactive Material Control | Pool | ||
EN-RP-122 Alpha Monitoring | EN-RP-100 Radiation Worker Expectations 12 | ||
EN-RP-143 Source Control | EN-RP-101 Access Control for Radiologically Controlled Areas 13 | ||
EN-RP-315 Operation and Calibration of the CRONOS Contamination Monitor | EN-RP-102 Radiological Control 5 | ||
EN-RP-104 Personnel Contamination Events 9 | |||
EN-RP-105 Radiological Work Permits 18 | |||
EN-RP-106 Radiological Survey Documentation 7 | |||
EN-RP-108 Radiation Protection Posting 19 | |||
EN-RP-109 Hot Spot Program 5 | |||
EN-RP-121 Radioactive Material Control 13 | |||
EN-RP-122 Alpha Monitoring 9 | |||
EN-RP-143 Source Control 13 | |||
EN-RP-315 Operation and Calibration of the CRONOS Contamination 2 | |||
Monitor | |||
Radiation Surveys | Radiation Surveys | ||
Number Title Date WF3-1704-0537 +46 Pressurizer Cubicle | Number Title Date | ||
April 18, 2017 | WF3-1704-0537 +46 Pressurizer Cubicle April 18, 2017 | ||
WF3-1705-0049 FHB +46 Fuel Handling Area | WF3-1705-0049 FHB +46 Fuel Handling Area May 1, 2017 | ||
May 1, 2017 | WF3-1711-0270 FHB +46 Fuel Handling Area November | ||
WF3-1711-0270 FHB +46 Fuel Handling Area | 30, 2017 | ||
WF3-1711-0271 FHB +46 Fuel Handling Area November | |||
30, 2017 | |||
January 16, 2018 WF3-1801-0213 RAB -35 Hallways | WF3-1801-0194 RAB -4 Hallways January 16, | ||
January 18, 2018 WF3-1801-0262 RAB -21 Hallways | 2018 | ||
January 24, 2018 | WF3-1801-0213 RAB -35 Hallways January 18, | ||
Number Title Revision 2017-0101 Work Activities in the Spent Fuel Pool and the Transfer Canal | 2018 | ||
2017-0510 Install/Remove Steam Generator Nozzle Dams, Pin Verification and Closure | WF3-1801-0262 RAB -21 Hallways January 24, | ||
2017-0705 RF21 Reassembly of Reactor Head and Associated Work Activities | 2018 | ||
2017-0727 RF21 Perform Reactor Vessel (ISI) Inspection Using the | Radiation Work Permits | ||
Number Title Revision | |||
2017-0101 Work Activities in the Spent Fuel Pool and the Transfer 1 | |||
Canal | |||
2017-0509 RF21 Remove/Replace Steam Generator Primary 1 | |||
Manways/Diaphragms | |||
2017-0510 Install/Remove Steam Generator Nozzle Dams, Pin 2 | |||
Verification and Closure | |||
2017-0705 RF21 Reassembly of Reactor Head and Associated Work 0 | |||
Activities | |||
2017-0727 RF21 Perform Reactor Vessel (ISI) Inspection Using the 2 | |||
WestDyne (ROSA) and a Submarine | WestDyne (ROSA) and a Submarine | ||
2018-0004 Maintenance Activities in all Radiologically Controlled Areas | 2018-0004 Maintenance Activities in all Radiologically Controlled Areas 0 | ||
2018-0007 Perform Various Decon and Housekeeping Activities in all Radiologically Controlled Areas | 2018-0007 Perform Various Decon and Housekeeping Activities in all 0 | ||
Radiologically Controlled Areas | |||
Condition Reports (CRs) | 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- | CR-WF3-2017-02540 CR-WF3-2017-02718 CR-WF3-2017-02956 CR-WF3-2017-03344 | ||
CR-WF3-2017-03349 CR-WF3-2017-03362 CR-WF3-2017-03799 CR-WF3-2017-03872 | |||
CR-WF3-2017-03953 CR-WF3-2017-06030 CR-WF3-2017-06758 CR-WF3-2017-07988 | |||
CR-WF3-2017-08330 CR-WF3-2018-00506 CR-WF3-2018-00507 WT-WTWF3-2017- | |||
273 | |||
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation | 71124.03 - In-Plant Airborne Radioactivity Control and Mitigation | ||
Air Quality Testing Results | Air Quality Testing Results | ||
Number Title Date 296484-0 Compressed Air/Gas Quality Testing Laboratory Report | Number Title Date | ||
February 15, 2017 296614-0 Compressed Air/Gas Quality Testing Laboratory Report | 296484-0 Compressed Air/Gas Quality Testing Laboratory Report February 15, | ||
February 16, 2017 309752-0 Compressed Air/Gas Quality Testing Laboratory Report | 2017 | ||
July 28, 2017 | 296614-0 Compressed Air/Gas Quality Testing Laboratory Report February 16, | ||
309780-0 Compressed Air/Gas Quality Testing Laboratory Report | 2017 | ||
July 31, 2017 | 309752-0 Compressed Air/Gas Quality Testing Laboratory Report July 28, 2017 | ||
Audits and Self | 309780-0 Compressed Air/Gas Quality Testing Laboratory Report July 31, 2017 | ||
-Assessments | Audits and Self-Assessments | ||
Number Title Date LO-WLO-2017- | Number Title Date | ||
71124.03 In | LO-WLO-2017- Pre-NRC Assessment IP 71124.03 In-Plant Airborne November | ||
-Plant Airborne Radioactivity Control and Mitigation | 00068 Radioactivity Control and Mitigation 23, 2017 | ||
Filtration Testing Results | |||
Number Title Date | Number Title Date | ||
May 31, 2016 | 257571 Charcoal Sample Testing May 31, 2016 | ||
2577572 In-Place HEPA Filter Testing | 2577572 In-Place HEPA Filter Testing June 1, 2016 | ||
June 1, 2016 | 2704414 In-Place Charcoal Filter Testing November 8, | ||
2704414 In-Place Charcoal Filter Testing | 2017 | ||
November 8, 2017 | Miscellaneous Documents | ||
Number Title Date | Number Title Date | ||
- Face Piece Inspection Log | Inspection and Maintenance of Respiratory Protection December | ||
Equipment - Face Piece Inspection Log 27, 2017 | |||
- SCBA Inspection Log | Inspection and Maintenance of Respiratory Protection December | ||
Equipment - SCBA Inspection Log 27, 2017 | |||
2017-0702-04 TEDE-ALARA Evaluation November | |||
15, 2016 | |||
Procedures | Procedures | ||
Number Title Revision EN-RP-502 Inspection and Maintenance of Respiratory Protection Equipment | Number Title Revision | ||
EN-RP-503 Selection, Issue And Use Of Respiratory Protection Equipment | EN-RP-310 Operation and Initial Setup of the Eberline AMS-4 4 | ||
Continuous Air Monitor | |||
EN-RP-501 Respiratory Protection Program 5 | |||
Procedures | |||
Number Title Revision | |||
EN-RP-502 Inspection and Maintenance of Respiratory Protection 10 | |||
Equipment | |||
EN-RP-502-01 Fire Hawk M7 SCBA 1 | |||
EN-RP-503 Selection, Issue And Use Of Respiratory Protection 7 | |||
Equipment | |||
EN-RP-504 Breathing Air 4 | |||
SCBA Maintenance Records | SCBA Maintenance Records | ||
Number Title Date UEM-6123 Posi3 USB Test Results | Number Title Date | ||
- Complete SCBA Test | UEM-6123 Posi3 USB Test Results - Complete SCBA Test March 31, | ||
March 31, 2016 UEM-6123 Posi3 USB Test Results | 2016 | ||
- Complete SCBA Test | UEM-6123 Posi3 USB Test Results - Complete SCBA Test February 13, | ||
February 13, 2017 UEM-6259 Posi3 USB Test Results | 2017 | ||
- Complete SCBA Test | UEM-6259 Posi3 USB Test Results - Complete SCBA Test March 30, | ||
March 30, 2016 UEM-6259 Posi3 USB Test Results | 2016 | ||
- Complete SCBA Test | UEM-6259 Posi3 USB Test Results - Complete SCBA Test February 14, | ||
February 14, 2017 | 2017 | ||
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 | Condition Reports (CRs) | ||
Audits and Self | CR-WF3-2016-03044 CR-WF3-2017-00011 CR-WF3-2017-00375 CR-WF3-2017-00678 | ||
-Assessments | CR-WF3-2017-04253 CR-WF3-2017-05533 CR-WF3-2017-06536 CR-WF3-2017-06758 | ||
Number Title Date LO-WLO-2017- | 71151 - Performance Indicator Verification | ||
Audits and Self-Assessments | |||
Number Title Date W3F1-2017- | Number Title Date | ||
- | LO-WLO-2017- Radiation Safety 71151 OR01 Occupational Exposure November | ||
W3F1-2017- | 00068 Control Effectiveness 29, 2017 | ||
- | Miscellaneous Documents | ||
Number Title Date | |||
W3F1-2017- NRC Performance Indicator (PI) Data - 1st Quarter 2017 April 12, 2017 | |||
0036 ROP Data | |||
W3F1-2017- NRC Performance Indicator (PI) Data - 2nd Quarter 2017 July 13, 2017 | |||
0058 ROP Data | |||
Miscellaneous Documents | Miscellaneous Documents | ||
Number Title Date W3F1-2017- | Number Title Date | ||
- | W3F1-2017- NRC Performance Indicator (PI) Data - 3rd Quarter 2017 October 6, | ||
- | 0076 ROP Data 2017 | ||
Number Title Revision EN-LI-114 Regulatory Performance Indicator Process | W3F1-2018- NRC Performance Indicator (PI) Data - 4th Quarter 2017 January 9, | ||
0004 ROP Data 2018 | |||
Procedures | |||
Number Title Revision | |||
EN-LI-114 Regulatory Performance Indicator Process 9 | |||
71152 - Problem Identification and Resolution | 71152 - Problem Identification and Resolution | ||
Miscellaneous Documents | Miscellaneous Documents | ||
Number Title Date White Paper | Number Title Date | ||
Cascading Technical Specifications During Emergency Diesel Generator Outages | White Paper Cascading Technical Specifications During Emergency February, | ||
Diesel Generator Outages 2018 | |||
Number Title Revision EN-LI-100 Process Applicability Determination Form | Procedures | ||
OP-100-014 Technical Specification and Technical Requirements | Number Title Revision | ||
336, 337, 340 | EN-LI-100 Process Applicability Determination Form 19 | ||
OP-100-014 Technical Specification and Technical Requirements 336, 337, 340 | |||
Compliance | |||
Condition Reports (CRs) | Condition Reports (CRs) | ||
CR-WF3-2017-00780 CR-WF3-2017-00785 | CR-WF3-2017-00780 CR-WF3-2017-00785 | ||
Occupational Radiation Safety Inspection | Occupational Radiation Safety Inspection | ||
Waterford-3 Dates of Inspection: January 22 | Waterford-3 | ||
- 26, 2018 Integrated Inspection Report | Dates of Inspection: January 22 - 26, 2018 | ||
Integrated Inspection Report 2018001 | |||
Please provide the requested information on or before January 5, 2018 | Inspection areas are listed in the attachments below. | ||
Please provide the requested information on or before January 5, 2018. | |||
should be in a file/folder titled | Please submit this information using the same lettering system as below. For example, all | ||
contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled | |||
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. | 1- A, applicable organization charts in file/folder 1- B, etc. | ||
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 information is placed on ims.certrec.com, please ensure the inspection exit date entered is at | ||
If you have any questions or comments, please contact Natasha Greene at (817) 200 | least 30 days later than the onsite inspection dates, so the inspectors will have access to the | ||
-1154 or Natasha.Greene@nrc.gov. | 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 | 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. | 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 | |||
-0011. | collection requirements were approved by the Office of Management and Budget, | ||
1. Radiological Hazard Assessment and Exposure Controls (71124.01) and Performance Indicator Verification (71151) | control number 3150-0011. | ||
Date of Last Inspection: | 1. Radiological Hazard Assessment and Exposure Controls (71124.01) and | ||
4/24/2017 | 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 | B. Applicable organization charts | ||
: [[contact::C. Audits]], self | : [[contact::C. Audits]], self-assessments, and LERs written since 4/24/2017, related to this inspection | ||
-assessments, and LERs written since 4/24/2017, related to this inspection area D. Procedure indexes for the radiation protection procedures | area | ||
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 | 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. | 2. Radiation Protection Conduct of Operations, if not included in #1. | ||
3. Personnel Dosimetry | 3. Personnel Dosimetry | ||
Line 541: | Line 641: | ||
7. Conduct of Radiological Surveys | 7. Conduct of Radiological Surveys | ||
8. Radioactive Source Inventory and Control | 8. Radioactive Source Inventory and Control | ||
F. List of corrective action documents (including corporate and sub | F. List of corrective action documents (including corporate and sub-tiered systems) since | ||
-tiered systems) since 4/24/2017. | 4/24/2017. | ||
a. Initiated by the radiation protection organization | a. Initiated by the radiation protection organization | ||
b. Assigned to the radiation protection organization | b. Assigned to the radiation protection organization | ||
NOTE: The lists should indicate the significance level | NOTE: The lists should indicate the significance level of each issue and the search | ||
of each issue and the search criteria used. Please provide in document formats which | criteria used. Please provide in document formats which are searchable so that | ||
are | 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 | H. List of active radiation work permits | ||
I. Radioactive source inventory list all radioactive sources that are required to be leak | |||
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 | tested. Indicate which sources are 10 CFR Part 20, Appendix E, Category 1 or Category | ||
K. A list of any non | 2. Please indicate the radioisotope, initial and current activity (w/assay date), and | ||
-fuel items stored in the spent fuel pools, and if available, their appropriate dose rates (Contact / @ 30cm) | storage location for each applicable source. | ||
J. The last two leak test results for the Category 1 or 2 radioactive sources and any other | |||
-point used during the entry (for Occupational Radiation Safety Performance Indicator verification in accordance with IP 71151). | radioactive source(s) that have failed its leak test within the last two years | ||
: [[contact::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) | 3. In-Plant Airborne Radioactivity Control and Mitigation (71124.03) | ||
Date of Last Inspection: | Date of Last Inspection: 3/21/2016 | ||
3/21/2016 | A. List of contacts and telephone numbers for the following areas: | ||
1. Respiratory Protection Program | 1. Respiratory Protection Program | ||
2. Self-contained breathing apparatus | 2. Self-contained breathing apparatus | ||
B. Applicable organization charts | B. Applicable organization charts | ||
: [[contact::C. Copies of audits]], self | : [[contact::C. Copies of audits]], self-assessments, vendor or NUPIC audits for contractor support | ||
-assessments, vendor or NUPIC audits for | (SCBA), and LERs, written since 3/21/2016 related to: | ||
contractor support (SCBA), and LERs, written since 3/21/2016 related to: | |||
1. Installed air filtration systems | 1. Installed air filtration systems | ||
2. Self-contained breathing apparatuses | 2. Self-contained breathing apparatuses | ||
Line 572: | Line 680: | ||
2. Use and operation of temporary air filtration units | 2. Use and operation of temporary air filtration units | ||
3. Respiratory protection | 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. | 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 | 1. Respiratory protection program | ||
2. Use of self | 2. Use of self-contained breathing apparatuses | ||
-contained breathing apparatuses | |||
3. Air quality testing for SCBAs | 3. Air quality testing for SCBAs | ||
4. Use of installed plant systems, such as containment purge, spent fuel pool ventilation, and auxiliary building ventilation | 4. Use of installed plant systems, such as containment purge, spent fuel pool | ||
F. A summary list of corrective action documents (including corporate and sub | ventilation, and auxiliary building ventilation | ||
-tiered systems) written since 3/21/2016, related to the Airborne Monitoring program including: | 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 | 1. Continuous air monitors | ||
2. Self-contained breathing apparatuses | 2. Self-contained breathing apparatuses | ||
3. Respiratory protection program | 3. Respiratory protection program | ||
NOTE: The lists should indicate the significance level | NOTE: The lists should indicate the significance level of each issue and the search | ||
of each issue and the search criteria used. Please provide in document formats which are | criteria used. Please provide in document formats which are searchable so that | ||
G. List of SCBA qualified personnel | the inspector can perform word searches. | ||
- reactor operators and emergency response personnel | G. List of SCBA qualified personnel - reactor operators and emergency response personnel | ||
H. Inspection records for self | H. Inspection records for self-contained breathing apparatuses (SCBAs) staged in the plant | ||
-contained breathing apparatuses (SCBAs) staged in the plant for use since 3/21/2016. | for use since 3/21/2016. | ||
: [[contact::I. SCBA training and qualification records for control room operators]], shift supervisors, STAs, and OSC personnel for the last year. | : [[contact::I. SCBA training and qualification records for control room operators]], shift supervisors, | ||
A selection of personnel may be asked to demonstrate proficiency in donning, doffing, and performance of functionality check for respiratory devices | STAs, and OSC personnel for the last year. | ||
: [[contact::J. List of respirators (available for use) by type (APR]], SCBA, PAPR, etc.), manufacturer, and model. | A selection of personnel may be asked to demonstrate proficiency in donning, doffing, | ||
and performance of functionality check for respiratory devices | |||
: [[contact::J. List of respirators (available for use) by type (APR]], SCBA, PAPR, etc.), manufacturer, | |||
and model. | |||
ML18128A066 | |||
SUNSI Review Non-Sensitive Publicly Available Keyword: | |||
By: JDixon/rdr Sensitive Non-Publicly Available NRC-002 | |||
OFFICE SRI:DRP/D RI:DRP/D PE:DRP/D BC:DRS/EB1 BC:DRS/EB2 BC:DRS/PSB2 | |||
NAME FRamirez CSpeer JChoate TFarnholtz JDrake HGepford | |||
SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ | |||
DATE 5/7/18 5/4/18 5/7/18 5/3/2018 5/3/18 5/3/18 | |||
OFFICE BC:DRS/OB TL:DRS/IPAT SPE:DRP/D BC:DRP/D | |||
NAME VGaddy GGeorge JDixon GMiller | |||
SIGNATURE /RA/ /RA/ /RA/ /RA/ | |||
DATE 5/7/18 5/3/18 5/3/18 5/8/18 | |||
SUNSI Review | |||
By: | |||
Non-Publicly Available | |||
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 | |||
May 8, 2018 | May 8, 2018 | ||
Mr. John Dinelli | Mr. John Dinelli | ||
Line 636: | Line 723: | ||
Entergy Operations, Inc. | Entergy Operations, Inc. | ||
