IR 05000382/2016001: Difference between revisions

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On March 31, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford Steam Electric Station, Unit 3. On April 21, 2016, 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.
On March 31, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford Steam Electric Station, Unit 3. On April 21, 2016, 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 one finding of very low safety significance (Green) in this report. This finding involved a violation of NRC requirements
NRC inspectors documented one finding of very low safety significance (Green) in this report. This finding involved a violation of NRC requirements. Further, inspectors documented a licensee-identified violation which was determined to be of very low safety significance.
. Further, inspectors documented a licensee-identified violation which was determined to be of very low safety significance.


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


If you contest the violation s or significance of the 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
If you contest the violation s or significance of the NCV s, 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; 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
-0001; and the NRC resident inspector at the Waterford Steam Electric Station, Unit 3
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Sincerely,/RA/
Sincerely,/RA/
Jeffrey Josey, Acting Chief Projects Branch D Division of Reactor Projects Docket No.
Jeffrey Josey , Acting Chief Projects Branch D Division of Reactor Projects Docket No.


50-382 License No
50-382 License No
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cc w/ encl: Electronic Distribution
cc w/ encl: Electronic Distribution


ML16116A21 0 SUNSI Review By: JEJ ADAMS Yes No Non-Sensitive Sensitive Publicly Available Non-Publicly Available Keyword: NRC-002 OFFICE SRI:DRP/D RI:DRP/D C:DRS/EB1 C:DRS/EB2 C:DRS/OB C:DRS/PSB1 C:DRS/PSB2 NAME FRamirez CSpeer TFarnholtz GWerner VGaddy MHaire HGepford SIGNATURE
ML16116A21 0 SUNSI Review By: JEJ ADAMS Yes No Non-Sensitive Sensitive Publicly Available Non-Publicly Available Keyword: NRC-002 OFFICE SRI:DRP/D RI:DRP/D C:DRS/EB1 C:DRS/EB2 C:DRS/OB C:DRS/PSB1 C:DRS/PSB2 NAME FRamirez CSpeer TFarnholtz GWerner VGaddy MHaire HGepford SIGNATURE /RA-E/ /RA-E/ /RA/ /RA/ /RA/ JKirkland, for /RA/ /RA/ DATE 4/22/16 4/22/16 4/15/16 4/20/16 4/21/16 4/21/16 4/21/16 OFFICE TL:DRS/TSS BC:DRP/D NAME THipschman JJosey SIGNATURE /RA/ /RA/ DATE 4/19/16 4/25/16 Letter to Michael from Jeffrey Josey April 25, 2016
/RA-E/ /RA-E/ /RA/ /RA/ /RA/ JKirkland, for /RA/ /RA/ DATE 4/22/16 4/22/16 4/15/16 4/20/16 4/21/16 4/21/16 4/21/16 OFFICE TL:DRS/TSS BC:DRP/D NAME THipschman JJosey SIGNATURE
/RA/ /RA/ DATE 4/19/16 4/25/16 Letter to Michael from Jeffrey Josey April 25, 2016


SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3  
SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3  
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Resident Inspector (Chris.Speer@nrc.gov)
Resident Inspector (Chris.Speer@nrc.gov)
WAT Administrative Assistant (Dawn
WAT Administrative Assistant (Dawn
.Yancey@nrc.gov)
.Yancey@nrc.gov) Acting Branch Chief, DRP/D (Jeffrey.Josey@nrc.gov) Project Engineer, DRP/D (Jan.Tice@nrc.gov)
Acting Branch Chief, DRP/D (Jeffrey.Josey@nrc.gov)
Project Engineer, DRP/D (Jan.Tice@nrc.gov)
Project Engineer, DRP/D (Jim.Melfi@nrc.gov)
Project Engineer, DRP/D (Jim.Melfi@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov
Public Affairs Officer (Victor.Dricks@nrc.gov
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RIV RSLO (Bill.Maier@nrc.gov)
RIV RSLO (Bill.Maier@nrc.gov)
ACES (R4Enforcement.Resource@nrc.gov)
ACES (R4Enforcement.Resource@nrc.gov)
ROPreports.Resource@nrc.gov ROPassessment.Resource@nrc.gov Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 05000382 License: NPF-38 Report: 05000382/2016001 Licensee:
ROPreports.Resource@nrc.gov ROPassessment.Resource@nrc.gov Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 05000 382 License: NPF-38 Report: 05000 382/20 1 6 0 01 Licensee: Entergy Operations, Inc.
Entergy Operations, Inc.


Facility:
Facility: Waterford Steam Electric Station, Unit 3 Location: 17265 River Road Killona, LA 70057 Dates: January 1 through Ma r ch 3 1, 20 16 Inspectors:
Waterford Steam Electric Station, Unit 3 Location:
17265 River Road Killona, LA 70057 Dates: January 1 through March 31, 2016 Inspectors:
F. Ramírez, Senior Resident Inspector C. Speer, Resident Inspector B. Hagar, Senior Project Engineer L. Carson, II, Senior Health Physicist N. Greene, PhD, Health Physicist Approved By:
F. Ramírez, Senior Resident Inspector C. Speer, Resident Inspector B. Hagar, Senior Project Engineer L. Carson, II, Senior Health Physicist N. Greene, PhD, Health Physicist Approved By:
Jeffrey Josey Acting Chief, Project s Branch D Division of Reactor Projects  
Jeffrey Josey Acting Chief, Project s Branch D Division of Reactor Projects  


=SUMMARY=
=SUMMARY=
IR 05000382/2016001; 01/01/2016 - 03/31/2016; Waterford Steam Electric Station, Unit 3; Maintenance Risk Assessments and Emergent Work Control The inspection activities described in this report were performed between January 1 and March 31, 2016, by the resident inspectors and inspectors from the NRC's Region IV office
IR 05000 382/20 16001; 01/01/20 16 - 03/31/20 16; Waterford Steam Electric Station, Unit 3; Maintenance Risk Assessments and Emergent Work Control The inspection activities described in this report were performed between January 1 and March 31 , 2016 , by the resident inspectors and inspectors from the NRC's Region IV office. One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609, "Significance Determination Process."  Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, "Aspects within the Cross-Cutting Areas."  Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG
. One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609, "Significance Determination Process."  Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, "Aspects within the Cross-Cutting Areas."  Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG
-1649, "Reactor Oversight Process."
-1649, "Reactor Oversight Process."


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The inspectors identified a non-cited violation of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," section a(4), for the licensee's failure to assess and manage the increase in risk during an auxiliary component cooling water system work window. Specifically, the licensee failed to re-asses risk when a dry cooling tower fan in the component cooling water system was declared unavailable during the ongoing auxiliary component cooling water system work window. As a result, for approximately 6 hours, on-line risk was maintained as Green when it should have been elevated to Orange, which would have required additional risk management actions. The licensee entered this issue into their corrective action program as Condition Report CR-WF3-2016-0660. Corrective actions included restoring the dry cooling tower fan to available status such that risk returned to Green and sending a communication to operations supervisors to re-emphasize the requirements to adequately address unavailability of plant components.
The inspectors identified a non-cited violation of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," section a(4), for the licensee's failure to assess and manage the increase in risk during an auxiliary component cooling water system work window. Specifically, the licensee failed to re-asses risk when a dry cooling tower fan in the component cooling water system was declared unavailable during the ongoing auxiliary component cooling water system work window. As a result, for approximately 6 hours, on-line risk was maintained as Green when it should have been elevated to Orange, which would have required additional risk management actions. The licensee entered this issue into their corrective action program as Condition Report CR-WF3-2016-0660. Corrective actions included restoring the dry cooling tower fan to available status such that risk returned to Green and sending a communication to operations supervisors to re-emphasize the requirements to adequately address unavailability of plant components.


The inspectors determined that the performance deficiency was more than minor, and therefore a finding, because it was associated with the configuration control 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, by not ensuring the risk assessment was adequate when an additional component was emergently declared unavailable, the licensee proceeded with a maintenance work window with no understanding of the increased risk associated with a different plant configuration. The inspectors used Inspection Manual Chapter 0609, Appendix K, "Maintenance Risk Assessment and Risk Management Significance Determination Process," dated May 19, 2005, Flowchart 1, "Assessment of Risk Deficit
The inspectors determined that the performance deficiency was more than minor, and therefore a finding, because it was associated with the configuration control 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, by not ensuring the risk assessment was adequate when an additional component was emergently declared unavailable, the licensee proceeded with a maintenance work window with no understanding of the increased risk associated with a different plant configu ration. The inspectors used Inspection Manual Chapter 0609, Appendix K, "Maintenance Risk Assessment and Risk Management Significance Determination Process," dated May 19, 2005, Flowchart 1, "Assessment of Risk Deficit
," and determined the need to calculate the risk deficit to determine the significance of this issue. The risk deficits were assumed to be equal to the incremental core damage probability (ICDP)actual and incremental large early release probability (ILERP)actual. The Waterford probabilistic risk assessment model yielded an incremental core damage probability (ICDP), or actual increase in risk during this work window, of 6.1x10
," and determined the need to calculate the risk deficit to determine the significance of this issue. The risk deficits were assumed to be equal to the incremental core damage probability (ICDP)actual and incremental large early release probability (ILERP)actual. The Waterford probabilistic risk assessment model yielded an incremental core damage probability (ICDP), or actual increase in risk during this work window, of 6.1x10
-8. The regional senior reactor analyst evaluated the licensee's risk significance evaluation and agreed with the results from the licensee's model.
-8. The regional senior reactor analyst evaluated the licensee's risk significance evaluation and agreed with the results from the licensee's model.


The ILERP
The ILERP , screened out as not risk significant. In accordance with Flowchart in Appendix K, because the ICDP was less than 1x10
, screened out as not risk significant
. In accordance with Flowchart in Appendix K, because the ICDP was less than 1x10
-6 and the ILERP was less than 1x10-7, the finding screened as having very low safety significance (Green). This finding has a procedure adherence cross-cutting aspect in the area of human performance, because individuals did not follow processes, procedures
-6 and the ILERP was less than 1x10-7, the finding screened as having very low safety significance (Green). This finding has a procedure adherence cross-cutting aspect in the area of human performance, because individuals did not follow processes, procedures
, and work instructions. Specifically, when the additional dry cooling tower fan was declared unavailable, the licensee did not re-assess risk as soon as practical as specified in site procedures
, and work instructions. Specifically, when the additional dry cooling tower fan was declared unavailable, the licensee did not re-assess risk as soon as practical as specified in site procedures
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This violation and associated corrective action tracking numbers are listed in Section 4OA7 of this report.
This violation and associated corrective action tracking numbers are listed in Section 4OA7 of this report.


==PLANT STATUS==
=PLANT STATUS=
 
The Waterford Steam Electric Station, Unit 3, began the inspection period at 100 percent power and remained at 100 percent power for the duration of the inspection period.
The Waterford Steam Electric Station, Unit 3, began the inspection period at 100 percent power and remained at 100 percent power for the duration of the inspection period.


=REPORT DETAILS=
REPORT DETAILS


==REACTOR SAFETY==
==REACTOR SAFETY==
Cornerstones:  Initiating Events, Mitigating Systems, and Barrier Integrity
Cornerstones:  Initiating Events, Mitigating Systems, and Barrier Integrity 1 R 01 Adverse Weather Protection (71111.01)
{{a|1R01}}
 
==1R01 Adverse Weather Protection==
{{IP sample|IP=IP 71111.01}}
===.1 Readiness for Seasonal Extreme Weather Conditions===
===.1 Readiness for Seasonal Extreme Weather Conditions===


====a. Inspection Scope====
====a. Inspection Scope====
On January 5, 2016, the inspectors completed an inspection of the station's readiness for seasonal extreme cold weather conditions. The inspectors reviewed the licensee's adverse weather procedures for the cold weather conditions and evaluated the licensee's implementation of these procedures. The inspectors verified that prior to the onset of cold weather, the licensee had corrected weather-related equipment deficiencies identified during the previous cold weather season. The inspectors selected four risk-significant systems that were required to be protected from cold weather condition s:  fire protection system train A  fire protection system train B  security diesel generator emergency diesel generator fuel oil storage The inspectors reviewed the licensee's procedures and design information to ensure the systems would remain functional when challenged by cold weather conditions.
On January 5, 2016, the inspectors completed an inspection of the station's readiness for seasonal extreme cold weather conditions. The inspectors reviewed the licensee's adverse weather procedures for the cold weather conditions and evaluated the licensee's implementation of these procedures. The inspectors verified that prior to the onset of cold weather , the licensee had corrected weather-related equipment deficiencies identified during the previous cold weather season. The inspectors selected four risk-significant systems that were required to be protected from cold weather condition s:  fire protection system train A  fire protection system train B  security diesel generator emergency diesel generator fuel oil storage The inspectors reviewed the licensee's procedures and design information to ensure the systems would remain functional when challenged by cold weather conditions.


The inspectors verified that operator actions described in the licensee's procedures were  
The inspectors verified that operator actions described in the licensee's procedures were  
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adequate to maintain readiness of these systems. The inspectors walked down portions of these systems to verify the physical condition of the cold weather protection features.
adequate to maintain readiness of these systems. The inspectors walked down portions of these systems to verify the physical condition of the cold weather protection features.


