ML13324B133

IR 05000382-13-004; on 07/01/2013 - 09/30/2013; Waterford Steam Electric Station, Unit 3, Integrated Resident and Regional Report; Fire Protection, Post-Maintenance Testing, and Other Activities

ML13324B133
Person / Time
Site:	Waterford
Issue date:	11/20/2013
From:	Greg Werner NRC/RGN-IV/DRP/RPB-E
To:	Jacobs D Entergy Operations
References
EA-12-257 IR-13-004
Download: ML13324B133 (66)

See also: IR 05000382/2013004

Text

November 20, 2013

EA-12-257

Donna Jacobs, Vice President, Operations

Entergy Operations, Inc.

Waterford Steam Electric Station, Unit 3

Killona, LA 70057-0751

SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED INSPECTION REPORT 05000382/2013004

Dear Ms. Jacobs:

On September 30, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford Steam Electric Station, Unit 3 facility. On October 1, 2013, the NRC inspectors discussed the results of this inspection with you and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.

NRC inspectors documented two findings of very low safety significance (Green) in this report.

Further, inspectors documented

a licensee-identified violation which was determined to be a Severity Level IV in this report. All of these findings involved violations of NRC requirements.

The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.

In addition, the enclosed inspection report discusses a Severity Level IV violation that was

identified during the closure of unres

olved item 05000382/2009010-01, documented in NRC Inspection Report 05000382/2009010 (ML093100238). This violation was evaluated in

accordance with the NRC Enforcement Policy, dated September 1, 2009, (ML092440278) which was in effect at the time the special inspection report was issued. In accordance with Supplement VII, Section C.6, of that Enforcement Policy, this violation would normally be

assessed as Severity Level III. However, in accordance with the Enforcement Policy, the

severity level of an untimely report may be reduced depending on the circumstances

surrounding the matter. Since the affected components were already removed from service as part of an unrelated manufacturer's recall and no longer considered a substantial safety hazard, the NRC concluded this violation is more appropriately assessed as Severity Level IV with a written response required.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The NRC's review of your response to the Notice will also determine whether further enforcement action is

necessary to ensure compliance with regulatory requirements.

UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION IV1600 EAST LAMAR BLVDARLINGTON, TEXAS 76011-4511

D. Jacobs - 2 -

If you contest the violation or significance of these NCVs, 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, U.S.

Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector

at the Waterford Steam Electric Station, Unit 3 facility.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date

of this inspection report, with the basis for your disagreement, to the Regional Administrator,

Region IV; and the NRC resident inspector at the Waterford Steam Electric Station, Unit 3

facility.

In accordance with Title 10 of the Code of Federal Regulations (10CFR) 2.390, "Public

Inspections, Exemptions, Requests for Withholding," a copy of this letter, its enclosure, and your

response (if any) will be available electronicall

y for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic

Reading Room).

Sincerely,

/RA/ Michael R. Bloodgood for

Gregory E. Werner, Acting Chief

Project Branch E

Division of Reactor Projects

Docket No.: 50-382 License No.: NPF-38

Enclosures: 1. Notice of Violation EA-12-257

2. Inspection Report 05000382/2013004 w/Attachment: Supplemental Information

Electronic Distribution to Waterford Steam Electric Station, Unit 3

ML13324B133

SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials MD Publicly Avail. Yes No Sensitive Yes No Sens. Type Initials MD

SRI:DRP/E RI:DRP/E C:DRP/E C:DRS/EB1 C:DRS/EB2 C:DRS/OBMDavis CSpeer GWerner TFarnholtz GMiller VGaddy /RA/ E /RA/ E /RA/ /RA/ /RA/ /RA/ 11/14/13 11/14/13 11/15/13 11/15/13 11/18/13 11/18/13 C:DRS/PSB1 C:DRS/PSB2 C:DRS/TSB C:ORA/ACES

BC:DRP/E MHaire JDrake RKellar HGepford GWerner /RA/ /RA/ /RA/ /RA/ /RA/MBloodgood for

11/15/13 11/18/13 11/18/13 11/18/13 11/20/2013

- 1 - Enclosure 1 NOTICE OF VIOLATION

Entergy Operations, Inc. Docket No: 50-382

Waterford Steam Electric Station, Unit 3 License No: NPF-38

EA-12-257

During the NRC inspection conducted from July 20-October 19, 2009, a violation of the NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below: Title 10 CFR, Part 21.21(a)(1) requires, in part, that entities subject to the regulations in this part shall evaluate deviations and failures to comply to identify defects associated

with substantial safety hazards as soon as practicable, and except as provided in paragraph (a)(2) of this section, in all cases within 60 days of discovery, in order to identify a reportable defect that could create a substantial safety hazard, were it to

remain uncorrected. Title 10 CFR, Part 21.21(a)(2) requires, in part, that entities subject to the regulations in the part shall ensure that if an evaluation of identified deviation or failure to comply

potentially associated with a substantial safety hazard cannot be completed within

60 days from discovery of the deviation or failure to comply, an interim report is prepared and submitted to the Commission. The interim report must be submitted in writing within 60 days of discovery of the deviation of failure to comply. Contrary to the above, from December 14, 2008 to April 29, 2010, the licensee failed to evaluate deviations and failures to comply to identify defects associated with substantial

safety hazards as soon as practicable and to submit a report or interim report within

60 days of its discovery, in order to identify a reportable defect or failure to comply that could create a substantial safety hazard, were it to remain uncorrected. Specifically, on October 14, 2008, the licensee performed bench testing on an Agastat E7024PB relay with date code 0835 and noted that the relay had a loose terminal point. Two more relays were obtained from the warehouse; one of these also had a bad terminal point. On October 27, 2008, the licensee quarantined the remaining four relays

in stock. Two of these quarantined relays were identified to have similarly deficient

terminal points. The licensee identified these relays as "defective" and returned them to

the manufacturer, for cause evaluation. All four affected relays shared a date code of

0835. On January 28, 2009, the licensee received a report from the manufacturer, which did not provide a cause evaluation. On August 18, 2009, the licensee submitted Licensee Event Report 2009-003-00, (ML092310548). This Licensee Event Report did

not mention the date code 0835 relays or loose terminal points. Rather, the Licensee

Event Report described relays that failed due to

incorrect adjustment of terminal blocks, a deviation different from that observed in the 0835 date code relays. On April 29, 2010, the licensee issued updated Licensee Event Report 2009003-01 (ML101230323). This revision to the Licensee Event Report described loose terminal points on two spare date

code 0835 relays as one of the defects identified in its Agastat E7024PB relays. The

April 29, 2010, Licensee Event Report revision would have met Part 21 evaluation and reporting requirements, but it was 501 days late.

- 2 - Enclosure 1

This is a Severity Level IV violation (Supplement VII of Enforcement Policy dated September 1, 2009). Pursuant to the provisions of 10 CFR 2.201, the Waterford Steam Electric Station, Unit 3 is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory

Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, Region IV, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of

Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of

Violation; EA 12-257" and should include (1) the reason for the violation, or, if contested, the

basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed

correspondence, if the correspondence adequately addresses the required response. If an

adequate reply is not received within the time specified in this Notice, an order or a Demand for

Information may be issued as to why the license should not be modified, suspended, or

revoked, or why such other action as may be proper should not be taken. Where good cause is

shown, consideration will be given to extending the response time. If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001. Because your response will be made available el

ectronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not

include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your

response that deletes such information. If you request withholding of such material, you must

specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial

information). If safeguards information is necessary to provide an acceptable response, please

provide the level of protection described in 10 CFR 73.21. Dated this 20

th day of November 2013

- 1 - Enclosure 2

U.S. NUCLEAR REGULATORY COMMISSION REGION IV

Docket: 05000382 License: NPF-38

Report: 05000382/2013004 Licensee: Entergy Operations, Inc. Facility: Waterford Steam Electric Station, Unit 3 Location: 17265 River Road Killona, LA 70057 Dates: July 1 through September 30, 2013 Inspectors: M. Davis, Senior Resident Inspector C. Speer, Resident Inspector T. Farina, Operations Engineer C. Steely, Operations Engineer

L. Carson, Senior Health Physicist

L. Ricketson, Senior Health Physicist

C. Alldredge, Health Physicist N. Greene, Health Physicist P. Hernandez, Health Physicist

J. O'Donnell, Health Physicist

E. Ruesch, Senior Reactor Engineer

Approved By: G. Werner, Acting Chief

Project Branch E

Division of Reactor Projects

- 2 - Enclosure 2

SUMMARY OF FINDINGS

IR 05000382/2013004; 07/01/2013 - 09/30/2013; Waterford Steam Electric Station, Unit 3, Integrated Resident and Regional Report; Fire Protection, Post-Maintenance Testing, and Other

Activities. The report covered a 3-month period of inspection by resident inspectors and an announced baseline inspections by region-based inspectors. Two Green non-cited violations and one

severity level IV violation were identified. The significance of most findings is indicated by their

color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609, "Significance Determination Process." The cross-cutting aspect is determined using Inspection Manual Chapter 0310, "Components Within the Cross-Cutting Areas." Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of

commercial nuclear power reactors is described in NUREG - 1649, "Reactor Oversight Process," Revision 4, dated December 2006.

A. NRC-Identified Findings and Self-Revealing Findings

Cornerstone: Mitigating Systems

• Green. The inspectors identified a non-cited violation of Waterford's Facility Operating License Number NPF-38, License Condition 2.C.9, because the licensee did not implement fire protection procedure FP-001-014, "Duties of a Fire Watch." Specifically, the licensee's fire watch personnel did not implement Section 6.5 of FP-001-014 to remove firefighting equipment from work areas when securing from a

fire watch. As a result, multiple undercharged fire extinguishers were left in a fire

area. The inspectors determined that this would affect safety-related equipment

because it would delay the response to fires in the fire areas. The licensee entered

this condition into their corrective action program as CR-WF3-2013-03398 and CR-WF3-2013-03523 for resolution. The immediate corrective actions taken to restore compliance included the removal of all undercharged fire extinguishers from

deactivated posts and returning them to their proper storage location.

The failure to implement a fire protection program procedure was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection against external factors (i.e., fire) attribute of the

Mitigating Systems Cornerstone and adversely affected the cornerstone objective of

ensuring the availability, reliability, and capability of systems that respond to initiating

events to prevent undesirable consequences. Specifically, the failure to remove undercharged fire extinguishers from work areas that contained safe shutdown equipment could hinder responses to fires in the fire area. The inspectors used the

NRC Inspection Manual Chapter 0609, Attachment 4, "Initial Characterization of

Findings," to evaluate this issue. The initial screening directed the inspectors to use

Appendix F, "Fire Protection Significance Determination Process," to determine the significance of the finding. The inspectors determined that the finding had a low degradation rating because it reflected a fire protection program element whose

- 3 - Enclosure 2

performance and reliability would be minimally impacted. Specifically, in all cases identified, there were permanent fully charged portable fire extinguishers of the

proper type nearby. Therefore, the finding was of very low safety significance (Green). The inspectors concluded that the finding reflected current licensee performance and involved a cross-cutting aspect in the work practices component of

the human performance area in that the licensee did not ensure supervisory and

management oversight of work activities, including contractors, such that nuclear

safety is supported H.4(c) (Section 1R05).

• Green. The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," because the licensee did not accomplish activities affecting quality on a degraded safety-related train B component cooling water (CCW) bypass valve (CC-134B) in accordance with

maintenance procedure EN-MA-101, "Fundamentals of Maintenance." Specifically,

the licensee did not control and perform testing on a leaking solenoid valve related to

the operation of a safety-related bypass valve (CC-134B) after maintenance personnel removed the degraded equipment from service as required by Section 5.10 of EN-MA-101. As a result, the licensee could not characterize and determine

the cause of the leakage for the safety-related valve. The inspectors determined that

this would challenge the safety function of the valve to provide CCW to the ultimate

heat sink following a tornado event. The licensee entered this condition into their corrective action program as CR-WF3-2012-05991, CR-WF3-2012-06288, and CR-WF3-2013-04047. The immediate corrective actions taken to restore compliance

included the installation of a new valve and debriefing personnel about controlling

equipment removed from service when

combining preventative and corrective maintenance tasks in one work order.

The failure to control failed equipment removed from the plant to determine the cause in accordance with maintenance procedure requirements was a performance

deficiency. The performance deficiency was more than minor because it was

associated with the equipment performance attribute of the Mitigating System

Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the degraded condition challenged

the safety function of the valve (CC-134B) to limit the loss of CCW through damaged

portions of the dry cooling tower fans following a tornado-generated missile strike.

The inspectors used the NRC Inspection Manual 0609, Attachment 4, "Initial

Characterization of Findings," to evaluate this issue. The finding required a detailed analysis because it was potentially risk significant for an external event (tornado). Therefore, the senior reactor analyst performed a bounding detailed risk evaluation.

The senior reactor analyst determined that the finding was of very low safety

significance (Green). The bounding change to the core damage frequency was less

than 3E-7/year. The finding was not significant with respect to the large early release frequency. The dominant core damage sequences included tornado induced losses of offsite power, failure of the dry cooling tower pressure boundary, failure to

isolate the damaged dry cooling tower, and failure to recover instrument air. The

redundant train A component cooling water system combined with the tornado

- 4 - Enclosure 2

frequency helped to reduce the risk exposure. The inspectors concluded that the finding reflected current licensee performance and involved a cross-cutting aspect in

the work control component of the human performance area in that the licensee did not appropriately coordinate work activities by incorporating actions to address the impact of changes to work scope or activity on plant and human performance

H.3(b) (Section 1R19).