265 River Road | 265 River Road | ||
Killona, LA | Killona, LA 70057-0751 | ||
70057-0751 | SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED | ||
INSPECTION REPORT 05000382/2018001 | |||
Dear Mr. Dinelli: | |||
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. | On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection | ||
NRC inspectors documented | at your Waterford Steam Electric Station, Unit 3. On April 12, 2018, the NRC inspectors | ||
one Severity Level IV violation with no associated finding. The | discussed the results of this inspection with you and other members of your staff. The results of | ||
NRC is treating this | this inspection are documented in the enclosed report. | ||
violation as | NRC inspectors documented one Severity Level IV violation with no associated finding. The | ||
a non-cited violation (NCV) consistent with Section | NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of | ||
2.3.2.a of the Enforcement Policy. | the Enforcement Policy. | ||
From April 2017 to April 2018, the NRC issued three Severity Level | From April 2017 to April 2018, the NRC issued three Severity Level IV traditional enforcement | ||
IV traditional enforcement violations associated with impacting the ability of the NRC to perform its regulatory oversight function. | violations associated with impacting the ability of the NRC to perform its regulatory oversight | ||
This | function. This includes the one Severity Level IV violation documented in this report. However, | ||
IV violation documented in this report. However , the NRC will not conduct Inspection Procedure | 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, | |||
-Month Period, | because one of the violations occurred in 2006 and is not representative of present | ||
violations | performance. | ||
occurred in 2006 and | If you contest the violation or significance of this NCV, you should provide a response within | ||
is not representative of present performance. | days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear | ||
If you contest the violation or significance of | 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 | |||
days of the date of this inspection report, with the basis for your denial, to the | NRC resident inspector at the Waterford Steam Electric Station, Unit 3. | ||
J. Dinelli 2 | |||
-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 | This letter, its enclosure, and your response (if any) will be made available for public inspection | ||
and copying at http://www.nrc.gov/reading | and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document | ||
-rm/adams.html | Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for | ||
and at the NRC Public Document Room in accordance with 10 | Withholding. | ||
CFR 2.390, | Sincerely, | ||
/RA/ | |||
Geoffrey Miller, Branch Chief | |||
Docket No. 50 | Project Branch D | ||
-382 License No. NPF-38 | Division of Reactor Projects | ||
Docket No. 50-382 | |||
License No. NPF-38 | |||
Enclosure: | |||
Inspection Report 05000382/2018001 | Inspection Report 05000382/2018001 | ||
w/ | w/ Attachments: | ||
1. Documents Reviewed | |||
2. Occupational Radiation Safety Inspection | 2. Occupational Radiation Safety Inspection | ||
Request for Information | Request for Information | ||
U.S. NUCLEAR REGULATORY COMMISSION | U.S. NUCLEAR REGULATORY COMMISSION | ||
Inspection Report | Inspection Report | ||
Docket Number: | Docket Number: 05000382 | ||
I-2018-001-0002 | License Number: NPF-38 | ||
Facility: Waterford Steam Electric Station, Unit | Report Number: 05000382/2018001 | ||
Location: 17265 River Road | Enterprise Identifier: I-2018-001-0002 | ||
Killona, LA | Licensee: Entergy Operations, Inc. | ||
Inspection Dates: January 1, 2018 , to March 31, 2018 | Facility: Waterford Steam Electric Station, Unit 3 | ||
Location: 17265 River Road | |||
Killona, LA 70057 | |||
Inspection Dates: January 1, 2018, to March 31, 2018 | |||
Inspectors: | |||
: [[contact::F. Ramírez]], Senior Resident Inspector | : [[contact::F. Ramírez]], Senior Resident Inspector | ||
: [[contact::C. Speer ]], Resident Inspector | : [[contact::C. Speer]], Resident Inspector | ||
: [[contact::J. Choate]], Project Engineer | : [[contact::J. Choate]], Project Engineer | ||
: [[contact::J. Dixon]], Senior Project Engineer | : [[contact::J. Dixon]], Senior Project Engineer | ||
: [[contact::N. Greene]], PhD, Senior Health Physicist | : [[contact::N. Greene]], PhD, Senior Health Physicist | ||
: [[contact::S. Money]], Health Physicist | : [[contact::S. Money]], Health Physicist | ||
: [[contact::J. | : [[contact::J. ODonnell]], CHP, Health Physicist | ||
Approved By: | Approved By: | ||
: [[contact::G. Miller ]], Chief | : [[contact::G. Miller]], Chief | ||
SUMMARY The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the | SUMMARY | ||
an integrated | The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees | ||
inspection at Waterford Steam Electric Station | performance by conducting an integrated inspection at Waterford Steam Electric Station, Unit 3, | ||
, Unit 3 , in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the | in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the | ||
for more information. An NRC-identified | NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer | ||
violation and additional items are summarized in the | to https://www.nrc.gov/reactors/operating/oversight.html for more information. An | ||
NRC-identified violation and additional items are summarized in the tables below. | |||
Failure to Obtain NRC Staff Authorization | List of Findings and Violations | ||
Prior to Changing a Procedure that Impacts Implementation of Technical | Failure to Obtain NRC Staff Authorization Prior to Changing a Procedure that Impacts | ||
Implementation of Technical Specifications | |||
Significance | Cornerstone Significance Cross-cutting Report | ||
Cross-cutting Aspect | Aspect Section | ||
Severity Level | Not Applicable Severity Level IV Not Applicable 71152 | ||
NCV 05000382/2018001-01 | |||
-01 Closed | Closed | ||
The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.59, Changes, | |||
IV, non-cited violation of 10 | Tests, and Experiments, Section (c)(1), for the licensees failure to submit and obtain | ||
CFR 50.59, | authorization prior to implementation procedures described in the Final Safety Analysis Report. | ||
Additional Tracking Items | |||
Additional Tracking | Type Issue number Title Report Status | ||
Title Report Section | Section | ||
-002-00 Automatic Reactor Scram due to the Failure of Fast Bus Transfer Relays to Automatically Transfer Station Loads to Off | LER 05000382/2017-002-00 Automatic Reactor Scram 71153 Closed | ||
-site Power on a Main Generator Trip | due to the Failure of Fast Bus | ||
Transfer Relays to | |||
Automatically Transfer | |||
Station Loads to Off-site | |||
Power on a Main Generator | |||
Trip | |||
PLANT STATUS | PLANT STATUS | ||
Waterford Steam Electric Station | Waterford Steam Electric Station Unit 3 operated at or near 100 percent rated thermal power for | ||
Unit 3 operated at or near | the entire inspection period. | ||
100 percent rated thermal power for the entire inspection period. | INSPECTION SCOPES | ||
INSPECTION | 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- | |||
-manual/inspection | rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared | ||
-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter | complete when the IP requirements most appropriate to the inspection activity were met | ||
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection | |||
-Water Reactor Inspection Program - Operations Phase. | Program - Operations Phase. The inspectors performed plant status activities described in | ||
D, | IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem | ||
71152, | 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. | with Commission rules and regulations, license conditions, site procedures, and standards. | ||
REACTOR SAFETY | REACTOR SAFETY | ||
71111.01 - Adverse Weather Protection | 71111.01 - Adverse Weather Protection | ||
Impending Severe Weather | Impending Severe Weather (1 Sample) | ||
The inspectors evaluated readiness for impending adverse weather conditions prior to the | |||
on January 16, 2018. 71111.04 - Equipment Alignment | onset of and during extreme low temperatures for the area on January 16, 2018. | ||
Partial Walkdown | 71111.04 - Equipment Alignment | ||
Partial Walkdown (3 Samples) | |||
The inspectors evaluated system configurations during partial walkdowns of the following | |||
systems/trains: | |||
A following maintenance on January | (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 | |||
A with train | January 24, 2018 | ||
B out of service for maintenance on January 24, 2018 (3) Low pressure safety injection train | (3) Low pressure safety injection train A with train B out of service for maintenance on | ||
A with train | March 13, 2018 | ||
B out of service for maintenance | 71111.05 - Fire Protection | ||
Quarterly Inspection (5 Samples) | |||
Quarterly Inspection | The inspectors evaluated fire protection program implementation in the following selected | ||
areas: | |||
rooms A and B, Fire Area | (1) Shutdown cooling heat exchanger rooms A and B, Fire Area RAB 33, on | ||
RAB 33 , on January 4, 2018 | January 4, 2018 | ||
(2) Switchgear room B, Fire Area RAB 8B, E, and F on February 12, 2018 | |||
(3) Control room, Fire Area RAB 1A, B, C, and D on February 12, 2018 | |||
RAB 8B, E, and | (4) Component cooling water heat exchanger B, Fire Area RAB 17 on March 13, 2018 | ||
F on February 12, 2018 (3) Control room, Fire Area | (5) Component cooling water pump room A, Fire Area RAB 19 on March 14, 2018 | ||
RAB 1A, B, C, and | 71111.07 - Heat Sink Performance | ||
D on February 12, 2018 (4) Component cooling water heat exchanger | Heat Sink (1 Sample) | ||
B, Fire Area | The inspectors evaluated the ultimate heat sink performance test on January 23, 2018. | ||
RAB 17 on March 13, 2018 (5) Component cooling water pump room | 71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance | ||
A, Fire Area | Operator Requalification (1 Sample) | ||
RAB 19 on March 14, 2018 71111.07 - Heat Sink Performance | The inspectors observed and evaluated operator performance in the simulator during an | ||
Heat Sink (1 Sample) The inspectors | evaluated emergency plan exercise on February 21, 2018. | ||
evaluated the ultimate heat sink | Operator Performance (1 Sample) | ||
performance | The inspectors observed and evaluated control room operator performance during main turbine | ||
test on January 23, 2018. 71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance | governor valve testing on January 19, 2018. | ||
Operator Requalification | 71111.12 - Maintenance Effectiveness | ||
Routine Maintenance Effectiveness (3 Samples) | |||
observed and evaluated operator performance in the simulator during an evaluated emergency plan exercise | The inspectors evaluated the effectiveness of routine maintenance activities associated | ||
on February 21, 2018. Operator Performance | with the following equipment and/or safety significant functions: | ||
(1) Component cooling water on January 25, 2018 | |||
observed and evaluated control room operator performance during main turbine governor valve testing | (2) 125 Vdc distribution system on March 12, 2018 | ||
on January 19, 2018. 71111.12 - Maintenance Effectiveness | (3) Plant protection system on March 28, 2018 | ||
Routine Maintenance Effectiveness | Quality Control (1 Sample) | ||
The inspectors evaluated maintenance and quality control activities associated with the | |||
the effectiveness of routine | following equipment performance issues: | ||
maintenance activities associated with the following equipment and/or safety significant functions | (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 | |||
25, 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: | |||
A1 vendor and licensee quality documents related to receipt of segments from vendor and associated welding on March | (1) Risk assessment associated with maintenance on boric acid makeup tanks A and B on | ||
7, 2018 | 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 | |||
A and B on January 3, 2018 (2) Risk assessment and risk management actions associated with maintenance on emergency diesel generator | operation on February 6, 2018 | ||
A on January 31, 2018 (3) Control element assembly emergency work and unexpected limiting condition for operation on February | 71111.15 - Operability Determinations and Functionality Assessments (6 Samples) | ||
6, 2018 71111.15 - Operability Determinations and Functionality Assessments | The inspectors evaluated the following operability determinations and functionality | ||
assessments: | |||
(1) Core element assembly calculator 2 unexpected trend on January 2, 2018 | |||
2, 2018 | (2) Atmospheric dump valve A leakage on February 8, 2018 | ||
8, 2018 | (3) Component cooling water heat exchanger B failed performance test on February 9, 2018 | ||
B failed performance test on February 9, 2018 | (4) Reactor coolant pump 2A oil leak on March 8, 2018 | ||
2A oil leak on March 8, 2018 | (5) Core protection calculator Channel C failure on March 26, 2018 | ||
C failure on March 26, 2018 | (6) Ultimate heat sink on March 28, 2018 | ||
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 | |||
A recirculation barrier installation, Phase 3, on March 16, 2018 71111.19 - Post Maintenance Testing | 71111.19 - Post Maintenance Testing (7 Samples) | ||
The inspectors evaluated the following post maintenance tests: | |||
tests: | (1) Reactor trip circuit breaker 6 on January 9, 2018 | ||
on January | (2) High pressure safety injection train B on January 23, 2018 | ||
9, 2018 (2) High pressure safety injection train | (3) Emergency diesel generator A on February 3, 2018 | ||
B on January | (4) Auxiliary component cooling water train B on February 21, 2018 | ||
23, 2018 (3) Emergency diesel generator | (5) Component cooling water pump B to AB suction cross-connect valve solenoid valve | ||
A on February | replacement on March 8, 2018 | ||
3, 2018 (4) Auxiliary component cooling water train | (6) Component cooling water pump B to AB discharge cross-connect valve solenoid valve | ||
B on February | replacement on March 8, 2018 | ||
21, 2018 (5) Component cooling water pump | (7) Low pressure safety injection pump B on March 14, 2018 | ||
B to AB suction | 71111.22 - Surveillance Testing | ||
The inspectors evaluated the following surveillance tests: | |||
8, 2018 (6) Component cooling water pump | Routine (3 Samples) | ||
B to AB discharge cross | (1) Emergency diesel generator A monthly surveillance on January 8, 2018 | ||
- | (2) Safety Channel A nuclear instrumentation functional test on January 24, 2018 | ||
8, 2018 (7) Low pressure safety injection pump | (3) Functional test of plant protective system Channel C on February 23, 2018 | ||
B on March | 71114.06 - Drill Evaluation | ||
14, 2018 | Emergency Planning Drill (1 Sample) | ||
71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: | The inspectors evaluated a site emergency plan drill on February 21, 2018. | ||
Routine (3 Samples) (1) Emergency diesel generator | RADIATION SAFETY | ||
A monthly surveillance on January | 71124.01 - Radiological Hazard Assessment and Exposure Controls | ||
8, 2018 | Radiological Hazard Assessment (1 Sample) | ||
A nuclear instrumentation functional test on January | The inspectors evaluated radiological hazards assessments and controls. | ||
24, 2018 | Instructions to Workers (1 Sample) | ||
C on February | The inspectors evaluated worker instructions. | ||
23, 2018 | Contamination and Radioactive Material Control (1 Sample) | ||
Emergency Planning Drill | The inspectors evaluated contamination and radioactive material controls. | ||
Radiological Hazards Control and Work Coverage (1 Sample) | |||
on February 21, 2018. RADIATION | The inspectors evaluated radiological hazards control and work coverage. | ||
High Radiation Area and Very High Radiation Area Controls (1 Sample) | |||
Radiological Hazard | The inspectors evaluated risk-significant high radiation area and very high radiation area | ||
Assessment | controls. | ||
Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample) | |||
evaluated radiological hazards assessments and controls | 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) | |||
evaluated radiological hazards control and work coverage | The inspectors evaluated respiratory protection. | ||
Self-Contained Breathing Apparatus for Emergency Use (1 Sample) | |||
The inspectors evaluated the licensees self-contained breathing apparatus program. | |||
-significant high radiation area and very high radiation area controls. Radiation Worker Performance and Radiation Protection Technician Proficiency | OTHER ACTIVITIES - BASELINE | ||
71151 - Performance Indicator Verification (5 Samples) | |||
The inspectors verified licensee performance indicator submittals listed below: | |||
Engineering Controls | (1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (January 1, 2017, through | ||
December 31, 2017) | |||
evaluated airborne controls and monitoring | (2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample (January 1, 2017, | ||
. | through December 31, 2017) | ||
Use of Respiratory Protection Devices | (3) IE04: Unplanned Scrams with Complications (USwC) Sample (January 1, 2017, | ||
through December 31, 2017) | |||
evaluated respiratory protection | (4) OR01: Occupational Exposure Control Effectiveness Sample (April 1, 2017, through | ||
December 31, 2017) | |||
for Emergency Use | (5) PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation | ||
Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent | |||
evaluated the | Occurrences Sample (April 1, 2017, through December 31, 2017) | ||
71152 - Problem Identification and Resolution | |||
Annual Follow-up of Selected Issues (1 Sample) | |||
verified licensee performance | The inspectors reviewed the licensees implementation of its corrective action program | ||
indicator submittals | related to the following issue: | ||
listed below: | (1) Implementation of change to technical specification and technical requirements | ||
7000 Critical Hours Sample (January 1, 2017, through December 31, 2017) (2) IE03: | compliance procedure | ||
7000 Critical Hours Sample (January 1, 2017, through December | 71153 - Follow-up of Events and Notices of Enforcement Discretion | ||
31, 2017) (3) IE04: | Licensee Event Reports (1 Sample) | ||
31, 2017) (4) OR01: | The inspectors evaluated the following licensee event reports which can be accessed at | ||
Annual Follow | https://lersearch.inl.gov/LERSearchCriteria.aspx: | ||
-up of Selected | (1) Licensee Event Report (LER) 05000382/2017-002-00, Automatic Reactor Scram due to | ||
the Failure of Fast Bus Transfer Relays to Automatically Transfer Station Loads to | |||
the following issue: | Off-site Power on a Main Generator Trip, on July 17, 2017 | ||
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 | |||
, on July 17, 2017 | |||
INSPECTION RESULTS | INSPECTION RESULTS | ||
Failure to Obtain NRC Staff Authorization | Failure to Obtain NRC Staff Authorization Prior to Changing a Procedure that Impacts | ||
Prior to Changing a Procedure that Impacts Implementation of Technical Specifications | Implementation of Technical Specifications | ||
Cornerstone | Cornerstone Significance Cross-cutting Report | ||
Significance | Aspect Section | ||
Cross-cutting Aspect | Not Applicable Severity Level IV Not Applicable 71152 | ||
Severity Level | NCV 05000382/2018001-01 | ||
Closed | |||
-01 Closed | The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.59, Changes, | ||
Tests, and Experiments, Section (c)(1), for the licensees failure to submit and obtain | |||
IV, non-cited violation of | authorization prior to implementation procedures described in the Final Safety Analysis | ||
CFR 50.59, | 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 | ||
3.7.4 , states , in part , that two independent trains of ultimate heat sink cooling towers shall be Operable in Modes | train consists of a dry cooling tower and a wet cooling tower and its associated water basin. | ||
1, 2, 3, and | Action c of Technical Specification 3.7.4 states that with a tornado watch in effect, all nine dry | ||
4. Each train consists of a dry cooling tower and a wet cooling tower and its associated water basin. | cooling tower fans under the missile protected portion of the dry cooling tower shall be | ||
Action c of Technical Specification | Operable. If the number of Operable fans is less than required, restore the inoperable fan(s) | ||
3.7.4 states that with a tornado watch in effect, all nine dry cooling tower | to Operable status within 1 hour, or be in at least Hot Standby within 6 hours and in Hot | ||
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 hour, or be in at least Hot Standby within 6 | Shutdown within the following 6 hours. The licensee established Procedure OP-100-014, | ||
hours and in Hot Shutdown within the following 6 | Technical Specification and Technical Requirements Compliance, Revision 336, to provide | ||
hours. The licensee established Procedure OP-100-014, | guidance for determining Operability of equipment and ensuring compliance with the technical | ||
technical requirements manual. Procedure OP-100-014, Attachment | specifications and technical requirements manual. Procedure OP-100-014, Attachment 6.6, | ||
6.6, | Specific System Guidelines, provides guidelines on actions when declaring a system | ||
One of the systems listed and discussed is the ultimate heat sink and its associated Technical Specification | inoperable. One of the systems listed and discussed is the ultimate heat sink and its | ||
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. | associated Technical Specification 3.7.4. | ||
The licensee revised Procedure OP-100-014, Revision | The Process Applicability Determination process is a method for determining which plant | ||
336, using a Process Applicability Determination | licensing basis documents and processes are affected by a proposed activity and must be | ||
Evaluation [ | revised to reflect that activity. The licensee revised Procedure OP-100-014, Revision 336, | ||
PAD-OP-100-014, Revision | using a Process Applicability Determination Evaluation [PAD-OP-100-014, Revision 337] to | ||
337] to provide additional guidance on implementation of | provide additional guidance on implementation of Technical Specification 3.7.4. | ||
Technical Specification | Procedure OP-100-014, Revision 337, was implemented in February 2017 with an added | ||
3.7.4. Procedure OP-100-014, Revision | note stating, in part, if the dry cooling tower fans are declared inoperable solely due to wet | ||
337, was implemented in February | cooling tower fans being out of service (cascading technical specification), then Technical | ||
2017 with an added note stating, in part , | Specification 3.7.4.c does not need to be applied upon a tornado watch/warning. The | ||
3.7.4.c does not need to be applied upon a tornado watch/warning. The licensee performed a technical analysis and concluded that | licensee performed a technical analysis and concluded that the missile-protected dry cooling | ||
the missile | tower fans were to be considered Operable for the tornado event because wet cooling tower | ||
-protected dry cooling tower fans were to be | fan operation is not credited in the tornado event analysis. | ||
considered Operable for the | The licensee used Procedure EN-LI-100, Process Applicability Determination, to evaluate | ||
tornado event because wet cooling tower fan operation is not credited in the tornado event analysis | 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 | |||
Procedure EN-LI-100, | render incorrect, information contained in any of the following Licensing Basis Documents? | ||
Determination | the licensee answered no for impact on Operating License/Technical Specifications. | ||
, | However, the inspectors determined that this addition to the site procedure could adversely | ||
When answering the question | 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 | ||
However, the inspectors determined that this addition to the site procedure could adversely impact the bases for the acceptability to ultimate heat sink | prepare a licensing basis document change request. The inspectors concluded that if | ||
design and operations. | Procedure OP-100-014, Revision 337, would have been implemented as written, it would | ||
As a result, that question should have been answered | have constituted a change affecting an evaluation that demonstrates the function of the | ||
change request. The inspectors concluded that | ultimate heat sink. | ||
The inspectors confirmed that between February 2017 and January 2018, there were no | |||
337, would have been | tornado watches that coincided with ultimate heat sink system work windows. Therefore, | ||
implemented as written, it would | during the time this note was in the procedure, the licensee did not invoke the provision. | ||
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 | Corrective Action(s): The licensee removed the note from Procedure OP-100-014, and | ||
system work windows. | corrected the interpretation of the technical specification. Procedure OP-100-014, | ||
Therefore, during the time this note was in the procedure, the licensee did not invoke the | Revision 342, which removed the note, became effective January 2018. Therefore, if the wet | ||
provision. | cooling tower fans are inoperable, and there is a simultaneous tornado watch/warning, the | ||
Corrective Action(s): | licensee will implement Technical Specification 3.7.4, Action c. | ||
interpretation of the technical specification. Procedure OP-100-014, Revision 342, which removed the note, became effective January | Corrective Action Reference(s): CR-WF3-2018-02111 | ||
fans are inoperable, and there is a simultaneous tornado watch/warning, the licensee will implement | Performance Assessment: | ||
Technical Specification | Performance Deficiency: The licensees failure to submit a licensing basis document change | ||
3.7.4, Action | request when performing a change impacting technical specifications in accordance with | ||
c. Corrective Action Reference(s): | Procedure EN-LI-100, Process Applicability Determination, was a performance deficiency. | ||
CR-WF3- | 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 | ||
technical specifications in accordance with Procedure EN-LI-100, | procedure instructs the licensee to prepare a licensing basis document change request in | ||
Screening: | accordance with the licensing basis document change process. | ||
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 | Screening: The inspectors determined the performance deficiency was of minor significance | ||
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 | 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 | |||
The | performance deficiency using the traditional enforcement process and the examples in | ||
2.1.3 of the NRC Enforcement Manual. | Section 6.1 of the Enforcement Policy. | ||
The inspectors | Enforcement: | ||
determined the violation to be a Severity Level | Severity: The ROPs significance determination process does not specifically consider the | ||
regulatory process impact in its assessment of licensee performance. Therefore, it is | |||
Violation: | necessary to address this violation which impedes the NRCs ability to regulate using | ||
traditional enforcement to adequately deter noncompliance. This violation was more than | |||
The licensee established | minor because there was a reasonable likelihood the change would require NRC review and | ||
Procedure | approval prior to implementation, similar to violations assessed in Section 2.1.3 of the NRC | ||
EN-LI-100, | Enforcement Manual. The inspectors determined the violation to be a Severity Level IV | ||
a proposed activity affects, invalidates, or renders incorrect, information contained in Technical Specifications. | violation similar to violation Example 6.1.d.2 in the NRC Enforcement Policy. | ||
Contrary to the above requirements, from February 2017, until December | Violation: As stated, in part, in 10 CFR 50.59, Changes, Tests, and Experiments, | ||
2017, the licensee | Section (c)(1), a licensee may make changes in the facility as described in the final safety | ||
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 | analysis report (as updated), make changes in the procedure as described in the final safety | ||
3.7.4, Action | analysis report (as updated), and conduct tests or experiments not described in the final | ||
c, through the implementation of Procedure OP-100-014, | safety analysis report (as updated) without obtaining a license amendment pursuant to | ||
3.7.4.c in the event of a tornado watch/warning if the dry cooling tower | 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 | |||
fans being out of service. This action was inconsistent with the current licensing basis and would have constituted a violation of technical specifications. | Determination, Revision 19, to comply with this requirement. Attachment 9.1 of | ||
Enforcement Action: | Procedure EN-LI-100 states, in part, to prepare a licensing basis document change request if | ||
corrective action program as CR | a proposed activity affects, invalidates, or renders incorrect, information contained in | ||
-WF3-2018-02111, this violation is being treated as a non | Technical Specifications. | ||
-cited violation, consistent with Section | Contrary to the above requirements, from February 2017, until December 2017, the licensee | ||
2.3.2 of the NRC Enforcement Policy | completed an activity that affected Technical Specifications and did not prepare a licensing | ||
basis document change request. Specifically, the licensee implemented a change to | |||
-002-00 | Technical Specification 3.7.4, Action c, through the implementation of | ||
: | Procedure OP-100-014, Technical Specification and Technical Requirements Compliance, | ||
the facts and circumstances surrounding this event. The results and findings of that inspection are documented in NRC Inspection Report | Revision 337, by adding a note that instructed Operations personnel to not enter Technical | ||
05000382/2017011 (Agencywide Documents Access and Management System (ADAMS) Accession No. | Specification 3.7.4.c in the event of a tornado watch/warning if the dry cooling tower fans | ||
ML17354A690). The inspectors did not identify any new deficiencies as a result of this review. This LER is closed. | were declared inoperable solely due to wet cooling tower fans being out of service. This | ||
action was inconsistent with the current licensing basis and would have constituted a violation | |||
of technical specifications. | |||
Enforcement Action: Because this violation was not repetitive or willful, and was entered into | |||
the licensees corrective action program as CR-WF3-2018-02111, this violation is being | |||
treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy. | |||
Licensee Event Automatic Reactor Scram due to the Failure of Fast Bus 71153 | |||
Report Transfer Relays to Automatically Transfer Station Loads to | |||
(Closed) Off-site Power on a Main Generator Trip | |||
05000382/2017-002-00 | |||
Description: The NRC conducted a special inspection to better understand the facts and | |||
circumstances surrounding this event. The results and findings of that inspection are | |||
documented in NRC Inspection Report 05000382/2017011 (Agencywide Documents Access | |||
and Management System (ADAMS) Accession No. ML17354A690). The inspectors did not | |||
identify any new deficiencies as a result of this review. This LER is closed. | |||
EXIT MEETINGS AND DEBRIEFS | |||
The inspectors verified no proprietary information was retained or documented in this report. | |||
On January 25, 2018, the inspectors presented the radiation safety inspection results to | |||
Mr. | |||
: [[contact::J. Dinelli]], Site Vice President, and other members of the licensee staff. | |||
On April 12, 2018, the resident inspectors presented the quarterly resident inspector inspection | |||
results to Mr. | |||
: [[contact::J. Dinelli]], Site Vice President, and other members of the licensee staff. | |||
DOCUMENTS REVIEWED | |||
71111.01 - Adverse Weather Protection | |||
Procedures | |||
Number Title Revision | |||
OP-002-007 Freeze Protection and Temperature Maintenance 25 | |||
OP-901-521 Severe Weather and Flooding 325 | |||
Condition Reports (CRs) | |||
CR-WF3-2017-09668 CR-WF3-2018-00004 CR-WF3-2018-00082 CR-WF3-2018-00098 | |||
CR-WF3-2018-00436 | |||
71111.04 - Equipment Alignment | |||
Procedures | |||
Number Title Revision | |||
OP-002-003 Component Cooling Water 317 | |||
OP-009-003 Emergency Feedwater 309 | |||
OP-009-008 Safety Injection System 41 | |||
71111.05 - Fire Protection | |||
Miscellaneous Documents | |||
Number Title Revision | |||
RAB1A-B-C-D- Control Room Proper, H&V Room, Emergency Living 10 | |||
001 Quarters, and Computer Room | |||
RAB8B-E-F-001 Switchgear B 12 | |||
RAB 17-001 Component Cooling Water Heat Exchanger B 8 | |||
RAB 19-001 Component Cooling Water Pump Room A 7 | |||
RAB 33-001 Shutdown Cooling Heat Exchanger Rooms A and B 8 | |||
Procedures | |||
Number Title Revision | |||
FP-001-018 Pre-fire Strategies, Development and Revision 304 | |||
71111.11 - Licensed Operator Requalification Program and Licensed Operator | |||
Performance | |||
Procedures | |||
Number Title Revision | |||
OP-901-111 Reactor Coolant System Leak 303 | |||
OP-901-403 High Airborne Activity in Containment 4 | |||
OP-901-404 High Airborne Activity in FHB 2 | |||
OP-901-405 Fuel Handling Incident 8 | |||
OP-901-513 Spent Fuel Pool Cooling Malfunction 21 | |||
OP-902-002 Loss of Coolant Accident Recovery 20 | |||
71111.12 - Maintenance Effectiveness | |||
Miscellaneous Documents | |||
Number Title Revision | |||
910163-001 PCI Quality Assurance Traveler - FOST A1 Fabrication 1 | |||
EC-53943 Station Battery B Cell Lid Cracking 0 | |||
EC-57534 Station Battery A Cell Lid Cracks 0 | |||
QPP-205 Graham, Visual Inspection 17 | |||
QPP-205 Graham, Visual Inspection addenda 1 | |||
Addenda | |||
WDT-0528 PCI Welding EDG Supplemental Fuel Oil Storage Tank 0 | |||
WF3-FOST-DN- Deviation Notice for Waterford 3 Fuel Oil Storage Tank, 1 | |||
21 Tank A1 - Rust and Arc Strikes on Shell | |||
Procedures | |||
Number Title Revision | |||
ME-003-200 Station Battery Bank and Charger (Weekly) 314 | |||
Condition Reports (CRs) | |||
CR-WF3-2014-05777 CR-WF3-2014-06375 CR-WF3-2014-06378 CR-WF3-2015-00842 | |||
CR-WF3-2015-01802 CR-WF3-2015-04849 CR-WF3-2015-04850 CR-WF3-2015-04854 | |||
CR-WF3-2017-03566 CR-WF3-2017-03607 CR-WF3-2017-06789 CR-WF3-2017-08771 | |||
CR-WF3-2017-08845 CR-WF3-2017-09167 | |||
Work Orders | |||
446024 | |||
71111.13 - Maintenance Risk Assessments and Emergent Work Control | |||
Procedures | |||
Number Title Revision | |||
OP-903-005 Control Element Assembly Operability Check 14 | |||
71111.15 - Operability Determinations and Functionality Assessments | |||
Miscellaneous Documents | |||
Number Title Revision/Date | |||
Protected Equipment List January 31, | |||
2018 | |||
EC-40444 Revised Impact AST Dose Analyses to Address MSSV and 1 | |||
ADV Leakages | |||
EC-75901 Component Cooling Water Heat Exchanger Degraded 1 | |||