These activities constitute d one sample of readiness for seasonal adverse weathe r, as defined in Inspection Procedure 71111.01.
These activities constitute d one sample of readiness for seasonal adverse weathe r , a s defined in Inspection Procedure 71111.01.


====b. Findings====
====b. Findings====
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====a. Inspection Scope====
====a. Inspection Scope====
On January 21, 2016, the inspectors completed an inspection of the station's readiness for impending adverse weather conditions. The inspectors reviewed plant design features, the licensee's procedures to respond to tornadoes and high winds, and the licensee's implementation of these procedures. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant.
On January 21, 201 6, the inspectors completed an inspection of the station's readiness for impending adverse weather conditions. The inspectors reviewed plant design features, the licensee's procedures to respond to tornadoes and high winds, and the licensee's implementation of these procedures. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant.


These activities constituted one sample of readiness for impending adverse weather conditions, as defined in Inspection Procedure 71111.01.
These activities constituted one sample of readiness for impending adverse weather conditions, as defined in Inspection Procedure 71111.01.
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====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.
{{a|1R04}}
 
==1R04 Equipment Alignment==
1 R 04 Equipment Alignment (71111.04)
{{IP sample|IP=IP 71111.04}}
 
===.1 Partial Walk===
===.1 Partial Walk===


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The inspecto rs performed partial system walk
The inspecto rs performed partial system walk
-downs of the following risk
-downs of the following risk
-significant systems:  On January 21, 2016, component cooling water train A with train B out of service for maintenance On February 24, 2016, low pressure safety injection train A following maintenance On March 2, 2016, emergency feedwater train B with train A out of service for maintenance On March 22, 2016, containment spray train A with train B out of service for maintenance The inspectors reviewed the licensee's procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems were correctly aligned for the existing plant configuration
-significant systems:  On January 21, 2016, component cooling water train A with train B out of service for maintenance On February 24, 2016, low pressure safety injection train A following maintenance On March 2, 2016, emergency feedwater train B with train A out of service for maintenance On March 22 , 2016, containment spray train A with train B out of service for maintenance The inspectors reviewed the licensee's procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems were correctly aligned for the existing plant configuration
. These activities constitute d four partial system walk
. These activities constitute d four partial system walk
-down samples as defined i n Inspection Procedure 71111.04.
-down samples as defined i n Inspection Procedure 71111.04.
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These activities constitute d one complete system walk
These activities constitute d one complete system walk
-down sample
-down sample , as defined in Inspection Procedure 71111.04.
, as defined in Inspection Procedure 71111.04.


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.
{{a|1R05}}
 
==1R05 Fire Protection==
1 R 05 Fire Protection (71111.05)
{{IP sample|IP=IP 71111.05}}
Quarterly Inspection
Quarterly Inspection


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:  On January 15, 2016, fire area RAB 6, electrical penetration area On January 15, 2016, fire area RAB 32, auxiliary component cooling water room and pipe penetration area On March 5, 2016, fire area RAB 18, component cooling water heat exchanger A  On March 5, 2016, fire area RAB 16, emergency diesel generator 3A  On March 5, 2016, fire area ROOF E, main steam isolation valve room B For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensee's fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.
:  On January 15, 2016, fire area RAB 6, electrical penetration area On January 15, 2016, fire area RAB 32, auxiliary component cooling water room and pipe penetration area On March 5, 2016, fire area RAB 18, component cooling water heat exchanger A  On March 5, 2016, fire area RAB 16, emergency diesel generator 3A  On March 5, 2016, fire area ROOF E, main steam isolation valve room B For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensee's fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.


These activities constitute d five quarterly inspection sample s, as defined in Inspection Procedure 71111.05.
These activities constitute d five quarterly inspection sample s , as defined in Inspection Procedure 71111.05.


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.
{{a|1R11}}
==1R11 Licensed Operator Requalification Program and Licensed Operator Performan==


ce (71111.11)
1 R 11 Licensed Operator Requalification Program and Licensed Operator Performan ce (71111.11)


===.1 Review of Licensed Operator Requalification===
===.1 Review of Licensed Operator Requalification===
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====a. Inspection Scope====
====a. Inspection Scope====
On March 8, 2016, the inspectors observed an evaluated simulator scenario performed by an operating crew. The inspectors assessed the performance of the operators and the evaluators' critique of their performance. The inspectors also assessed the modeling and performance of the simulator during the observation
On March 8, 2016, the inspectors observed an evaluated simulator scenario performed by an operating crew. The inspectors assessed the performance of the operators and the evaluators' critique of their performance. The inspectors also assessed the modeling and performance of the simulator during the observation
. These activities constitute completion of one quarterly licensed operator requalification program sample
. These activities constitute completion of on e quarterly licensed operator requalification program sample , as defined in Inspection Procedure 71111.11.
, as defined in Inspection Procedure 71111.11.


====b. Findings====
====b. Findings====
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====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.
{{a|1R12}}
 
==1R12 Maintenance Effectiveness==
1 R 12 Maintenance Effectiveness (71111.12)
{{IP sample|IP=IP 71111.12}}


====a. Inspection Scope====
====a. Inspection Scope====
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On February 2, 2016, emergency diesel generator room ventilation system On February 29, 2016, auxiliary component cooling water system The inspectors reviewed the extent of condition of possible common cause structure, system, and component failures and evaluated the adequacy of the licensee's corrective actions. The inspectors reviewed the licensee's work practices to evaluate whether these may have played a role in the degradation of the structures, systems, and components. The inspectors assessed the licensee's characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.
On February 2, 2016, emergency diesel generator room ventilation system On February 29, 2016, auxiliary component cooling water system The inspectors reviewed the extent of condition of possible common cause structure, system, and component failures and evaluated the adequacy of the licensee's corrective actions. The inspectors reviewed the licensee's work practices to evaluate whether these may have played a role in the degradation of the structures, systems, and components. The inspectors assessed the licensee's characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.


These activities constitute d completion of two maintenance effectiveness samples
These activities constitute d completion of two maintenance effectiveness samples , a s defined in Inspection Procedure 71111.12.
, as defined in Inspection Procedure 71111.12.


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.
{{a|1R13}}
 
==1R13 Maintenance Risk Assessments and Emergent Work Control==
1 R 13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
{{IP sample|IP=IP 71111.13}}


====a. Inspection Scope====
====a. Inspection Scope====
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The inspectors also observed portions of three emergent work activities that had the potential to cause an initiating event and to affect the functional capability of mitigating systems:
The inspectors also observed portions of three emergent work activities that had the potential to cause an initiating event and to affect the functional capability of mitigating systems:
On January 20, 2016, emergent work on core element assembly driv e mechanism motor generator set B  On March 4, 2015, emergent work on core element drive mechanism control system  On March 23, 2016, emergent yellow risk due to isolation of the essential chiller train AB The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected structures, systems, and components
On January 20, 2016, emergent work on core element assembly driv e mechanism motor generator set B  On March 4, 2015, emergent work on core element drive mechanism control system  On March 23, 2016, emergent yellow risk due to isolation of the essential chiller train AB The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected structures, systems, and components
. These activities constitute completion of five maintenance risk assessments and emergent work control inspection samples
. These activities constitute completion of five maintenance risk assessments and emergent work control inspection samples , as defined in Inspection Procedure 71111.13.
, as defined in Inspection Procedure 71111.13.


====b. Findings====
====b. Findings====
Failure to Assess and Manage the Increase in Risk from Emergent Maintenance Activities Introduction
Failure to Assess and Manage the Increase in Risk from Emergent Maintenance Activities Introduction
. The inspectors identified a Green non-cited violation of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," section a(4), for the licensee's failure to assess and manage the increase in risk during an auxiliary component cooling water (ACCW) system work window. Specifically, the licensee failed to re
. The inspectors identified a Green non-cited violation of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," section a(4), for the licensee's failure to assess and manage the increase in risk during an auxiliary component cooling water (ACCW) system work window. Specifically, the licensee failed to re
-asses risk when a dry cooling tower fan in the component cooling water (CCW) system was declared unavailable during the ongoing ACCW system work window. As a result, for approximately 6 hours, on
-asses risk when a dry cooling tower fan in the component cooling water (CCW) system was declared unavailable during the ongoing ACCW system work window. As a result, for approximately 6 hours, on-line risk was maintained as Green when it should have been elevated to Orange, which would have required additional risk management actions.
-line risk was maintained as Green when it should have been elevated to Orange, which would have required additional risk management actions.


=====Description.=====
=====Description.=====
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-line risk was restored to Green at 7:45 p.m. the same day.
-line risk was restored to Green at 7:45 p.m. the same day.


During their review of this issue, the inspectors noted that the licensee had not identified the inadequate timeliness with which the risk assessment was performed. Procedure EN-WM-104, "On-Line Risk Assessment," step 5.2[1](a) states that operations will perform risk assessments for emergent items, unplanned maintenance activities, or conditions impacting risk as soon as practical using quantitative and/or qualitative considerations. The inspectors also noted that this failure to adequately assess and manage risk was not recognized as a failure to meet site expectations since operations personnel were under the mindset that it was not a significant issue because this condition was allowed by plant technical specifications
During their review of this issue, the inspectors noted that the licensee had not identified the inadequate timeliness with which the risk assessment was performed. Procedure E N-WM-104, "On-Line Risk Assessment," step 5.2[1](a) states that operations will perform risk assessments for emergent items, unplanned maintenance activities, or conditions impacting risk as soon as practical using quantitative and/or qualitative considerations. The inspectors also noted that this failure to adequately assess and manage risk was not recognized as a failure to meet site expectations since operations personnel were under the mindset that it was not a significant issue because this condition was allowed by plant technical specifications.
.


=====Analysis.=====
=====Analysis.=====
The inspectors determined that the licensee's failure to re
The inspectors determined that the licensee's failure to re
-assess and manage the increase in risk during an ACCW system work window when dry cooling tower fan 12A became unexpectedly unavailable was a performance deficiency which was reasonably within their ability to foresee and correct. The performance deficiency was more than minor, and therefore a finding, because it associated with the configuration control 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, by not ensuring the risk assessment was adequate when an additional component was emergently declared unavailable, the licensee proceeded with a maintenance work window with no understanding of the increased risk associated with a different plant configuration. As a result, additional risk mitigating actions were not performed and activities to restore the plant to a lower risk condition were delayed.
-assess and manage the increase in risk during an ACCW system work window when dry cooling tower fan 12A became unexpectedly unavailable was a performance deficiency which was reasonably within their ability to foresee and correct. The performance deficiency was more than minor, and therefore a finding, because it associated with the configuration control 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, by not ensuring the risk assessment was adequate when an additional component was emergently declared unavailable, the licensee proceeded with a maintenance work window with no understanding of the increased risk associated with a different plant configu ration. As a result, additional risk mitigating actions were not performed and activities to restore the plant to a lower risk condition were delayed.


The inspectors used Inspection Manual Chapter 0609, Appendix K, "Maintenance Risk Assessment and Risk Management Significance Determination Process," dated May 19, 2005, Flowchart 1, "Assessment of Risk Deficit
The inspectors us ed Inspection Manual Chapter 0609, Appendix K, "Maintenance Risk Assessment and Risk Management Significance Determination Process," dated May 19, 2005, Flowchart 1, "Assessment of Risk Deficit
," and determined the need to calculate the risk deficit to determine the significance of this issue. The risk deficits were assumed to be equal to the incremental core damage probability (ICDP)actual and incremental large early release probability (ILERP)actual. The Waterford probabilistic risk assessment model yielded an incremental core damage probability (ICDP), or actual increase in risk during this work window, of 6.1x10
," and determined the need to calculate the risk deficit to determine the significance of this issue. The risk deficits were assumed to be equal to the incremental core damage probability (ICDP)actual and incremental large early release probability (ILERP)actual. The Waterford probabilistic risk assessment model yielded an incremental core damage probability (ICDP), or actual increase in risk during this work window, of 6.1x10
-8. The regional senior reactor analyst evaluated the licensee's risk significance evaluation and agreed with the results from the licensee's model. The ILERP, screened out as not risk significant
-8. The regional senior reactor analyst evaluated the licensee's risk significance evaluation and agreed with the results from the licensee's model. The ILERP, screened out as not risk significant. In accordance with Flowchart 1 in Appendix K, because the ICDP was less than 1x10
. In accordance with Flowchart 1 in Appendix K, because the ICDP was less than 1x10
-6 and the ILERP was less than 1x10-7, the finding screened as having very low safety significance (Green). This finding had a cross
-6 and the ILERP was less than 1x10-7, the finding screened as having very low safety significance (Green). This finding had a cross
-cutting aspect in the area of human performance, procedure adherence, because individuals did not follow processes, procedures and work instructions. Specifically, when dry cooling tower fan 12A was declared unavailable, the licensee did not re
-cutting aspect in the area of human performance, procedure adherence, because individuals did not follow processes, procedures and work instructions. Specifically, when dry cooling tower fan 12A was declared unavailable, the licensee did not re
Line 293: Line 269:
Title 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," section a(4), state s, in part, that the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities.
Title 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," section a(4), state s, in part, that the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities.