Cornerstone: Miscellaneous

• Severity Level IV. The team identified a violation of 10 CFR 21.21 that occurred when the licensee failed to submit a report or interim report on a deviation in a basic component within 60 days of discovery.

The failure of the licensee to adequately evaluate deviations in basic components and to report defects is a performance deficiency. The NRC's significance

determination process (SDP) considers the safety significance of findings by

evaluating their potential safety consequences. This performance deficiency was of

minor safety significance. The traditional enforcement process separately considers the significance of willful violations, violations that impact the regulatory process, and violations that result in actual safety consequences. Traditional enforcement applied to this finding because it involved a violation that impacted the regulatory process.

Supplement VII to the version of the NRC Enforcement Policy that was in effect at

the time the violation was identified provided as an example of a violation of

significant regulatory concern (Severity Level III), "An inadequate review or failure to review such that, if an appropriate review had been made as required, a 10 CFR Part 21 report would have been made." Based on this example, the NRC

determined that the violation met the criteria to be cited as a Severity Level III

violation. However, because of the circumstances surrounding the violation,

including the removal from service of the affected components by an unrelated

manufacturer's recall, the severity of the cited violation is being reduced to Severity Level IV. Cross-cutting aspects are not assigned to traditional enforcement violations. (Section 4OA5.2)

B. Licensee-Identified Violations

A violation of very low safety significance (Severity Level IV), which was identified by the licensee, has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. This violation and associated corrective action tracking numbers are listed in Section 4OA7 of this report.

- 5 - Enclosure 2

PLANT STATUS

The Waterford Steam Electric Station, Unit 3, began the inspection period at 100 percent power.

On September 18, 2013, operators commenced a reactor down power to approximately 82 percent to perform maintenance on the normal level control valve 2B and the heater drain

pump B, respectively. Operators began to raise power to 100 percent the same day. The unit

maintained a 100 percent power for the remainder of the inspection period.

REPORT DETAILS

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity and

Emergency Preparedness

1R01 Adverse Weather Protection (71111.01) Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

Since tropical depression Dorian was forecast in the vicinity of the facility for August 4, 2013, the inspectors reviewed the plant personnel's overall preparations and protection for the expected weather conditions. On August 2, 2013, the inspectors did a partial

walkdown of the switchyard and the startup unit transformer systems because their

functions could be affected, as a result of high winds, tornado-generated missiles, or the

loss of offsite power. The inspectors evaluated the plant staff's preparations against site

procedures and determined that the staff's actions were adequate. During the inspection, the inspectors focused on plant design features and the licensee's procedures to respond to

tornadoes and high winds. The inspectors also toured the plant grounds to look for any loose debris that could become missiles during a tornado.

The inspectors' evaluated operator staffing and accessibility of controls and indications

for those systems required to control the plant. Additionally, the inspectors reviewed the final safety analysis report and performance requirements for the systems selected for inspection, and verified that operator actions were appropriate as specified by plant-

specific procedures. The inspectors also reviewed a sample of corrective action

program items to verify that the licensee had identified adverse weather issues at an

appropriate threshold and entered them into the corrective action program for resolution.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one sample of impending adverse weather

conditions, as defined in Inspection Procedure 71111.01. b. Findings

No findings were identified.

- 6 - Enclosure 2

1R04 Equipment Alignment (71111.04) Partial Walkdown

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant systems:

• On July 29, 2013, high pressure safety injection train B while train A was out of service for maintenance activities

• On August 20, 2013, essential chiller AB while essential chiller B was out of service for maintenance activities

• On September 5, 2013, auxiliary component cooling water train B while train A was out of service for maintenance activities

The inspectors selected these systems based on their risk significance relative to the

reactor safety cornerstones at the time they were inspected, while considering out of

service time, inoperable or degraded conditions, recent system outages, and

maintenance, modification, and testing. The inspectors attempted to identify any

discrepancies that could affect the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, final safety analysis report, technical specification requirements,

administrative technical specifications, outstanding work orders, condition reports, and

the impact of ongoing work activities on redundant trains of equipment in order to identify

conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also inspected accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The

inspectors examined the material condition of the components and observed operating

parameters of equipment to verify that there were no obvious deficiencies. The

inspectors also verified that the licensee had properly identified and resolved equipment

alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this

inspection are listed in the attachment.

These activities constitute completion of three partial system walkdown samples, as defined in Inspection Procedure 71111.04. b. Findings

No findings were identified.

- 7 - Enclosure 2

1R05 Fire Protection (71111.05) Quarterly Fire Inspection Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns that were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant

plant areas:

• On July 18, 2013, reactor auxiliary building, fire area 2, heat and ventilation

mechanical room

• On July 30, 2013, reactor auxiliary building, fire area 7, relay room

• On August 12, 2013, reactor auxiliary building, fire area 39, -35' foot elevation general area

• On August 27, 2013, turbine building, fire area 2, turbine building +15.00' foot elevation west side area

The inspectors reviewed areas to assess if licensee personnel had implemented a fire

protection program that adequately controlled combustibles and ignition sources within

the plant; effectively maintained fire detection and suppression capability; maintained

passive fire protection features in good material condition; and had implemented adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features, in accordance with the licensee's fire plan.

The inspectors selected fire areas based on their overall contribution to internal fire risk

as documented in the plant's Individual Plant Examination of External Events with later

additional insights, their potential to affect equipment that could initiate or mitigate a plant transient, or their impact on the plant's ability to respond to a security event. Using the documents listed in the attachment, the inspectors verified that fire hoses and

extinguishers were in their designated locations and available for immediate use; that

fire detectors and sprinklers were unobstructed; that transient material loading was

within the analyzed limits; and fire doors, dampers, and penetration seals appeared to

be in satisfactory condition and verified that adequate compensatory measures were put in place by the licensee for out of service, degraded, or inoperable fire protection equipment systems or features. The inspectors also verified that minor issues identified

during the inspection were entered into the licensee's corrective action program.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of four quarterly fire protection inspection samples, as defined in Inspection Procedure 71111.05-05.

b. Findings

Introduction. The inspectors identified a Green non-cited violation of Waterford's Facility Operating License Number NPF-38, License Condition 2.C.9, because the licensee did

- 8 - Enclosure 2

not implement fire protection procedure FP-001-014, "Duties of a Fire Watch." Specifically, the licensee's fire watch personnel did not implement section 6.5 of FP-001-014 to remove firefighting equipment from work areas when securing from a fire watch.

Description. On July 18, 2013, during a walkdown of the reactor auxiliary building (RAB) fire area number two, inspectors identified an undercharged and improperly stored fire

extinguisher in the fire area. The inspectors communicated this concern to the licensee.

The licensee dispatched personnel to remove the extinguisher and discovered two additional fire extinguishers in the same area with degraded charges. The licensee initiated condition report CR-WF3-2013-03398 and removed the undercharged fire

extinguishers from the area. Upon further questioning from the inspectors, the licensee stated that all of the uncharged fire extinguishers identified and removed from this fire area were equipment used by fire watch personnel during recent hot work activities. The inspectors reviewed the initial condition report, hot work permits, fire protection program procedures EN-DC-127, "Control of Hot Work and Ignition Sources," and FP-001-014,

"Duties of a Fire Watch." The inspectors noted that procedure FP-001-014 required, in

part, that when a fire watch is deactivated the fire watch shall return all equipment to

their proper storage location. The inspectors determined that the licensee's fire watch personnel did not implement section 6.5.4.2 of FP-001-014 to remove firefighting equipment from work areas when securing from a fire watch. The inspectors concluded

that this could affect the safety-related equipment located in the area because it would

delay the response to fires in the fire area by using undercharged fire extinguishers.

In addition, the inspectors noted that procedure EN-DC-127 stated, in part, that for hot work, fire watches shall ensure that the proper fire extinguishers are available and fully charged. The inspectors questioned if the licensee could confirm if the fire extinguishers

lost their charge after being left in the area over time or if personnel received the

extinguishers uncharged prior to establishing their fire watch. At the time the inspectors

proposed this question, the licensee could not confirm if the fire watch extinguishers were undercharged because of the improper storage or if personnel was issued degraded extinguishers. Due to the inspectors' questioning, the licensee initiated

another condition report CR-WF3-2013-03523 and determined that no controls existed

to assure fire extinguishers were in acceptable condition prior to assigning them to fire

watches or that fire extinguishers were returned to their proper storage location. The

inspectors concluded that given the lack of controls over the fire watch extinguishers, the licensee did not ensure supervisory and management oversight of fire watches. As a result, the licensee established measures for tracking extinguishers prior to and after

being assigned to fire watches. Additionally, the licensee planned to conduct training for

all departments with fire watch responsibilities on procedural requirements.

Analysis. The failure to implement a fire protection program procedure was a performance deficiency. The inspectors determined that this deficiency was reasonably

within the licensee's ability to foresee and correct. The performance deficiency was more than minor because it was associated with the protection against external factors

(i.e., fire) attribute of the Mitigating Systems Cornerstone and adversely affected the

cornerstone objective of ensuring the availability, reliability, and capability of systems

- 9 - Enclosure 2

that respond to initiating events to prevent undesirable consequences. Specifically, the failure to remove undercharged fire extinguishers from work areas could hinder

responses to fires in the area. The inspectors used NRC Inspection Manual Chapter 0609, Attachment 4, "Initial Characterization of Findings," to evaluate this issue. The initial screening directed the inspectors to use Appendix F, "Fire Protection

Significance Determination Process," to determine the significance of the finding. The

inspectors determined that the finding had a low degradation rating because it reflected

a fire protection program element whose performance and reliability would be minimally

impacted. Specifically, in accordance with Appendix F, Attachment 2, in all cases identified, there were fully charged portable fire extinguishers of the proper type nearby. Therefore, the finding was of very low safety significance (Green). The inspectors

concluded that the finding reflected current licensee performance and involved a cross-

cutting aspect in the work practices component of human performance area in that the

licensee did not ensure supervisory and management oversight of work activities, including contractors, such that nuclear safety is supported H.4(c).

Enforcement. Waterford's Facility Operating License Number NPF-38, License Condition 2.C.9, requires, in part, that the licensee shall implement and maintain in effect

all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility. Final Safety Analysis Report, Section 9.5.1.6.3, specifies Procedure UNT-005-013, "Fire Protection Program," which describes responsibilities,

controls, and implementing requirements for the Waterford 3 Fire Protection Program. Procedure UNT-005-013, Section 5.9.2 specifies that individual fire watch activities shall

be performed in accordance with Procedure FP-001-014, "Duties of A Fire Watch."

Procedure FP-001-014, Section 6.5.4.2, states, in part, that to deactivate a fire watch post, the fire watch shall return all equipment to their proper storage location.

Contrary to the above, as of July 2013, the licensee failed to comply with License

Condition 2.C.9 to implement and maintain in effect all provisions of the approved fire protection program as described in the final safety analysis report for the facility and as

approved in the Safety Evaluation Report. Specifically, fire watch personnel failed to return fire extinguishers assigned to fire watches to their proper storage location when

the fire watch personnel deactivated their fire watch posts. The licensee entered this

condition into their corrective action program as Condition Reports CR-WF3-2013-03398

and CR-WF3-2013-03523 for resolution. The immediate corrective action taken to

restore compliance was to remove and store fire watch extinguishers to their proper storage location. The planned corrective actions include establishing a tool to track the return of all equipment once personnel deactivate a fire watch post.

Because this violation was of very low safety significance and the licensee entered the

issue into their corrective action program, this violation was treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy: (NCV 05000382/2013004-02, "Failure to Implement Fire Protection Program Procedure

Requirements When Securing from a Fire Watch."

- 10 - Enclosure 2

1R06 Flood Protection Measures (71111.06) a. Inspection Scope

The inspectors reviewed the final safety analysis report, the flooding analysis, and plant procedures to assess susceptibilities involving internal flooding; reviewed the corrective

action program to determine if licensee personnel identified and corrected flooding

problems; inspected underground bunkers/manholes to verify the adequacy of sump

pumps, level alarm circuits, cable splices subject to submergence, and drainage for bunkers/manholes; and verified that operator actions for coping with flooding can reasonably achieve the desired outcomes. The inspectors also inspected the areas

listed below to verify the adequacy of equipment seals located below the flood line, floor

and wall penetration seals, watertight door seals, common drain lines and sumps, sump

pumps, level alarms, and control circuits, and temporary or removable flood barriers. Specific documents reviewed during this inspection are listed in the attachment.

• On September 16, 2013, heater drain pump B motor feeder cable

• On September 18, 2013, safeguards pump room B

These activities constitute completion of one flood protection measure inspection sample

and one bunker/manhole sample, as defined in Inspection Procedure 71111.06-05.

b. Findings

No findings were identified.

1R07 Heat Sink Performance (71111.07) a. Inspection Scope

On August 14, 2013, the inspectors reviewed licensee programs, verified performance against industry standards, and reviewed critical operating parameters and maintenance records for the essential chillers B and A/B. The inspectors verified that performance

tests were satisfactorily conducted for heat exchangers/heat sinks and reviewed for

problems or errors; the licensee utilized the periodic maintenance method outlined in EPRI Report NP 7552, "Heat Exchanger Performance Monitoring Guidelines"; the licensee properly utilized bio-fouling controls; the licensee's heat exchanger inspections adequately assessed the state of cleanliness of their tubes; and the heat exchanger was

correctly categorized under 10 CFR 50.65, "Requirements for Monitoring the

Effectiveness of Maintenance at Nuclear Power Plants." Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of two heat sink inspection sample, as defined in Inspection Procedure 71111.07-05.