Performance | |||
ECM95-008 Ultimate Heat Sink Design Basis 3 | |||
ECS05-13 Ultimate Head Sink Containment Heat Loads 1 | |||
MNQ9-2 Component Cooling Water System 2 | |||
MNQ9-50 ACCW System Resistance 2 | |||
TD-G080.0495 General Electric Spare Reactor Coolant Pump Motor 1 | |||
Drawings | |||
WF3-ME-16- Meteorological Parameters and Parameter Relationships for 0 | |||
00001 Design and Operability of the Waterford 3 Ultimate Heat | |||
Sink | |||
Procedures | |||
Number Title Revision | |||
OP-001-002 Reactor Coolant Pump Operation 22 | |||
PE-004-021 CCW Heat Exchanger Performance Test 5 | |||
Condition Reports (CRs) | |||
CR-WF3-2011-07700 CR-WF3-2012-02332 CR-WF3-2018-00662 CR-WF3-2018-00785 | |||
CR-WF3-2018-00948 CR-WF3-2018-00951 CR-WF3-2018-00986 CR-WF3-2018-01225 | |||
Condition Reports (CRs) | |||
CR-WF3-2018-01426 CR-WF3-2018-01549 CR-WF3-2018-01559 | |||
Work Orders | |||
481333 495770 495771 496893 52348919 | |||
71111.18 - Plant Modifications | |||
Miscellaneous Documents | |||
Number Title Revision | |||
6W12CM10 Common Mat Stress Analysis - Cooling Tower Area 2 | |||
ECC16-004 Horizontal Air Flow Barrier Roof and Gutters at Dry Cooling 0 | |||
Tower Outside Missile Protection | |||
ECM95-008 Ultimate Heat Sink Design Basis 3 | |||
MNQ9-52 Ultimate Heat Sink Performance based on data 2 | |||
WF3-ME-16- Meteorological Parameters and Parameter Relationships for 0 | |||
00001 Design and Operability of the Waterford 3 Ultimate Heat | |||
Sink | |||
Condition Reports (CRs) | |||
CR-WF3-2012-02332 | |||
Work Orders | |||
444257 | |||
71111.19 - Post-Maintenance Testing | |||
Miscellaneous Documents | |||
Number Title Revision | |||
AR 184566 Replace Solenoid Valve | |||
AR 186060 Align PMRQs for AOV PM Optimization Program | |||
TD A610.0155 ASCO Installation and Maintenance Instructions for 3-Way 0 | |||
Solenoid Valves Series 8316 | |||
Procedures | |||
Number Title Revision/Date | |||
ME-007-019 ASCO/AVCO/MAC/Parker Hannifin Solenoid Valves 306 | |||
Procedures | |||
Number Title Revision/Date | |||
MM-003-041 Six Year Emergency Diesel Engine Inspection February 2, | |||
2018 | |||
OP-903-030 Safety Injection Pump Operability Verification 35 | |||
OP-903-050 Component Cooling Water and Auxiliary Component 039 | |||
Cooling Water Pump and Valve Operational Test | |||
OP-903-118 Primary Auxiliaries Quarterly IST Valve Tests 43 | |||
OP-903-121 Safety System Quarterly IST Valve Tests 27 | |||
Condition Reports (CRs) | |||
CR-WF3-2017-07146 CR-WF3-2018-00441 CR-WF3-2018-00808 CR-WF3-2018-01498 | |||
Work Orders | |||
436357 52649596 52673039 52701091 | |||
71111.22 - Surveillance Testing | |||
Miscellaneous Documents | |||
Number Title Date | |||
TD-C490.0485 Combustion Engineering Ex-Core Neutron Flux Monitoring April, 1985 | |||
System Safety Channel Operation and Maintenance Manual | |||
Procedures | |||
Number Title Revision | |||
MI-003-002 Safety Channel Nuclear Instrumentation Functional Test 17 | |||
OP-903-068 Emergency Diesel Generator and Subgroup Relay 319 | |||
Operability Verification | |||
OP-903-107 Plant Protection System Channel C Functional Test 312 | |||
Work Orders | |||
2800018 52800019 | |||
71114.06 - Drill Evaluation | |||
Procedures | |||
Number Title Revision | |||
EP-001-010 Unusual Event 306 | |||
EP-001-020 Alert 309 | |||
EP-001-030 Site Area Emergency 308 | |||
EP-002-010 Notifications and Communications 315 | |||
OP-902-002 Loss of Coolant Accident Recovery 20 | |||
Condition Reports (CRs) | |||
CR-WF3-2018-01082 CR-WF3-2018-01083 CR-WF3-2018-01084 CR-WF3-2018-01095 | |||
71124.01 - Radiological Hazard Assessment and Exposure Controls | |||
Air Sample Surveys | |||
Number Title Date | |||
OL-011518-002 Pool Purification Pump Shaft Removal January 15, | |||
2018 | |||
OL-02112017- Sluice CVC IX A February 11, | |||
013 2017 | |||
OL-032717-006 Lapel Air Sample for RWP 2017-0064 March 27, | |||
2017 | |||
OL-040417-004 Alpha Air - RAB -35 Safeguards Room A April 4, 2017 | |||
OL-072217-0015 Alpha Air - Letdown Valve Gallery July 22, 2017 | |||
RF-05162017- Alpha Air - Top of UGS May 16, 2017 | |||
561 | |||
Audits and Self-Assessments | |||
Number Title Date | |||
LO-WLO-2017- November | |||
Pre-NRC Self-Assessment Radiation Safety - IP 71124.01 | |||
00068 CA-00005 30, 2017 | |||
Miscellaneous Documents | |||
Number Title Date | |||
NSTS Annual Inventory Reconciliation Report January 4, | |||
2018 | |||
Miscellaneous Documents | |||
Number Title Date | |||
Periodic Review of Plant Isotopic Mix Compared to September | |||
Radiation Protection Instrument, Revision 1 21, 2017 | |||
Review of Smears Taken for Alpha Characterization During September | |||
RF21 19, 2017 | |||
Spent Fuel Pool Inventory October 25, | |||
2017 | |||
Update to the Review of the Capabilities of Our Passive October 4, | |||
Monitoring Program to Detect Intakes at Waterford-3 2017 | |||
2017-2018 Entergy Waterford 3 Radiation Protection Department August 10, | |||
Respiratory Improvement Plan 2017 | |||
Att. 9.6 to EN- LHRA/VHRA Key Log January 23- | |||
RP-101 25, 2018 | |||
WO 52734309 Sealed Source Leak Test June 22, | |||
2017 | |||
WO 52768769 Semi-Annual Source Inventory December | |||
11, 2017 | |||
Procedures | |||
Number Title Revision | |||
EN-RE-220 PWR Control of Miscellaneous Materials in the Spent Fuel 3 | |||
Pool | |||
EN-RP-100 Radiation Worker Expectations 12 | |||
EN-RP-101 Access Control for Radiologically Controlled Areas 13 | |||
EN-RP-102 Radiological Control 5 | |||
EN-RP-104 Personnel Contamination Events 9 | |||
EN-RP-105 Radiological Work Permits 18 | |||
EN-RP-106 Radiological Survey Documentation 7 | |||
EN-RP-108 Radiation Protection Posting 19 | |||
EN-RP-109 Hot Spot Program 5 | |||
EN-RP-121 Radioactive Material Control 13 | |||
EN-RP-122 Alpha Monitoring 9 | |||
EN-RP-143 Source Control 13 | |||
EN-RP-315 Operation and Calibration of the CRONOS Contamination 2 | |||
Monitor | |||
Radiation Surveys | |||
Number Title Date | |||
WF3-1704-0537 +46 Pressurizer Cubicle April 18, 2017 | |||
WF3-1705-0049 FHB +46 Fuel Handling Area May 1, 2017 | |||
WF3-1711-0270 FHB +46 Fuel Handling Area November | |||
30, 2017 | |||
WF3-1711-0271 FHB +46 Fuel Handling Area November | |||
30, 2017 | |||
WF3-1801-0194 RAB -4 Hallways January 16, | |||
2018 | |||
WF3-1801-0213 RAB -35 Hallways January 18, | |||
2018 | |||
WF3-1801-0262 RAB -21 Hallways January 24, | |||
2018 | |||
Radiation Work Permits | |||
Number Title Revision | |||
2017-0101 Work Activities in the Spent Fuel Pool and the Transfer 1 | |||
Canal | |||
2017-0509 RF21 Remove/Replace Steam Generator Primary 1 | |||
Manways/Diaphragms | |||
2017-0510 Install/Remove Steam Generator Nozzle Dams, Pin 2 | |||
Verification and Closure | |||
2017-0705 RF21 Reassembly of Reactor Head and Associated Work 0 | |||
Activities | |||
2017-0727 RF21 Perform Reactor Vessel (ISI) Inspection Using the 2 | |||
WestDyne (ROSA) and a Submarine | |||
2018-0004 Maintenance Activities in all Radiologically Controlled Areas 0 | |||
2018-0007 Perform Various Decon and Housekeeping Activities in all 0 | |||
Radiologically Controlled Areas | |||
Condition Reports (CRs) | |||
CR-WF3-2017-02540 CR-WF3-2017-02718 CR-WF3-2017-02956 CR-WF3-2017-03344 | |||
CR-WF3-2017-03349 CR-WF3-2017-03362 CR-WF3-2017-03799 CR-WF3-2017-03872 | |||
CR-WF3-2017-03953 CR-WF3-2017-06030 CR-WF3-2017-06758 CR-WF3-2017-07988 | |||
CR-WF3-2017-08330 CR-WF3-2018-00506 CR-WF3-2018-00507 WT-WTWF3-2017- | |||
273 | |||
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation | |||
Air Quality Testing Results | |||
Number Title Date | |||
296484-0 Compressed Air/Gas Quality Testing Laboratory Report February 15, | |||
2017 | |||
296614-0 Compressed Air/Gas Quality Testing Laboratory Report February 16, | |||
2017 | |||
309752-0 Compressed Air/Gas Quality Testing Laboratory Report July 28, 2017 | |||
309780-0 Compressed Air/Gas Quality Testing Laboratory Report July 31, 2017 | |||
Audits and Self-Assessments | |||
Number Title Date | |||
LO-WLO-2017- Pre-NRC Assessment IP 71124.03 In-Plant Airborne November | |||
00068 Radioactivity Control and Mitigation 23, 2017 | |||
Filtration Testing Results | |||
Number Title Date | |||
257571 Charcoal Sample Testing May 31, 2016 | |||
2577572 In-Place HEPA Filter Testing June 1, 2016 | |||
2704414 In-Place Charcoal Filter Testing November 8, | |||
2017 | |||
Miscellaneous Documents | |||
Number Title Date | |||
Inspection and Maintenance of Respiratory Protection December | |||
Equipment - Face Piece Inspection Log 27, 2017 | |||
Inspection and Maintenance of Respiratory Protection December | |||
Equipment - SCBA Inspection Log 27, 2017 | |||
2017-0702-04 TEDE-ALARA Evaluation November | |||
15, 2016 | |||
Procedures | |||
Number Title Revision | |||
EN-RP-310 Operation and Initial Setup of the Eberline AMS-4 4 | |||
Continuous Air Monitor | |||
EN-RP-501 Respiratory Protection Program 5 | |||
Procedures | |||
Number Title Revision | |||
EN-RP-502 Inspection and Maintenance of Respiratory Protection 10 | |||
Equipment | |||
EN-RP-502-01 Fire Hawk M7 SCBA 1 | |||
EN-RP-503 Selection, Issue And Use Of Respiratory Protection 7 | |||
Equipment | |||
EN-RP-504 Breathing Air 4 | |||
SCBA Maintenance Records | |||
Number Title Date | |||
UEM-6123 Posi3 USB Test Results - Complete SCBA Test March 31, | |||
2016 | |||
UEM-6123 Posi3 USB Test Results - Complete SCBA Test February 13, | |||
2017 | |||
UEM-6259 Posi3 USB Test Results - Complete SCBA Test March 30, | |||
2016 | |||
UEM-6259 Posi3 USB Test Results - Complete SCBA Test February 14, | |||
2017 | |||
Condition Reports (CRs) | |||
CR-WF3-2016-03044 CR-WF3-2017-00011 CR-WF3-2017-00375 CR-WF3-2017-00678 | |||
CR-WF3-2017-04253 CR-WF3-2017-05533 CR-WF3-2017-06536 CR-WF3-2017-06758 | |||
71151 - Performance Indicator Verification | |||
Audits and Self-Assessments | |||
Number Title Date | |||
LO-WLO-2017- Radiation Safety 71151 OR01 Occupational Exposure November | |||
00068 Control Effectiveness 29, 2017 | |||
Miscellaneous Documents | |||
Number Title Date | |||
W3F1-2017- NRC Performance Indicator (PI) Data - 1st Quarter 2017 April 12, 2017 | |||
0036 ROP Data | |||
W3F1-2017- NRC Performance Indicator (PI) Data - 2nd Quarter 2017 July 13, 2017 | |||
0058 ROP Data | |||
Miscellaneous Documents | |||
Number Title Date | |||
W3F1-2017- NRC Performance Indicator (PI) Data - 3rd Quarter 2017 October 6, | |||
0076 ROP Data 2017 | |||
W3F1-2018- NRC Performance Indicator (PI) Data - 4th Quarter 2017 January 9, | |||
0004 ROP Data 2018 | |||
Procedures | |||
Number Title Revision | |||
EN-LI-114 Regulatory Performance Indicator Process 9 | |||
71152 - Problem Identification and Resolution | |||
Miscellaneous Documents | |||
Number Title Date | |||
White Paper Cascading Technical Specifications During Emergency February, | |||
Diesel Generator Outages 2018 | |||
Procedures | |||
Number Title Revision | |||
EN-LI-100 Process Applicability Determination Form 19 | |||
OP-100-014 Technical Specification and Technical Requirements 336, 337, 340 | |||
Compliance | |||
Condition Reports (CRs) | |||
CR-WF3-2017-00780 CR-WF3-2017-00785 | |||
Occupational Radiation Safety Inspection | |||
Waterford-3 | |||
Dates of Inspection: January 22 - 26, 2018 | |||
Integrated Inspection Report 2018001 | |||
Inspection areas are listed in the attachments below. | |||
Please provide the requested information on or before January 5, 2018. | |||
Please submit this information using the same lettering system as below. For example, all | |||
contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled | |||
1- A, applicable organization charts in file/folder 1- B, etc. | |||
If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at | |||
least 30 days later than the onsite inspection dates, so the inspectors will have access to the | |||
information while writing the report. | |||
In addition to the corrective action document lists provided for each inspection procedure listed | |||
below, please provide updated lists of corrective action documents at the entrance meeting. | |||
The dates for these lists should range from the end dates of the original lists to the day of the | |||
entrance meeting. | |||
If more than one inspection procedure is to be conducted and the information requests appear | |||
to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which | |||
file the information can be found. | |||
If you have any questions or comments, please contact Natasha Greene at (817) 200-1154 or | |||
Natasha.Greene@nrc.gov. | |||
PAPERWORK REDUCTION ACT STATEMENT | |||
This letter does not contain new or amended information collection requirements subject | |||
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information | |||
collection requirements were approved by the Office of Management and Budget, | |||
control number 3150-0011. | |||
1. Radiological Hazard Assessment and Exposure Controls (71124.01) and | |||
Performance Indicator Verification (71151) | |||
Date of Last Inspection: 4/24/2017 | |||
A. List of contacts and telephone numbers for the Radiation Protection Organization Staff | |||
and Technicians | |||
B. Applicable organization charts | |||
: [[contact::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 | |||
: [[contact::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 | |||
: [[contact::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. | |||
: [[contact::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 | |||
: [[contact::J. List of respirators (available for use) by type (APR]], SCBA, PAPR, etc.), manufacturer, | |||
and model. | |||
ML18128A066 | |||
SUNSI Review Non-Sensitive Publicly Available Keyword: | |||
By: JDixon/rdr Sensitive Non-Publicly Available NRC-002 | |||
OFFICE SRI:DRP/D RI:DRP/D PE:DRP/D BC:DRS/EB1 BC:DRS/EB2 BC:DRS/PSB2 | |||
NAME FRamirez CSpeer JChoate TFarnholtz JDrake HGepford | |||
SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ | |||
DATE 5/7/18 5/4/18 5/7/18 5/3/2018 5/3/18 5/3/18 | |||
OFFICE BC:DRS/OB TL:DRS/IPAT SPE:DRP/D BC:DRP/D | |||
NAME VGaddy GGeorge JDixon GMiller | |||
SIGNATURE /RA/ /RA/ /RA/ /RA/ | |||
DATE 5/7/18 5/3/18 5/3/18 5/8/18 | |||
}} | }} |
Latest revision as of 22:40, 18 December 2019
ML18128A066 | |
Person / Time | |
---|---|
Site: | Waterford |
Issue date: | 05/08/2018 |
From: | Geoffrey Miller NRC/RGN-IV/DRP/RPB-D |
To: | Dinelli J Entergy Operations |
Miller G | |
References | |
IR 2018001 | |
Download: ML18128A066 (29) | |
Text
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED INSPECTION REPORT 05000382/2018001
Dear Mr. Dinelli:
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford Steam Electric Station, Unit 3. On April 12, 2018, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
NRC inspectors documented one Severity Level IV violation with no associated finding. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
From April 2017 to April 2018, the NRC issued three Severity Level IV traditional enforcement violations associated with impacting the ability of the NRC to perform its regulatory oversight function. This includes the one Severity Level IV violation documented in this report. However, the NRC will not conduct Inspection Procedure 92723, Follow Up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period, because one of the violations occurred in 2006 and is not representative of present performance.
If you contest the violation or significance of this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the Waterford Steam Electric Station, Unit 3. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Geoffrey Miller, Branch Chief Project Branch D Division of Reactor Projects Docket No. 50-382 License No. NPF-38
Enclosure:
Inspection Report 05000382/2018001 w/ Attachments:
1. Documents Reviewed 2. O
Inspection Report
Docket Number: 05000382 License Number: NPF-38 Report Number: 05000382/2018001 Enterprise Identifier: I-2018-001-0002 Licensee: Entergy Operations, Inc.
Facility: Waterford Steam Electric Station, Unit 3 Location: 17265 River Road Killona, LA 70057 Inspection Dates: January 1, 2018, to March 31, 2018 Inspectors: F. Ramírez, Senior Resident Inspector C. Speer, Resident Inspector J. Choate, Project Engineer J. Dixon, Senior Project Engineer N. Greene, PhD, Senior Health Physicist S. Money, Health Physicist J. ODonnell, CHP, Health Physicist Approved By: G. Miller, Chief Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Waterford Steam Electric Station, Unit 3, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. An NRC-identified violation and additional items are summarized in the tables below.
List of Findings and Violations Failure to Obtain NRC Staff Authorization Prior to Changing a Procedure that Impacts Implementation of Technical Specifications Cornerstone Significance Cross-cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 71152 NCV 05000382/2018001-01 Closed The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.59, Changes,
Tests, and Experiments, Section (c)(1), for the licensees failure to submit and obtain authorization prior to implementation procedures described in the Final Safety Analysis Report.
Additional Tracking Items Type Issue number Title Report Status Section LER 05000382/2017-002-00 Automatic Reactor Scram 71153 Closed due to the Failure of Fast Bus Transfer Relays to Automatically Transfer Station Loads to Off-site Power on a Main Generator Trip
PLANT STATUS
Waterford Steam Electric Station Unit 3 operated at or near 100 percent rated thermal power for the entire inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection Impending Severe Weather
The inspectors evaluated readiness for impending adverse weather conditions prior to the onset of and during extreme low temperatures for the area on January 16, 2018.