Contrary to the above, on January 26, 2016, the licensee failed to assess and manage risk that resulted from a proposed maintenance activity. Specifically, during an ACCW system maintenance work window, a dry cooling tower fan in the CCW system was emergently declared unavailable; however, the increase in risk was not adequately accounted for in a timely manner in accordance with site procedures. As a result, for approximately 6 hours, on
Contrary to the above, on January 26, 2016, the licensee failed to assess and manage risk that resulted from a proposed maintenance activity. Specifically, during an ACCW system maintenance work window, a dry cooling tower fan in the CCW system was emergently declared unavailable; however, the increase in risk was not adequately accounted for in a timely manner in accordance with site procedures. As a result, for approximately 6 hours, on-line risk was maintained as Green when it should have b een elevated to Orange, which would have required additional risk management actions. The licensee entered this issue into their corrective action program as Condition Report CR-WF3-2016-0660. Corrective actions included restoring the dry cooling tower fan to available status such that risk returned to Green, and sending a communication to operations supervisors to re
-line risk was maintained as Green when it should have b een elevated to Orange, which would have required additional risk management actions. The licensee entered this issue into their corrective action program as Condition Report CR-WF3-2016-0660. Corrective actions included restoring the dry cooling tower fan to available status such that risk returned to Green, and sending a communication to operations supervisors to re
-emphasize the requirements to adequately address unavailability of plant components. Because the licensee has entered the issue into their corrective action program and the finding is of very low safety significance, this violation of 10 CFR 50.65(a)(4) is being treated as an non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy
-emphasize the requirements to adequately address unavailability of plant components. Because the licensee has entered the issue into their corrective action program and the finding is of very low safety significance, this violation of 10 CFR 50.65(a)(4) is being treated as an non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy
:  NCV 05000382/2016001
:  NCV 05000382/2016001
-01, "Failure to Assess and Manage the Increase in Risk from Emergent Maintenance Activities.
-01, "Failure to Assess and Manage the Increase in Risk from Emergent Maintenance Activities.


"  1R15 Operability Determinations and Functionality Assessments (71111.15)
"  1 R 15 Operability Determinations and Functionality Assessments (71111.15)


====a. Inspection Scope====
====a. Inspection Scope====
Line 309: Line 284:
====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.
{{a|1R18}}
 
==1R18 Plant Modifications==
1 R 18 Plant Modifications (71111.18)
{{IP sample|IP=IP 71111.18}}


====a. Inspection Scope====
====a. Inspection Scope====
On January 11, 2016, the inspectors reviewed a permanent modification to the speed sensors associated with reactor coolant pump 2A and core protection calculator B. The inspectors reviewed the design and implementation of the modification. The inspectors verified that work activities involved in implementing the modification did not adversely impact operator actions that may be required in response to an emergency or other unplanned event. The inspectors verified that post
On January 11, 2016, the inspectors reviewed a permanent modification to the sp eed sensors associated with reactor coolant pump 2A and core protection calculator B. The inspectors reviewed the design and implementation of the modification. The inspectors verified that work activities involved in implementing the modification did not adversely impact operator actions that may be required in response to an emergency or other unplanned event. The inspectors verified that post
-modification testing was adequate to establish the operability of the structures, systems, or components as modified.
-modification testing was adequate to establish the operability of the structures, systems, or components as modified.


These activities constitute completion of one sample of permanent modifications
These activities constitute completion of one sample of permanent modifications , a s defined in Inspection Procedure 71111.18.
, as defined in Inspection Procedure 71111.18.


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.
{{a|1R19}}
==1R19 Post-Maintenance==


Testing (71111.19)
1 R 19 Post-Maintenance Testing (71111.19)


====a. Inspection Scope====
====a. Inspection Scope====
Line 334: Line 305:


The inspectors observed the performance of the post
The inspectors observed the performance of the post
-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected structures, systems, or component s. These activities constitute completion of five post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.
-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected structures, systems, or component s. These activities constitute completion of five post-maintenance testing inspection samples , as defined in Inspection Procedure 71111.19.


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.
{{a|1R22}}
 
==1R22 Surveillance Testing==
1 R 22 Surveillance Testing (71111.22)
{{IP sample|IP=IP 71111.22}}


====a. Inspection Scope====
====a. Inspection Scope====
Line 348: Line 318:
On January 11, 2016, review of missed surveillance for wet and dry cooling tower operability On February 25, 2016, core protection calculato r train A  On March 1, 2016, containment spray pump A The inspectors verified that these test s met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected structures, systems, and component s following testing.
On January 11, 2016, review of missed surveillance for wet and dry cooling tower operability On February 25, 2016, core protection calculato r train A  On March 1, 2016, containment spray pump A The inspectors verified that these test s met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected structures, systems, and component s following testing.


These activities constitute completion of five surveillance testing inspection samples
These activities constitute completion of five surveillance testing inspection samples , a s defined in Inspection Procedure 71111.22.
, as defined in Inspection Procedure 71111.22.


====b. Findings====
====b. Findings====
Line 355: Line 324:


==RADIATION SAFETY==
==RADIATION SAFETY==
Cornerstones: Public Radiation Safety and Occupational Radiation Safety
Cornerstones: Public Radiation Safety and Occupational Radiation Safety 2 RS 1 Radiological Hazard Assessment and Exposure Controls (71124.01)
{{a|2RS1}}
==2RS1 Radiological Hazard Assessment and Exposure Controls==
{{IP sample|IP=IP 71124.01}}


====a. Inspection Scope====
====a. Inspection Scope====
Line 369: Line 335:
====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.
{{a|2RS3}}
 
==2RS3 In-plant Airborne Radioactivity Control and Mitigation==
2 RS 3 In-plant Airborne Radioactivity Control and Mitigation (71124.03)
{{IP sample|IP=IP 71124.03}}


====a. Inspection Scope====
====a. Inspection Scope====
Line 387: Line 352:


==OTHER ACTIVITIES==
==OTHER ACTIVITIES==
Cornerstones:  Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security
Cornerstones:  Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security 4OA 1 Performance Indicator Verification (71151)
{{a|4OA1}}
 
==4OA1 Performance Indicator Verification==
{{IP sample|IP=IP 71151}}
===.1 Unplanned Scrams per 7000===
===.1 Unplanned Scrams per 7000===


Line 396: Line 359:


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed licensee event reports for the period of January 1 through December 31, 2015, to determine the number of scrams that occurred. The inspectors compared the number of scrams reported in th ese licensee event reports to the number reported for the performance indicator. Additionally, the inspectors sampled monthly operating logs to verify the number of critical hours during the period.
The inspectors reviewed licensee event reports for the period of January 1 through December 31, 2015 , to determine the number of scrams that occurred. The inspectors compared the number of scrams reported in th ese licensee event reports to the number reported for the performance indicator. Additionally, the inspectors sampled monthly operating logs to verify the number of critical hours during the period.


The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of the data reported.
The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of the data reported.
Line 432: Line 395:
The inspectors verified that there were no unplanned exposures or losses of radiological control over locked high radiation areas and very high radiation areas during the period of October 1, 2015 to December 31, 2015. The inspectors reviewed a sample of radiologically controlled area exit transactions showing exposures greater than  
The inspectors verified that there were no unplanned exposures or losses of radiological control over locked high radiation areas and very high radiation areas during the period of October 1, 2015 to December 31, 2015. The inspectors reviewed a sample of radiologically controlled area exit transactions showing exposures greater than  


100 mRem. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99
100 m Rem. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99
-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of the reported data.
-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of the reported data.


Line 451: Line 414:
No findings were identified.
No findings were identified.


{{a|4OA2}}
4OA 2 Problem Identification and Resolution (71152)
==4OA2 Problem Identification and Resolution==
 
(71152)


===.1 Routine Review===
===.1 Routine Review===
Line 482: Line 442:
====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.
{{a|4OA3}}
 
==4OA3 Follow-up of Events and Notices of Enforcement Discretion==
4OA 3 Follow-up of Events and Notices of Enforcement Discretion (71153)
{{IP sample|IP=IP 71153}}
 
===.1 (Closed) Licensee Event Report===
===.1 (Closed) Licensee Event Report===


05000382/2015 01, "Manual Reactor Trip due to Low Steam Generator Levels
05000382/2015 01 , "Manual Reactor Trip due to Low Steam Generator Levels
" On June 3, 2015, at approximately 5:05 p.m., the control room operators manually tripped the reactor in anticipation of an automatic reactor trip. The inspectors' review of the reactor trip was documented in NRC Integrated Inspection Report 05000382/2015003. Following the reactor trip, off-site power train B failed to transfer from the unit auxiliary transformer to the unit startup transformers. Subsequently, emergency diesel generator B started and powered the safety
" On June 3, 2015, at approximately 5:05 p.m., the control room operators manually tripped the reactor in anticipation of an automatic reactor trip. The inspectors' review of the reactor trip was documented in NRC Integrated Inspection Report 05000382/2015003. Following the reactor trip, off-site power train B failed to transfer from the unit auxiliary transformer to the unit startup transformers. Subsequently, emergency diesel generator B started and powered the safety
-related train B electrical buses. In reviewing the causes of the failure of the fast bus transfer, the inspectors reviewed a performance deficiency associated with the design of the alarm circuit installed for the fast bus transfer electrical components.
-related train B electrical buses. In reviewing the causes of the failure of the fast bus transfer, the inspectors reviewed a performance deficiency associated with the design of the alarm circuit installed for the fast bus transfer electrical components.


However, since the alarm circuit did not play a role in the failure of the fast bus transfer, the inspectors determined the performance deficiency to be minor. The previous revision of this licensee event report was included as part of this review
However, since the alarm circuit did not play a role in the failure of the fast bus transfer, the inspectors determined the performance deficiency to be minor. The previous revision of this licensee event report was included as part of this review. Th is licensee event report is closed.
. This licensee event report is closed.


===.2 (Closed) Licensee Event Report 05000382/201===
===.2 (Closed) Licensee Event Report 05000382/201===


4-004-03, "Emergency Diesel Generators Rendered Inoperable by Potential Water Intrusion into Diesel Fuel Oil Feed Tanks
4-00 4-03 , "Emergency Diesel Generators Rendered Inoperable by Potential Water Intrusion into Diesel Fuel Oil Feed Tanks
" During a plant walk-down on October 22, 2014, the inspectors identified through-wall corrosion on the emergency diesel generator fuel oil day tank vents.
" During a plant walk-down on October 22, 2014, the inspector s identified through-wall corrosion on the emergency diesel generator fuel oil day tank vents.


The holes in these vent pipes could have allowed water to enter the day tanks and contaminate the diesel fuel oil, challenging the operability a nd functionality of both safety
The holes in these vent pipes could have allowed water to enter the day tanks and contaminate the diesel fuel oil, challenging the operability a nd functionality of both safety
Line 505: Line 464:


The inspectors review ed the licensee event report associated with this event and did not identify additional performance deficiencies. The previous revisions of this licensee event report were included as part of this review. This licensee event report is closed. These activities constitute completion of two event follow
The inspectors review ed the licensee event report associated with this event and did not identify additional performance deficiencies. The previous revisions of this licensee event report were included as part of this review. This licensee event report is closed. These activities constitute completion of two event follow
-up samples, as defined in Inspection Procedure 71153.
-up samples, as defined in Inspection Procedure 71153. 4OA 5 Other Activities Temporary Instruction 2515/190 - Inspection of the Proposed Interim Actions Associated with Near-Term Task Force Recommendation 2.1 Flooding Hazard Evaluations.
{{a|4OA5}}
==4OA5 Other Activities==
 
Temporary Instruction 2515/190  
- Inspection of the Proposed Interim Actions Associated with Near
-Term Task Force Recommendation 2.1 Flooding Hazard Evaluations.


The inspectors independently verified that the licensee's proposed interim actions would perform their intended function for flooding mitigation. Specifically:
The inspectors independently verified that the licensee's proposed interim actions would perform their intended function for flooding mitigation. Specifically:
Line 524: Line 477:
-downs, the inspectors only identified administrative issues. The inspectors verified that the licensee entered those issues into their corrective action program.
-downs, the inspectors only identified administrative issues. The inspectors verified that the licensee entered those issues into their corrective action program.


{{a|4OA6}}
4OA 6 Meetings, Including Exit
==4OA6 Meetings, Including Exit==


===Exit Meeting Summary===
===Exit Meeting Summary===
Line 533: Line 485:
On April 21, 2016, the resident inspectors presented the inspection results to Mr. Michael Chisum, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
On April 21, 2016, the resident inspectors presented the inspection results to Mr. Michael Chisum, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.


{{a|4OA7}}
4OA 7 Licensee-Identified Violations The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy fo r being dispositioned as a non
==4OA7 Licensee-Identified Violations==
-cited violation s.
 
The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy fo r being dispositioned as a non
-cited violations.