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b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance (71111.11)

.1 Quarterly Review of Licensed Operator Requalification Program

a. Inspection Scope

On July 22, 2013, the inspectors observed a crew of licensed operators in the plant's simulator during training. The inspectors assessed the following areas:

• Licensed operator performance

• The ability of the licensee to administer the evaluations

• The modeling and performance of the control room simulator

• The quality of post-scenario critiques

• Follow-up actions taken by the licensee for identified discrepancies

These activities constitute completion of one quarterly licensed operator requalification

program sample, as defined in Inspection Procedure 71111.11. b. Findings

No findings were identified. .2 Quarterly Observation of Licensed Operator Performance

a. Inspection Scope

On September 18, 2013, the inspectors observed the performance of on-shift licensed operators in the plant's main control room. At the time of the observations, the plant was

in a period of heightened activity

due to reactivity management maneuvers. The inspectors observed the operators' performance of the following activities:

• the pre-job brief

• start-up activities

• reactivity control

In addition, the inspectors assessed the operators' adherence to plant procedures, including conduct of operations procedure and other operations department policies.

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These activities constitute completion of one quarterly licensed-operator performance

sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified. .3 Licensed Operator Requalification Biennial Inspection (71111.11B)

The licensed operator requalification program involves two training cycles that are conducted over a 2-year period. In the first cycle, the annual cycle, the operators are

administered an operating test consisting of job performance measures and simulator scenarios. In the second part of the training cycle, the biennial cycle, operators are administered an operating test and a co

mprehensive written examination.

a. Inspection Scope

To assess the performance effectiveness of the licensed operator requalification

program, the inspectors interviewed training staff, reviewed both the operating tests and written examinations, and observed ongoing operating test activities.

The inspectors reviewed operator performance on the written exams and operating

tests. These reviews included observations of portions of the operating tests by the

inspectors, as well as observing exam security measures taken during written exam administration. The operating tests obser

ved included five job performance measures and two scenarios that were used in the current biennial requalification cycle,

administered to multiple operators. These observations allowed the inspectors to

assess the licensee's effectiveness in conducting the operating test to ensure operator

mastery of the training program content. The inspectors also reviewed medical records

of 8 licensed operators for conformance to license conditions and the licensee's system for tracking qualifications and records of license reactivation.

The results of these examinations were reviewed to determine the effectiveness of the

licensee's appraisal of operator performance and to determine if feedback of

performance analyses into the requalification training program was being accomplished. The inspectors interviewed members of the training department and reviewed corrective actions related to operator errors to assess the responsiveness of the licensed operator

requalification program to incorporate the lessons learned from both plant and industry

events. Examination results were also assessed to determine if they were consistent

with the guidance contained in NUREG 1021, "Operator Licensing Examination Standards for Power Reactors", Revision 9, Supplement 1, and NRC Manual

Chapter 0609, Appendix I, "Operator Requalification Human Performance Significance Determination Process."

In addition to the above, the inspectors reviewed examination security measures, simulator fidelity, existing logs of simulator deficiencies, and Problem Identification and

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Resolution records related to training. The inspectors conducted a detailed review for quality of five full weeks of operating tests and one full written exam.

On August 8, 2013, the licensee informed the lead inspector of the results of the written examinations and operating tests for the Licensed Operator Requalification Program. The inspectors compared the written and operating test results to the Appendix I,

"Licensed Operator Requalification Significance Determination Process," values and

determined that there were no findings based on these results and because the

individuals that failed the applicable portions of their exams and/or operating tests were remediated, retested, and passed their retake exams prior to returning to shift.

The inspectors completed one inspection sample of the biennial licensed operator

requalification program.

b. Findings

One licensee-identified Severity Level IV NCV was evaluated during this inspection. It is documented in section 4OA7 of this report.

1R12 Maintenance Effectiveness (71111.12) a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk significant systems:

• On September 2, 2013, essential chiller B

• On September 10, 2013, control room air handling unit train A inlet damper (HCV-103A)

The inspectors reviewed events such as where ineffective equipment maintenance has

resulted in valid or invalid automatic actuations of engineered safeguards systems and

independently verified the licensee's actions to address system performance or condition problems in terms of the following:

• Implementing appropriate work practices

• Identifying and addressing common cause failures

• Scoping of systems in accordance with 10 CFR 50.65(b)

• Characterizing system reliability issues for performance

• Charging unavailability for performance

• Trending key parameters for condition monitoring

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• Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or -(a)(2)

• Verifying appropriate performance criteria for structures, systems, and components classified as having an adequate demonstration of performance through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as

requiring the establishment of appropriate and adequate goals and corrective actions for systems classified as not having adequate performance, as described

in 10 CFR 50.65(a)(1)

The inspectors assessed performance issues with respect to the reliability, availability,

and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were appropriately handled by a screening and identification process and that those issues were entered into the corrective action program with the

appropriate significance characterization. Specific documents reviewed during this

inspection are listed in the attachment.

These activities constitute completion of two maintenance effectiveness samples, as defined in Inspection Procedure 71111.12-05.

b Findings

No findings were identified. 1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13) a. Inspection Scope

The inspectors reviewed licensee personnel's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were

performed prior to removing equipment for work:

• On July 31, 2013, scheduled replacement of reactor trip circuit breaker number 5

• On August 19, 2013, emergent maintenance on the EDG A2 compressor

component

• On August 21, 2013, scheduled maintenance on the component cooling water pump and auxiliary feedwater pump breaker with the EDG A2 and B1 air compressors out of service

• On September 3, 2013, scheduled maintenance on the switchgear ventilation system air handling unit AH-30A with EDG A1 air receiver out of service

The inspectors selected these activities based on potential risk significance relative to

the reactor safety cornerstones. As applicable for each activity, the inspectors verified

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that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When licensee personnel

performed emergent work, the inspectors verified that the licensee personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk

analyst or shift technical advisor, and verified plant conditions were consistent with the

risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk

analysis assumptions were valid and applicable requirements were met. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of four maintenance risk assessments and

emergent work control inspection samples, as defined in Inspection

Procedure 71111.13-05.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments (71111.15) a. Inspection Scope

The inspectors reviewed the following assessments:

• On August 5, 2013, pressurizer level control system

• On August 15, 2013, essential chiller A/B

• On August 20, 2013, main steam isolation valve number 2 steam leak

• On August 25, 2013, control room air handling unit A inlet damper (HCV-103A)

• On September 5, 2013, snubber pin (FWSR-60) missing

The inspectors selected these operability and functionality assessments based on the

risk significance of the associated components and systems along with other factors, such as engineering analysis and judgment, operating experience, and performance history. The inspectors evaluated the technical adequacy of the evaluations to ensure

technical specification operability was properly justified and to verify the subject

component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate

sections of the technical specifications and final safety analysis report to the licensee's evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors

determined whether the measures in place would function as intended and were

properly controlled. Additionally, the inspectors reviewed a sampling of corrective action

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documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Specific documents reviewed during this

inspection are listed in the attachment.

These activities constitute completion of five operability evaluations inspection samples,

as defined in Inspection Procedure 71111.15 - 05.

b. Findings

No findings were identified.

1R18 Plant Modifications (71111.18) .1 Temporary Modifications

a. Inspection Scope

To verify that the safety functions of important safety systems were not degraded, on August 28, 2013, the inspectors reviewed the temporary modification identified as

EC-45995, main steam isolation valve B to repair a bonnet vent plug.

The inspectors reviewed the temporary modification and the associated safety-

evaluation screening against the system design bases documentation, including the final

safety analysis report and the technical specifications, and verified that the modification

did not adversely affect the system operability/availability. The inspectors also verified that the installation and restoration were consistent with the modification documents and that configuration control was adequate. Additionally, the inspectors verified that the

temporary modification was identified on control room drawings, appropriate tags were

placed on the affected equipment, and licensee personnel evaluated the combined

effects on mitigating systems and the integrity of radiological barriers.

These activities constitute completion of one sample for temporary plant modifications, as defined in Inspection Procedure 71111.18-05.

b. Findings

No findings were identified.

.2 Permanent Modifications

a. Inspection Scope

On September 26, 2013, the inspectors reviewed key parameters associated with materials, replacement components, operations, flow paths, pressure boundary,

ventilation boundary, structural, process medium properties, licensing basis, and failure modes for the permanent modification identified as EC-46914, main feedwater isolation valve A nitrogen accumulator B tubing replacement.

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The inspectors verified that modification preparation, staging, and implementation did not impair emergency/abnormal operating procedure actions, key safety functions, or

operator response to loss of key safety functions; post modification testing will maintain the plant in a safe configuration during testing by verifying that unintended system interactions will not occur; systems, structures and components' performance characteristics still meet the design basis; the modification design assumptions were

appropriate; the modification test acceptance criteria will be met; and licensee personnel

identified and implemented appropriate corrective actions associated with permanent

plant modifications. Specific documents reviewed during this inspection are listed in the

attachment.

These activities constitute completion of one sample for permanent plant modifications,

as defined in Inspection Procedure 71111.18-05.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing (71111.19) a. Inspection Scope

The inspectors reviewed the following post-maintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional

capability:

• On July 29, 2013, emergency feedwater to steam generator 1 backup flow control valve (EFW-223A)

• On July 30, 2013, dry cooling tower B component cooling water bypass valve (CC-134B)

• On August 1, 2013, replaced reactor trip circuit breakers

• On August 6, 2013, corrective maintenance on the emergency generator A1 compressor pressure switch

• On September 24, 2013, replaced control room air handling unit A inlet damper (HCV-103A)

The inspectors selected these activities based upon the structure, system, or

component's ability to affect risk. The inspectors evaluated these activities for the

following (as applicable):

• The effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed

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• Acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate

The inspectors evaluated the activities against the technical specifications, the final safety analysis report, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the

equipment met the licensing basis and design requirements. In addition, the inspectors

reviewed corrective action documents associated with post-maintenance tests to

determine whether the licensee was identifying problems and entering them in the

corrective action program and that the problems were being corrected commensurate with their importance to safety. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five post-maintenance testing inspection

samples, as defined in Inspection Procedure 71111.19-05.

b. Findings

.1 Failure to Control Failed Equipment Removed from the Plant in Accordance with Procedure Requirements

Introduction. The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," because the licensee did not control and determine the extent of leaking safety-related bypass valve associated with the dry cooling tower B component cooling water solenoid valve

(CC-134B) after maintenance personnel removed the degraded equipment from service

as required by Section 5.10 of EN-MA-101.

Description. On October 31, 2012, the licensee conducted a post-maintenance leak test on the actuator for a safety-related air operate solenoid valve CC-134B. During the process of conducting the leak test, maintenance personnel identified air coming from

the exhaust vent port of a solenoid valve associated with the operation of CC-134B. The

licensee replaced the valve on November 1, 2012, and restored valve CC-134B to an

operable status. However, the licensee did not retain the original solenoid valve for testing to determine the cause or extent of the leakage. Without supporting information regarding the leak rate or cause, the licensee assumed that CC-134B and its air

accumulator were inoperable from October 20, 2011, the dates of the last satisfactory

leak test, until November 1, 2012, when maintenance personnel replaced the valve.

The licensee initiated a condition report and performed an apparent cause evaluation. The inspectors performed a review of the apparent cause evaluation, the event timeline,

work orders, and maintenance history of valve CC-134B. The licensee determined that

the valve leakage could have adversely affected the backup air accumulator inventory.

However, the licensee did not retain the leaking valve to perform any testing. As a

result, the licensee could not characterize and determine the cause of the leakage for the safety-related valve. The inspectors determined that the licensee did not accomplish

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activities in accordance with maintenance procedure EN-MA-101, "Fundamentals of Maintenance". Section 5.10, Control of Failed Plant Equipment, of EN-MA-101,

requires, in part, that the licensee control failed equipment removed from the plant to determine necessary testing to establish the cause of the failure.

As a part of the review of the apparent cause evaluation, the inspectors also noted that

an incomplete work order contributed to discarding the solenoid valve prior to testing.

The licensee combined a corrective maintenance with a preventative maintenance task

into the existing work order for CC-134B during the replacement of the solenoid valve. This led to an error-trap, as explicit instructions for retaining failed parts were not a part

of the preventative maintenance tasks. The immediate corrective actions taken to restore compliance included the installation of a new valve and debriefing personnel

about controlling equipment removed from service when combining preventative and

corrective maintenance tasks in one work order. The licensee entered this condition into their corrective action program as Condition Reports CR-WF3-2012-05991 and CR-WF3-2012-06288. However, inspectors questioned the effectiveness of the original

corrective action by the licensee to have personnel briefed on the effects of combining

preventative and corrective maintenance tasks in a work order. The inspectors felt that

a briefing did not provide an adequate barrier to prevent this from happening again. As a result, the licensee initiated CR-HQN-2013-00709 and CR-WF3-2013-04047 to determine additional corrective actions to address the error trap. The inspectors

determined that the licensee did not appropriately coordinate work activities by

incorporating actions to address the impact of changes to work scope on the plant and

human performance.

Analysis. The failure to control failed equipment removed from the plant to determine the cause was a performance deficiency. The inspectors determined that this deficiency

was reasonably within the licensee's ability to foresee and correct. The performance

deficiency was more than minor because it was associated with the equipment

performance attribute of the Mitigating System Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the

degraded condition challenged the safety function of valve CC-134B to limit the loss of component cooling water through damaged portions of the dry cooling towers following a

tornado-generated missile strike.