71111.04 - Equipment Alignment Partial Walkdown
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Emergency feedwater train A following maintenance on January 12, 2018
- (2) Component cooling water train A with train B out of service for maintenance on January 24, 2018
- (3) Low pressure safety injection train A with train B out of service for maintenance on March 13, 2018
71111.05 - Fire Protection Quarterly Inspection
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) Shutdown cooling heat exchanger rooms A and B, Fire Area RAB 33, on January 4, 2018
- (2) Switchgear room B, Fire Area RAB 8B, E, and F on February 12, 2018
- (3) Control room, Fire Area RAB 1A, B, C, and D on February 12, 2018
- (4) Component cooling water heat exchanger B, Fire Area RAB 17 on March 13, 2018
- (5) Component cooling water pump room A, Fire Area RAB 19 on March 14, 2018
71111.07 - Heat Sink Performance Heat Sink
The inspectors evaluated the ultimate heat sink performance test on January 23, 2018.
71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification
The inspectors observed and evaluated operator performance in the simulator during an evaluated emergency plan exercise on February 21, 2018.
Operator Performance (1 Sample)
The inspectors observed and evaluated control room operator performance during main turbine governor valve testing on January 19, 2018.
71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
- (1) Component cooling water on January 25, 2018
- (2) 125 Vdc distribution system on March 12, 2018
- (3) Plant protection system on March 28, 2018
Quality Control (1 Sample)
The inspectors evaluated maintenance and quality control activities associated with the following equipment performance issues:
- (1) Fuel oil storage tank A1 vendor and licensee quality documents related to receipt of segments from vendor and associated welding on March 7, 2018
71111.13 - Maintenance Risk Assessments and Emergent Work Control
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Risk assessment associated with maintenance on boric acid makeup tanks A and B on January 3, 2018
- (2) Risk assessment and risk management actions associated with maintenance on emergency diesel generator A on January 31, 2018
- (3) Control element assembly emergency work and unexpected limiting condition for operation on February 6, 2018
71111.15 - Operability Determinations and Functionality Assessments
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Core element assembly calculator 2 unexpected trend on January 2, 2018
- (2) Atmospheric dump valve A leakage on February 8, 2018
- (3) Component cooling water heat exchanger B failed performance test on February 9, 2018
- (4) Reactor coolant pump 2A oil leak on March 8, 2018
- (5) Core protection calculator Channel C failure on March 26, 2018
- (6) Ultimate heat sink on March 28, 2018
71111.18 - Plant Modifications
The inspectors evaluated the following temporary or permanent modifications:
- (1) Dry cooling tower train A recirculation barrier installation, Phase 3, on March 16, 2018
71111.19 - Post Maintenance Testing
The inspectors evaluated the following post maintenance tests:
- (1) Reactor trip circuit breaker 6 on January 9, 2018
- (2) High pressure safety injection train B on January 23, 2018
- (3) Emergency diesel generator A on February 3, 2018
- (4) Auxiliary component cooling water train B on February 21, 2018
- (5) Component cooling water pump B to AB suction cross-connect valve solenoid valve replacement on March 8, 2018
- (6) Component cooling water pump B to AB discharge cross-connect valve solenoid valve replacement on March 8, 2018
- (7) Low pressure safety injection pump B on March 14, 2018
71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Routine
- (1) Emergency diesel generator A monthly surveillance on January 8, 2018
- (2) Safety Channel A nuclear instrumentation functional test on January 24, 2018
- (3) Functional test of plant protective system Channel C on February 23, 2018
71114.06 - Drill Evaluation Emergency Planning Drill
The inspectors evaluated a site emergency plan drill on February 21,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls Radiological Hazard Assessment
===The inspectors evaluated radiological hazards assessments and controls.
Instructions to Workers===
The inspectors evaluated worker instructions.
Contamination and Radioactive Material Control (1 Sample)
The inspectors evaluated contamination and radioactive material controls.
Radiological Hazards Control and Work Coverage (1 Sample)
The inspectors evaluated radiological hazards control and work coverage.
High Radiation Area and Very High Radiation Area Controls (1 Sample)
The inspectors evaluated risk-significant high radiation area and very high radiation area controls.
Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample)
The inspectors evaluated radiation worker performance and radiation protection technician proficiency.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation Engineering Controls
The inspectors evaluated airborne controls and monitoring.
Use of Respiratory Protection Devices
The inspectors evaluated respiratory protection.
Self-Contained Breathing Apparatus for Emergency Use (1 Sample)
The inspectors evaluated the licensees self-contained breathing apparatus program.
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicator submittals listed below:
- (1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (January 1, 2017, through December 31, 2017)
- (2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample (January 1, 2017, through December 31, 2017)
- (3) IE04: Unplanned Scrams with Complications (USwC) Sample (January 1, 2017, through December 31, 2017)
- (4) OR01: Occupational Exposure Control Effectiveness Sample (April 1, 2017, through December 31, 2017)
- (5) PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (April 1, 2017, through December 31, 2017)
71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues
The inspectors reviewed the licensees implementation of its corrective action program related to the following issue:
- (1) Implementation of change to technical specification and technical requirements compliance procedure
71153 - Follow-up of Events and Notices of Enforcement Discretion Licensee Event Reports
The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:
- (1) Licensee Event Report (LER) 05000382/2017-002-00, Automatic Reactor Scram due to the Failure of Fast Bus Transfer Relays to Automatically Transfer Station Loads to Off-site Power on a Main Generator Trip, on July 17,
INSPECTION RESULTS
Failure to Obtain NRC Staff Authorization Prior to Changing a Procedure that Impacts Implementation of Technical Specifications Cornerstone Significance Cross-cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 71152 NCV 05000382/2018001-01 Closed The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.59, Changes, Tests, and Experiments, Section (c)(1), for the licensees failure to submit and obtain authorization prior to implementation procedures described in the Final Safety Analysis Report.
Description:
Waterford Technical Specification 3.7.4, states, in part, that two independent trains of ultimate heat sink cooling towers shall be Operable in Modes 1, 2, 3, and 4. Each train consists of a dry cooling tower and a wet cooling tower and its associated water basin.
Action c of Technical Specification 3.7.4 states that with a tornado watch in effect, all nine dry cooling tower fans under the missile protected portion of the dry cooling tower shall be Operable. If the number of Operable fans is less than required, restore the inoperable fan(s)to Operable status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, or be in at least Hot Standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Hot Shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The licensee established Procedure OP-100-014, Technical Specification and Technical Requirements Compliance, Revision 336, to provide guidance for determining Operability of equipment and ensuring compliance with the technical specifications and technical requirements manual. Procedure OP-100-014, Attachment 6.6, Specific System Guidelines, provides guidelines on actions when declaring a system inoperable. One of the systems listed and discussed is the ultimate heat sink and its associated Technical Specification 3.7.4.
The Process Applicability Determination process is a method for determining which plant licensing basis documents and processes are affected by a proposed activity and must be revised to reflect that activity. The licensee revised Procedure OP-100-014, Revision 336, using a Process Applicability Determination Evaluation [PAD-OP-100-014, Revision 337] to provide additional guidance on implementation of Technical Specification 3.7.4.
Procedure OP-100-014, Revision 337, was implemented in February 2017 with an added note stating, in part, if the dry cooling tower fans are declared inoperable solely due to wet cooling tower fans being out of service (cascading technical specification), then Technical Specification 3.7.4.c does not need to be applied upon a tornado watch/warning. The licensee performed a technical analysis and concluded that the missile-protected dry cooling tower fans were to be considered Operable for the tornado event because wet cooling tower fan operation is not credited in the tornado event analysis.
The licensee used Procedure EN-LI-100, Process Applicability Determination, to evaluate the change in licensing basis documents. When answering the question, does the proposed activity affect, invalidate, or render incorrect, OR have the potential to affect, invalidate, or render incorrect, information contained in any of the following Licensing Basis Documents?
the licensee answered no for impact on Operating License/Technical Specifications.
However, the inspectors determined that this addition to the site procedure could adversely impact the bases for the acceptability to ultimate heat sink design and operations. As a result, that question should have been answered yes and the licensee would have had to prepare a licensing basis document change request. The inspectors concluded that if Procedure OP-100-014, Revision 337, would have been implemented as written, it would have constituted a change affecting an evaluation that demonstrates the function of the ultimate heat sink.
The inspectors confirmed that between February 2017 and January 2018, there were no tornado watches that coincided with ultimate heat sink system work windows. Therefore, during the time this note was in the procedure, the licensee did not invoke the provision.
Corrective Action(s): The licensee removed the note from Procedure OP-100-014, and corrected the interpretation of the technical specification. Procedure OP-100-014, Revision 342, which removed the note, became effective January 2018. Therefore, if the wet cooling tower fans are inoperable, and there is a simultaneous tornado watch/warning, the licensee will implement Technical Specification 3.7.4, Action c.
Corrective Action Reference(s): CR-WF3-2018-02111
Performance Assessment:
Performance Deficiency: The licensees failure to submit a licensing basis document change request when performing a change impacting technical specifications in accordance with Procedure EN-LI-100, Process Applicability Determination, was a performance deficiency.
Specifically, Procedure EN-LI-100 states that if proposed activities affect, invalidate, or render incorrect information contained in Licensing Basis Documents such as the Operating License/Technical Specifications, then the proper regulatory reviews are performed. The procedure instructs the licensee to prepare a licensing basis document change request in accordance with the licensing basis document change process.
Screening: The inspectors determined the performance deficiency was of minor significance because the licensee did not implement this procedure change and as a result, did not incur a violation of technical specifications. However, because 10 CFR 50.59 violations could potentially impede or impact the regulatory process, the inspectors processed this performance deficiency using the traditional enforcement process and the examples in Section 6.1 of the Enforcement Policy.
Enforcement:
Severity: The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter noncompliance. This violation was more than minor because there was a reasonable likelihood the change would require NRC review and approval prior to implementation, similar to violations assessed in Section 2.1.3 of the NRC Enforcement Manual. The inspectors determined the violation to be a Severity Level IV violation similar to violation Example 6.1.d.2 in the NRC Enforcement Policy.
Violation: As stated, in part, in 10 CFR 50.59, Changes, Tests, and Experiments, Section (c)(1), a licensee may make changes in the facility as described in the final safety analysis report (as updated), make changes in the procedure as described in the final safety analysis report (as updated), and conduct tests or experiments not described in the final safety analysis report (as updated) without obtaining a license amendment pursuant to Sec. 50.90 only if:
- (i) a change to the Technical Specifications incorporated in the license is not required. The licensee established Procedure EN-LI-100, Process Applicability Determination, Revision 19, to comply with this requirement. Attachment 9.1 of Procedure EN-LI-100 states, in part, to prepare a licensing basis document change request if a proposed activity affects, invalidates, or renders incorrect, information contained in Technical Specifications.
Contrary to the above requirements, from February 2017, until December 2017, the licensee completed an activity that affected Technical Specifications and did not prepare a licensing basis document change request. Specifically, the licensee implemented a change to Technical Specification 3.7.4, Action c, through the implementation of Procedure OP-100-014, Technical Specification and Technical Requirements Compliance, Revision 337, by adding a note that instructed Operations personnel to not enter Technical Specification 3.7.4.c in the event of a tornado watch/warning if the dry cooling tower fans were declared inoperable solely due to wet cooling tower fans being out of service. This action was inconsistent with the current licensing basis and would have constituted a violation of technical specifications.
Enforcement Action: Because this violation was not repetitive or willful, and was entered into the licensees corrective action program as CR-WF3-2018-02111, this violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy.
Licensee Event Automatic Reactor Scram due to the Failure of Fast Bus 71153 Report Transfer Relays to Automatically Transfer Station Loads to (Closed) Off-site Power on a Main Generator Trip 05000382/2017-002-00
Description:
The NRC conducted a special inspection to better understand the facts and circumstances surrounding this event. The results and findings of that inspection are documented in NRC Inspection Report 05000382/2017011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17354A690). The inspectors did not identify any new deficiencies as a result of this review. This LER is closed.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On January 25, 2018, the inspectors presented the radiation safety inspection results to Mr. J. Dinelli, Site Vice President, and other members of the licensee staff.
On April 12, 2018, the resident inspectors presented the quarterly resident inspector inspection results to Mr. J. Dinelli, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
71111.01 - Adverse Weather Protection
Procedures
Number Title Revision
OP-002-007 Freeze Protection and Temperature Maintenance 25
OP-901-521 Severe Weather and Flooding 325
Condition Reports (CRs)
CR-WF3-2017-09668 CR-WF3-2018-00004 CR-WF3-2018-00082 CR-WF3-2018-00098
CR-WF3-2018-00436
71111.04 - Equipment Alignment
Procedures
Number Title Revision
OP-002-003 Component Cooling Water 317
OP-009-003 Emergency Feedwater 309
OP-009-008 Safety Injection System 41
71111.05 - Fire Protection
Miscellaneous Documents
Number Title Revision
RAB1A-B-C-D- Control Room Proper, H&V Room, Emergency Living 10
001 Quarters, and Computer Room
RAB8B-E-F-001 Switchgear B 12
RAB 17-001 Component Cooling Water Heat Exchanger B 8
RAB 19-001 Component Cooling Water Pump Room A 7
RAB 33-001 Shutdown Cooling Heat Exchanger Rooms A and B 8
Procedures
Number Title Revision
FP-001-018 Pre-fire Strategies, Development and Revision 304
71111.11 - Licensed Operator Requalification Program and Licensed Operator
Performance
Procedures
Number Title Revision
OP-901-111 Reactor Coolant System Leak 303
OP-901-403 High Airborne Activity in Containment 4
OP-901-404 High Airborne Activity in FHB 2
OP-901-405 Fuel Handling Incident 8
OP-901-513 Spent Fuel Pool Cooling Malfunction 21
OP-902-002 Loss of Coolant Accident Recovery 20
71111.12 - Maintenance Effectiveness
Miscellaneous Documents
Number Title Revision
910163-001 PCI Quality Assurance Traveler - FOST A1 Fabrication 1
EC-53943 Station Battery B Cell Lid Cracking 0
EC-57534 Station Battery A Cell Lid Cracks 0
QPP-205 Graham, Visual Inspection 17
QPP-205 Graham, Visual Inspection addenda 1
Addenda
WDT-0528 PCI Welding EDG Supplemental Fuel Oil Storage Tank 0
WF3-FOST-DN- Deviation Notice for Waterford 3 Fuel Oil Storage Tank, 1
21 Tank A1 - Rust and Arc Strikes on Shell
Procedures
Number Title Revision
ME-003-200 Station Battery Bank and Charger (Weekly) 314
Condition Reports (CRs)
CR-WF3-2014-05777 CR-WF3-2014-06375 CR-WF3-2014-06378 CR-WF3-2015-00842
CR-WF3-2015-01802 CR-WF3-2015-04849 CR-WF3-2015-04850 CR-WF3-2015-04854
CR-WF3-2017-03566 CR-WF3-2017-03607 CR-WF3-2017-06789 CR-WF3-2017-08771
CR-WF3-2017-08845 CR-WF3-2017-09167
Work Orders
446024
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Procedures
Number Title Revision
OP-903-005 Control Element Assembly Operability Check 14
71111.15 - Operability Determinations and Functionality Assessments
Miscellaneous Documents
Number Title Revision/Date
Protected Equipment List January 31,
2018
EC-40444 Revised Impact AST Dose Analyses to Address MSSV and 1
ADV Leakages
EC-75901 Component Cooling Water Heat Exchanger Degraded 1
Performance
ECM95-008 Ultimate Heat Sink Design Basis 3
ECS05-13 Ultimate Head Sink Containment Heat Loads 1
MNQ9-2 Component Cooling Water System 2
MNQ9-50 ACCW System Resistance 2
TD-G080.0495 General Electric Spare Reactor Coolant Pump Motor 1
Drawings
WF3-ME-16- Meteorological Parameters and Parameter Relationships for 0
00001 Design and Operability of the Waterford 3 Ultimate Heat
Sink
Procedures
Number Title Revision
OP-001-002 Reactor Coolant Pump Operation 22
PE-004-021 CCW Heat Exchanger Performance Test 5
Condition Reports (CRs)
CR-WF3-2011-07700 CR-WF3-2012-02332 CR-WF3-2018-00662 CR-WF3-2018-00785