Technical Specification 6.8.1, states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, "Quality Assurance Program Requirements," Appendix A, Section 2.l, requires procedures for refueling and core alterations. Step 6.2.1 of Procedure OP 005, Revision 309, "RCS Drain and Fill Below RCS Hot Leg Centerline," instructs the licensee to verify, in part, that "Containment Purge is aligned for Refueling Ventilation with RAB Normal Ventilation, or adequate provisions or controls are in place to acceptably address radiological concerns."  Contrary to the above, on November 18, 2015, the licensee failed to verify that Containment Purge was aligned for Refueling Ventilation with RAB Normal Ventilation or that adequate controls were in place to acceptably address radiological concerns. Specifically, the licensee proceeded with RCS fill without radiation protection monitoring for airborne radioactivity in the vicinity of the TRH hoses as required. The alignment for Refueling Ventilation was not completed because the required valve (CAP
Technical Specification 6.8.1, states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, "Quality Assurance Program Requirements," Appendix A, Section 2.l, requires procedures for refueling and core alterations. Step 6.2.1 of Procedure OP 005, Revision 309, "RCS Drain and Fill Below RCS Hot Leg Centerline," instructs the licensee to verify, in part, that "Containment Purge is aligned for Refueling Ventilation with RAB Normal Ventilation, or adequate provisions or controls are in place to acceptably address radiological concerns."  Contrary to the above, on November 18, 2015, the licensee failed to verify that Containment Purge was aligned for Refueling Ventilation with RAB Normal Ventilation or that adequate controls were in place to acceptably address radiological concerns. Specifically, the licensee proceeded with RCS fill without radiation protection monitoring for airborne radioactivity in the vicinity of the TRH hoses as required. The alignment for Refueling Ventilation was not completed because the required valve (CAP
Line 564: Line 513:
: [[contact::J. Jarrell]], Director, Regulatory & Performance Improvement
: [[contact::J. Jarrell]], Director, Regulatory & Performance Improvement
: [[contact::B. Lanka]], Director, Engineering
: [[contact::B. Lanka]], Director, Engineering
: [[contact::N. Lawless]], Manager, Chemistry
: [[contact::N. Lawless ]], Manager, Chemistry
: [[contact::B. Lindsey]], Senior Manager, Operations
: [[contact::B. Lindsey]], Senior Manager, Operations
: [[contact::W. McKinney]], Manager, Training
: [[contact::W. McKinney]], Manager, Training
Line 576: Line 525:
: [[contact::R. Simpson]], Superintendent, Operator Training  
: [[contact::R. Simpson]], Superintendent, Operator Training  
: [[contact::M. Vollmer]], CHP, Specialist Radiation Protection
: [[contact::M. Vollmer]], CHP, Specialist Radiation Protection
: [[contact::M. Zamber]], Licensing Specialist, Regulatory Assurance
: [[contact::M. Zamber]], Licensing Specialist, Regulatory Assurance
 
===NRC Personnel===
===NRC Personnel===
: [[contact::R. Deese]], Senior Reactor Analyst
: [[contact::R. Deese]], Senior Reactor Analyst
Line 584: Line 532:


===Opened and Closed===
===Opened and Closed===
: 05000382-2016-001-01 NCV Failure to Assess and Manage the Increase in Risk from Emergent Maintenance Activities
 
05000 382-2016-001-01 NCV Failure to Assess and Manage the Increase in Risk from Emergent Maintenance Activities
  (Section 1R13)   
  (Section 1R13)   
===Closed===
===Closed===
: 05000382/2015
: 05000382/2015
-005-01 LER Manual Reactor Trip due to Low Steam Generator Levels (Section 4OA3.1)  
-005-0 1 LER Manual Reactor Trip due to Low Steam Generator Levels (Section 4OA3.1)  
: 05000382/201
: 05000382/201
: 4-004-03 LER Emergency Diesel Generators Rendered Inoperable by Potential Water Intrusion into Diesel Fuel Oil Feed Tanks
: 4-00 4-0 3 LER Emergency Diesel Generators Rendered Inoperable by Potential Water Intrusion into Diesel Fuel Oil Feed Tanks
  (Section 4OA3.2)   
  (Section 4OA3.2)   


Line 626: Line 575:
: RAB 32-001 Waterford S.E.S Prefire Strategy Elev. -4.00', -35.00' RAB (RCA)
: RAB 32-001 Waterford S.E.S Prefire Strategy Elev. -4.00', -35.00' RAB (RCA)
: Auxiliary Component Cooling Water Room and Pipe Penetration Area
: Auxiliary Component Cooling Water Room and Pipe Penetration Area
: RAB 6-001 Waterford S.E.S Prefire Strategy Elev. +35.00' RAB Electrical Penetration Area "A"
: RAB 6-001 Waterford S.E.S Prefire Strategy Elev. +35.00' RAB Electri cal Penetration Area "A"
: ROOF E-001 Waterford S.E.S Prefire Strategy Elev. +46.00' ROOF E (MSIV B)
: ROOF E-001 Waterford S.E.S Prefire Strategy Elev. +46.00' ROOF E (MSIV B)


Line 653: Line 602:
: CR-WF3-2016-01389
: CR-WF3-2016-01389
: CR-WF3-2012-02692
: CR-WF3-2012-02692
: CR-WF3-2012-03280 CR-WF3-2015-06782
: CR-WF3-2012-0 3280 CR-WF3-2015-06782


==Section 1R13: Maintenance Risk Assessments and Emergent Work Control==
==Section 1R13: Maintenance Risk Assessments and Emergent Work Control==
Line 698: Line 647:
: General Electric Spare Reactor Coolant Pump Motor Description
: General Electric Spare Reactor Coolant Pump Motor Description
: TD G080.0455
: TD G080.0455
: General Electric Spare Reactor Coolant Pump Motor Operation
: General Electric Spare Reactor Coolant Pump Motor Operation 0 TD G080.0465
: TD G080.0465
: General Electric Spare Reactor Coolant Pump Motor Maintenance  
: General Electric Spare Reactor Coolant Pump Motor Maintenance  
===Condition Reports===
===Condition Reports===
Line 716: Line 664:
: Procedures/Documents Number Title Revision TMOD 62287
: Procedures/Documents Number Title Revision TMOD 62287
: Replacing CPC Channel B RCP
: Replacing CPC Channel B RCP
-2A Speed Sensor with COLSS RCP
-2A Speed Sensor with COLSS
-2A Speed Sensor  
: RCP-2A Speed Sensor  
===Condition Reports===
===Condition Reports===
: CR-WF3-2015-09183
: CR-WF3-2015-09183
Line 746: Line 694:
: OP-903-121 Safety Systems Quarterly IST Valve Tests
: OP-903-121 Safety Systems Quarterly IST Valve Tests
: STA-001-005 Leakage Testing of Air and Nitrogen Accumulators for Safety Related Systems
: STA-001-005 Leakage Testing of Air and Nitrogen Accumulators for Safety Related Systems
: 317 TD-A180.0075
: 317
: Allis-Chalmers Installation Operation Maintenance Instruction Induction Motors Vertical "P" Flanged 0  
: TD-A180.0075 Allis-Chalmers Installation Operation Maintenance Instruction Induction Motors Vertical "P" Flanged 0  
===Condition Reports===
===Condition Reports===
: CR-WF3-2015-09592
: CR-WF3-2015-09592
Line 862: Line 810:
: EN-RP-404 Operation and Maintenance of HEPA Vacuum Cleaners and HEPA Ventilation Units
: EN-RP-404 Operation and Maintenance of HEPA Vacuum Cleaners and HEPA Ventilation Units
: EN-RP-501 Respiratory Protection Program
: EN-RP-501 Respiratory Protection Program
: EN-RP-502 Inspection and Maintenance of Respiratory Protection Equipment
: EN-RP-502 Inspection and Maintenance of Respiratory Protection Equipment 9
: EN-RP-502-01 Fire Hawk M7 SCBA
: EN-RP-502-01 Fire Hawk M7 SCBA
: EN-RP-502-02 Flow Testing MSA Breathing Apparatus
: EN-RP-502-02 Flow Testing MSA Breathing Apparatus
Line 953: Line 901:
- 2015 Quarter 3
- 2015 Quarter 3
rd Quarter 0 W3F1-2016-0005 NRC Performance Indicator (PI) Data  
rd Quarter 0 W3F1-2016-0005 NRC Performance Indicator (PI) Data  
- 4th Quarter 2015
- 4 th Quarter 2015
: W3F1-2016-0011 NRC Performance Indicator (PI) Data  
: W3F1-2016-0011 NRC Performance Indicator (PI) Data  
- Change Report Data 4th Quarter 2015 SCRAM without complications correction
- Change Report Data 4 th Quarter 2015 SCRAM without complications correction


==Section 4OA2: Problem Identification and Resolution==
==Section 4OA2: Problem Identification and Resolution==
Line 993: Line 941:
: Warning Time for Maximum Precipitation Events
: Warning Time for Maximum Precipitation Events
  (prepared by the Nuclear Energy Institute)
  (prepared by the Nuclear Energy Institute)
: WF3-CS-15-00010 Waterford Steam Electric Station Unit 3 Fukushima Flood Hazard Re
: WF3-CS-15-00010 Waterford Steam Electric Station Unit 3 Fukushima Flood Hazard Re-evaluation Report
-evaluation Report
: W3F1-2015-0042 Flood Hazard Reevaluation Report Waterford Steam Electric Station, Unit 3 (Waterford 3)
: W3F1-2015-0042 Flood Hazard Reevaluation Report Waterford Steam Electric Station, Unit 3 (Waterford 3)
: July 21, 2015
: July 21 , 2015
: WO 00420362 01
: WO 00420362 01
  [REACTOR CONTAINMENT BUILDING  
  [REACTOR CONTAINMENT BUILDING  
Line 1,002: Line 949:
===Condition Reports===
===Condition Reports===
: CR-WF3-2015-01282         
: CR-WF3-2015-01282         
: Attachment The following items are requested for the Occupational Radiation Safety Inspection at Waterford
: A 2-1 Attachment The following items are requested for the Occupational Radiation Safety Inspection at Waterford
-3 (March 21  
-3 (March 21  
- March 25, 2016)
- March 25, 2016)
Line 1,025: Line 972:
: Existing information collection requirements were approved by the Office of Management and Budget, control number 3150
: Existing information collection requirements were approved by the Office of Management and Budget, control number 3150
-0011.
-0011.
: 1. Radiological Hazard Assessment and Exposure Controls (71124.01) and Performance Indicator Verification (71151)
: A 2-2 1. Radiological Hazard Assessment and Exposure Controls (71124.01) and Performance Indicator Verification (71151)
: Date of Last Inspection:
: Date of Last Inspection:
: October 26, 2015
: October 26, 2015
Line 1,055: Line 1,002:
: G. List of radiologically significant work activities scheduled to be conducted during the inspection period (If the inspection is scheduled during an outage, please also include a list of work activities greater than 1 rem, scheduled during the outage with the dose estimate for the work activity.)
: G. List of radiologically significant work activities scheduled to be conducted during the inspection period (If the inspection is scheduled during an outage, please also include a list of work activities greater than 1 rem, scheduled during the outage with the dose estimate for the work activity.)
: H. List of active radiation work permits
: H. List of active radiation work permits
: I. Radioactive source inventory list:
: A 2-3 I. Radioactive source inventory list:
a.
a.
: All radioactive sources that are required to be leak tested
: All radioactive sources that are required to be leak tested
Line 1,096: Line 1,043:
: 2. Self-contained breathing apparatuses  
: 2. Self-contained breathing apparatuses  
: 3. Respiratory protection program
: 3. Respiratory protection program
: NOTE:
: A 2-4 NOTE:
: The lists should indicate the significance level of each issue and the search criteria used.
: The lists should indicate the significance level of each issue and the search criteria used.
: Please provide in document formats which are "searchable" so that the inspector can perform word searches.
: Please provide in document formats which are "searchable" so that the inspector can perform word searches.

Revision as of 11:48, 8 July 2018

Waterford Steam Electric Station, Unit 3 - NRC Integrated Inspection Report 05000382/2016001, January 1, 2016 Through March 31, 2016
ML16116A210
Person / Time
Site: Waterford Entergy icon.png
Issue date: 04/25/2016
From: Josey J E
NRC/RGN-IV/DRP/RPB-D
To: Chisum M R
Entergy Operations
Josey J E
References
IR 2016001
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UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 1600 E. LAMAR BLVD.

ARLINGTON, TX 76011-4511 April 25, 2016 Mr. Michael Site Vice President Entergy Operations, Inc.

17265 River Road Killona, LA 70057

-0751

SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3

- NRC INTEGRATED INSPECTION REPORT 05000382/2016 001

Dear Mr. Chisum:

On March 31, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford Steam Electric Station, Unit 3. On April 21, 2016, 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 one finding of very low safety significance (Green) in this report. This finding involved a violation of NRC requirements. Further, inspectors documented a licensee-identified violation which was determined to be of very low safety significance.

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

If you contest the violation s or significance of the NCV s, 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

. If you disagree with the cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV; and the NRC resident inspector at the Waterford Steam Electric Station, Unit 3

. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding," a copy of this letter, its enclosure, and your response (if any) will be available electronically 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/

Jeffrey Josey , Acting Chief Projects Branch D Division of Reactor Projects Docket No.