The inspectors used NRC Inspection Manual Chapter 0609, Attachment 4, "Initial Characterization of Findings," and Appendix A, "The Significance Determination Process

(SDP) for Findings At-Power," to evaluate this issue. The inspectors determined that the

finding required a detailed analysis because it was potentially risk significant for an

external event (tornado) based on using

Exhibit 4, "External Events Screening Questions". Therefore, the senior reactor analyst performed the following bounding

detailed risk evaluation:

Tornado Statistics: About one out of every three tornadoes (29 percent) is classified as "strong." Strong tornadoes have an average path length of 9 miles and a path width of 200 yards (approximately 1 square mile of land affected). Although very rare

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(about 2 percent are violent), violent tornadoes can last for hours. Average path lengths and widths are 26 miles and 425 yards, respectively.

Since the strong tornadoes can affect approximately 1 square mile, weaker tornadoes, on average, would affect significantly less than 1 square mile. Most tornadoes are of the weaker variety. Violent tornadoes can affect approximately 6 to 7 square miles (on average), but are relatively rare. Therefore, the analyst assumed that the average tornado would affect 1 square mile of land.

The average number of tornadoes in Louisiana per year was 27.

The total area for the state of Louisiana was 51,840 square miles.

Plant Area: For this risk evaluation, the analyst assumed that the Waterford-3 nuclear island and switchyard occupied one square mile of land. This was conservative, in that this equipment occupies less than one square mile.

The analyst conservatively assumed that a tornado within a 1 square mile area would

cause a loss of offsite power and cause physical damage to the train B dry cooling tower train. This in turn would cause the B component cooling water train to fail. Because the dry cooling towers are at least partially protected from missiles by the surrounding

building, this is a very conservative assumption. Not all tornadoes will result in

damaging this equipment.

Tornado Frequency: The frequency of a tornado hitting the Waterford-3 nuclear island

and switchyard was therefore:

= 27 tornadoes/year / 51840 sq miles = 5.2E-4/yr.

Calculations:

The analyst used the NRC's Waterford-3 Standardized Plant Analysis Risk (SPAR) model, Revision 8.16, with a truncation limit of E-11, to evaluate this finding. The analyst assumed a full year exposure period.

The analyst calculated the incremental conditional core damage probability (ICCDP)

considering a loss of offsite power (LOOP) coincident with the failure of the train B

component cooling water system. To account for an earlier finding at Waterford-3, the analyst set the basic event for alternate room cooling to 1.0. The analyst used this adjustment in both the nominal case (no performance deficiency) and the current case

(with the performance deficiency). In addition, for both cases the analyst set the basic

event for a LOOP to 1.0. The analyst solved only the LOOP sequences. The nominal

case CCDP was 2.15E-4.

For the current case calculation, the analyst additionally set the basic events for the

B and AB (swing) motor driven component cooling water pumps to 1.0. The resultant

CCDP was 5.9E-3.

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The initial ICCDP was therefore the difference between the nominal and current case CCDPs = 5.7E-3.

The analyst considered recovery of the instrument air system. As noted in Licensee Event Report 2012-007, dated December 31, 2012, operators could recover an

instrument air compressor and power the unit from an operable running emergency

diesel generator. The resident inspectors had reviewed these procedures and estimated

that it may take 2.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> to perform this action. The analyst assumed a non-recovery

probability of 0.1 for this action. The nominal non-recovery probability as specified in NUREG/CR-6883, "The SPAR-H Human Reliability Analysis Method," was 1.1E-2. Therefore, 0.1 was conservative when compared to 1.1E-2. The resultant ICCDP,

considering recovery, was 5.7E-4.

The change to the core damage frequency (delta CDF) was the tornado frequency multiplied by the ICCDP = 5.2E-4/yr * 5.7E-4 = 2.9E-7/yr.

The dominant core damage sequences included tornado induced losses of offsite power,

failure of the dry cooling tower pressure boundary, failure to isolate the damaged dry

cooling tower, and failure to recovery instrument air. The redundant train A component cooling water system combined with the tornado frequency helped to reduce the risk

exposure.

Large Early Release Frequency (LERF): To address the contribution to conditional large early release frequency, the analyst used NRC Inspection Manual Chapter 0609,

Appendix H, "Containment Integrity Significance Determination Process," dated May 6, 2004. The finding was not significant to LERF because it did not directly affect the steam generator tube rupture or the intersystem loss of coolant accident sequences.

The inspectors concluded that the finding reflected current licensee performance and

involved a cross-cutting aspect in the work control component of the human performance area in that the licensee did not appropriately coordinate work activities by incorporating actions to address the impact changes to work scope or activity on plant

and human performance H.3(b).

Enforcement. Title 10 of CFR, Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions,

procedures, or drawings. Specifically, Section 5.10, "Control of Failed Plant Equipment"

of maintenance procedure EN-MA-101, "Fundamentals of Maintenance," requires, in

part, that it be determined "whether the component should be tested to establish cause of failure before it is scrapped."

Contrary to the above, on November 1, 2012, the licensee did not accomplish activities

in accordance with maintenance procedure requirements. Specifically, the licensee did

not control failed plant equipment to determine whether the component should be tested

to establish the cause of failure before it was scrapped. The licensee discarded the

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solenoid valve prior to performing any analysis to determine the cause or severity of the

valve's failure. Consequently, the licensee assumed that the valve was unable to fulfill its safety function if called upon after a tornado-generated missile strike on dry cooling tower train B. The licensee entered this condition into their corrective action program as Condition Reports CR-WF3-2012-05991, CR-WF3-2012-06288, and

CR-WF3-2013-04047 for resolution. Although corrective actions are on-going, the

immediate corrective action taken to restore compliance included replacing the leaking

valve and to brief personnel about the potential problems regarding combining

preventative and corrective maintenance tasks in one work order.

Because this violation was of very low safety significance and the licensee entered the

issue into their corrective action program, this violation was treated as a non-cited

violation, consistent with Section 2.3.2.a of the Enforcement Policy:

NCV 05000382/2013004-03, "Failure to Accomplish Activities Affecting Quality on a Degraded Safety-Related Solenoid Valve In Accordance With Procedure Requirements."

1R22 Surveillance Testing (71111.22) a. Inspection Scope

The inspectors selected risk-significant surveillance activities based on risk information

and reviewed the final safety analysis report, procedure requirements, and technical specifications to ensure that the surveillance activities listed below demonstrated that the systems, structures, and/or components tested were capable of performing their

intended safety functions. The inspectors either witnessed or reviewed test data to

verify that the significant surveillance test attributes were adequate to address the

following:

• Preconditioning

• Evaluation of testing impact on the plant

• Acceptance criteria

• Test equipment

• Procedures

• Jumper/lifted lead controls

• Test data

• Testing frequency and method demonstrated technical specification operability

• Test equipment removal

• Restoration of plant systems

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• Fulfillment of ASME Code requirements

• Updating of performance indicator data

• Engineering evaluations, root causes, and bases for returning tested systems, structures, and components not meeting the test acceptance criteria were correct

• Reference setting data

• Annunciators and alarms setpoints

The inspectors also verified that licensee personnel identified and implemented any needed corrective actions associated with the surveillance testing.

• On August 6, 2013, surveillance test on containment vacuum relief train A control valve CVR-201A (in-service test)

• On August 19, 2013, surveillance test on auxiliary component cooling water pump B (in-service test)

• On August 22, 2013, surveillance test on containment cooling fans

• On August 28, 2013, surveillance test on low pressure safety injection pump A

• On September 9, 2013, surveillance test on component cooling water pump A/B

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five surveillance testing inspection samples, as

defined in Inspection Procedure 71111.22-05.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness 1EP6 Drill Evaluation (71114.06) Training Observations

a. Inspection Scope

The inspectors observed a simulator training evolution for licensed operators on July 22, 2013, this required emergency plan implementation by a licensee operations crew. This evolution was planned to be evaluated and included in performance indicator

- 24 - Enclosure 2

data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also

attended the post evolution critique for the scenario. The focus of the inspectors' activities was to note any weaknesses and deficiencies in the crew's performance and ensure that the licensee evaluators noted the same issues and entered them into the

corrective action program. As part of the inspection, the inspectors reviewed the

scenario package and other documents listed in the attachment.

These activities constitute completion of one training observation sample, as defined in Inspection Procedure 71114.06-05.

b. Findings

No findings were identified.

2. RADIATION SAFETY Cornerstone: Public Radiation Safety and Occupational Radiation Safety 2RS01 Radiological Hazard Assessment and Exposure Controls (71124.01) a. Inspection Scope

This area was inspected to: (1) review and assess licensee's performance in assessing

the radiological hazards in the workplace associated with licensed activities and the implementation of appropriate radiation monitoring and exposure control measures for both individual and collective exposures, (2) verify the licensee is properly identifying

and reporting Occupational Radiation Safety Cornerstone performance indicators, and

(3) identify those performance deficiencies that were reportable as a performance

indicator and which may have represented a substantial potential for overexposure of the worker. The inspectors used the requirements in 10 CFR Part 20, the technical specifications, and the licensee's procedures required by technical specifications as criteria for determining compliance. During the inspection, the inspectors interviewed the radiation protection manager, radiation protection supervisors, and radiation workers. The

inspectors performed walkdowns of various portions of the plant, performed independent radiation dose rate measurements and reviewed the following items:

• Performance indicator events and associated documentation reported by the licensee in the Occupational Radiation Safety Cornerstone

• The hazard assessment program, including a review of the licensee's evaluations of changes in plant operations and radiological surveys to detect dose rates, airborne radioactivity, and surface contamination levels

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• Instructions and notices to workers, including labeling or marking containers of radioactive material, radiation work permits, actions for electronic dosimeter alarms, and changes to radiological conditions

• Programs and processes for control of sealed sources and release of potentially contaminated material from the radiologically controlled area, including survey performance, instrument sensitivity, release criteria, procedural guidance, and sealed source accountability

• Radiological hazards control and work coverage, including the adequacy of surveys, radiation protection job coverage, and contamination controls; the use of electronic dosimeters in high noise areas; dosimetry placement; airborne

radioactivity monitoring; controls for highly activated or contaminated materials

(non-fuel) stored within spent fuel and other storage pools; and posting and physical controls for high radiation areas and very high radiation areas

• Radiation worker and radiation protection technician performance with respect to radiation protection work requirements

• Emergency contingencies in place during the steam generator replacement activities

• Project staffing and training plans for t

he previous steam generator replacement activities

• Audits, self-assessments, and corrective action documents related to radiological hazard assessment and exposure controls

since the last inspection

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in

Inspection Procedure 71124.01-05.

b. Findings

No findings were identified. 2RS02 Occupational ALARA Planning and Controls (71124.02) a. Inspection Scope

This area was inspected to assess performance with respect to maintaining occupational

individual and collective radiation exposures as low as is reasonably achievable (ALARA). The inspectors used the requirements in 10 CFR Part 20, the technical specifications, and the licensee's procedures required by technical specifications as criteria for determining compliance. During the inspection, the inspectors interviewed licensee personnel and reviewed the following items:

- 26 - Enclosure 2

• Site-specific ALARA procedures and collective exposure history, including the current 3-year rolling average, site-specific trends in collective exposures, and source-term measurements

• ALARA work activity evaluations/post job reviews, exposure estimates, and exposure mitigation requirements

• The methodology for estimating work activity exposures, the intended dose outcome, the accuracy of dose rate and man-hour estimates, and intended versus actual work activity doses and the reasons for any inconsistencies

• Records detailing the historical trends and current status of tracked plant source terms and contingency plans for expected changes in the source term due to changes in plant fuel performance issues or changes in plant primary chemistry

• Radiation worker and radiation protection technician performance during work activities in radiation areas, airborne radioactivity areas, or high radiation areas

• Audits, self-assessments, and corrective action documents related to ALARA planning and controls since the last inspection

Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.02-05. b. Findings

No findings were identified. 2RS05 Radiation Monitoring Instrumentation (71124.05) a. Inspection Scope

This area was inspected to verify the licensee is assuring the accuracy and operability of

radiation monitoring instruments that are used to: (1) monitor areas, materials, and

workers to ensure a radiologically safe work environment; and (2) detect and quantify radioactive process streams and effluent releases. The inspectors used the requirements in 10 CFR Part 20, the technical specifications, and the licensee's

procedures required by technical specifications as criteria for determining compliance.

During the inspection, the inspectors interviewed licensee personnel, performed walkdowns of various portions of the plant, and reviewed the following items:

• Selected plant configurations and alignments of process, postaccident, and effluent monitors with descriptions in the Final Safety Analysis Report and the offsite dose calculation manual

- 27 - Enclosure 2

• Select instrumentation, including effluent monitoring instrument, portable survey instruments, area radiation monitors, continuous air monitors, personnel

contamination monitors, portal monitors, and small article monitors to examine their configurations and source checks

• Calibration and testing of process and effluent monitors, laboratory instrumentation, whole body counters, postaccident monitoring instrumentation, portal monitors, personnel contaminati

on monitors, small article monitors, portable survey instruments, area radiation monitors, electronic dosimetry, air

samplers, continuous air monitors

• Audits, self-assessments, and corrective action documents related to radiation

monitoring instrumentation

since the last inspection

Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.05-05.

b. Findings

No findings were identified.