CR-WF3-2018-00948 CR-WF3-2018-00951 CR-WF3-2018-00986 CR-WF3-2018-01225
Condition Reports (CRs)
CR-WF3-2018-01426 CR-WF3-2018-01549 CR-WF3-2018-01559
Work Orders
481333 495770 495771 496893 52348919
71111.18 - Plant Modifications
Miscellaneous Documents
Number Title Revision
6W12CM10 Common Mat Stress Analysis - Cooling Tower Area 2
ECC16-004 Horizontal Air Flow Barrier Roof and Gutters at Dry Cooling 0
Tower Outside Missile Protection
ECM95-008 Ultimate Heat Sink Design Basis 3
MNQ9-52 Ultimate Heat Sink Performance based on data 2
WF3-ME-16- Meteorological Parameters and Parameter Relationships for 0
00001 Design and Operability of the Waterford 3 Ultimate Heat
Sink
Condition Reports (CRs)
Work Orders
444257
71111.19 - Post-Maintenance Testing
Miscellaneous Documents
Number Title Revision
AR 184566184566 Replace Solenoid Valve
AR 186060186060 Align PMRQs for AOV PM Optimization Program
TD A610.0155 ASCO Installation and Maintenance Instructions for 3-Way 0
Solenoid Valves Series 8316
Procedures
Number Title Revision/Date
ME-007-019 ASCO/AVCO/MAC/Parker Hannifin Solenoid Valves 306
Procedures
Number Title Revision/Date
MM-003-041 Six Year Emergency Diesel Engine Inspection February 2,
2018
OP-903-030 Safety Injection Pump Operability Verification 35
OP-903-050 Component Cooling Water and Auxiliary Component 039
Cooling Water Pump and Valve Operational Test
OP-903-118 Primary Auxiliaries Quarterly IST Valve Tests 43
OP-903-121 Safety System Quarterly IST Valve Tests 27
Condition Reports (CRs)
CR-WF3-2017-07146 CR-WF3-2018-00441 CR-WF3-2018-00808 CR-WF3-2018-01498
Work Orders
436357 52649596 52673039 52701091
71111.22 - Surveillance Testing
Miscellaneous Documents
Number Title Date
TD-C490.0485 Combustion Engineering Ex-Core Neutron Flux Monitoring April, 1985
System Safety Channel Operation and Maintenance Manual
Procedures
Number Title Revision
MI-003-002 Safety Channel Nuclear Instrumentation Functional Test 17
OP-903-068 Emergency Diesel Generator and Subgroup Relay 319
Operability Verification
OP-903-107 Plant Protection System Channel C Functional Test 312
Work Orders
2800018 52800019
71114.06 - Drill Evaluation
Procedures
Number Title Revision
EP-001-010 Unusual Event 306
EP-001-020 Alert 309
EP-001-030 Site Area Emergency 308
EP-002-010 Notifications and Communications 315
OP-902-002 Loss of Coolant Accident Recovery 20
Condition Reports (CRs)
CR-WF3-2018-01082 CR-WF3-2018-01083 CR-WF3-2018-01084 CR-WF3-2018-01095
71124.01 - Radiological Hazard Assessment and Exposure Controls
Number Title Date
OL-011518-002 Pool Purification Pump Shaft Removal January 15,
2018
OL-02112017- Sluice CVC IX A February 11,
013 2017
OL-032717-006 Lapel Air Sample for RWP 2017-0064 March 27,
2017
OL-040417-004 Alpha Air - RAB -35 Safeguards Room A April 4, 2017
OL-072217-0015 Alpha Air - Letdown Valve Gallery July 22, 2017
RF-05162017- Alpha Air - Top of UGS May 16, 2017
561
Audits and Self-Assessments
Number Title Date
LO-WLO-2017- November
Pre-NRC Self-Assessment Radiation Safety - IP 71124.01
00068 CA-00005 30, 2017
Miscellaneous Documents
Number Title Date
NSTS Annual Inventory Reconciliation Report January 4,
2018
Miscellaneous Documents
Number Title Date
Periodic Review of Plant Isotopic Mix Compared to September
Radiation Protection Instrument, Revision 1 21, 2017
Review of Smears Taken for Alpha Characterization During September
RF21 19, 2017
Spent Fuel Pool Inventory October 25,
2017
Update to the Review of the Capabilities of Our Passive October 4,
Monitoring Program to Detect Intakes at Waterford-3 2017
2017-2018 Entergy Waterford 3 Radiation Protection Department August 10,
Respiratory Improvement Plan 2017
Att. 9.6 to EN- LHRA/VHRA Key Log January 23-
RP-101 25, 2018
WO 52734309 Sealed Source Leak Test June 22,
2017
WO 52768769 Semi-Annual Source Inventory December
11, 2017
Procedures
Number Title Revision
EN-RE-220 PWR Control of Miscellaneous Materials in the Spent Fuel 3
Pool
EN-RP-100 Radiation Worker Expectations 12
EN-RP-101 Access Control for Radiologically Controlled Areas 13
EN-RP-102 Radiological Control 5
EN-RP-104 Personnel Contamination Events 9
EN-RP-105 Radiological Work Permits 18
EN-RP-106 Radiological Survey Documentation 7
EN-RP-108 Radiation Protection Posting 19
EN-RP-109 Hot Spot Program 5
EN-RP-121 Radioactive Material Control 13
EN-RP-122 Alpha Monitoring 9
EN-RP-143 Source Control 13
EN-RP-315 Operation and Calibration of the CRONOS Contamination 2
Monitor
Radiation Surveys
Number Title Date
WF3-1704-0537 +46 Pressurizer Cubicle April 18, 2017
WF3-1705-0049 FHB +46 Fuel Handling Area May 1, 2017
WF3-1711-0270 FHB +46 Fuel Handling Area November
30, 2017
WF3-1711-0271 FHB +46 Fuel Handling Area November
30, 2017
WF3-1801-0194 RAB -4 Hallways January 16,
2018
WF3-1801-0213 RAB -35 Hallways January 18,
2018
WF3-1801-0262 RAB -21 Hallways January 24,
2018
Radiation Work Permits
Number Title Revision
2017-0101 Work Activities in the Spent Fuel Pool and the Transfer 1
Canal
2017-0509 RF21 Remove/Replace Steam Generator Primary 1
Manways/Diaphragms
2017-0510 Install/Remove Steam Generator Nozzle Dams, Pin 2
Verification and Closure
2017-0705 RF21 Reassembly of Reactor Head and Associated Work 0
Activities
2017-0727 RF21 Perform Reactor Vessel (ISI) Inspection Using the 2
WestDyne (ROSA) and a Submarine
2018-0004 Maintenance Activities in all Radiologically Controlled Areas 0
2018-0007 Perform Various Decon and Housekeeping Activities in all 0
Radiologically Controlled Areas
Condition Reports (CRs)
CR-WF3-2017-02540 CR-WF3-2017-02718 CR-WF3-2017-02956 CR-WF3-2017-03344
CR-WF3-2017-03349 CR-WF3-2017-03362 CR-WF3-2017-03799 CR-WF3-2017-03872
CR-WF3-2017-03953 CR-WF3-2017-06030 CR-WF3-2017-06758 CR-WF3-2017-07988
CR-WF3-2017-08330 CR-WF3-2018-00506 CR-WF3-2018-00507 WT-WTWF3-2017-
273
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Air Quality Testing Results
Number Title Date
296484-0 Compressed Air/Gas Quality Testing Laboratory Report February 15,
2017
296614-0 Compressed Air/Gas Quality Testing Laboratory Report February 16,
2017
309752-0 Compressed Air/Gas Quality Testing Laboratory Report July 28, 2017
309780-0 Compressed Air/Gas Quality Testing Laboratory Report July 31, 2017
Audits and Self-Assessments
Number Title Date
LO-WLO-2017- Pre-NRC Assessment IP 71124.03 In-Plant Airborne November
00068 Radioactivity Control and Mitigation 23, 2017
Filtration Testing Results
Number Title Date
257571 Charcoal Sample Testing May 31, 2016
2577572 In-Place HEPA Filter Testing June 1, 2016
2704414 In-Place Charcoal Filter Testing November 8,
2017
Miscellaneous Documents
Number Title Date
Inspection and Maintenance of Respiratory Protection December
Equipment - Face Piece Inspection Log 27, 2017
Inspection and Maintenance of Respiratory Protection December
Equipment - SCBA Inspection Log 27, 2017
2017-0702-04 TEDE-ALARA Evaluation November
15, 2016
Procedures
Number Title Revision
EN-RP-310 Operation and Initial Setup of the Eberline AMS-4 4
Continuous Air Monitor
EN-RP-501 Respiratory Protection Program 5
Procedures
Number Title Revision
EN-RP-502 Inspection and Maintenance of Respiratory Protection 10
Equipment
EN-RP-502-01 Fire Hawk M7 SCBA 1
EN-RP-503 Selection, Issue And Use Of Respiratory Protection 7
Equipment
EN-RP-504 Breathing Air 4
SCBA Maintenance Records
Number Title Date
UEM-6123 Posi3 USB Test Results - Complete SCBA Test March 31,
2016
UEM-6123 Posi3 USB Test Results - Complete SCBA Test February 13,
2017
UEM-6259 Posi3 USB Test Results - Complete SCBA Test March 30,
2016
UEM-6259 Posi3 USB Test Results - Complete SCBA Test February 14,
2017
Condition Reports (CRs)
CR-WF3-2016-03044 CR-WF3-2017-00011 CR-WF3-2017-00375 CR-WF3-2017-00678
CR-WF3-2017-04253 CR-WF3-2017-05533 CR-WF3-2017-06536 CR-WF3-2017-06758
71151 - Performance Indicator Verification
Audits and Self-Assessments
Number Title Date
LO-WLO-2017- Radiation Safety 71151 OR01 Occupational Exposure November
00068 Control Effectiveness 29, 2017
Miscellaneous Documents
Number Title Date
W3F1-2017- NRC Performance Indicator (PI) Data - 1st Quarter 2017 April 12, 2017
0036 ROP Data
W3F1-2017- NRC Performance Indicator (PI) Data - 2nd Quarter 2017 July 13, 2017
0058 ROP Data
Miscellaneous Documents
Number Title Date
W3F1-2017- NRC Performance Indicator (PI) Data - 3rd Quarter 2017 October 6,
0076 ROP Data 2017
W3F1-2018- NRC Performance Indicator (PI) Data - 4th Quarter 2017 January 9,
0004 ROP Data 2018
Procedures
Number Title Revision
EN-LI-114 Regulatory Performance Indicator Process 9
71152 - Problem Identification and Resolution
Miscellaneous Documents
Number Title Date
White Paper Cascading Technical Specifications During Emergency February,
Diesel Generator Outages 2018
Procedures
Number Title Revision
EN-LI-100 Process Applicability Determination Form 19
OP-100-014 Technical Specification and Technical Requirements 336, 337, 340
Compliance
Condition Reports (CRs)
CR-WF3-2017-00780 CR-WF3-2017-00785
Occupational Radiation Safety Inspection
Waterford-3
Dates of Inspection: January 22 - 26, 2018
Integrated Inspection Report 2018001
Inspection areas are listed in the attachments below.
Please provide the requested information on or before January 5, 2018.
Please submit this information using the same lettering system as below. For example, all
contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled
1- A, applicable organization charts in file/folder 1- B, etc.
If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at
least 30 days later than the onsite inspection dates, so the inspectors will have access to the
information while writing the report.
In addition to the corrective action document lists provided for each inspection procedure listed
below, please provide updated lists of corrective action documents at the entrance meeting.
The dates for these lists should range from the end dates of the original lists to the day of the
entrance meeting.
If more than one inspection procedure is to be conducted and the information requests appear
to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which
file the information can be found.
If you have any questions or comments, please contact Natasha Greene at (817) 200-1154 or
Natasha.Greene@nrc.gov.
PAPERWORK REDUCTION ACT STATEMENT
This letter does not contain new or amended information collection requirements subject
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information
collection requirements were approved by the Office of Management and Budget,
control number 3150-0011.
1. Radiological Hazard Assessment and Exposure Controls (71124.01) and
Performance Indicator Verification (71151)
Date of Last Inspection: 4/24/2017
A. List of contacts and telephone numbers for the Radiation Protection Organization Staff
and Technicians
B. Applicable organization charts
- C. Audits, self-assessments, and LERs written since 4/24/2017, related to this inspection
area
D. Procedure indexes for the radiation protection procedures
E. Please provide procedures related to the following areas noted below. Additional
procedures may be requested by number after the inspector reviews the procedure
indexes.
1. Radiation Protection Program
2. Radiation Protection Conduct of Operations, if not included in #1.
3. Personnel Dosimetry
4. Posting of Radiological Areas
5. High Radiation Area Controls
6. RCA Access Controls and Radiation Worker Instructions
7. Conduct of Radiological Surveys
8. Radioactive Source Inventory and Control
F. List of corrective action documents (including corporate and sub-tiered systems) since
4/24/2017.
a. Initiated by the radiation protection organization
b. Assigned to the radiation protection organization
NOTE: The lists should indicate the significance level of each issue and the search
criteria used. Please provide in document formats which are searchable so that
the inspector can perform word searches.
G. List of radiologically significant work activities scheduled to be conducted during the
inspection period. (If the inspection is scheduled during an outage, please also include a
list of work activities greater than 1 rem, scheduled during the outage with the dose
estimate for the work activity.)
H. List of active radiation work permits
I. Radioactive source inventory list all radioactive sources that are required to be leak
tested. Indicate which sources are 10 CFR Part 20, Appendix E, Category 1 or Category
2. Please indicate the radioisotope, initial and current activity (w/assay date), and
storage location for each applicable source.
J. The last two leak test results for the Category 1 or 2 radioactive sources and any other
radioactive source(s) that have failed its leak test within the last two years
- K. A list of any non-fuel items stored in the spent fuel pools, and if available, their
appropriate dose rates (Contact / @ 30cm)
L. A list of radiological controlled area entries greater than 100 millirem since 4/24/2017.
The list should include the date of entry, some form of worker identification, the radiation
work permit used by the worker, dose accrued by the worker, and the electronic
dosimeter dose alarm set-point used during the entry (for Occupational Radiation Safety
Performance Indicator verification in accordance with IP 71151).
3. In-Plant Airborne Radioactivity Control and Mitigation (71124.03)
Date of Last Inspection: 3/21/2016
A. List of contacts and telephone numbers for the following areas:
1. Respiratory Protection Program
2. Self-contained breathing apparatus
B. Applicable organization charts
- C. Copies of audits, self-assessments, vendor or NUPIC audits for contractor support
(SCBA), and LERs, written since 3/21/2016 related to:
1. Installed air filtration systems
2. Self-contained breathing apparatuses
D. Procedure index for:
1. Use and operation of continuous air monitors
2. Use and operation of temporary air filtration units
3. Respiratory protection
E. Please provide specific procedures related to the following areas noted below.
Additional Specific Procedures may be requested by number after the inspector reviews
the procedure indexes.
1. Respiratory protection program
2. Use of self-contained breathing apparatuses
3. Air quality testing for SCBAs
4. Use of installed plant systems, such as containment purge, spent fuel pool
ventilation, and auxiliary building ventilation
F. A summary list of corrective action documents (including corporate and sub-tiered
systems) written since 3/21/2016, related to the Airborne Monitoring program including:
1. Continuous air monitors
2. Self-contained breathing apparatuses
3. Respiratory protection program
NOTE: The lists should indicate the significance level of each issue and the search
criteria used. Please provide in document formats which are searchable so that
the inspector can perform word searches.
G. List of SCBA qualified personnel - reactor operators and emergency response personnel
H. Inspection records for self-contained breathing apparatuses (SCBAs) staged in the plant
for use since 3/21/2016.
- I. SCBA training and qualification records for control room operators, shift supervisors,
STAs, and OSC personnel for the last year.
A selection of personnel may be asked to demonstrate proficiency in donning, doffing,
and performance of functionality check for respiratory devices
- J. List of respirators (available for use) by type (APR, SCBA, PAPR, etc.), manufacturer,
and model.
SUNSI Review Non-Sensitive Publicly Available Keyword:
By: JDixon/rdr Sensitive Non-Publicly Available NRC-002
OFFICE SRI:DRP/D RI:DRP/D PE:DRP/D BC:DRS/EB1 BC:DRS/EB2 BC:DRS/PSB2
NAME FRamirez CSpeer JChoate TFarnholtz JDrake HGepford
SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/
DATE 5/7/18 5/4/18 5/7/18 5/3/2018 5/3/18 5/3/18
OFFICE BC:DRS/OB TL:DRS/IPAT SPE:DRP/D BC:DRP/D
NAME VGaddy GGeorge JDixon GMiller
SIGNATURE /RA/ /RA/ /RA/ /RA/
DATE 5/7/18 5/3/18 5/3/18 5/8/18
May 8, 2018
Mr. John Dinelli
Site Vice President
Entergy Operations, Inc.
265 River Road
Killona, LA 70057-0751
SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED
INSPECTION REPORT 05000382/2018001
Dear Mr. Dinelli:
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at your Waterford Steam Electric Station, Unit 3. On April 12, 2018, the NRC inspectors
discussed the results of this inspection with you and other members of your staff. The results of
this inspection are documented in the enclosed report.
NRC inspectors documented one Severity Level IV violation with no associated finding. The
NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of
the Enforcement Policy.
From April 2017 to April 2018, the NRC issued three Severity Level IV traditional enforcement
violations associated with impacting the ability of the NRC to perform its regulatory oversight
function. This includes the one Severity Level IV violation documented in this report. However,
the NRC will not conduct Inspection Procedure 92723, Follow Up Inspection for Three or More
Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period,
because one of the violations occurred in 2006 and is not representative of present
performance.
If you contest the violation or significance of this NCV, you should provide a response within
days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear
Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with
copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the
NRC resident inspector at the Waterford Steam Electric Station, Unit 3.
J. Dinelli 2
This letter, its enclosure, and your response (if any) will be made available for public inspection
and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document
Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for
Withholding.
Sincerely,
/RA/
Geoffrey Miller, Branch Chief
Project Branch D
Division of Reactor Projects
Docket No. 50-382
License No. NPF-38
Enclosure:
Inspection Report 05000382/2018001
w/ Attachments:
1. Documents Reviewed
2. Occupational Radiation Safety Inspection
Request for Information
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number: 05000382
License Number: NPF-38
Report Number: 05000382/2018001
Enterprise Identifier: I-2018-001-0002
Licensee: Entergy Operations, Inc.
Facility: Waterford Steam Electric Station, Unit 3
Location: 17265 River Road
Killona, LA 70057
Inspection Dates: January 1, 2018, to March 31, 2018
Inspectors:
- F. Ramírez, Senior Resident Inspector
- C. Speer, Resident Inspector
- J. Choate, Project Engineer
- J. Dixon, Senior Project Engineer
- N. Greene, PhD, Senior Health Physicist
- S. Money, Health Physicist
- J. ODonnell, CHP, Health Physicist
Approved By:
- G. Miller, Chief
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting an integrated inspection at Waterford Steam Electric Station, Unit 3,
in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the
NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer
to https://www.nrc.gov/reactors/operating/oversight.html for more information. An
NRC-identified violation and additional items are summarized in the tables below.