50-382 License No

. NPF-38

Enclosure:

Inspection Report 05000382/2016-001 w/ Attachment s: 1. Supplemental Information 2. The following items are requested for the Occupational Radiation Safety Inspection

cc w/ encl: Electronic Distribution

ML16116A21 0 SUNSI Review By: JEJ ADAMS Yes No Non-Sensitive Sensitive Publicly Available Non-Publicly Available Keyword: NRC-002 OFFICE SRI:DRP/D RI:DRP/D C:DRS/EB1 C:DRS/EB2 C:DRS/OB C:DRS/PSB1 C:DRS/PSB2 NAME FRamirez CSpeer TFarnholtz GWerner VGaddy MHaire HGepford SIGNATURE /RA-E/ /RA-E/ /RA/ /RA/ /RA/ JKirkland, for /RA/ /RA/ DATE 4/22/16 4/22/16 4/15/16 4/20/16 4/21/16 4/21/16 4/21/16 OFFICE TL:DRS/TSS BC:DRP/D NAME THipschman JJosey SIGNATURE /RA/ /RA/ DATE 4/19/16 4/25/16 Letter to Michael from Jeffrey Josey April 25, 2016

SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3

- NRC INTEGRATED

INSPECTION REPORT 05000382/2016001 DISTRIBUTION

Regional Administrator (Marc.Dapas@nrc.gov)

Deputy Regional Administrator (Kriss.Kennedy@nrc.gov) DRP Director (Troy.Pruett@nrc.gov)

DRP Deputy Director (Ryan.Lantz@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

DRS Deputy Director (Jeff.Clark@nrc.gov)

Senior Resident Inspector (Frances.Ramirez@nrc.gov)

Resident Inspector (Chris.Speer@nrc.gov)

WAT Administrative Assistant (Dawn

.Yancey@nrc.gov) Acting Branch Chief, DRP/D (Jeffrey.Josey@nrc.gov) Project Engineer, DRP/D (Jan.Tice@nrc.gov)

Project Engineer, DRP/D (Jim.Melfi@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov

) Project Manager (April.Pulvirenti@nrc.gov)

Team Leader, DRS/TSS (Thomas.Hipschman@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

RIV Congressional Affairs Officer (Angel.Moreno@nrc.gov)

RIV/ETA: OEDO (Jeremy.Bowen@nrc.gov)

RIV RSLO (Bill.Maier@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

ROPreports.Resource@nrc.gov ROPassessment.Resource@nrc.gov Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 05000 382 License: NPF-38 Report: 05000 382/20 1 6 0 01 Licensee: Entergy Operations, Inc.

Facility: Waterford Steam Electric Station, Unit 3 Location: 17265 River Road Killona, LA 70057 Dates: January 1 through Ma r ch 3 1, 20 16 Inspectors:

F. Ramírez, Senior Resident Inspector C. Speer, Resident Inspector B. Hagar, Senior Project Engineer L. Carson, II, Senior Health Physicist N. Greene, PhD, Health Physicist Approved By:

Jeffrey Josey Acting Chief, Project s Branch D Division of Reactor Projects

SUMMARY

IR 05000 382/20 16001; 01/01/20 16 - 03/31/20 16; Waterford Steam Electric Station, Unit 3; Maintenance Risk Assessments and Emergent Work Control The inspection activities described in this report were performed between January 1 and March 31 , 2016 , by the resident inspectors and inspectors from the NRC's Region IV office. One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609, "Significance Determination Process." Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, "Aspects within the Cross-Cutting Areas." Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG

-1649, "Reactor Oversight Process."

Cornerstone: Mitigating Systems

Green.

The inspectors identified a non-cited violation of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," section a(4), for the licensee's failure to assess and manage the increase in risk during an auxiliary component cooling water system work window. Specifically, the licensee failed to re-asses risk when a dry cooling tower fan in the component cooling water system was declared unavailable during the ongoing auxiliary component cooling water system work window. As a result, for approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, on-line risk was maintained as Green when it should have been elevated to Orange, which would have required additional risk management actions. The licensee entered this issue into their corrective action program as Condition Report CR-WF3-2016-0660. Corrective actions included restoring the dry cooling tower fan to available status such that risk returned to Green and sending a communication to operations supervisors to re-emphasize the requirements to adequately address unavailability of plant components.

The inspectors determined that the performance deficiency was more than minor, and therefore a finding, because it was associated with the configuration control 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, by not ensuring the risk assessment was adequate when an additional component was emergently declared unavailable, the licensee proceeded with a maintenance work window with no understanding of the increased risk associated with a different plant configu ration. The inspectors used Inspection Manual Chapter 0609, Appendix K, "Maintenance Risk Assessment and Risk Management Significance Determination Process," dated May 19, 2005, Flowchart 1, "Assessment of Risk Deficit

," and determined the need to calculate the risk deficit to determine the significance of this issue. The risk deficits were assumed to be equal to the incremental core damage probability (ICDP)actual and incremental large early release probability (ILERP)actual. The Waterford probabilistic risk assessment model yielded an incremental core damage probability (ICDP), or actual increase in risk during this work window, of 6.1x10

-8. The regional senior reactor analyst evaluated the licensee's risk significance evaluation and agreed with the results from the licensee's model.

The ILERP , screened out as not risk significant. In accordance with Flowchart in Appendix K, because the ICDP was less than 1x10

-6 and the ILERP was less than 1x10-7, the finding screened as having very low safety significance (Green). This finding has a procedure adherence cross-cutting aspect in the area of human performance, because individuals did not follow processes, procedures

, and work instructions. Specifically, when the additional dry cooling tower fan was declared unavailable, the licensee did not re-assess risk as soon as practical as specified in site procedures

[H.8]. (Section 1R13)

Licensee-Identified Violations

A violation of very low safety significance that wa s 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.

PLANT STATUS

The Waterford Steam Electric Station, Unit 3, began the inspection period at 100 percent power and remained at 100 percent power for the duration of the inspection period.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 1 R 01 Adverse Weather Protection (71111.01)

.1 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

On January 5, 2016, the inspectors completed an inspection of the station's readiness for seasonal extreme cold weather conditions. The inspectors reviewed the licensee's adverse weather procedures for the cold weather conditions and evaluated the licensee's implementation of these procedures. The inspectors verified that prior to the onset of cold weather , the licensee had corrected weather-related equipment deficiencies identified during the previous cold weather season. The inspectors selected four risk-significant systems that were required to be protected from cold weather condition s: fire protection system train A fire protection system train B security diesel generator emergency diesel generator fuel oil storage The inspectors reviewed the licensee's procedures and design information to ensure the systems would remain functional when challenged by cold weather conditions.

The inspectors verified that operator actions described in the licensee's procedures were

adequate to maintain readiness of these systems. The inspectors walked down portions of these systems to verify the physical condition of the cold weather protection features.

These activities constitute d one sample of readiness for seasonal adverse weathe r , a s defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

.2 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

On January 21, 201 6, the inspectors completed an inspection of the station's readiness for impending adverse weather conditions. The inspectors reviewed plant design features, the licensee's procedures to respond to tornadoes and high winds, and the licensee's implementation of these procedures. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant.

These activities constituted one sample of readiness for impending adverse weather conditions, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

1 R 04 Equipment Alignment (71111.04)

.1 Partial Walk

-Down

a. Inspection Scope

The inspecto rs performed partial system walk

-downs of the following risk

-significant systems: On January 21, 2016, component cooling water train A with train B out of service for maintenance On February 24, 2016, low pressure safety injection train A following maintenance On March 2, 2016, emergency feedwater train B with train A out of service for maintenance On March 22 , 2016, containment spray train A with train B out of service for maintenance The inspectors reviewed the licensee's procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems were correctly aligned for the existing plant configuration

. These activities constitute d four partial system walk

-down samples as defined i n Inspection Procedure 71111.04.

b. Findings

No findings were identified.

.2 Complete Walk

-Down

a. Inspection Scope

On February 3, 2016, the inspectors performed a complete system walk-down inspection of the auxiliary component cooling water system. The inspectors reviewed the licensee's procedures and system design information to determine the correct lineup for the existing plant configuration. The inspectors also reviewed outstanding work orders, open condition reports, in

-process design changes, temporary modifications, and other open items tracked by the licensee's operations and engineering departments. The inspectors then visually verified that the system was correctly aligned for the existing plant configuration.

These activities constitute d one complete system walk

-down sample , as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

1 R 05 Fire Protection (71111.05)

Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensee's fire protection program for operational status and material condition. The inspectors focused their inspection on five plant areas important to safety

On January 15, 2016, fire area RAB 6, electrical penetration area On January 15, 2016, fire area RAB 32, auxiliary component cooling water room and pipe penetration area On March 5, 2016, fire area RAB 18, component cooling water heat exchanger A On March 5, 2016, fire area RAB 16, emergency diesel generator 3A On March 5, 2016, fire area ROOF E, main steam isolation valve room B For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensee's fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.

These activities constitute d five quarterly inspection sample s , as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1 R 11 Licensed Operator Requalification Program and Licensed Operator Performan ce (71111.11)

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On March 8, 2016, the inspectors observed an evaluated simulator scenario performed by an operating crew. The inspectors assessed the performance of the operators and the evaluators' critique of their performance. The inspectors also assessed the modeling and performance of the simulator during the observation

. These activities constitute completion of on e quarterly licensed operator requalification program sample , as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

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.

The inspectors observed the operators' performance of the following activities:

On February 3, 2016, control room observation during the failure of the pressurizer level control system On February 12, 2016, control room observation during a toxic chemical release in the vicinity of the plant In addition, the inspectors assessed the operators' adherence to plant procedures, including conduct of operations procedure s, and other operations department policies.

These activities constitute completion of one quarterly licensed operator performance sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

1 R 12 Maintenance Effectiveness (71111.12)

a. Inspection Scope

The inspectors reviewed two instances of degraded performance or condition of safety

-related structures, systems, and components:

On February 2, 2016, emergency diesel generator room ventilation system On February 29, 2016, auxiliary component cooling water system The inspectors reviewed the extent of condition of possible common cause structure, system, and component failures and evaluated the adequacy of the licensee's corrective actions. The inspectors reviewed the licensee's work practices to evaluate whether these may have played a role in the degradation of the structures, systems, and components. The inspectors assessed the licensee's characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.

These activities constitute d completion of two maintenance effectiveness samples , a s defined in Inspection Procedure 71111.12.

b. Findings

No findings were identified.

1 R 13 Maintenance Risk Assessments and Emergent Work Control (71111.13)

a. Inspection Scope

The inspectors reviewed two risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:

On January 26, 2016, risk assessment associated with work on wet cooling tower fan 4A On January 27, 2016, risk assessment associated with work on dry cooling tower fan 12A The inspectors verified that these risk assessment were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensee's risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments.

The inspectors also observed portions of three emergent work activities that had the potential to cause an initiating event and to affect the functional capability of mitigating systems:

On January 20, 2016, emergent work on core element assembly driv e mechanism motor generator set B On March 4, 2015, emergent work on core element drive mechanism control system On March 23, 2016, emergent yellow risk due to isolation of the essential chiller train AB The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected structures, systems, and components

. These activities constitute completion of five maintenance risk assessments and emergent work control inspection samples , as defined in Inspection Procedure 71111.13.

b. Findings

Failure to Assess and Manage the Increase in Risk from Emergent Maintenance Activities Introduction

. The inspectors identified a Green non-cited violation of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," section a(4), for the licensee's failure to assess and manage the increase in risk during an auxiliary component cooling water (ACCW) system work window. Specifically, the licensee failed to re

-asses risk when a dry cooling tower fan in the component cooling water (CCW) system was declared unavailable during the ongoing ACCW system work window. As a result, for approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, on-line risk was maintained as Green when it should have been elevated to Orange, which would have required additional risk management actions.

Description.

On January 26, 2016, the licensee was conducting planned maintenance on train A of the ACCW system. In addition to ACCW train A, other unavailable plant equipment included dry cooling tower fan 1A, the train B CCW pump, and the emergency diesel generator B2 air receiver. For this work window, the Plant Safety Index had been assessed as 9.3, which meant on

-line risk was Green.

At 8:47 a.m., dry cooling tower fan 12A started in slow speed with the control switch in the off position. The control room operators placed dry cooling tower fan 12A in fast speed to maintain its availability. At 11:58 a.m., operations personnel opened the circuit breaker for dry cooling tower fan 12A because the fan started cycling and did not consistently remain in fast speed. When the operators opened the breaker for dry cooling tower fan 12A, the fan was declared unavailable for on

-line risk purposes. Since Waterford Technical Specification 3.7.3, "Component Cooling Water and Auxiliary Component Cooling Water Systems," allows up to three dry cooling tower fans to be inoperable before entering the Limiting Condition for Operation Action Statement, operations personnel did not consider it a priority to immediately assess the impact of this additional unavailability on on

-line risk. Consequently, the site proceeded with the maintenance activities on the ACCW system as planned.

At 5:45 p.m., a risk assessment was completed and operations personnel discovered that the Plant Safety Index had changed to 7.6 when dry cooling tower fan 12A was declared unavailable. As a result, the plant's on

-line risk was Orange and had been in that condition for nearly 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. After this discovery, the licensee took actions to lower on-line risk by closing the breaker on dry cooling tower fan 12A and restoring it to available status.

The plant's on

-line risk was restored to Green at 7:45 p.m. the same day.

During their review of this issue, the inspectors noted that the licensee had not identified the inadequate timeliness with which the risk assessment was performed. Procedure E N-WM-104, "On-Line Risk Assessment," step 5.2[1](a) states that operations will perform risk assessments for emergent items, unplanned maintenance activities, or conditions impacting risk as soon as practical using quantitative and/or qualitative considerations. The inspectors also noted that this failure to adequately assess and manage risk was not recognized as a failure to meet site expectations since operations personnel were under the mindset that it was not a significant issue because this condition was allowed by plant technical specifications.

Analysis.