2RS06 Radioactive Gaseous and Liquid Effluent Treatment (71124.06) a. Inspection Scope

This area was inspected to: (1) ensure the gaseous and liquid effluent processing

systems are maintained so radiological discharges are properly mitigated, monitored, and evaluated with respect to public exposure; (2) ensure abnormal radioactive gaseous

or liquid discharges and conditions, when effluent radiation monitors are out-of-service, are controlled in accordance with the applicable regulatory requirements and licensee procedures; (3) verify the licensee's quality control program ensures the radioactive

effluent sampling and analysis requirements are satisfied so discharges of radioactive

materials are adequately quantified and evaluated; and (4) verify the adequacy of public

dose projections resulting from radioactive effluent discharges. The inspectors used the requirements in 10 CFR Part 20; 10 CFR Part 50, Appendices A and I; 40 CFR Part 190; the Offsite Dose Calculation Manual, and licensee procedures required by the Technical

Specifications as criteria for determining compliance. The inspectors interviewed licensee personnel and reviewed and/or observed the following items:

• Radiological effluent release reports since the previous inspection and reports related to the effluent program issued since the previous inspection, if any

• Effluent program implementing procedures, including sampling, monitor setpoint determinations and dose calculations

- 28 - Enclosure 2

• Equipment configuration and flow paths of selected gaseous and liquid discharge system components, filtered ventilation system material condition, and significant changes to their effluent release points, if any, and associated 10 CFR 50.59

reviews * Selected portions of the routine processing and discharge of radioactive gaseous and liquid effluents (including sample collection and analysis)

• Controls used to ensure representative sampling and appropriate compensatory

sampling

• Results of the inter-laboratory comparison program

• Effluent stack flow rates

• Surveillance test results of technical specification-required ventilation effluent discharge systems since the previous inspection

• Significant changes in reported dose values, if any

• A selection of radioactive liquid and gaseous waste discharge permits

• Part 61 analyses and methods used to determine which isotopes are included in the source term

• Offsite dose calculation manual changes, if any

• Meteorological dispersion and deposition factors

• Latest land use census

• Records of abnormal gaseous or liquid tank discharges, if any

• Groundwater monitoring results

• Changes to the licensee's written program for indentifying and controlling contaminated spills/leaks to groundwater, if any

• Identified leakage or spill events and entries made into 10 CFR 50.75 (g) records, if any, and associated evaluations of the extent of the contamination and the radiological source term

• Offsite notifications

, and reports of events associated with spills, leaks, or

groundwater monitoring results, if any

- 29 - Enclosure 2

• Audits, self-assessments, reports, and corrective action documents related to radioactive gaseous and liquid effluent treatment

since the last inspection

Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of the one required sample, as defined in Inspection Procedure 71124.06-05. b. Findings

No findings were identified. 2RS07 Radiological Environmental Monitoring Program (71124.07) a. Inspection Scope

This area was inspected to: (1) ensure that the radiological environmental monitoring program verifies the impact of radioactive effluent releases to the environment and sufficiently validates the integrity of the radioactive gaseous and liquid effluent release

program; (2) verify that the radiological environmental monitoring program is implemented consistent with the licensee's technical specifications and/or offsite dose

calculation manual, and to validate that the radioactive effluent release program meets the design objective contained in Appendix I to 10 CFR Part 50; and (3) ensure that the radiological environmental monitoring pr

ogram monitors non-effluent exposure pathways, is based on sound principles and assumptions, and validates that doses to

members of the public are within the dose limits of 10 CFR Part 20 and 40 CFR Part 190, as applicable. The inspectors reviewed and/or observed the following

items: * Annual environmental monitoring reports and offsite dose calculation manual

• Selected air sampling and thermoluminescence dosimeter monitoring stations

• Collection and preparation of environmental samples

Operability, calibration, and maintenance of meteorological instruments

• Selected events documented in the annual environmental monitoring report which involved a missed sample, inoperable sampler, lost thermo luminescence dosimeter, or anomalous measurement

• Selected structures, systems, or components that may contain licensed material and has a credible mechanism for licensed material to reach ground water

• Records required by 10 CFR 50.75(g)

- 30 - Enclosure 2

• Significant changes made by the licensee to the offsite dose calculation manual as the result of changes to the land census or sampler station modifications since the last inspection

• Calibration and maintenance records for selected air samplers and environmental sample radiation measurement instrumentation

• Inter-laboratory comparison program results

• Audits, self-assessments, reports, and co

rrective action documents related to the radiological environmental monitoring program since the last inspection

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in

Inspection Procedure 71124.07-05.

b. Findings

No findings were identified.

2RS08 Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage, and Transportation (71124.08) a. Inspection Scope

This area was inspected to verify the effectiveness of the licensee's programs for processing, handling, storage, and transportation of radioactive material. The inspectors used the requirements of 10 CFR Parts 20, 61, and 71 and Department of

Transportation regulations contained in 49 CFR Parts 171-180 for determining

compliance. The inspectors interviewed licensee personnel and reviewed the following

items: * The solid radioactive waste system description, process control program, and the scope of the licensee's audit program

• Control of radioactive waste storage areas including container labeling/marking and monitoring containers for deformation or signs of waste decomposition

• Changes to the liquid and solid waste processing system configuration including a review of waste processing equipment that is not operational or abandoned in

place * Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides

- 31 - Enclosure 2

• Processes for waste classification including use of scaling factors and 10 CFR Part 61 analysis

• Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and preparation of the disposal manifest

• Audits, self-assessments, reports, and corrective action reports radioactive solid waste processing, and radioactive material handling, storage, and transportation

performed since the last inspection

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.08-05. b. Findings

No findings were identified.

4. OTHER ACTIVITIES Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and

Security Protection 4OA1 Performance Indicator Verification (71151) .1 Data Submission Issue

a. Inspection Scope

The inspectors performed a review of the performance indicator data submitted by the licensee for the second Quarter 2013 performance indicators for any obvious

inconsistencies prior to its public release in accordance with Inspection Manual Chapter 0608, "Performance Indicator Program."

This review was performed as part of the inspectors' normal plant status activities and,

as such, did not constitute a separate inspection sample.

b. Findings

No findings were identified.

- 32 - Enclosure 2

.2 Safety System Functional Failures (MS05)

a. Inspection Scope

The inspectors sampled licensee submittals for the safety system functional failures performance indicator for the period from the fourth quarter 2012 through the

second quarter 2013. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in

NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, and NUREG-1022, "Event Reporting Guidelines 10 CFR 50.72 and 50.73." The inspectors reviewed the licensee's operator

narrative logs, operability assessments, maintenance rule records, maintenance work orders, issue reports, event reports, and

NRC integrated inspection reports for the period of October 2012

through September

2013 to validate the accuracy of the submittals. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none

were identified. Specific documents reviewed are described in the attachment to this report.

These activities constitute completion of one safety system functional failures sample, as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.3 Mitigating Systems Performance Index - Residual Heat Removal System (MS09)

a. Inspection Scope

The inspectors sampled licensee submittals for the mitigating systems performance index - residual heat removal system performance indicator for the period from the third

quarter 2012 through the third quarter 2013. To determine the accuracy of the

performance indicator data reported during those periods, the inspectors used definitions

and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6. The inspectors reviewed the licensee's operator narrative logs, issue reports, mitigating

systems performance index derivation reports, event reports, and NRC integrated inspection reports for the period of July 2012

through September 2013 to validate the accuracy of the submittals. The inspectors reviewed the

mitigating systems performance index component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also

reviewed the licensee's issue report database to determine if any problems had been

identified with the performance indicator data collected or transmitted for this indicator

and none were identified. Specific documents reviewed are described in the attachment to this report.

These activities constitute completion of one mitigating systems performance index -

residual heat removal system sample, as defined in Inspection Procedure 71151-05.

- 33 - Enclosure 2

b. Findings

No findings were identified.

.4 Mitigating Systems Performance Index - Cooling Water Systems (MS10)

a. Inspection Scope

The inspectors sampled licensee submittals for the mitigating systems performance

index - cooling water systems performance indicator for the period from the third

quarter 2012 through the third quarter 2013. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance

Indicator Guideline," Revision 6. The inspectors reviewed the licensee's operator

narrative logs, issue reports, mitigating

systems performance index derivation reports, event reports, and NRC integrated inspection reports for the period of July 2012

through September 2013 to validate the accuracy of the submittals. The inspectors reviewed the mitigating systems performance index component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that

the change was in accordance with applicable NEI guidance. The inspectors also

reviewed the licensee's issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment

to this report.

These activities constitute completion of one mitigating systems performance index -

cooling water system sample, as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.5 Occupational Exposure Control Effectiveness (OR01)

a. Inspection Scope

Cornerstone: Occupational Radiation Safety

The inspectors reviewed performance indicator data for the fourth quarter 2012 through the third quarter 2013

. The objective of the inspection was to determine the accuracy and completeness of the performance indicator data reported during these periods. The inspectors used the definitions and clarifying notes contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, as criteria for determining whether the licensee was in compliance.

- 34 - Enclosure 2

The inspectors reviewed corrective action program records associated with high radiation area (greater than 1 rem/hr) and very high radiation area nonconformances.

The inspectors reviewed radiological, controlled area exit transactions greater than 100 mrem. The inspectors also conducted walkdowns of high radiation areas (greater than 1 rem/hr) and very high radiation area entrances to determine the adequacy of the controls of these areas. These activities constitute completion of the occupational exposure control effectiveness sample as defined in Inspection Procedure 71151-05. b. Findings

No findings were identified. .6 Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (PR01)

a. Inspection Scope

Cornerstone: Public Radiation Safety

The inspectors reviewed performance indicator data for fourth quarter 2012 through the third quarter 2013. The objective of the inspection was to determine the accuracy and completeness of the performance indicator data reported during these periods. The inspectors used the definitions and clarifying notes contained in NEI Document 99-02,

"Regulatory Assessment Performance Indicator Guideline," Revision 6, as criteria for determining whether the licensee was in compliance. The inspectors reviewed the licensee's corrective action program records and selected individual annual or special reports to identify potential occurrences such as

unmonitored, uncontrolled, or improperly calculated effluent releases that may have

impacted offsite dose. These activities constitute completion of the radiological effluent technical specifications/offsite dose calculation manual radiological effluent occurrences sample as defined in Inspection Procedure 71151-05. b. Findings

No findings were identified. 4OA2 Problem Identification and Resolution (71152) .1 Routine Review of Identification and Resolution of Problems

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities

- 35 - Enclosure 2

and plant status reviews to verify that they were being entered into the licensee's corrective action program at an appropriate threshold, that adequate attention was being

given to timely corrective actions, and that adverse trends were identified and addressed. The inspectors reviewed attributes that included the complete and accurate identification of the problem; the timely correction, commensurate with the safety

significance; the evaluation and disposition of performance issues, generic implications,

common causes, contributing factors, root causes, extent of condition reviews, and

previous occurrences reviews; and the classification, prioritization, focus, and timeliness

of corrective actions. Minor issues entered into the licensee's corrective action program because of the inspectors' observations are included in the attached list of documents reviewed.

These routine reviews for the identification and resolution of problems did not constitute

any additional inspection samples. Instead, by procedure, they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.

c. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of

items entered into the licensee's corrective action program. The inspectors

accomplished this through review of the station's daily corrective action documents.

The inspectors performed these daily reviews as part of their daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings were identified.

.3 In-depth Review of Operator Workarounds

a. Inspection Scope

On August 14, 2013, during a review of items entered in the licensee's corrective action program, the inspectors reviewed operator workarounds and burdens. The inspectors

considered the following during the review of the licensee's actions: (1) complete and accurate identification of problems in a timely manner; (2) evaluation and disposition of operability/reportability issues; (3) consideration of extent of condition, generic

implications, common cause, and previous occurrences; (4) classification and

prioritization of the resolution of the problem; (5) identification of root and contributing

- 36 - Enclosure 2

causes of the problem; (6) identification of corrective actions; and (7) completion of corrective actions in a timely manner.

These activities constitute completion of one in-depth problem identification and resolution sample as defined in Inspection Procedure 71152-05 b. Findings

No findings were identified.

4OA3 Follow-up of Events and Notices of Enforcement Discretion (71153)

.1 (Closed) Licensee Event Report 05000382/2012-007-00, Inoperability Of A Safety Related Valve Due To Backup Air Accumulator Leakage

On October 10, 2012, during refueling outage RFO-18, the licensee identified a dual

solenoid valve CC ISV0134B1/B2 associated with train B dry cooling tower component

cooling water bypass valve CC-134B was leaking air through the solenoid valve exhaust

vent port. Following replacement of the solenoid valve, the licensee discarded it without

determining the cause or rate of leakage. The licensee determined on November 1, 2012, that the solenoid valve leakage could have adversely affected the backup air accumulator relied on to allow valve CC-134B to fulfill its safety function in the event that

a tornado-generated missile damaged the train B dry cooling tower. The licensee

concluded that the valve may have been inoperable since the last accumulator leak test

because the rate of the leakage was unknown. As part of the review of this event, the inspectors identified a Green non-cited violation 05000382/2013004-03, "Failure to accomplish activities affecting quality on a degraded safety-related solenoid valve in

accordance with procedure requirements." The inspectors documented this violation of

NRC requirements in Section 1R19 of this repor

t. This licensee event report is closed.