List of Findings and Violations
Failure to Obtain NRC Staff Authorization Prior to Changing a Procedure that Impacts
Implementation of Technical Specifications
Cornerstone Significance Cross-cutting Report
Aspect Section
Not Applicable Severity Level IV Not Applicable 71152
Closed
The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.59, Changes,
Tests, and Experiments, Section (c)(1), for the licensees failure to submit and obtain
authorization prior to implementation procedures described in the Final Safety Analysis Report.
Additional Tracking Items
Type Issue number Title Report Status
Section
LER 05000382/2017-002-00 Automatic Reactor Scram 71153 Closed
due to the Failure of Fast Bus
Transfer Relays to
Automatically Transfer
Station Loads to Off-site
Power on a Main Generator
Trip
PLANT STATUS
Waterford Steam Electric Station Unit 3 operated at or near 100 percent rated thermal power for
the entire inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
complete when the IP requirements most appropriate to the inspection activity were met
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors performed plant status activities described in
IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem
Identification and Resolution. The inspectors reviewed selected procedures and records,
observed activities, and interviewed personnel to assess licensee performance and compliance
with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather (1 Sample)
The inspectors evaluated readiness for impending adverse weather conditions prior to the
onset of and during extreme low temperatures for the area on January 16, 2018.
71111.04 - Equipment Alignment
Partial Walkdown (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) Emergency feedwater train A following maintenance on January 12, 2018
(2) Component cooling water train A with train B out of service for maintenance on
January 24, 2018
(3) Low pressure safety injection train A with train B out of service for maintenance on
March 13, 2018
71111.05 - Fire Protection
Quarterly Inspection (5 Samples)
The inspectors evaluated fire protection program implementation in the following selected
areas:
(1) Shutdown cooling heat exchanger rooms A and B, Fire Area RAB 33, on
January 4, 2018
(2) Switchgear room B, Fire Area RAB 8B, E, and F on February 12, 2018
(3) Control room, Fire Area RAB 1A, B, C, and D on February 12, 2018
(4) Component cooling water heat exchanger B, Fire Area RAB 17 on March 13, 2018
(5) Component cooling water pump room A, Fire Area RAB 19 on March 14, 2018
71111.07 - Heat Sink Performance
Heat Sink (1 Sample)
The inspectors evaluated the ultimate heat sink performance test on January 23, 2018.
71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance
Operator Requalification (1 Sample)
The inspectors observed and evaluated operator performance in the simulator during an
evaluated emergency plan exercise on February 21, 2018.
Operator Performance (1 Sample)
The inspectors observed and evaluated control room operator performance during main turbine
governor valve testing on January 19, 2018.
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness (3 Samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated
with the following equipment and/or safety significant functions:
(1) Component cooling water on January 25, 2018
(2) 125 Vdc distribution system on March 12, 2018
(3) Plant protection system on March 28, 2018
Quality Control (1 Sample)
The inspectors evaluated maintenance and quality control activities associated with the
following equipment performance issues:
(1) Fuel oil storage tank A1 vendor and licensee quality documents related to receipt of
segments from vendor and associated welding on March 7, 2018
71111.13 - Maintenance Risk Assessments and Emergent Work Control (3 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent
work activities:
(1) Risk assessment associated with maintenance on boric acid makeup tanks A and B on
January 3, 2018
(2) Risk assessment and risk management actions associated with maintenance on
emergency diesel generator A on January 31, 2018
(3) Control element assembly emergency work and unexpected limiting condition for
operation on February 6, 2018
71111.15 - Operability Determinations and Functionality Assessments (6 Samples)
The inspectors evaluated the following operability determinations and functionality
assessments:
(1) Core element assembly calculator 2 unexpected trend on January 2, 2018
(2) Atmospheric dump valve A leakage on February 8, 2018
(3) Component cooling water heat exchanger B failed performance test on February 9, 2018
(4) Reactor coolant pump 2A oil leak on March 8, 2018
(5) Core protection calculator Channel C failure on March 26, 2018
(6) Ultimate heat sink on March 28, 2018
71111.18 - Plant Modifications (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
(1) Dry cooling tower train A recirculation barrier installation, Phase 3, on March 16, 2018
71111.19 - Post Maintenance Testing (7 Samples)
The inspectors evaluated the following post maintenance tests:
(1) Reactor trip circuit breaker 6 on January 9, 2018
(2) High pressure safety injection train B on January 23, 2018
(3) Emergency diesel generator A on February 3, 2018
(4) Auxiliary component cooling water train B on February 21, 2018
(5) Component cooling water pump B to AB suction cross-connect valve solenoid valve
replacement on March 8, 2018
(6) Component cooling water pump B to AB discharge cross-connect valve solenoid valve
replacement on March 8, 2018
(7) Low pressure safety injection pump B on March 14, 2018
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Routine (3 Samples)
(1) Emergency diesel generator A monthly surveillance on January 8, 2018
(2) Safety Channel A nuclear instrumentation functional test on January 24, 2018
(3) Functional test of plant protective system Channel C on February 23, 2018
71114.06 - Drill Evaluation
Emergency Planning Drill (1 Sample)
The inspectors evaluated a site emergency plan drill on February 21, 2018.
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (1 Sample)
The inspectors evaluated radiological hazards assessments and controls.
Instructions to Workers (1 Sample)
The inspectors evaluated worker instructions.
Contamination and Radioactive Material Control (1 Sample)
The inspectors evaluated contamination and radioactive material controls.
Radiological Hazards Control and Work Coverage (1 Sample)
The inspectors evaluated radiological hazards control and work coverage.
High Radiation Area and Very High Radiation Area Controls (1 Sample)
The inspectors evaluated risk-significant high radiation area and very high radiation area
controls.
Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample)
The inspectors evaluated radiation worker performance and radiation protection technician
proficiency.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Engineering Controls (1 Sample)
The inspectors evaluated airborne controls and monitoring.
Use of Respiratory Protection Devices (1 Sample)
The inspectors evaluated respiratory protection.
Self-Contained Breathing Apparatus for Emergency Use (1 Sample)
The inspectors evaluated the licensees self-contained breathing apparatus program.
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification (5 Samples)
The inspectors verified licensee performance indicator submittals listed below:
(1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (January 1, 2017, through
December 31, 2017)
(2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample (January 1, 2017,
through December 31, 2017)
(3) IE04: Unplanned Scrams with Complications (USwC) Sample (January 1, 2017,
through December 31, 2017)
(4) OR01: Occupational Exposure Control Effectiveness Sample (April 1, 2017, through
December 31, 2017)
(5) PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation
Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent
Occurrences Sample (April 1, 2017, through December 31, 2017)
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issue:
(1) Implementation of change to technical specification and technical requirements
compliance procedure
71153 - Follow-up of Events and Notices of Enforcement Discretion
Licensee Event Reports (1 Sample)
The inspectors evaluated the following licensee event reports which can be accessed at
https://lersearch.inl.gov/LERSearchCriteria.aspx:
(1) Licensee Event Report (LER) 05000382/2017-002-00, Automatic Reactor Scram due to
the Failure of Fast Bus Transfer Relays to Automatically Transfer Station Loads to
Off-site Power on a Main Generator Trip, on July 17, 2017
INSPECTION RESULTS
Failure to Obtain NRC Staff Authorization Prior to Changing a Procedure that Impacts
Implementation of Technical Specifications
Cornerstone Significance Cross-cutting Report
Aspect Section
Not Applicable Severity Level IV Not Applicable 71152
Closed
The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.59, Changes,
Tests, and Experiments, Section (c)(1), for the licensees failure to submit and obtain
authorization prior to implementation procedures described in the Final Safety Analysis
Report.
Description: Waterford Technical Specification 3.7.4, states, in part, that two independent
trains of ultimate heat sink cooling towers shall be Operable in Modes 1, 2, 3, and 4. Each
train consists of a dry cooling tower and a wet cooling tower and its associated water basin.
Action c of Technical Specification 3.7.4 states that with a tornado watch in effect, all nine dry
cooling tower fans under the missile protected portion of the dry cooling tower shall be
Operable. If the number of Operable fans is less than required, restore the inoperable fan(s)
to Operable status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, or be in at least Hot Standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Hot
Shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The licensee established Procedure OP-100-014,
Technical Specification and Technical Requirements Compliance, Revision 336, to provide
guidance for determining Operability of equipment and ensuring compliance with the technical
specifications and technical requirements manual. Procedure OP-100-014, Attachment 6.6,
Specific System Guidelines, provides guidelines on actions when declaring a system
inoperable. One of the systems listed and discussed is the ultimate heat sink and its
associated Technical Specification 3.7.4.
The Process Applicability Determination process is a method for determining which plant
licensing basis documents and processes are affected by a proposed activity and must be
revised to reflect that activity. The licensee revised Procedure OP-100-014, Revision 336,
using a Process Applicability Determination Evaluation [PAD-OP-100-014, Revision 337] to
provide additional guidance on implementation of Technical Specification 3.7.4.
Procedure OP-100-014, Revision 337, was implemented in February 2017 with an added
note stating, in part, if the dry cooling tower fans are declared inoperable solely due to wet
cooling tower fans being out of service (cascading technical specification), then Technical Specification 3.7.4.c does not need to be applied upon a tornado watch/warning. The
licensee performed a technical analysis and concluded that the missile-protected dry cooling
tower fans were to be considered Operable for the tornado event because wet cooling tower
fan operation is not credited in the tornado event analysis.
The licensee used Procedure EN-LI-100, Process Applicability Determination, to evaluate
the change in licensing basis documents. When answering the question, does the proposed
activity affect, invalidate, or render incorrect, OR have the potential to affect, invalidate, or
render incorrect, information contained in any of the following Licensing Basis Documents?
the licensee answered no for impact on Operating License/Technical Specifications.
However, the inspectors determined that this addition to the site procedure could adversely
impact the bases for the acceptability to ultimate heat sink design and operations. As a
result, that question should have been answered yes and the licensee would have had to
prepare a licensing basis document change request. The inspectors concluded that if
Procedure OP-100-014, Revision 337, would have been implemented as written, it would
have constituted a change affecting an evaluation that demonstrates the function of the
The inspectors confirmed that between February 2017 and January 2018, there were no
tornado watches that coincided with ultimate heat sink system work windows. Therefore,
during the time this note was in the procedure, the licensee did not invoke the provision.
Corrective Action(s): The licensee removed the note from Procedure OP-100-014, and
corrected the interpretation of the technical specification. Procedure OP-100-014,
Revision 342, which removed the note, became effective January 2018. Therefore, if the wet
cooling tower fans are inoperable, and there is a simultaneous tornado watch/warning, the
licensee will implement Technical Specification 3.7.4, Action c.
Corrective Action Reference(s): CR-WF3-2018-02111
Performance Assessment:
Performance Deficiency: The licensees failure to submit a licensing basis document change
request when performing a change impacting technical specifications in accordance with
Procedure EN-LI-100, Process Applicability Determination, was a performance deficiency.
Specifically, Procedure EN-LI-100 states that if proposed activities affect, invalidate, or render
incorrect information contained in Licensing Basis Documents such as the Operating
License/Technical Specifications, then the proper regulatory reviews are performed. The
procedure instructs the licensee to prepare a licensing basis document change request in
accordance with the licensing basis document change process.
Screening: The inspectors determined the performance deficiency was of minor significance
because the licensee did not implement this procedure change and as a result, did not incur a
violation of technical specifications. However, because 10 CFR 50.59 violations could
potentially impede or impact the regulatory process, the inspectors processed this
performance deficiency using the traditional enforcement process and the examples in
Section 6.1 of the Enforcement Policy.
Enforcement:
Severity: The ROPs significance determination process does not specifically consider the
regulatory process impact in its assessment of licensee performance. Therefore, it is
necessary to address this violation which impedes the NRCs ability to regulate using
traditional enforcement to adequately deter noncompliance. This violation was more than
minor because there was a reasonable likelihood the change would require NRC review and
approval prior to implementation, similar to violations assessed in Section 2.1.3 of the NRC
Enforcement Manual. The inspectors determined the violation to be a Severity Level IV
violation similar to violation Example 6.1.d.2 in the NRC Enforcement Policy.
Violation: As stated, in part, in 10 CFR 50.59, Changes, Tests, and Experiments,
Section (c)(1), a licensee may make changes in the facility as described in the final safety
analysis report (as updated), make changes in the procedure as described in the final safety
analysis report (as updated), and conduct tests or experiments not described in the final
safety analysis report (as updated) without obtaining a license amendment pursuant to
Sec. 50.90 only if: (i) a change to the Technical Specifications incorporated in the license is
not required. The licensee established Procedure EN-LI-100, Process Applicability
Determination, Revision 19, to comply with this requirement. Attachment 9.1 of
Procedure EN-LI-100 states, in part, to prepare a licensing basis document change request if
a proposed activity affects, invalidates, or renders incorrect, information contained in
Technical Specifications.
Contrary to the above requirements, from February 2017, until December 2017, the licensee
completed an activity that affected Technical Specifications and did not prepare a licensing
basis document change request. Specifically, the licensee implemented a change to
Technical Specification 3.7.4, Action c, through the implementation of
Procedure OP-100-014, Technical Specification and Technical Requirements Compliance,
Revision 337, by adding a note that instructed Operations personnel to not enter Technical Specification 3.7.4.c in the event of a tornado watch/warning if the dry cooling tower fans
were declared inoperable solely due to wet cooling tower fans being out of service. This
action was inconsistent with the current licensing basis and would have constituted a violation
of technical specifications.
Enforcement Action: Because this violation was not repetitive or willful, and was entered into
the licensees corrective action program as CR-WF3-2018-02111, this violation is being
treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy.
Licensee Event Automatic Reactor Scram due to the Failure of Fast Bus 71153
Report Transfer Relays to Automatically Transfer Station Loads to
(Closed) Off-site Power on a Main Generator Trip
05000382/2017-002-00
Description: The NRC conducted a special inspection to better understand the facts and
circumstances surrounding this event. The results and findings of that inspection are
documented in NRC Inspection Report 05000382/2017011 (Agencywide Documents Access
and Management System (ADAMS) Accession No. ML17354A690). The inspectors did not
identify any new deficiencies as a result of this review. This LER is closed.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On January 25, 2018, the inspectors presented the radiation safety inspection results to
Mr.
- J. Dinelli, Site Vice President, and other members of the licensee staff.
On April 12, 2018, the resident inspectors presented the quarterly resident inspector inspection
results to Mr.