The inspectors determined that the licensee's failure to re

-assess and manage the increase in risk during an ACCW system work window when dry cooling tower fan 12A became unexpectedly unavailable was a performance deficiency which was reasonably within their ability to foresee and correct. The performance deficiency was more than minor, and therefore a finding, because it associated with the configuration control 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, by not ensuring the risk assessment was adequate when an additional component was emergently declared unavailable, the licensee proceeded with a maintenance work window with no understanding of the increased risk associated with a different plant configu ration. As a result, additional risk mitigating actions were not performed and activities to restore the plant to a lower risk condition were delayed.

The inspectors us ed Inspection Manual Chapter 0609, Appendix K, "Maintenance Risk Assessment and Risk Management Significance Determination Process," dated May 19, 2005, Flowchart 1, "Assessment of Risk Deficit

," and determined the need to calculate the risk deficit to determine the significance of this issue. The risk deficits were assumed to be equal to the incremental core damage probability (ICDP)actual and incremental large early release probability (ILERP)actual. The Waterford probabilistic risk assessment model yielded an incremental core damage probability (ICDP), or actual increase in risk during this work window, of 6.1x10

-8. The regional senior reactor analyst evaluated the licensee's risk significance evaluation and agreed with the results from the licensee's model. The ILERP, screened out as not risk significant. In accordance with Flowchart 1 in Appendix K, because the ICDP was less than 1x10

-6 and the ILERP was less than 1x10-7, the finding screened as having very low safety significance (Green). This finding had a cross

-cutting aspect in the area of human performance, procedure adherence, because individuals did not follow processes, procedures and work instructions. Specifically, when dry cooling tower fan 12A was declared unavailable, the licensee did not re

-assess risk as soon as practical as specified in site procedures [H.8]

.

Enforcement.

Title 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," section a(4), state s, in part, that the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities.

Contrary to the above, on January 26, 2016, the licensee failed to assess and manage risk that resulted from a proposed maintenance activity. Specifically, during an ACCW system maintenance work window, a dry cooling tower fan in the CCW system was emergently declared unavailable; however, the increase in risk was not adequately accounted for in a timely manner in accordance with site procedures. As a result, for approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, on-line risk was maintained as Green when it should have b een elevated to Orange, which would have required additional risk management actions. The licensee entered this issue into their corrective action program as Condition Report CR-WF3-2016-0660. Corrective actions included restoring the dry cooling tower fan to available status such that risk returned to Green, and sending a communication to operations supervisors to re

-emphasize the requirements to adequately address unavailability of plant components. Because the licensee has entered the issue into their corrective action program and the finding is of very low safety significance, this violation of 10 CFR 50.65(a)(4) is being treated as an non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy

NCV 05000382/2016001

-01, "Failure to Assess and Manage the Increase in Risk from Emergent Maintenance Activities.

" 1 R 15 Operability Determinations and Functionality Assessments (71111.15)

a. Inspection Scope

The inspectors reviewed five operability determinations and functionality assessments that the licensee performed for degraded or nonconforming structures, systems, or components

On January 14, 2016, operability determination of the component cooling water system On February 1, 2016, operability determination of reactor coolant pump 1B On February 16, 2016, operability determination of startup channel
  1. 1 On February 17, 2016, functionality assessment of the fire protection system On February 25, 2016, functionality assessment of the pressurizer pressure control system The inspectors reviewed the timeliness and technical adequacy of the licensee's evaluations. Where the licensee determined the degraded structure, system, or component to be operable or functional, t he inspectors verified that the licensee's compensatory measures were appropriate to provide reasonable assurance of operability or functionality. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability or functionality of the degraded structures, system, or component

. These activities constitute completion of five operability and functionality review samples as defined in Inspection Procedure 71111.15.

b. Findings

No findings were identified.

1 R 18 Plant Modifications (71111.18)

a. Inspection Scope

On January 11, 2016, the inspectors reviewed a permanent modification to the sp eed sensors associated with reactor coolant pump 2A and core protection calculator B. The inspectors reviewed the design and implementation of the modification. The inspectors verified that work activities involved in implementing the modification did not adversely impact operator actions that may be required in response to an emergency or other unplanned event. The inspectors verified that post

-modification testing was adequate to establish the operability of the structures, systems, or components as modified.

These activities constitute completion of one sample of permanent modifications , a s defined in Inspection Procedure 71111.18.

b. Findings

No findings were identified.

1 R 19 Post-Maintenance Testing (71111.19)

a. Inspection Scope

The inspectors reviewed five post-maintenance testing activities that affected risk

-significant structures, systems, or components

On January 13, 2016, dry cooling tower fan 8B On January 21, 2016, wet cooling tower fans train A On February 10, 2016, nitrogen accumulator
  1. 6 On March 10, 2016, emergency feedwater pump B On March 23, 2016, containment spray B header isolation valve CS-125B The inspectors reviewed licensing- and design-basis documents for the structures, systems, or components and the maintenance and post-maintenance test procedures.

The inspectors observed the performance of the post

-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected structures, systems, or component s. These activities constitute completion of five post-maintenance testing inspection samples , as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1 R 22 Surveillance Testing (71111.22)

a. Inspection Scope

The inspectors observed five risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the structures, systems, and components were capable of performing their safety functions:

In-service test s: On January 6, 2015, nitrogen accumulator

  1. 5 On February 12, 2016, auxiliary component cooling water pump B Other surveillance tests:

On January 11, 2016, review of missed surveillance for wet and dry cooling tower operability On February 25, 2016, core protection calculato r train A On March 1, 2016, containment spray pump A The inspectors verified that these test s met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected structures, systems, and component s following testing.

These activities constitute completion of five surveillance testing inspection samples , a s defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety 2 RS 1 Radiological Hazard Assessment and Exposure Controls (71124.01)

a. Inspection Scope

The inspectors assessed the licensee's performance in assessing the radiological hazards in the workplace associated with licensed activities. The inspectors assessed the licensee's implementation of appropriate radiation monitoring and exposure control measures for both individual and collective exposures. The inspectors walked down various portions of the plant and performed independent radiation dose rate measurements. The inspectors interviewed the radiation protection manager, radiation protection supervisors, and radiation workers. The inspectors reviewed licensee performance in the following areas:

The review of plant isotopic mix and percent abundance, including hard

-to-detect radionuclides and potential alpha hazards 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 monitoring, and surface contamination leve ls 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, implementation of EDEX, and the application of dosimetry to effectively monitor exposure for work in areas with significant dose rate gradients Controls for highly activated or contaminated materials (non

-fuel) stored within spent fuel and other storage pools 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 Audits, self

-assessments, and corrective action documents related to radiological hazard assessment and exposure controls since the last inspection These activities constitute completion of the radiological hazard assessment and exposure controls inspection, as defined in Inspection Procedure 71124.01.

b. Findings

No findings were identified.

2 RS 3 In-plant Airborne Radioactivity Control and Mitigation (71124.03)

a. Inspection Scope

The inspectors evaluated whether the licensee controlled in

-plant airborne radioactivity concentrations consistent with ALARA principles and that the use of respiratory protection devices did not pose an undue risk to the wearer. During the inspection, the inspectors interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance in the following areas:

The licensee's use, when applicable, of installed ventilation systems as part of its engineering controls Utilization of temporary ventilation systems (e.g., high

-efficiency particulate air units) to support work in contaminated areas Airborne monitoring protocols, air quality and quantity for supplied air devices and SCBA bottles.

The licensee's respiratory protection program for use, storage, maintenance, and quality assurance of NIOSH certified equipment, qualification and training of personnel, and user performance Evaluations for the use of respirators in lieu of engineering controls to maintain occupational doses ALARA The licensee's capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency conditions, status of SCBA staged and ready for use in the plant and associated surveillance records, and personnel qualification and training Audits, self

-assessments, and corrective action documents related to in-plant airborne radioactivity control and mitigation since the last inspection These activities constitute completion of the in

-plant airborne radioactivity control and mitigation inspection, as defined in Inspection Procedure 71124.03.

b. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security 4OA 1 Performance Indicator Verification (71151)

.1 Unplanned Scrams per 7000

Critical Hours (IE01)

a. Inspection Scope

The inspectors reviewed licensee event reports for the period of January 1 through December 31, 2015 , to determine the number of scrams that occurred. The inspectors compared the number of scrams reported in th ese licensee event reports to the number reported for the performance indicator. Additionally, the inspectors sampled monthly operating logs to verify the number of critical hours during the period.

The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of the data reported.

These activities constituted verification of one unplanned scrams per 7000 critical hours performance indicator as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.2 Unplanned Power Changes per 7000 Critical Hours (IE03)

a. Inspection Scope

The inspectors reviewed operating logs, corrective action program records, and licensee performance indicator data for the period of January 1 through December 31, 2015, to determine the number of unplanned power changes that occurred. The inspectors compared the number of unplanned power changes documented to the number reported for the performance indicator. Additionally, the inspectors sampled monthly operating logs to verify the number of critical hours during the period. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of the data reported.

These activities constituted verification of one unplanned power outages per 7000 critical hours performance indicator as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.3 Unplanned Scrams with Complications (IE04)

a. Inspection Scope

The inspectors reviewed the licensee's basis for including or excluding in this performance indicator each scram that occurred between January 1 and December 31, 2015. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of the data reported.

These activities constitute d verification of one unplanned scrams with complications performance indicator as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.4 Occupational Exposure Control

Effectiveness (OR01)

a. Inspection Scope

The inspectors verified that there were no unplanned exposures or losses of radiological control over locked high radiation areas and very high radiation areas during the period of October 1, 2015 to December 31, 2015. The inspectors reviewed a sample of radiologically controlled area exit transactions showing exposures greater than

100 m Rem. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99

-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the occupational exposure control effectiveness performance indicator as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.5 Radiological Effluent Technical Specifications (RETS)/Offsite Dose Calculation Manual (ODCM) Radiological Effluent Occurrences (PR01)

a. Inspection Scope

The inspectors reviewed corrective action program records for liquid or gaseous effluent releases that occurred between October 1, 2015 and December 31, 2015, and were reported to the NRC to verify the performance indicator data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99

-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the radiological effluent technical specifications (RETS)/offsite dose calculation manual (ODCM) radiological effluent occurrences performance indicator as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA 2 Problem Identification and Resolution (71152)

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensee's corrective action program and periodically attended the licensee's condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified.

The inspectors also reviewed the licensee's problem identification and resolution activities during the performance of the other inspection activities documented in this report.

b. Findings

No findings were identified.

.2 Annual Follow

-up of Selected Issues

a. Inspection Scope

On February 18, 2016, the inspectors reviewed the licensee's apparent cause evaluation entitled "Misalignment Between Problem Statements, Causes and Corrective Actions and Misclassifications of Condition Reports," for an in

-depth follow

-up. The licensee had initiated this evaluation to address several deficiencies that had been identified with the creation and disposition of condition reports.

The inspectors assessed the licensee's problem identification threshold, cause analyses, extent of condition reviews and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to ensure the resolution of issues that had been previously identified with the corrective action program. In addition, the inspectors verified that condition reports were initiated in a timely manner, and were classified appropriately.

These activities constitute completion of one annual follow

-up sample as defined i n Inspection Procedure 71152.

b. Findings

No findings were identified.

4OA 3 Follow-up of Events and Notices of Enforcement Discretion (71153)

.1 (Closed) Licensee Event Report

05000382/2015 01 , "Manual Reactor Trip due to Low Steam Generator Levels

" On June 3, 2015, at approximately 5:05 p.m., the control room operators manually tripped the reactor in anticipation of an automatic reactor trip. The inspectors' review of the reactor trip was documented in NRC Integrated Inspection Report 05000382/2015003. Following the reactor trip, off-site power train B failed to transfer from the unit auxiliary transformer to the unit startup transformers. Subsequently, emergency diesel generator B started and powered the safety

-related train B electrical buses. In reviewing the causes of the failure of the fast bus transfer, the inspectors reviewed a performance deficiency associated with the design of the alarm circuit installed for the fast bus transfer electrical components.

However, since the alarm circuit did not play a role in the failure of the fast bus transfer, the inspectors determined the performance deficiency to be minor. The previous revision of this licensee event report was included as part of this review. Th is licensee event report is closed.

.2 (Closed) Licensee Event Report 05000382/201

4-00 4-03 , "Emergency Diesel Generators Rendered Inoperable by Potential Water Intrusion into Diesel Fuel Oil Feed Tanks

" During a plant walk-down on October 22, 2014, the inspector s identified through-wall corrosion on the emergency diesel generator fuel oil day tank vents.

The holes in these vent pipes could have allowed water to enter the day tanks and contaminate the diesel fuel oil, challenging the operability a nd functionality of both safety

-related emergency diesel generators.

The inspectors documented their findings in NRC Inspection Reports 05000382/2014007 and 05000382/2015001.

The inspectors review ed the licensee event report associated with this event and did not identify additional performance deficiencies. The previous revisions of this licensee event report were included as part of this review. This licensee event report is closed. These activities constitute completion of two event follow

-up samples, as defined in Inspection Procedure 71153. 4OA 5 Other Activities Temporary Instruction 2515/190 - Inspection of the Proposed Interim Actions Associated with Near-Term Task Force Recommendation 2.1 Flooding Hazard Evaluations.