4OA5 Other Activities .1 (Closed) Temporary Instruction 2515/185, "Follow-up on the Industry's Ground Water Protection Initiative"

a. Inspection Scope

The ground water protection program was inspected September 16-19, 2013, to

determine whether the licensee had implemented the program elements which were found to be incomplete when previously reviewed during NRC Inspection Report 05000382/2012003. Inspectors interviewed cognizant licensee personnel and performed walk-downs. b. Findings

The following element had been implement

ed since the previous review:

- 37 - Enclosure 2

• Element 1.4.a - Establish written procedures outlining the decision making process for remediation of leaks and spills or other instances of inadvertent releases. The following element had not been implemented since the previous review and is documented in the corrective action document listed with the element:

• Element 1.3.f - Establish a long-term program for preventative maintenance of ground water wells (CR-HQN-2013-00861). This element lacked an implementing procedure or process. Additionally, the appropriateness for

preventative maintenance in relation to the specific type of ground water wells

has yet to be determined. .2 (Closed) Unresolved Item 05000382/2009010-01, "Failures to Evaluate Adverse Conditions for Reportability to the NRC"

On October 19, 2009, the NRC completed a special inspection at the Waterford 3

initiated in response to a series of failures of safety-related Agastat timing relays. During

this inspection, the team identified two examples in which the licensee failed to adequately review a deviation observed in specific batches of relays to determine

whether the deviations were required to be reported to the NRC. The first of these examples involved a number of relays from the same manufacturing lot (date code 9948) that, after being installed in the plant, were determined to be unreliable, thus deviating

from procurement requirements. The second of these examples involved several relays

from a different manufacturing lot (date code 0835) that also did not conform to

specifications; however, the deviation of the date code 0835 relays was discovered during bench testing prior to installation. On November 5, 2009, the NRC issued inspection report 05000382/2009010, documenting an unresolved item pending a

determination of whether the licensee's failures to evaluate and report the deviations

constituted violations of one or more of the reporting requirements contained in

10 CFR Part 21, 10 CFR 50.72, and 10 CFR 50.73.

The NRC has determined that these deviations in basic components were not evaluated in accordance with 10 CFR 21.21(a)(1). Further, the NRC determined that had the

licensee evaluated the deviations, it would have concluded that the deviations

constituted defects as defined in 10 CFR 21.3. Where Part 21 applies, such defects are

required to be reported to the NRC in accordance with 10 CFR 21.21(d)(1).

The NRC is developing new guidance to clarify the reporting requirements of

10 CFR Part 21 including whether in-service failure of installed parts-those subject to the

reporting requirements in Part 50 (§§ 50.72 and 50.73)-are also subject to the evaluation

and reporting requirements of Part 21. See Task Interface Agreement (TIA) 2010-003

(ML11319A134). However, Part 21 evaluation and reporting criteria continue to apply to basic components that are not installed. Therefore, section 4OA5.2 below documents a violation of 10 CFR Part 21 for only the date code 0835 relays, in which the deviations

were discovered prior to installation of the components. No violation will be issued for

the licensee's failure to evaluate the installed relays in accordance with Part 21

requirements.

- 38 - Enclosure 2

.3 Failures to perform evaluations and make a report as required by 10 CFR Part 21

Introduction. The team identified a Severity Level IV violation of 10 CFR 21.21 that occurred when the licensee failed to complete an evaluation of a deviation in a basic component within 60 days of discovery.

Description. On October 14, 2008, while replacing a failed Agastat E7024PB relay, maintenance personnel noted that the replacement relay obtained from the warehouse

had a loose terminal point. Two more relays were obtained from the warehouse; one of

these also had a bad terminal point. On October 27, 2008, the licensee quarantined the remaining four relays in stock. Two of these were identified to have similarly deficient terminal points. All four affected relays shared a date code of 0835. The licensee

identified these relays as defective. On November 4, 2008, the licensee issued a

corrective action request to Tyco Electronics requesting an investigation into the cause,

extent of condition, potential reporting, and development of corrective and preventive action for the Agastat E7024PB relays with date code 0835 noted to have defective

terminal points. On November 11, 2008, the licensee incorrectly determined that the deficiencies with the four 0835 date code relays were the same condition as had been previously captured in Condition Report CR-WF3-2008-4765. This condition report had been written for date

code 0804 relays that had failed in service on September 11 and October 13, 2008. The

licensee incorrectly documented in Condition Report CR-WF3-2008-4782 that a

reportability evaluation for that previous condition would satisfy the requirements to

evaluate the October 14 deficiencies for reportability. On November 25, 2008, Tyco Electronics issued a 10 CFR 21 report regarding an Agastat E7024PB relay, date code 0813, which was manufactured with an incorrect recycle spring. Coincident with this Part 21 report, on November 26, 2008, Tyco

Electronics issued a recall of Agastat E7024PB relays with date codes ranging from

0808 through 0835. This recall included seven relays with a 0835 date code that had

been sold to the Waterford 3 and two which had been procured by the Waterford 3 from another station. Four of these recalled relays were the subject of the November 4, 2008, corrective action request issued to Tyco by the licensee. It was later determined that none of the relays procured by the Waterford 3 had an incorrect recycle spring installed. On January 28, 2009, the Waterford 3 received an evaluation from Tyco Electronics which identified misadjusted terminal blocks as the cause of the failures of the two 0804

date code relays, a different failure mechanism than that initially identified for the 0835 relays. The Tyco Electronics report did not provide an evaluation for the 0835 relays. In August 2009, the licensee issued Licensee Event Report (LER) 2009-003-00 (ML092310548). This LER did not mention relay 0835 or loose terminal points. It instead discussed incorrect adjustment of terminal blocks. In April 2010, the licensee issued an updated LER 2009-003-01 (ML101230323). This revision discussed relay 0835 and listed loose terminal points on two spare relays as a Part 21-reportable defect.

- 39 - Enclosure 2

The NRC identified that the licensee had failed to evaluate the loose terminal points on the four relays with date code 0835 in accordance with 10 CFR Part 21. Though the

licensee's initial actions to have the vendor perform an evaluation may have been appropriate, it was the licensee's responsibility and obligation under Part 21 to complete such an evaluation within 60 days of the initial discovery, or issue an interim report within 60 days of the initial discovery. The initial LER or Part 21 report should have been made in December 2008 (60 days after the date of discovery in October 2008). However, the Part 21 report that describes relay 0835 was made approximately 16 months later (April 2010).

Analysis. The failure of the licensee to adequately evaluate deviations in basic components and to report defects is a performance deficiency. The NRC's significance

determination process (SDP) considers the safety significance of findings by evaluating their potential safety consequences. This performance deficiency was of minor safety significance. The traditional enforcement process separately considers the significance

of willful violations, violations that impact the regulatory process, and violations that

result in actual safety consequences. Traditional enforcement applied to this finding

because it involved a violation that impacted the regulatory process. Supplement VII to

the version of the NRC Enforcement Policy that was in effect at the time the violation was identified provided as an example of a violation of significant regulatory concern (Severity Level III), "An inadequate review or failure to review such that, if an appropriate

review had been made as required, a 10 CFR Part 21 report would have been made."

Based on this example, the NRC determined that the violation met the criteria to be cited

as a Severity Level III violation. However, in accordance with the Enforcement Policy, because the affected components were already removed from service as part of an unrelated manufacturer's recall, the severity of the cited violation is being assessed as

Severity Level IV. Cross-cutting aspects are not assigned to traditional enforcement violations.

Enforcement. Title 10, CFR Part 21.21(a)(1) requires, in part, that entities subject to the regulations in this part shall evaluate deviations and failures to comply to identify defects

associated with substantial safety hazards as soon as practicable except as provided in paragraph (a)(2) of this section, and in all cases within 60 days of discovery, in order to identify a reportable defect that could create a substantial safety hazard, were it to

remain uncorrected. Title 10 CFR, Part 21.21(a)(2) requires, in part, that entities subject to the regulations in the part shall ensure that if an evaluation of identified deviation or failure to comply

potentially associated with a substantial safety hazard cannot be completed within

60 days from discovery of the deviation or failure to comply, an interim report is prepared

and submitted to the Commission. The interim report must be submitted in writing within

60 days of discovery of the deviation of failure to comply. Contrary to the above, from December 14, 2008, to April 29, 2010, the licensee failed to evaluate deviations and failures to comply to identify defects associated with substantial

safety hazards as soon as practicable and to submit a report or interim report within

- 40 - Enclosure 2

60 days of its discovery, in order to identify a reportable defect or failure to comply that could create a substantial safety hazard, were it to remain uncorrected. Specifically, on October 14, 2008, the licensee performed bench test on an

Agastat E7024PB relay with date code 0835 and noted that the relay had a loose

terminal point. Two more relays were obtained from the warehouse; one of these also had a bad terminal point. On October 27, 2008, the licensee quarantined the remaining four relays in stock. Two of these quarantined relays were identified to have similarly

deficient terminal points. The licensee identified these relays as "defective" and returned

them to the manufacturer, Tyco Electronics, for cause evaluation. All four affected relays shared a date code of 0835. On January 28, 2009, the licensee received a report from the manufacturer, which had failed to perform the required evaluation. On August 18, 2009, the licensee submitted LER 2009-003-00, (ML092310548). This LER

did not mention the date code 0835 relays or loose terminal points. Rather, the LER

described relays that failed due to incorrect adjustment of terminal blocks, a deviation

different from that observed in the 0835 date code relays. On April 29, 2010, the

licensee issued updated LER 2009003-01 (ML101230323). This revision to the LER described loose terminal points on two spare date code 0835 relays as one of the defects identified in its Agastat E7024PB relays. The April 29, 2010, LER revision would

have met Part 21 evaluation and reporting requirements, but it was 501 days late:

VIO 05000382/2013004-01, "Failure to Make a Report Required by 10 CFR 21.21."

4OA6 Meetings, Including Exit Exit Meeting Summary

The inspectors debriefed Mr. Carl Rich, Director of Nuclear Safety Assurance, and other members of the licensee's staff of the results of the licensed operator requalification

program inspection on July 25, 2013, and telephonically exited with Mr. Carl Rich and other staff members on August 19, 2013. The licensee representatives acknowledged

the findings presented. The inspectors asked the licensee whether any materials

examined during the inspection should be c

onsidered proprietary. No proprietary information was identified.

On September 19, 2013, the inspectors presented the results of the radiation safety

inspections to Ms. D. Jacobs, Vice President, Operations, and other members of the

licensee staff. The licensee acknowledged the issues presented. The inspector asked

the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified. On October 1, 2013, the inspectors presented the inspection results to Ms. D. Jacobs, Vice President, Operations, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No

proprietary information was identified.

- 41 - Enclosure 2

On November 19, 2013, a re-exit was held with Mr. John Jarrell, Regulatory Assurance Manager, and other members of your staff. The purpose of this re-exit was to further

discuss the violations contained in the report.

4OA7 Licensee-Identified Violations The following violation of very low safety significance (SL-IV) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the

NRC Enforcement Policy for being dispositioned as a Non-Cited Violation.

Title 10 CFR, Part 55.9, "Completeness and Accuracy of Information," requires that "information provided to the Commission by an applicant for a license or by a licensee - shall be complete and accurate in all material respects." Contrary to the above, on

September 13, 2012, an NRC Form 396, "Certifi

cation of Medical Examination by Facility Licensee," was submitted to the NRC for a licensed operator applicant with inaccurate

information. Specifically, a restriction for corrective lenses was omitted, even though the applicant's medical exam stated that the individual required corrective lenses. An operating license was granted by the NRC to the individual without a corrective lens restriction. The error was identified during the operator's subsequent annual medical

examination in July 2013, after which the operator reported to licensing that an additional restriction was being placed on his license though his vision had not changed. The

licensee confirmed that the operator had not performed any licensed duties and a revised NRC Form 396 was submitted to Region IV on July 29, 2013. The licensee documented the deficiency in Condition Report 2013-03181. The submission of

inaccurate information to the NRC is a violation. The violation was evaluated using the

traditional enforcement process because it

impacted the NRC's ability to perform its regulatory function. The violation was determined to be Severity Level IV because it fits

the example of Enforcement Policy Section 6.4.d.1(d), "Violation Examples: Licensed Reactor Operators." This section states, "SL IV violations involve , for example - an individual operator who met ANSI/ANS 3.4, Section 5, as certified on NRC Form 396,

required by Title 10, Part CFR 55.23, but failed to report a condition that would have

required a license restriction to establish or maintain medical qualification based on

having the undisclosed medical condition." In this case, the individual operator did report the condition to the licensee, but the licensee failed to include that information in its original license application to the NRC.