- J. Dinelli, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
71111.01 - Adverse Weather Protection
Procedures
Number Title Revision
OP-002-007 Freeze Protection and Temperature Maintenance 25
OP-901-521 Severe Weather and Flooding 325
Condition Reports (CRs)
CR-WF3-2017-09668 CR-WF3-2018-00004 CR-WF3-2018-00082 CR-WF3-2018-00098
CR-WF3-2018-00436
71111.04 - Equipment Alignment
Procedures
Number Title Revision
OP-002-003 Component Cooling Water 317
OP-009-003 Emergency Feedwater 309
OP-009-008 Safety Injection System 41
71111.05 - Fire Protection
Miscellaneous Documents
Number Title Revision
RAB1A-B-C-D- Control Room Proper, H&V Room, Emergency Living 10
001 Quarters, and Computer Room
RAB8B-E-F-001 Switchgear B 12
RAB 17-001 Component Cooling Water Heat Exchanger B 8
RAB 19-001 Component Cooling Water Pump Room A 7
RAB 33-001 Shutdown Cooling Heat Exchanger Rooms A and B 8
Procedures
Number Title Revision
FP-001-018 Pre-fire Strategies, Development and Revision 304
71111.11 - Licensed Operator Requalification Program and Licensed Operator
Performance
Procedures
Number Title Revision
OP-901-111 Reactor Coolant System Leak 303
OP-901-403 High Airborne Activity in Containment 4
OP-901-404 High Airborne Activity in FHB 2
OP-901-405 Fuel Handling Incident 8
OP-901-513 Spent Fuel Pool Cooling Malfunction 21
OP-902-002 Loss of Coolant Accident Recovery 20
71111.12 - Maintenance Effectiveness
Miscellaneous Documents
Number Title Revision
910163-001 PCI Quality Assurance Traveler - FOST A1 Fabrication 1
EC-53943 Station Battery B Cell Lid Cracking 0
EC-57534 Station Battery A Cell Lid Cracks 0
QPP-205 Graham, Visual Inspection 17
QPP-205 Graham, Visual Inspection addenda 1
Addenda
WDT-0528 PCI Welding EDG Supplemental Fuel Oil Storage Tank 0
WF3-FOST-DN- Deviation Notice for Waterford 3 Fuel Oil Storage Tank, 1
21 Tank A1 - Rust and Arc Strikes on Shell
Procedures
Number Title Revision
ME-003-200 Station Battery Bank and Charger (Weekly) 314
Condition Reports (CRs)
CR-WF3-2014-05777 CR-WF3-2014-06375 CR-WF3-2014-06378 CR-WF3-2015-00842
CR-WF3-2015-01802 CR-WF3-2015-04849 CR-WF3-2015-04850 CR-WF3-2015-04854
CR-WF3-2017-03566 CR-WF3-2017-03607 CR-WF3-2017-06789 CR-WF3-2017-08771
CR-WF3-2017-08845 CR-WF3-2017-09167
Work Orders
446024
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Procedures
Number Title Revision
OP-903-005 Control Element Assembly Operability Check 14
71111.15 - Operability Determinations and Functionality Assessments
Miscellaneous Documents
Number Title Revision/Date
Protected Equipment List January 31,
2018
EC-40444 Revised Impact AST Dose Analyses to Address MSSV and 1
ADV Leakages
EC-75901 Component Cooling Water Heat Exchanger Degraded 1
Performance
ECM95-008 Ultimate Heat Sink Design Basis 3
ECS05-13 Ultimate Head Sink Containment Heat Loads 1
MNQ9-2 Component Cooling Water System 2
MNQ9-50 ACCW System Resistance 2
TD-G080.0495 General Electric Spare Reactor Coolant Pump Motor 1
Drawings
WF3-ME-16- Meteorological Parameters and Parameter Relationships for 0
00001 Design and Operability of the Waterford 3 Ultimate Heat
Sink
Procedures
Number Title Revision
OP-001-002 Reactor Coolant Pump Operation 22
PE-004-021 CCW Heat Exchanger Performance Test 5
Condition Reports (CRs)
CR-WF3-2011-07700 CR-WF3-2012-02332 CR-WF3-2018-00662 CR-WF3-2018-00785
CR-WF3-2018-00948 CR-WF3-2018-00951 CR-WF3-2018-00986 CR-WF3-2018-01225
Condition Reports (CRs)
CR-WF3-2018-01426 CR-WF3-2018-01549 CR-WF3-2018-01559
Work Orders
481333 495770 495771 496893 52348919
71111.18 - Plant Modifications
Miscellaneous Documents
Number Title Revision
6W12CM10 Common Mat Stress Analysis - Cooling Tower Area 2
ECC16-004 Horizontal Air Flow Barrier Roof and Gutters at Dry Cooling 0
Tower Outside Missile Protection
ECM95-008 Ultimate Heat Sink Design Basis 3
MNQ9-52 Ultimate Heat Sink Performance based on data 2
WF3-ME-16- Meteorological Parameters and Parameter Relationships for 0
00001 Design and Operability of the Waterford 3 Ultimate Heat
Sink
Condition Reports (CRs)
Work Orders
444257
71111.19 - Post-Maintenance Testing
Miscellaneous Documents
Number Title Revision
AR 184566184566 Replace Solenoid Valve
AR 186060186060 Align PMRQs for AOV PM Optimization Program
TD A610.0155 ASCO Installation and Maintenance Instructions for 3-Way 0
Solenoid Valves Series 8316
Procedures
Number Title Revision/Date
ME-007-019 ASCO/AVCO/MAC/Parker Hannifin Solenoid Valves 306
Procedures
Number Title Revision/Date
MM-003-041 Six Year Emergency Diesel Engine Inspection February 2,
2018
OP-903-030 Safety Injection Pump Operability Verification 35
OP-903-050 Component Cooling Water and Auxiliary Component 039
Cooling Water Pump and Valve Operational Test
OP-903-118 Primary Auxiliaries Quarterly IST Valve Tests 43
OP-903-121 Safety System Quarterly IST Valve Tests 27
Condition Reports (CRs)
CR-WF3-2017-07146 CR-WF3-2018-00441 CR-WF3-2018-00808 CR-WF3-2018-01498
Work Orders
436357 52649596 52673039 52701091
71111.22 - Surveillance Testing
Miscellaneous Documents
Number Title Date
TD-C490.0485 Combustion Engineering Ex-Core Neutron Flux Monitoring April, 1985
System Safety Channel Operation and Maintenance Manual
Procedures
Number Title Revision
MI-003-002 Safety Channel Nuclear Instrumentation Functional Test 17
OP-903-068 Emergency Diesel Generator and Subgroup Relay 319
Operability Verification
OP-903-107 Plant Protection System Channel C Functional Test 312
Work Orders
2800018 52800019
71114.06 - Drill Evaluation
Procedures
Number Title Revision
EP-001-010 Unusual Event 306
EP-001-020 Alert 309
EP-001-030 Site Area Emergency 308
EP-002-010 Notifications and Communications 315
OP-902-002 Loss of Coolant Accident Recovery 20
Condition Reports (CRs)
CR-WF3-2018-01082 CR-WF3-2018-01083 CR-WF3-2018-01084 CR-WF3-2018-01095
71124.01 - Radiological Hazard Assessment and Exposure Controls
Number Title Date
OL-011518-002 Pool Purification Pump Shaft Removal January 15,
2018
OL-02112017- Sluice CVC IX A February 11,
013 2017
OL-032717-006 Lapel Air Sample for RWP 2017-0064 March 27,
2017
OL-040417-004 Alpha Air - RAB -35 Safeguards Room A April 4, 2017
OL-072217-0015 Alpha Air - Letdown Valve Gallery July 22, 2017
RF-05162017- Alpha Air - Top of UGS May 16, 2017
561
Audits and Self-Assessments
Number Title Date
LO-WLO-2017- November
Pre-NRC Self-Assessment Radiation Safety - IP 71124.01
00068 CA-00005 30, 2017
Miscellaneous Documents
Number Title Date
NSTS Annual Inventory Reconciliation Report January 4,
2018
Miscellaneous Documents
Number Title Date
Periodic Review of Plant Isotopic Mix Compared to September
Radiation Protection Instrument, Revision 1 21, 2017
Review of Smears Taken for Alpha Characterization During September
RF21 19, 2017
Spent Fuel Pool Inventory October 25,
2017
Update to the Review of the Capabilities of Our Passive October 4,
Monitoring Program to Detect Intakes at Waterford-3 2017
2017-2018 Entergy Waterford 3 Radiation Protection Department August 10,
Respiratory Improvement Plan 2017
Att. 9.6 to EN- LHRA/VHRA Key Log January 23-
RP-101 25, 2018
WO 52734309 Sealed Source Leak Test June 22,
2017
WO 52768769 Semi-Annual Source Inventory December
11, 2017
Procedures
Number Title Revision
EN-RE-220 PWR Control of Miscellaneous Materials in the Spent Fuel 3
Pool
EN-RP-100 Radiation Worker Expectations 12
EN-RP-101 Access Control for Radiologically Controlled Areas 13
EN-RP-102 Radiological Control 5
EN-RP-104 Personnel Contamination Events 9
EN-RP-105 Radiological Work Permits 18
EN-RP-106 Radiological Survey Documentation 7
EN-RP-108 Radiation Protection Posting 19
EN-RP-109 Hot Spot Program 5
EN-RP-121 Radioactive Material Control 13
EN-RP-122 Alpha Monitoring 9
EN-RP-143 Source Control 13
EN-RP-315 Operation and Calibration of the CRONOS Contamination 2
Monitor
Radiation Surveys
Number Title Date
WF3-1704-0537 +46 Pressurizer Cubicle April 18, 2017
WF3-1705-0049 FHB +46 Fuel Handling Area May 1, 2017
WF3-1711-0270 FHB +46 Fuel Handling Area November
30, 2017
WF3-1711-0271 FHB +46 Fuel Handling Area November
30, 2017
WF3-1801-0194 RAB -4 Hallways January 16,
2018
WF3-1801-0213 RAB -35 Hallways January 18,
2018
WF3-1801-0262 RAB -21 Hallways January 24,
2018
Radiation Work Permits
Number Title Revision
2017-0101 Work Activities in the Spent Fuel Pool and the Transfer 1
Canal
2017-0509 RF21 Remove/Replace Steam Generator Primary 1
Manways/Diaphragms
2017-0510 Install/Remove Steam Generator Nozzle Dams, Pin 2
Verification and Closure
2017-0705 RF21 Reassembly of Reactor Head and Associated Work 0
Activities
2017-0727 RF21 Perform Reactor Vessel (ISI) Inspection Using the 2
WestDyne (ROSA) and a Submarine
2018-0004 Maintenance Activities in all Radiologically Controlled Areas 0
2018-0007 Perform Various Decon and Housekeeping Activities in all 0
Radiologically Controlled Areas
Condition Reports (CRs)
CR-WF3-2017-02540 CR-WF3-2017-02718 CR-WF3-2017-02956 CR-WF3-2017-03344
CR-WF3-2017-03349 CR-WF3-2017-03362 CR-WF3-2017-03799 CR-WF3-2017-03872
CR-WF3-2017-03953 CR-WF3-2017-06030 CR-WF3-2017-06758 CR-WF3-2017-07988
CR-WF3-2017-08330 CR-WF3-2018-00506 CR-WF3-2018-00507 WT-WTWF3-2017-
273
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Air Quality Testing Results
Number Title Date
296484-0 Compressed Air/Gas Quality Testing Laboratory Report February 15,
2017
296614-0 Compressed Air/Gas Quality Testing Laboratory Report February 16,
2017
309752-0 Compressed Air/Gas Quality Testing Laboratory Report July 28, 2017
309780-0 Compressed Air/Gas Quality Testing Laboratory Report July 31, 2017
Audits and Self-Assessments
Number Title Date
LO-WLO-2017- Pre-NRC Assessment IP 71124.03 In-Plant Airborne November
00068 Radioactivity Control and Mitigation 23, 2017
Filtration Testing Results
Number Title Date
257571 Charcoal Sample Testing May 31, 2016
2577572 In-Place HEPA Filter Testing June 1, 2016
2704414 In-Place Charcoal Filter Testing November 8,
2017
Miscellaneous Documents
Number Title Date
Inspection and Maintenance of Respiratory Protection December
Equipment - Face Piece Inspection Log 27, 2017
Inspection and Maintenance of Respiratory Protection December
Equipment - SCBA Inspection Log 27, 2017
2017-0702-04 TEDE-ALARA Evaluation November
15, 2016
Procedures
Number Title Revision
EN-RP-310 Operation and Initial Setup of the Eberline AMS-4 4
Continuous Air Monitor
EN-RP-501 Respiratory Protection Program 5
Procedures
Number Title Revision
EN-RP-502 Inspection and Maintenance of Respiratory Protection 10
Equipment
EN-RP-502-01 Fire Hawk M7 SCBA 1
EN-RP-503 Selection, Issue And Use Of Respiratory Protection 7
Equipment
EN-RP-504 Breathing Air 4
SCBA Maintenance Records
Number Title Date
UEM-6123 Posi3 USB Test Results - Complete SCBA Test March 31,
2016
UEM-6123 Posi3 USB Test Results - Complete SCBA Test February 13,
2017
UEM-6259 Posi3 USB Test Results - Complete SCBA Test March 30,
2016
UEM-6259 Posi3 USB Test Results - Complete SCBA Test February 14,
2017
Condition Reports (CRs)
CR-WF3-2016-03044 CR-WF3-2017-00011 CR-WF3-2017-00375 CR-WF3-2017-00678
CR-WF3-2017-04253 CR-WF3-2017-05533 CR-WF3-2017-06536 CR-WF3-2017-06758
71151 - Performance Indicator Verification
Audits and Self-Assessments
Number Title Date
LO-WLO-2017- Radiation Safety 71151 OR01 Occupational Exposure November
00068 Control Effectiveness 29, 2017
Miscellaneous Documents
Number Title Date
W3F1-2017- NRC Performance Indicator (PI) Data - 1st Quarter 2017 April 12, 2017
0036 ROP Data
W3F1-2017- NRC Performance Indicator (PI) Data - 2nd Quarter 2017 July 13, 2017
0058 ROP Data
Miscellaneous Documents
Number Title Date
W3F1-2017- NRC Performance Indicator (PI) Data - 3rd Quarter 2017 October 6,
0076 ROP Data 2017
W3F1-2018- NRC Performance Indicator (PI) Data - 4th Quarter 2017 January 9,
0004 ROP Data 2018
Procedures
Number Title Revision
EN-LI-114 Regulatory Performance Indicator Process 9
71152 - Problem Identification and Resolution
Miscellaneous Documents
Number Title Date
White Paper Cascading Technical Specifications During Emergency February,
Diesel Generator Outages 2018
Procedures
Number Title Revision
EN-LI-100 Process Applicability Determination Form 19
OP-100-014 Technical Specification and Technical Requirements 336, 337, 340
Compliance
Condition Reports (CRs)
CR-WF3-2017-00780 CR-WF3-2017-00785
Occupational Radiation Safety Inspection
Waterford-3
Dates of Inspection: January 22 - 26, 2018
Integrated Inspection Report 2018001
Inspection areas are listed in the attachments below.
Please provide the requested information on or before January 5, 2018.
Please submit this information using the same lettering system as below. For example, all
contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled
1- A, applicable organization charts in file/folder 1- B, etc.
If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at
least 30 days later than the onsite inspection dates, so the inspectors will have access to the
information while writing the report.
In addition to the corrective action document lists provided for each inspection procedure listed
below, please provide updated lists of corrective action documents at the entrance meeting.
The dates for these lists should range from the end dates of the original lists to the day of the
entrance meeting.
If more than one inspection procedure is to be conducted and the information requests appear
to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which
file the information can be found.
If you have any questions or comments, please contact Natasha Greene at (817) 200-1154 or
Natasha.Greene@nrc.gov.
PAPERWORK REDUCTION ACT STATEMENT
This letter does not contain new or amended information collection requirements subject
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information
collection requirements were approved by the Office of Management and Budget,
control number 3150-0011.
1. Radiological Hazard Assessment and Exposure Controls (71124.01) and
Performance Indicator Verification (71151)
Date of Last Inspection: 4/24/2017
A. List of contacts and telephone numbers for the Radiation Protection Organization Staff
and Technicians
B. Applicable organization charts
- C. Audits, self-assessments, and LERs written since 4/24/2017, related to this inspection
area
D. Procedure indexes for the radiation protection procedures
E. Please provide procedures related to the following areas noted below. Additional
procedures may be requested by number after the inspector reviews the procedure
indexes.
1. Radiation Protection Program
2. Radiation Protection Conduct of Operations, if not included in #1.
3. Personnel Dosimetry
4. Posting of Radiological Areas
5. High Radiation Area Controls
6. RCA Access Controls and Radiation Worker Instructions
7. Conduct of Radiological Surveys
8. Radioactive Source Inventory and Control
F. List of corrective action documents (including corporate and sub-tiered systems) since
4/24/2017.
a. Initiated by the radiation protection organization
b. Assigned to the radiation protection organization
NOTE: The lists should indicate the significance level of each issue and the search
criteria used. Please provide in document formats which are searchable so that
the inspector can perform word searches.
G. List of radiologically significant work activities scheduled to be conducted during the
inspection period. (If the inspection is scheduled during an outage, please also include a
list of work activities greater than 1 rem, scheduled during the outage with the dose
estimate for the work activity.)
H. List of active radiation work permits
I. Radioactive source inventory list all radioactive sources that are required to be leak
tested. Indicate which sources are 10 CFR Part 20, Appendix E, Category 1 or Category
2. Please indicate the radioisotope, initial and current activity (w/assay date), and
storage location for each applicable source.
J. The last two leak test results for the Category 1 or 2 radioactive sources and any other
radioactive source(s) that have failed its leak test within the last two years
- K. A list of any non-fuel items stored in the spent fuel pools, and if available, their
appropriate dose rates (Contact / @ 30cm)
L. A list of radiological controlled area entries greater than 100 millirem since 4/24/2017.
The list should include the date of entry, some form of worker identification, the radiation
work permit used by the worker, dose accrued by the worker, and the electronic
dosimeter dose alarm set-point used during the entry (for Occupational Radiation Safety
Performance Indicator verification in accordance with IP 71151).
3. In-Plant Airborne Radioactivity Control and Mitigation (71124.03)
Date of Last Inspection: 3/21/2016
A. List of contacts and telephone numbers for the following areas:
1. Respiratory Protection Program
2. Self-contained breathing apparatus
B. Applicable organization charts
- C. Copies of audits, self-assessments, vendor or NUPIC audits for contractor support
(SCBA), and LERs, written since 3/21/2016 related to:
1. Installed air filtration systems
2. Self-contained breathing apparatuses
D. Procedure index for:
1. Use and operation of continuous air monitors
2. Use and operation of temporary air filtration units
3. Respiratory protection
E. Please provide specific procedures related to the following areas noted below.
Additional Specific Procedures may be requested by number after the inspector reviews
the procedure indexes.
1. Respiratory protection program
2. Use of self-contained breathing apparatuses
3. Air quality testing for SCBAs
4. Use of installed plant systems, such as containment purge, spent fuel pool
ventilation, and auxiliary building ventilation
F. A summary list of corrective action documents (including corporate and sub-tiered
systems) written since 3/21/2016, related to the Airborne Monitoring program including:
1. Continuous air monitors
2. Self-contained breathing apparatuses
3. Respiratory protection program
NOTE: The lists should indicate the significance level of each issue and the search
criteria used. Please provide in document formats which are searchable so that
the inspector can perform word searches.
G. List of SCBA qualified personnel - reactor operators and emergency response personnel
H. Inspection records for self-contained breathing apparatuses (SCBAs) staged in the plant
for use since 3/21/2016.
- I. SCBA training and qualification records for control room operators, shift supervisors,
STAs, and OSC personnel for the last year.
A selection of personnel may be asked to demonstrate proficiency in donning, doffing,
and performance of functionality check for respiratory devices
- J. List of respirators (available for use) by type (APR, SCBA, PAPR, etc.), manufacturer,
and model.
SUNSI Review Non-Sensitive Publicly Available Keyword:
By: JDixon/rdr Sensitive Non-Publicly Available NRC-002
OFFICE SRI:DRP/D RI:DRP/D PE:DRP/D BC:DRS/EB1 BC:DRS/EB2 BC:DRS/PSB2
NAME FRamirez CSpeer JChoate TFarnholtz JDrake HGepford
SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/
DATE 5/7/18 5/4/18 5/7/18 5/3/2018 5/3/18 5/3/18
OFFICE BC:DRS/OB TL:DRS/IPAT SPE:DRP/D BC:DRP/D
NAME VGaddy GGeorge JDixon GMiller
SIGNATURE /RA/ /RA/ /RA/ /RA/
DATE 5/7/18 5/3/18 5/3/18 5/8/18