The inspectors independently verified that the licensee's proposed interim actions would perform their intended function for flooding mitigation. Specifically:

Through a tabletop simulation with the licensee, the inspectors reviewed the sequence of licensee activities from the initial triggers that prompt them to implement their interim actions, through full implementation of those actions. The inspector s verified not only that the associated procedures clearly describe how to implement the interim actions, but also that the licensee staff has ready access to the necessary resources.

The inspectors visually examined each relevant flood

-protection feature for any indication of degradation that could prevent the feature from performing its credited function.

The inspectors walked down the associated manual actions, to verify that operators would have access to both the implementing procedures and the involved components during postulated adverse conditions.

Through these reviews, examinations, and walk

-downs, the inspectors only identified administrative issues. The inspectors verified that the licensee entered those issues into their corrective action program.

4OA 6 Meetings, Including Exit

Exit Meeting Summary

On March 24, 2016, the inspectors presented the radiation safety inspection results to Mr. R an Gilmore, General Plant Manager of Operations, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On April 21, 2016, the resident inspectors presented the inspection results to Mr. Michael Chisum, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

4OA 7 Licensee-Identified Violations The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy fo r being dispositioned as a non

-cited violation s.

Technical Specification 6.8.1, states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, "Quality Assurance Program Requirements," Appendix A, Section 2.l, requires procedures for refueling and core alterations. Step 6.2.1 of Procedure OP 005, Revision 309, "RCS Drain and Fill Below RCS Hot Leg Centerline," instructs the licensee to verify, in part, that "Containment Purge is aligned for Refueling Ventilation with RAB Normal Ventilation, or adequate provisions or controls are in place to acceptably address radiological concerns." Contrary to the above, on November 18, 2015, the licensee failed to verify that Containment Purge was aligned for Refueling Ventilation with RAB Normal Ventilation or that adequate controls were in place to acceptably address radiological concerns. Specifically, the licensee proceeded with RCS fill without radiation protection monitoring for airborne radioactivity in the vicinity of the TRH hoses as required. The alignment for Refueling Ventilation was not completed because the required valve (CAP

-201), which allows alignment between containment purge and refuel ventilation, was inoperable. The licensee indicated that this condition had existed since at least Refueling Outage 18 in 2012. This finding adversely affected the Occupational Radiation Safety cornerstone because it had the potential to cause a high airborne condition local to the refuel cavity and cause unplanned exposures. The licensee's immediate corrective action was to initiate a work order to complete repairs of the inoperable CAP

-201 valve. The licensee entered this issue into their corrective action program as CR

-WF3-2015-08474. The significance of the finding was determined to be of very low safety significance (Green) because it was: (1) not an ALARA finding, (2) did not result in an overexposure, (3) did not involve substantial potential for an exposure, and (4) the ability to assess dose was not compromised. Licensee

-identified findings do not involve cross

-cutting aspects.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

M. Chisum, Site Vice President, Operations
R. Gilmore, Acting General Manager, Plant Operations
D. Breaud, Radiological Effluents Specialist, Chemistry
L. Brown, Licensing Specialist, Regulatory Assurance
J. Cary, Supervisor, Radiation Protection
M. Chaisson, Superintendent, Radiological Operations
J. Clavelle, Manager, Systems

and Components

D. Frey, Manager, Radiation Protection
M. Haydel, Manager, Design & Program Engineering
P. Hernandez, Supervisor, Reactor Engineering
J. Jarrell, Director, Regulatory & Performance Improvement
B. Lanka, Director, Engineering
N. Lawless, Manager, Chemistry
B. Lindsey, Senior Manager, Operations
W. McKinney, Manager, Training
S. Meiklejohn, Senior Licensing Specialist
C. Miller, Supervisor, Radiation Protection
L. Milster, Licensing Engineer, Regulatory Assurance
N. Petit, Supervisor, Design Engineering
P. Robinson, Supervisor, System & Component Engineering
R. Sherman, ALARA Supervisor, Radiation Protection
J. Signorelli, Manager, Emergency Planning
R. Simpson, Superintendent, Operator Training
M. Vollmer, CHP, Specialist Radiation Protection
M. Zamber, Licensing Specialist, Regulatory Assurance

NRC Personnel

R. Deese, Senior Reactor Analyst

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000 382-2016-001-01 NCV Failure to Assess and Manage the Increase in Risk from Emergent Maintenance Activities

(Section 1R13)

Closed

05000382/2015

-005-0 1 LER Manual Reactor Trip due to Low Steam Generator Levels (Section 4OA3.1)

05000382/201
4-00 4-0 3 LER Emergency Diesel Generators Rendered Inoperable by Potential Water Intrusion into Diesel Fuel Oil Feed Tanks

(Section 4OA3.2)

LIST OF DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

Procedures/Documents Number Title Revision
CE-002-030 Maintaining Diesel Fuel Oil
OP-002-007 Freeze Protection and Temperature Maintenance
OP-901-521 Severe Weather and Flooding
317

Condition Reports

CR-WF3-2016-00656

Section 1R04: Equipment Alignment

Procedures/Documents Number Title Revision
OP-002-003 Component Cooling Water
316
OP-009-001 Containment Spray
306
OP-009-003 Emergency Feedwater
308
OP-009-008 Safety Injection

Condition Reports

CR-WF3-2016-01337

Section 1R05: Fire Protection

Procedures/Documents Number Title Revision
FP-001-018 Pre-fire Strategies, Development and Revision
303
RAB 16-001 Waterford S.E.S Prefire Strategy Elev. +21.00' RAB (RCA)
Emergency Diesel Generator "3A"
RAB 18-001 Waterford S.E.S Prefire Strategy Elev. +21.00' RAB (RCA)
Component Cooling Water Heat Exchanger "A"
Procedures/Documents Number Title Revision
RAB 32-001 Waterford S.E.S Prefire Strategy Elev. -4.00', -35.00' RAB (RCA)
Auxiliary Component Cooling Water Room and Pipe Penetration Area
RAB 6-001 Waterford S.E.S Prefire Strategy Elev. +35.00' RAB Electri cal Penetration Area "A"
ROOF E-001 Waterford S.E.S Prefire Strategy Elev. +46.00' ROOF E (MSIV B)

Section 1R11: Licensed Operator Requalification Program

and Licensed Operator Performance Procedures/Documents Number Title Revision

EP-004-010 Toxic Chemical Contingency Procedure
OP-901-110 Pressurizer Level Control Malfunction

Section 1R12: Maintenance Effectiveness

Procedures/Documents Number Title Revision/Date
System Health Report

- ACC March 2, 2016

SEP-WF3-IST-1 WF3 Inservice Testing Bases Document
PM Basis Template
ENS-I&C - Electronic Circuit Cards
EN-DC-153 Preventive Maintenance Component Classification
EN-DC-335 PM Basis Template
MRule Scoping Auxiliary Component cooling Water March 2, 2016 PM Basis Template EN - Relay - Control
February 14, 2012
EN-DC-203 Maintenance Rule Program
EN-DC-205 Maintenance Rule Monitoring
EN-DC-204 Maintenance Rule Scope and Basis

Condition Reports

CR-WF3-2016-00353
CR-WF3-2016-01389
CR-WF3-2012-02692
CR-WF3-2012-0 3280 CR-WF3-2015-06782

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Procedures/Documents Number Title Revision/Date 1DEV-1 Tagout: CC

-110 DCT Fan 12A

January 26, 2016
EN-MA-101 Conduct of Planned Maintenance
EN-MA-119 Material Handling Program
EN-OP-102 Protective and Caution Tagging
EN-OP-111 Operational Decision

-Making Issue (ODMI) Process

EN-OP-115 Control Room Logs January 26, 2016
EN-OP-119 Protected Equipment Postings
EN-WM-104 On Line Risk Assessment
OI-037-000 Operations' Risk Assessment Guide
308
OP-100-009 Control of Valves and Breakers

Condition Reports

CR-WF3-2016-00102
CR-WF3-2016-00494
CR-WF3-2016-00536
CR-WF3-2016-01522
CR-WF3-2016-00065
CR-WF3-2016-00525
CR-WF3-2016-00426
CR-WF3-2004-1332
CR-WF3-2016-00592
CR-WF3-2016-00628
CR-WF3-2016-00627
CR-WF3-2016-00660
CR-WF3-2016-01944

Work Orders

WO 00434437
WO 00412066
WO 00439799

Section 1R15: Operability Determinations and Functionality Assessments

Procedures/Documents Number Title Revision
SD-PLC Pressurizer Level and Pressure Control
TD G080.0405
General Electric Instructions GEK

-31879 Rev 3 For Reactor Coolant Pump Motors

Procedures/Documents Number Title Revision TD G080.0435
General Electric Spare Reactor Coolant Pump Motor Description
TD G080.0455
General Electric Spare Reactor Coolant Pump Motor Operation 0 TD G080.0465
General Electric Spare Reactor Coolant Pump Motor Maintenance

Condition Reports

CR-WF3-2016-00736
CR-WF3-2015-07528
CR-WF3-2016-01131
CR-WF3-2016-00208
CR-WF3-2015-07417
CR-WF3-2016-00906
CR-WF3-2016-00038
CR-WF3-2016-00841
CR-WF3-2016-00770
CR-WF3-2016-00859 CR-WF3-2016-01033

Section 1R18: Plant Modifications

Procedures/Documents Number Title Revision TMOD 62287
Replacing CPC Channel B RCP

-2A Speed Sensor with COLSS

RCP-2A Speed Sensor

Condition Reports

CR-WF3-2015-09183
CR-WF3-2015-06798
CR-WF3-2015-9183
CR-WF3-2016-00134
CR-WF3-2015-09570
CR-WF3-2015-06868

Condition Reports

WO 0035505

Section 1R19:

Post

-Maintenance Testing Procedures/Documents Number Title Revision Date B-289 Power Distribution and Motor Data 480V MCC 3A315

January 31, 1975 Work Orders
WO 00426387
Procedures/Documents Number Title Revision Date
EN-MA-135 On-line Motor Electrical Testing
EN-WM-107 Post Maintenance Testing
ER-W3-2001-1091-000 Replacement Wet Cooling Tower Fan Motors, Siemens Motor 0
ME-007-057 MCE/EMAX Data Acquisition
306
OP-903-046 Emergency Feed Pump Operability Check
315
OP-903-118 Primary Auxiliaries Quarterly IST Valve Tests
OP-903-119 Secondary Auxiliaries Quarterly IST Valve Tests
OP-903-121 Safety Systems Quarterly IST Valve Tests
OP-903-121 Safety Systems Quarterly IST Valve Tests
STA-001-005 Leakage Testing of Air and Nitrogen Accumulators for Safety Related Systems
317
TD-A180.0075 Allis-Chalmers Installation Operation Maintenance Instruction Induction Motors Vertical "P" Flanged 0

Condition Reports

CR-WF3-2015-09592
CR-WF3-2016-00713
CR-WF3-2016-00712
CR-WF3-2016-00667
CR-WF3-2016-00619

Work Orders

WO 52451298
WO 52573126 WO 43637401

Section 1R22: Surveillance Testing

Procedures/Documents Number Title Revision
MI-003-126 Core Protection Calculator Functional Test
OP-903-036 Containment Spray Actuation Signal Test
305
OP-903-050 Component Cooling Water and Auxiliary Component Cooling Water Pump and Valve Operability Test
STA-001-005 Leakage Testing of Air and Nitrogen Accumulators for Safety Related Valves
317

Condition Reports

CR-WF3-2016-01385

Work Orders

WO 00412716
WO 52659370
WO 52665913
WO 52622268

Section 2RS1: Radiological Hazard Assessment and Exposure Controls

Procedures

Number Title Revision
EN-RE-220 PWR Control of Miscellaneous Material in the Spent Fuel Pool
EN-RP-101 Access Control for Radiologically Controlled Areas
EN-RP-102 Radiological Control
EN-RP-105 Radiation Work Permits
EN-RP-108 Radiation Protection Posting
EN-RP-113 Response to Contaminated Spills/Leaks
EN-RP-121 Radioactive Material Control
EN-RP-122 Alpha Monitoring
EN-RP-123 Radiological Controls for Highly Radioactive Objects
EN-RP-131 Air Sampling
EN-RP-142 Failed Fuel Response
EN-RP-143 Source Control
EN-RP-308 Operation and Calibration of Gamma Scintillation Tool Monitors
EN-RP-317 Central Calibration Facility
EN-CY-108 Monitoring of Non

-Radioactive Systems

EN-CY-113 PWR Chemistry Control During Shutdown

Condition Reports

CR-WF3-2016-02000
CR-WF3-2016-01999
CR-WF3-2016-01985
CR-WF3-2016-01808
CR-WF3-2016-01542
CR-WF3-2016-00304
CR-WF3-2015-09348
CR-WF3-2015-09064
CR-WF3-2015-09009
CR-WF3-2015-09005
CR-WF3-2015-09004
CR-WF3-2015-08994
CR-WF3-2015-08962
CR-WF3-2015-06828
CR-WF3-2015-01992
CR-WF3-2015-01992

Miscellaneous Documents

Number Title Date
OL-OLW-2014-00095 Spent Fuel Pool Trash Can Storage March 24, 2015
GEL Laboratories Part 61 Analysis December 8, 2015
W.O.#52516543
DCT
RM-35 Calibration June 19, 2015
Personnel Contamination Events
2015
Selected Air Sample Records
2015 and 2016
Selected Radiological Survey Records
2015 and 2016
Radioactive Material Release Log
2015 and 2016
Semi-Annual Source Leak Check March 2016
Audits, Self