A1-1 Attachment SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel D. Jacobs, Vice President, Operations

K. Cook, General Manager, Plant Operations

S. Adams, Senior Manager, Production D. Boan, Supervisor, Radiation Protection J. Briggs, Superintendent, Electrical Maintenance

K. Crissman, Senior Manager, Maintenance

D. Frey, Manager, Radiation Protection

R. Gilmore, Manager, Systems and Components W. Hardin, Senior Licensing Specialist, Licensing

A. James, Manager, Security

B. Lanka, Director, Engineering

N. Lawless Manager, Chemistry

B. Lindsey, Senior Manager, Operations M. Mason, Senior Licensing Specialist, Licensing M. Mills, Manager, Nuclear Oversight

W. McKinney Manager, Performance Improvement

S.W. Meiklejohn, Superintendent, I & C Maintenance

B. Pellegrin, Manager, Regulatory Assurance

G. Pierce, Manager, Training

R. Porter, Manager, Design & Program Engineering

D. Reider, Supervisor, Quality Assurance

C. Rich, Jr., Director, Regulatory & Performance Improvement

J. Russo, Supervisor, Design Engineering

J. Signorelli, Supervisor, Simulator Support R. Simpson, Superintendent, Licensed Operator Requalification

P. Stanton, Supervisor, Design Engineering

J. Williams, Senior Licensing Specialist

A1-2 LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened 05000382-2013004-01 VIO Failure to Make a Report Required by 10 CFR 21.21 (Section 4OA5)

Opened and Closed

05000382-2013004-02 NCV Failure to Implement Fire Protection Program Procedure Requirements When Securing from a Fire Watch (Section 1R05)05000382-2013004-03 NCV Failure to Accomplish Activities Affecting Quality on a Degraded Safety-Related Solenoid Valve In Accordance With

Procedure Requirements (Section 1R19)

Closed 05000382/2012-007-00 LER Inoperability of a Safety Related Valve Due to Backup Air Accumulator Leakage 05000382/2009010-01 URI Failure to Evaluate Adverse Conditions for Reportability to the NRC (Section 4OA5)

LIST OF DOCUMENTS REVIEWED

Section 1R01: Adverse Weather ProtectionPROCEDURES/DOCUMENTS

NUMBER TITLE REVISION OP-901-521 Severe Weather and Flooding 309

ENS-EP-302 Severe Weather Response 11

Section 1R04: Equipment Alignment

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION OP-009-008 Safety Injection System 33

OP-002-004 Chilled Water System 311

OP-002-001 Auxiliary Component Cooling Water 305

A1-3 Section 1R05: Fire Protection

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION UNT-005-013 Fire Protection Program 12 FP-001-014 Duties of a Fire Watch 16

RAB 2-001 Prefire Strategy Elevation +46.00' RAB HVAC

Equipment Room

12 RAB 7-001 Prefire Strategy Elevation +35.00' RAB HVAC Relay

Room 9 RAB 39-001 Prefire Strategy Elevation -35.00' RAB General Area 11 FP-001-018 Pre Fire Strategies, Development and Revision 301

NS-TB-002 Prefire Strategy Turbing Building +15.00' West 2

CONDITION REPORTS

CR-WF3-2013-03523 CR-WF3-2013-03398

Section 1R06: Flood Protection Measures

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION EN-DC-346 Cable Reliability Program 5 MNQ3-5 Flooding Analysis Outside Containment 4 W3F1-2007-0017 Response to Generic Letter 2007-01 0

W3F1-2009-0066 Clarification of Response to Generic Letter 2007-01 0 SEP-UIP-WF3 Underground Components Inspection Plan 1

WORK ORDERS

WO 227249

Section 1R07: Heat Sink Performance PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION EN-DC-316 Heat Exchanger Performance and Condition 3

A1-4 Section 1R07: Heat Sink Performance PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION Monitoring PE-001-004 Heat Exchanger Performance 2 SEP-HX-WF3-001 Waterford's Generic Letter 89-13 Heat Exchanger Test Basis

0 Section 1R11: Licensed Operator Requalification Program PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION/

DATE EN-OP-115 Conduct of Operations

12 EN-TQ-114

Licensed Operator Requalification Training Program Description

8 TM-OP-100 Operations Training Manual 24 ANSI/ANS-3.4-

1983 Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants April 29, 1983 ANSI/ANS-3.5-

2009 Nuclear Power Plant Simulators for Use in Operator Training and Examination September 4, 2009 ACAD 07-001 Guidelines for the Continuing Training of Licensed

Personnel

January 2007 EN-TQ-217 Examination Security 2 OI-024-000 Maintaining Active SRO/RO Status 306

EN-NS-112 Medical Program 11

TM-OP-100 Operations Training Manual 24

MISCELLANEOUS DOCUMENTS

NUMBER TITLE DATE WSIM-DIR-003-ANNUALTESTS

Att. 4.1 Steady State Test - 20%, 70%, 100% May 5, 2013 WSIM-DIR-003-ANNUALTESTS

Att. 4.2 Manual Reactor Trip May 5, 2013

A1-5 WSIM-DIR-003-ANNUALTESTS

Att. 4.6 Trip of any single RCP May 15, 2013 WWEX-LOR-11044R 2011 LOR Biennial RO Exam Week 4 August 4, 2011 WWEX-LOR-11046R 2011 LOR Biennial RO Exam Week 4 (Remedial) August 18, 2011 N/A 2013 LOR Cycle Written Exam Question Matrix July 23, 2013 WWEX-LOR-13042R 2013 LOR Biennial RO Exam Week 2 July 18, 2013 TQF-201-IM06 Academic Review Board Recommendation November 14, 2011 N/A Simulator Differences List July 22, 2013

DR-08-0158 Simulator Discrepancy Report July 28, 2008

DR-13-0056 Simulator Discrepancy Report April 3, 2013

DR-10-0239 Simulator Discrepancy Report September 23, 2010

DR-13-0048 Simulator Discrepancy Report March 26, 2013

DR-13-0044 Simulator Discrepancy Report March 25, 2013

DR-12-0166 Simulator Discrepancy Report December 5, 2012

N/A Scenarios, LOR Annual Op Tests Weeks 1-6 (18) July 22, 2013

N/A JPMs, LOR Annual Op Tests Weeks 1-6 (36) July 22, 2013

N/A 2013 Annual Exam Schedule, Weeks 1-6 July 22, 2013

TQF-210-DD03 LOR Simulator Crew Performance Evaluation Report - Crews "A" and "3" (6)

July 25, 2013

W-OPS-LOR-

2012-Cycles 1-6 Requal Training Attendance Records for 2012

Cycles 1-6

July 22, 2013 CONDITION REPORTS

CR-WF3-2013-03181 CR-WF3-2013-03441 CR-WF3-2013-00747 CR-WF3-2013-00961 CR-HQN-2013-00708 CR-WF3-2013-02266 CR-WF3-2013-03522

A1-6 Section 1R12: Maintenance Effectiveness PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION ECM97-006 Design Basis for CCW Makeup 1

CONDITION REPORTS

CR-WF3-2013-02876 CR-WF3-2013-3170 CR-WF3-2013-3245 CR-WF3-2013-2897

WORK ORDERS

WO 354081 WO 355051 WO 322052

Section 1R13: Maintenance Risk Assessment and Emergent Work Controls PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION EN-WM-104 On Line Risk Assessment 7

Integrated Risk Summary Form for Week of 7/29/13

8/4/13 0 Integrated Risk Summary Form for Week of 9/02/13

9/8/13 0 OI-037-000 Operations' Risk Assessment Guideline 304

CONDITION REPORTS

CR-WF3-2013-03574

Section 1R15: Operability Determinations and Functionality Assessments

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION EN-LI-108 Event Notification and Reporting 8

EN-OP-104 Operability Determinations 6

EC 46218 Provide Minimum Wall Thickness Data for Degraded

Piping Identified in CR-WF3-2012-3855

0 PS-S-004 Thermal Expansion Evaluation of Low Temperature

Piping Systems

1 EN-PS-S-021-W Design Guide for Pipe Stress Analysis 0

A1-7 Section 1R15: Operability Determinations and Functionality Assessments

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION OP-100-014 Technical Specifications and Technical Requirement

Compliance

313 OI-037-000 Operations' Risk Assessment Guideline 304 EN-CS-S-008-MULTI Pipe Wall Thinning Structural Evaluation 0

CONDITION REPORTS

CR-WF3-2013-03641 CR-WF3-2013-02876 CR-WF3-2013-03170 CR-WF3-2013-03245

CR-WF3-2013-03855 CR-WF3-2013-4098

Section 1R18: Plant Modifications

PROCEDURES/DOCUMENTS NUMBER TITLE REVISION EC 45995 Main Steam Isolation Valve B to Repair a Bonnet Vent

Plug 0 EC 46914 Main Feedwater Isolation Valve A Nitrogen

Accumulator B tubing replacement

0 Section 1R19: Post-Maintenance Testing

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION EC 38218 Operability Input for CR-WF3-2012-2870, ACC-126A(B) Potential Leakage

0 EC-M90-013 Auxiliary Component Cooling Water (ACCW) Jockey Pump Analysis

0 EN-WM-107 Post Maintenance Testing 4 MI-005-211 Calibration of Control Valves and Accessories 8 MI-005-211 Calibration of Control Valves and Accessories 9 MN(Q)9-50 ACCW System Resistance 2

OP-002-001 Auxiliary Component Cooling Water 305

OP-903-006 Reactor Trip Circuit Breaker Test 10

A1-8 Section 1R18: Plant Modifications

PROCEDURES/DOCUMENTS NUMBER TITLE REVISION OP-903-050 Component Cooling Water and Auxiliary Component Cooling Water Pump and Valve Operability Test

28 OP-903-065 Emergency Diesel Generator and Subgroup Relay Operability Verification

307 OP-903-118 Primary Auxiliaries Quarterly IST Valve Tests 31 OP-903-119 Secondary Auxiliaries Quarterly IST Valve Test 18 STA-001-005 Leakage Testing of Air and Nitrogen Accumulators for Safety Related Valves

310 TD-M120.0045

Masoneilan Instruction Manual 2034 for Electro-Pneumatic Positioner Models 8012 & 8012-1-C &

8012-2-C & 8012-3-C

0 TD-M120.0055 Masoneilan Instruction Manual ES-5000 for Electro-Pneumatic Positioner Models 8012 & 8012-2-C &

8012-3-C & 8012-5-C & 8012-6-C

1 W3-DBD-14 Safety Related Air Operated Valves 301

CONDITION REPORTS

CR-WF3-2013-00451 CR-WF3-2013-00447 CR-WF3-2013-00491 CR-HQN-2013-00709

CR-WF3-2012-05991 CR-WF3-2012-03280 CR-WF3-2012-02870 CR-WF3-2013-04290

CR-WF3-2013-04332 CR-WF3-2013-04324 CR-WF3-2013-04274 CR-WF3-2012-02870

CR-WF3-2012-03217 CR-WF3-2010-03602 CR-WF3-2013-04047

WORK ORDERS

WO 52486712 WO 360921

Section 1R22: Surveillance Testing PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION EC 18218 Change CVRIDPIS5220A & B Setpoints 0

EC 18219 Replace CVRIDPIS5220A, B CVRIDPIS5221A, B Design Basis

0 OP-903-050 Component Cooling Water and Auxiliary Component 28

A1-9 Section 1R22: Surveillance Testing PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION Cooling Water Pump and Valve Operability Test OP-903-120 Containment and Mi

scellaneous Systems Quarterly IST Valve Tests

15 W3-DBD-04 Design Basis Document: Component Cooling Water, Auxiliary Component Cooling Water

302 SD-CCS Containment Cooling and Ventilation System Description

7 OP-903-037 Containment Cooling Fan Operability Verification 6 OP-903-037 Safety Injection Pump Operability Verification 19

WORK ORDERS

WO 227323 WO 5251325 Section 1EP6: Drill Evaluation

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION EP Emergency Plan 44 EP-001-001 Recognition and Classification of Emergency

Conditions

30 2RS1 Radiological Hazard Assessment and Exposure Controls (71124.01) PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION EN-RP-101 Access Control for Radiologically Controlled Areas 7

EN-RP-106-01 Radiological Survey Guidelines 0

EN-RP-108 Radiation Protection Postings 13

EN-RP-121 Radioactive Material Control 7

EN-RP-143 Source Control 9

A1-10 AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES

NUMBER TITLE DATE QA-14115-2011-

W3-1 Quality Assurance Audit - Combined Radiation Protection and Radwaste November 16, 2011

CONDITION REPORTS

CR-WF3-2013-2256 CR-WF3-2013-3086

CR-WF3-2013-6848

CR-WF3-2012-06131

CR-WF3-2012-0622

RADIATION SURVEY RECORDS

NUMBER TITLE DATE WF3-1212-1262 Reactor Containment Building +46-foot December 23, 2012

WF3-1210-0434 Reactor Coolant Pump 2B October 20, 2012

WF3-1211-1617 Reactor Coolant Pump 2B November 24, 2012

WF3-1210-0719 Reactor Coolant Pump 2B October 24, 2012

WF3-1210-0365 Reactor Coolant Pump 1A October 18, 2012 WF3-1210-0626 Reactor Cavity +21-foot October 23, 2012 WF3-1210-0560 Reactor Containment Building October 22, 2012

WF3-1210-0502 Lower Reactor Cavity October 21, 2012

WF3-1211-1720 Reactor Coolant Pump 1B November 26, 2012

WF3-1211-1722 No. 1 Steam Generator Platform November 26, 2012 WF3-1211-1822 D Ring November 27, 2012

AIR SAMPLE RECORDS

NUMBER TITLE DATE 112512-003 Reactor Coolant Pump 2B November 24, 2012

112512-007 Reactor Coolant Pump 2B November 24, 2012

4022475 HP Lapel Sample - Upper Cavity October 20, 2012

4022484 HP Lapel Sample - Canal October 20, 2012

5019973 HP Lapel Sample - Canal Under Reactor October 20, 2012 5019974 HP Lapel Sample - Canal Under Reactor October 20, 2012

SEALED SOURCE INVENTORY AND LEAK TESTS

NUMBER DATE 310182 July 2, 2013

A1-11 2RS2 Occupational ALARA Planning and Controls (71124.02) PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION EN-RP-105 Radiological Work Permits 012 EN-RP-110 ALARA Program 011

EN-RP-110-03 Collective Radiation Exposure (CRE) Reduction

Guidelines

002 EN-RP-110-04 Radiation Protection Risk Assessment Process 002 EN-RP-110-05 ALARA Planning and Controls 002 EN-RP-110-06 Outage Dose Estimation and Tracking 001

RADIATION WORK PERMIT ALARA PACKAGES

NUMBER TITLE DATE 2012-0414 SI-109 "A" and "B" Refurbishing/Repair

February 25, 2013

2012-0515 RCP 2B Motor Removal and Replacement.

January 10, 2013

2012-0915 RSG Reactor Coolant System (RCS) Cutting and Welding.

January 8, 2013

2012-0916 RSG Pipe End Decontamination (PED) Activities and

Support Activities

January 25, 2013

2012-0917 RSG Steam Generator Removal/Installation Activities and Support. Including Rigging Activities

February 18, 2013

2012-0924 RSG Support Structure / Restraints Modifications

February 7, 2013

CONDITION REPORTS

CR-W3-2012-06441 CR-W3-2012-06446 CR-W3-2012-06502 CR-W3-2012-06515 CR-W3-2012-06543 CR-W3-2012-06593 CR-W3-2012-06660 CR-W3-2012-06770

CR-W3-2012-06778 CR-W3-2012-06843 CR-W3-2012-06877 CR-W3-2012-06879

CR-W3-2012-07150 CR-W3-2012-07289 CR-W3-2012-07493 CR-W3-2013-00306

CR-W3-2013-00344

A1-12 SURVEYS

WF3-1210-0855 WF3-1210-0859 WF3-1210-0932 WF3-1210-0880 WF3-1211-0112 WF3-1211-0194 WF3-1211-0572 WF3-1211-0948 WF3-1211-1122 WF3-1211-1113 WF3-1211-1116 WF3-1211-1175

WF3-1211-1189 WF3-1211-1313 WF3-1211-1332 WF3-1211-1508

WF3-1211-1571 WF3-1211-1822 WF3-1211-1907 WF3-1212-0179

WF3-1212-0812 WF3-1212-0912

MISCELLANEOUS DOCUMENTS

NUMBER TITLE DATE CR-W3-2013-

00250 LT - Apparent Cause Evaluation Report Refuel 18

Dose Goal Exceeded May 13, 2013 Refuel 18 Outage ALARA Report

2RS5 Radiation Monitoring Instrumentation (71124.05)

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION MI-005-906 Radiation Monitoring System Desk Guide 002

MI-003-387 Condenser Vacuum Pump Discharge Wide Range

Noble Gas Radiation Monitor Channel Calibration

(PRMIR0002)

12 MI-003-461 Boric Acid Condensate Discharge Liquid Effluent Radiation Monitor Channel Calibration (PRMIR0627)

12 MI-003-371 Fuel Handling Building Ventilation System Emergency Exhaust High Range Noble Gas Radiation Monitor

Channel Calibration (PRMIR3032)

306 MI-003-391 Component Cooling Water System A or B Liquid Radiation Monitor Channel Calibration (PRMIR7050A

or B)

306 CE-003-321 Use of EG&G Ortec Gamma Spectroscopy System 303

EN-CY-110 Chemistry Gamma Spectroscopy System Operation 2

CE-003-332 Use of the Beckman LS6500 2

EN-RP-301 Radiation Protection Instrument Control 5

A1-13 NUMBER TITLE REVISION EN-RP-303-01 Automated Contamination Monitor Performance Testing 0 AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES

NUMBER TITLE DATE

QS-2012-W3-

008

Quality Assurance Surveillance Report May 15, 2012 QA-14/15-2011-

W3-1 Quality Assurance Audit November 10, 2011

CONDITION REPORTS

2013-04550 2013-04559 2013-04552 2013-04551

2012-04918

RADIATION MONITORING SYSTEM CALIBRATION RECORDS

WO# NUMBER TITLE DATE 52321504 PRMIR7050A, Cal CCW System Rad Monitor per

MI-003-391

March 1, 2012 52321537 PRMIR0002, Calibrate Electronics as per MI-003-387 August, 2012

52321563 PRMIR0627, Cal Boric Acid Cond Disch Liquid Mon

MI-003-461

July 2, 2012 52324842 PRMIR0002, Calibrate Flow Portion per MI003-387 October 15, 2012

52335214 PRMIR3032, Calibrate Electronics as per MI-003-371 January 10, 2013

52358658 PRMIR3032, Calibrate Flow Portion per MI-003-371 June 3, 2013

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION CE-003-300 Preparation of Liquid Samples for Radiological Chemical

Analysis

008

A1-14 PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION CE-003-509 Routine Filter Replacement and Grab Sampling on PIG

Monitors and WRGMS

302 CE-003-512 Liquid Radioactive Waste Release Permit (Manual) 001

CE-003-513 Gaseous Radioactive Waste Release Permit (Manual) 303

CE-003-514 Liquid Radioactive Waste Release Permit (Computer) 301

CE-003-515 Gaseous Radioactive Waste Release Permit (Computer) 303

CE-003-516 Calculation and Adjustment of Radiation Monitor

Setpoints

302 CE-003-700 General Grab Sampling Techniques 306

EN-CY-102 Laboratory Analytical Quality Control 004

EN-CY-108 Monitoring of Nonradioactive Systems 005

EN-CY-113 Response to Contaminated Spills/Leaks 007

MM-003-044 Shield Building Ventilation System Surveillance 301

MM-003-045 Control Room Air Conditioning 304

MM-003-046 Controlled Ventilation Area System Surveillance 301

UNT-005-014 Offsite Dose Calculation Manual 303

AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES

NUMBER TITLE DATE 22873 Audit of GEL Laboratories December 13, 2011

WLO-2013-00016 Pre-NRC Inspection Focused Assessment May 3, 2012

23428 Exelon Nuclear Audit of NUCON International, Inc. March 11, 2013

A1-15 CONDITION REPORTS

CR-WF3-2012-00910 CR-WF3-2012-01284 CR-WF3-2012-02107 CR-WF3-2012-02240 CR-WF3-2012-02491 CR-WF3-2012-03509 CR-WF3-2012-03956 CR-WF3-2012-04363 CR-WF3-2012-04571 CR-WF3-2012-04840 CR-WF3-2012-04995 CR-WF3-2012-05597

CR-WF3-2012-06182 CR-WF3-2012-06551 CR-WF3-2013-00282 CR-WF3-2013-00318

CR-WF3-2013-00677 CR-WF3-2013-02795 CR-WF3-2013-03087 CR-WF3-2013-04547

LO-WLO-2013-00016

10 CFR 50.75(g) CONDITION REPORTS

CR-WF3-2011-06065 CR-WF3-2012-02705

EFFLUENT RELEASE PERMITS

PERMIT NO TYPE RELEASE SYSTEM DATE

W3LB2012-147 Liquid Boric Acid Condensate Tank B (BWM) July 25, 2012

W3LC2012-202 Liquid Turbine Building Industrial Waste Tank (TBIWS)

September 26, 2012W3LB2013-066 Liquid Waste Condensate Tank B (LWM) April 2, 2013

W3GC2012-079 Gaseous Plant Stack June 27, 2012

EFFLUENT RELEASE PERMITS

PERMIT NO TYPE RELEASE SYSTEM DATE W3GB2013-050 Gaseous Containment May 9, 2013

W3GC2013-057 Gaseous Fuel Handling Building May 13, 2013

IN-PLACE FILTER TESTING RECORDS

WORK ORDER SYSTEM TRAIN TEST DATE 52434436 Shield Building Ventilation B Charcoal absorber December 19, 201252321632 Shield Building Ventilation A HEPA Filter February 10, 2012

52351427 Control Room Emergency Filtration Unit B Charcoal absorber March 29, 2013 52331428 Control Room Emergency Filtration Unit B HEPA Filter March 27, 2013

A1-16 52376581 Controlled Ventilation Area B HEPA Filter June 25, 2013 52376581 Controlled Ventilation Area B Charcoal absorber June 29, 2013

MISCELLANEOUS DOCUMENTS

NUMBER TITLE DATE 2011 Annual Radiological Effluent Release Report April 30, 2012

2012 Annual Radiological Effluent Release Report April 30, 2013

Intra-Laboratory Comparison Results 2011 EC-10953 Engineering Change for Modified Release Path to Circulating Water System

May 11, 2009 EC-28466 Engineering Change for Circulating Water System Piping

Rerouting

In Progress

2RS7 Radiological Environmental Monitoring Program (71124.07) PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION CE-003-522 Meteorological Data Collection and Processing 4

CE-003-523 Meteorological Monitoring Program 1

CE-003-525 REMP Evaluations and Reports 301

CE-003-526 Collection and Preparation of REMP Liquid Samples 302

CE-003-527 Collection of Milk Samples 1

CE-003-528 Collection of Sediment Samples 1

CE-003-529 Collection of Vegetation Samples 1

CE-003-530 Collection and Preparation of Fish Sample 1

CE-003-531 Collection and Preparation of REMP Air Samples 1

CE-003-532 Preparation and Distribution of REMP Thermoluminescent

Dosimeters

301 CE-003-533 REMP Shipping 1 CE-003-534 Land Use Census 2

A1-17 ESP-8-069 Radiological Environmental Analytical Services 00 UNT-005-014 Offsite Dose Calculation Manual 303

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION EN-QV-108 QA Surveillance Process 9

EN-QV-109 Audit Process 24

Quality Assurance Program Manual 24 AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES

NUMBER TITLE REVISION EN-LI-104 Pre-NRC Inspection Focused Assessment - Effluents and Environmental

9 CONDITION REPORTS

CR-WF3-2012-1360 CR-WF3-2012-2737 CR-WF3-2012-2942 CR-WF3-2012-4067

CR-WF3-2012-4281

CR-WF3-2012-4296

CR-WF3-2012-4385 CR-WF3-2012-4408 CR-WF3-2012-7354 CR-WF3-2012-7487 CR-WF3-2013-1967 CR-WF3-2013-2941

CALIBRATION AND MAINTENANCE RECORDS

NUMBER TITLE DATE

WO-WF3-52410699 Primary Met Tower Calibration Package October 2012 WO-WF3-52447365 Primary Met Tower Calibration Package May 2013 WO-WF3-52431357 Secondary Met Tower Calibration Package February 2012

WO-WF3-52469672 Secondary Met Tower Calibration Package August 2013

MISCELLANEOUS DOCUMENTS

TITLE DATE

Annual Radiological Environmental Operating Report 2011 Annual Radiological Environmental Operating Report 2012

Annual Radioactive Effluent Release Report 2011 Annual Radioactive Effluent Release Report 2012 Annual Meteorological Monitoring Program Report 2011

Annual Meteorological Monitoring Program Report 2012

A1-18 2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation (71124.08) PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

EN-RP-121 Radioactive Material Control 7 EN-RW-102 Radioactive Shipping Procedure 10

EN-RW-104 Scaling Factors 3

RW-002-200 Collection & Packaging of Solid Radwaste 303 RW-002-210 Radioactive Waste Solidification & Dewatering 301 RW-002-240 Package and Handling Radwaste DAW 300

RW-002-300 Blowdown Demineralizer Resin Transfer 300

AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES

NUMBER TITLE DATE NUPIC Audit No.

2012-011 Energy Solutions Mega Audit November 23, 2012 EN-LI-104 Pre-Assessment Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and

Transportation

April 24, 2012

QA-14/15-20011-GGNS-1

Quality Assurance Audit Report: Radiation

Protection/Radwaste

October 11, 2011

CONDITION REPORTS

CR-WF3-2011-07711 CR-WF3-2012-03042 CR-WF3-2012-07168 CR-WF3-2013-00508

CR-WF3-2013-01253 CR-WF3-2013-01682 CR-WF3-2013-02905 CR-WF3-2013-03335 CR-WF3-2013-03952 CR-WF3-2013-04553 CR-WF3-2013-04556 CR-WF3-2013-04557 CR-HQN-2013-00858 CR-HQN-2013-00859

RADIOACTIVE MATERIAL AND WASTE SHIPMENTS

NUMBER TITLE DATE 11-1010 Bead Resin and Dry Active Waste, Oak Ridge, TN June 23, 2011

11-1011 LWM Resin, Oak Ridge, TN August 22, 2011

11-1011 Dewatered Resin, Studsvik Erwin, TN September 21, 2011

11-3024 Lead Blankets, 3-Mile Island, Harrisburg, PA February 25, 2011 12-1008 Dry Active Waste, Energy Solutions, Oak Ridge, TN June 21,2012 12-1009 SGBD Resin, Energy Solutions, Oak Ridge, TN October 24, 2012

12-3049 Empty Fuel Cask, Energy Solutions, Oak Ridge, TN August 9, 2012

A1-19 MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION / DATE

FSAR Chapter 11 WSES Updated Final Safety Analysis Report 12 FSAR Chapter

12 WSES Updated Final Safety Analysis Report 12 2012 Annual Radiological Effluent Release Report April 30, 2012 2011 Annual Radiological Effluent Release Report April 30, 2013 Section 4OA1: Performance Indicator VerificationPROCEDURES/DOCUMENTS

NUMBER TITLE REVISION EN-LI-104 Performance Indicator Process 6

EN-FAP-OM-005 Nuclear Performance Indicator Process 0

ECH-NE-09-

00036 Waterford 3 Mitigating System Performance Index Basis Document 2 MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION NEI 99-02 Regulatory Assessment Performance Indicator Guideline 6

Section 4OA2: Identification and Resolution of Problems

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION EN-LI-102 Corrective Action Process 20 EN-LI-119 Apparent Cause Evaluation (ACE) Process 16

Section 4OA3: Event Follow-Up PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION LER 05000382/2012-

007-00 Inoperability Of A Safety Related Valve Due To Backup Air Accumulator Leakage

0

A1-20 Section 4OA5: Other Activities

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION EN-CY-109 Sampling and Analysis of Groundwater Monitoring Wells 2

EN-CY-111 Radiological Ground Water Monitoring Program 2

CONDITION REPORTS

CR-HQN-2012-00676 CR-HQN-2012-00673 CR-HQN-2013-00861

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION/

DATE LO-WTHQN-2011-123 Focused Self-Assessment Report - NEI 07-07 Compliance - Waterford-3 November 30, 2011 NEI Ground Water Protection Initiative NEI Peer Assessment Report December 9, 2009 Ground Water Monitoring Plan - Entergy Nuclear Waterford-3 Station

2