-Assessments, and Surveillances Number Title Date

LO-WLO-2015-0128 Pre-NRC Inspection FSA:
Radiation Protection March 1, 2016
Radiological Work Permits Number Title
20150702 RF20 Disassembly of Reactor Head and All Associated Work Activities
20150705 Reassembly of Reactor Head and Associated Work Activities
20150633 Replace Resilient Seat Check Valves SI

-142B and sI

-143B in the Reactor Containment Building including staging/de

-staging and work in Hot Shop

20160054 I&C to Enter

-4 RCB to Troubleshoot RCP

-2A Proximity Box

20160001 Radiation Protection Coverage
20160005 Tours and Inspections
20160059 Fuel Pool Heat Exchanger Eddy Current and Maintenance Activities
20160101 Work Activities in the Spent Fuel Pool and the Transfer Canal
20160110 Perform Work Activities in Alpha Level Three Areas in the RCA

Section 2RS3:

In

-plant Airborne Radioactivity Control and Mitigation

Procedures

Number Title Revision
EN-FAP-OU-100 High Airborne Radioactivity in Containment
EN-RP-110-04 Radiation Protection Risk Assessment Process
EN-RP-131 Air Sampling
EN-RP-310 Operation and Initial Setup of the Eberline AMS

-4 Continuous Air Monitor

EN-RP-402 DOP Challenge Testing of HEPA Vacuums and Portable Ventilation
Units
EN-RP-404 Operation and Maintenance of HEPA Vacuum Cleaners and HEPA Ventilation Units
EN-RP-501 Respiratory Protection Program
EN-RP-502 Inspection and Maintenance of Respiratory Protection Equipment 9
EN-RP-502-01 Fire Hawk M7 SCBA
EN-RP-502-02 Flow Testing MSA Breathing Apparatus
EN-RP-502-03 Air Hawk II SCBA
EN-RP-503 Selection, Issue, and Use of
Respiratory Protection Equipment
EN-RP-504 Breathing Air
FPF-GET-RPT Respiratory Protection Practical Factor Guide
OP-001-005 RCS Drain and Fill Below RCS Hot Leg Centerline
309
OP-002-010 Reactor Auxiliary Building HVAC and Containment Purge
308

Condition Reports

CR-WF3-2014-02243
CR-WF3-2014-02244
CR-WF3-2014-02477
CR-WF3-2015-03890
CR-WF3-2015-08307
CR-WF3-2015-08474
CR-WF3-2015-08676
CR-WF3-2015-09206
CR-WF3-2016-01490
CR-WF3-2016-01492
Audits, Self

-Assessments, and Surveillances Number Title Date

LO-WLO-2015-00128 Radiation Safety
IP 71124.01, and 03 and 71151 Pre NRC Inspection January 17, 2016
Posi 3 USB Test Results Number Title Date AMAG172670
SCBA MSA Firehawk M7 Air Mask April 6, 2015
AMAG168310
SCBA MSA Firehawk M7 Air Mask April 7, 2015
AMAG171609
SCBA MSA Firehawk M7 Air Mask April 8, 2015
AMAG172696
SCBA MSA Firehawk M7 Air Mask April 8, 2015
AMAG172643
SCBA MSA Firehawk M7 Air Mask April 9, 2015
AMAG172665
SCBA MSA Firehawk M7 Air Mask April 9, 2015
UES-6021 Facepiece Test

- PD Respirators April 9, 2015

UES-6034 Facepiece Test

- PD Respirators April 9, 2015

UES-6135 Facepiece Test

- PD Respirators April 9, 2015

UES-6331 Facepiece Test

- PD Respirators April 9, 2015

UES-6439 Facepiece Test

- PD Respirators April 9, 2015

UES-6450 Facepiece Test

- PD Respirators April 9, 2015

HVC Filter Train Testing Number Title Date PO10122064
Radioiodine Test Report:
Control Room Emergency Unit A

- HVC A August 8, 2014

PO10122064
Radioiodine Test Report:
Control Room Emergency Unit A

- HVC B November 1, 2014

Surveys
Number Title Date 1210-0749 -4 Reactor Containment Building October 24, 2012
211-0090 -4 Reactor Containment Building November 2, 2012
211-0976 -4 Reactor Containment Building November 14, 2012
1511-0639 -4 Reactor Containment Building November 14, 2016
1603-0181 FHB +1 Fuel Pool Purification March 22, 2016
Air Sample Surveys Number Title Date 111415-033 142B Valve Disk Grind November 14, 2015
111415-029 Scaffold 337 Valve SI

-137B November 14, 2015

111415-027
SI 142B November 14, 2015
111415-020 -4 Reactor Building
SI 142B

- General Area November 14, 2015

111415-030 Decon Pad on 21' Reactor Building November 14, 2015

Miscellaneous Documents

Number Title Date/Revision
SCBA Training Qualification Matrix March 22, 2016
SCBA Inspection Log September 1

-16, 2015

RFO-20 Cavity Decontamination Plan
2015
WSES-FSAR-Unit-3 307 G853 HVAC Air Flow Diagram Reactor Containment Building 307

Section 4OA1: Performance Indicator Verification

Procedures/Documents Number Title Revision W3F1-2015-0029 NRC Performance Indicator (PI) Data

- 2015 Quarter 1

st 0 W3F1-2015-0055 NRC Performance Indicator (PI) Data

- 2015 Quarter 2

nd Quarter 0 W3F1-2015-0083 NRC Performance Indicator (PI) Data

- 2015 Quarter 3

rd Quarter 0 W3F1-2016-0005 NRC Performance Indicator (PI) Data

- 4 th Quarter 2015

W3F1-2016-0011 NRC Performance Indicator (PI) Data

- Change Report Data 4 th Quarter 2015 SCRAM without complications correction

Section 4OA2: Problem Identification and Resolution

Procedures/Documents Number Title Revision
EN-LI-102 Corrective Action Program

Condition Reports

CR-WF3-2014-05641
CR-WF3-2014-05232 CR-WF3-2014-05228

Section 4OA3:

Follow

-up of Events and Notices of Enforcement Discretion Procedures/Documents Number Title Revision/Date 14.21629.01.002

Failure Analysis of Allen Bradley 700

-RTC Relay November 13, 2015

EN-MA-125 Troubleshooting Control of Maintenance Activities
ES-P-002-00 Design Verification January 16, 1996
NOECP-303 Design Change Packages
PC-3448 Annunciator and Interlock for Monitoring a Loss of Bus Transfer Capability

Condition Reports

CR-WF3-2015-03566
CR-WF3-2015-03629

Work Orders

WO 00415592

Section 4OA5: Other Activities

Procedures/Documents Number Title Revision
EN-DC-324 Preventive Maintenance Program
OP-100-014 Technical Specification and Technical Requirements Compliance
2
OP-500-02 Control Room Cabinet B Alarm Response Procedure
OP-901-521 Severe Weather and Flooding
317
OI-037-000 Operations' Risk Assessment Guideline
308

Other Documents

Number Title Revision/Date ML14309A597
Warning Time for Maximum Precipitation Events

(prepared by the Nuclear Energy Institute)

WF3-CS-15-00010 Waterford Steam Electric Station Unit 3 Fukushima Flood Hazard Re-evaluation Report
W3F1-2015-0042 Flood Hazard Reevaluation Report Waterford Steam Electric Station, Unit 3 (Waterford 3)
July 21 , 2015
WO 00420362 01

[REACTOR CONTAINMENT BUILDING

- INSPECT & CLEAN ROOF DRAINS

Condition Reports

CR-WF3-2015-01282
A 2-1 Attachment The following items are requested for the Occupational Radiation Safety Inspection at Waterford

-3 (March 21

- March 25, 2016)

Integrated Report
2016-001
Inspection areas are listed in the attachments below.
Please provide the requested information on or before March 7, 2016.
Please submit this information using the same lettering system as below.
For example, all contacts and phone numbers for Inspection Procedure 71124.0

should be in a file/folder titled

"1- A," applicable organization charts in file/folder "

1- B," etc.
If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at least 30 days later than the onsite inspection dates, so the inspectors will have access to the information while writing the report.
In addition to the corrective action document lists provided for each inspection procedure listed below, please provide updated lists of corrective action documents at the entrance meeting.
The dates for these lists should range from the end dates of the original lists to the day of the entrance meeting.
If more than one inspection procedure is to be conducted and the information requests appear to be redundant, there is no need to provide duplicate copies.
Enter a note explaining in which file the information can be found.
If you have any questions or comments, please contact Natasha Greene at (817) 200

-1154 or Natasha.Greene@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT
This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.).
Existing information collection requirements were approved by the Office of Management and Budget, control number 3150

-0011.

A 2-2 1. Radiological Hazard Assessment and Exposure Controls (71124.01) and Performance Indicator Verification (71151)
Date of Last Inspection:
October 26, 2015
A. List of contacts and telephone numbers for the Radiation Protection Organization Staff and Technicians
B. Applicable organization charts
C. Audits, self

-assessments, and LERs written since date of last inspection

, related to this inspection area

D. Procedure indexes for the radiation protection procedures
E. Please provide specific procedures related to the following areas noted below.
Additional Specific Procedures may be requested by number after the inspector reviews the procedure indexes:
1. Radiation Protection Program Description
2. Radiation Protection Conduct of Operations
3. Personnel Dosimetry Program
4. Posting of Radiological Areas
5. High Radiation Area Controls
6. RCA Access Controls and Handworker Instructions
7. Conduct of Radiological Surveys
8. Radioactive Source Inventory and Control
9. Declared Pregnant Worker Program
F. List of corrective action documents (including corporate and sub

-tiered systems) since date of last inspection:

a. Initiated by the radiation protection organization

b. Assigned to the radiation protection organization

NOTE:
The lists should indicate the significance level of each issue and the search criteria used.
Please provide in document formats which are "searchable" so that the inspector can perform word searches.
If not covered above, a summary of corrective action documents since date of last inspection involving unmonitored releases, unplanned releases, or releases in which any dose limit or administrative dose limit was exceeded (for Public Radiation Safety Performance Indicator verification in accordance with IP 71151)
G. List of radiologically significant work activities scheduled to be conducted during the inspection period (If the inspection is scheduled during an outage, please also include a list of work activities greater than 1 rem, scheduled during the outage with the dose estimate for the work activity.)
H. List of active radiation work permits
A 2-3 I. Radioactive source inventory list:

a.

All radioactive sources that are required to be leak tested

b.

All radioactive sources that meet the 10 CFR Part 20, Appendix E, Category 2 and above threshold.
Please indicate the radioisotope, initial and current activity (w/assay date), and storage location for each applicable source.
J. The last two leak test results for the radioactive sources inventoried and required to be leak tested.
If applicable, specifically provide a list of all radioactive source(s) that have failed its leak test within the last two years
K. A current listing of any non

-fuel items stored within your pools, and if available, their appropriate dose rates (Contact/@ 30cm)

L. Computer printout of radiological controlled area entries greater than 100 millirems since the previous inspection to the current inspection entrance date.
The printout should include the date of entry, some form of worker identification, the radiation work permit used by the worker, dose accrued by the worker, and the electronic dosimeter dose alarm setpoint used during the entry (for Occupational Radiation Safety Performance Indicator verification in accordance with IP 71151)

.

3. In-Plant Airborne Radioactivity Control and Mitigation (71124.03)
Date of Last Inspection:
April 21, 2014
A. List of contacts and telephone numbers for the following areas:
1. Respiratory Protection Program
2. Self-contained breathing apparatus
B. Applicable organization charts
C. Copies of audits, self

-assessments, vendor or NUPIC audits for contractor support (SCBA), and LERs, written since date of last inspection related to:

1. Installed air filtration systems
2. Self-contained breathing apparatuses
D. Procedure index for:
1. Use and operation of continuous air monitors
2. Use and operation of temporary air filtration units
3. Respiratory protection
E. Please provide specific procedures related to the following areas noted below.
Additional Specific Procedures may be requested by number after the inspector reviews the procedure indexes:
1. Respiratory protection program
2. Use of self

-contained breathing apparatuses

3. Air quality testing for SCBAs
4. Use of installed plant systems, such as containment purge, spent fuel pool ventilation, and auxiliary building ventilation
F. A summary list of corrective action documents (including corporate and sub

-tiered systems) written since date of last inspection

, related to the Airborne Monitoring program including:

1. Continuous air monitors
2. Self-contained breathing apparatuses
3. Respiratory protection program
A 2-4 NOTE:
The lists should indicate the significance level of each issue and the search criteria used.
Please provide in document formats which are "searchable" so that the inspector can perform word searches.
G. List of SCBA qualified personnel

- reactor operators and emergency response personnel.

H. Inspection records for self

-contained breathing apparatuses (SCBAs) staged in the plant for use since date of last inspection.

I. SCBA training and qualification records for control room operators, shift supervisors, STAs, and OSC personnel for the last year.
A selection of personnel may be asked to demonstrate proficiency in donning, doffing, and performance of functionality check for respiratory devices.
J. List of respirators (available for use) by type (APR, SCBA, PAPR, etc.), manufacturer, and model.
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