ML15147A192

IR 05000382/2015007; on 01/26/2015 - 04/15/2015; Waterford Steam Electric Station, Unit 3; Triennial Fire Protection Team Inspection

ML15147A192
Person / Time
Site:	Waterford
Issue date:	05/27/2015
From:	Greg Werner NRC/RGN-IV/DRS/EB-2
To:	Chisum M Entergy Operations
References
EA-15-077 IR 2015007
Download: ML15147A192 (50)

See also: IR 05000382/2015007

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E. LAMAR BLVD

ARLINGTON, TX 76011-4511

May 27, 2015

EA-15-077

Mr. Michael R. Chisum

Site Vice President

Entergy Operations, Inc.

17265 River Road

Killona, LA 70057-0751

SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC TRIENNIAL FIRE

PROTECTION INSPECTION REPORT 05000382/2015007 AND EXERCISE OF

ENFORCEMENT DISCRETION

Dear Mr. Chisum:

On April 15, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at

the Waterford Steam Electric Station, Unit 3, and discussed the results of this inspection with

Mr. B. Lanka, Director, Engineering, and other members of your staff. Inspectors documented

the results of this inspection in the enclosed inspection report.

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

All of these findings involved violations of NRC requirements. The NRC is treating these

violations as non-cited violations consistent with Section 2.3.2.a of the Enforcement Policy.

Additionally, one finding involving 10 CFR 50.48(b) was identified and was a violation of NRC

requirements. The inspectors have screened this finding and determined that it warrants

enforcement discretion per the NRC Enforcement Policy Section 9.1, Enforcement Discretion

for Certain Fire Protection Issues (10 CFR 50.48) and Section 11.05(b) of Inspection Manual

Chapter 0305 (EA-15-077).

If you contest the violations or significance of the violations in this report, you should provide a

written 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 a cross-cutting aspect assignment in this report, you should provide a

response within 30 days of the date of this inspection report, with the basis for your

disagreement, to the Regional Administrator, Region IV; and the NRC resident inspector at the

Waterford Steam Electric Station, Unit 3.

M. Chisum -2-

In accordance with Title 10 of the Code of Federal Regulations 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 NRCs 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/

Gregory E. Werner, Chief

Engineering Branch 2

Division of Reactor Safety

Docket No. 50-382

License No. NPF-38

Enclosure:

Inspection Report No. 05000382/2015007

w/Attachment: Supplemental Information

cc w/encl: Waterford Steam Electric Station

ML15147A192

SUNSI Review ADAMS Publicly Available Non-Sensitive Keyword:

By: Yes No Non-Publicly Available Sensitive NRC-002

OFFICE DRS/EB2 DRS/EB2 DRS/EB1 DRS/SRA DRS/EB2 C:ACES BC:DRP/D

NAME JMateychick JWatkins RKopriva GReplogle SAlferink MHay GMiller

SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ /RA/

DATE 5/11/2015 4/21/2015 4/29/2015 4/29/2015 5/5/2015 4/30/2015 5/5/2015

OFFICE OE BC:DRS/EB2

NAME KHanley GWerner

SIGNATURE /RA/ email /RA/

DATE 5/5/2015 5/27/2015

Letter to Michael R. Chisum from Gregory E. Werner, dated May 27, 2015

SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC TRIENNIAL FIRE

PROTECTION INSPECTION REPORT 05000382/2015007 AND EXERCISE OF

ENFORCEMENT DISCRETION

Electronic distribution by RIV:

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 (Linda.Dufrene@nrc.gov)

Branch Chief, DRP/D (Geoffrey.Miller@nrc.gov)

Senior Project Engineer, DRP/D (Bob.Hagar@nrc.gov)

Project Engineer, DRP/D (Brian.Parks@nrc.gov

Project Engineer, DRP/D (Jan.Tice@nrc.gov)

Branch Chief, RES/DRA/FRB (MarkHenry.Salley@nrc.gov

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Michael.Orenak@nrc.gov)

Branch Chief, DRS/TSS (Don.Allen@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

Branch Chief, OE (Nick.Hilton@nrc.gov)

Enforcement Specialist, OE (Kyle.Hanley@nrc.gov)

NRR Enforcement (Lauren.Casey@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

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

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

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

RIV/ETA: OEDO (Michael.Waters@nrc.gov)

RidsOEMailCenter.Resource

NRREnforcement.Resource

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000382

License: NPF-38

Report: 05000382/2015007

Licensee: Entergy Operations, Inc.

Facility: Waterford Steam Electric Station, Unit 3

Location: Hwy. 18

Killona, Louisiana

Dates: January 26 through April 15, 2015

Team Leader: J. Mateychick, Senior Reactor Inspector, Engineering Branch 2

Inspectors: S. Alferink, Reactor Inspector, Engineering Branch 2

J. Watkins, Reactor Inspector, Engineering Branch 2

R. Kopriva, Senior Reactor Inspector, Engineering Branch 1

Approved By: Gregory E. Werner

Chief, Engineering Branch 2

Division of Reactor Safety

-1- Enclosure

SUMMARY OF FINDINGS

IR 05000382/2015007; 01/26/2015 - 04/15/2015; Waterford Steam Electric Station, Unit 3;

Triennial Fire Protection Team Inspection.

The report covered a two-week triennial fire protection team inspection by specialist inspectors

from Region IV. Four findings of very low safety significance (Green) are documented in this

report. Four of these findings involved violations of NRC requirements. The significance of

inspection findings is indicated by their color (i.e., Green, White, Yellow, or Red) which is

determined using Inspection Manual Chapter 0609, Significance Determination Process,

dated June 2, 2011. Cross-cutting aspects are determined using Inspection Manual

Chapter 0310, Aspects within the Cross-Cutting Areas, dated December 4, 2014. Violations

of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy. The

NRCs program for overseeing the safe operation of commercial nuclear power reactors is

described in NUREG-1649, Reactor Oversight Process, Revision 4.

Cornerstone: Mitigating Systems

• Green. The team identified a non-cited violation of License Condition 2.C.(9), Fire

Protection, for the failure to ensure the required separation between fire areas.

Specifically, the licensee installed fire barriers on two ventilation ducts which were not in

a configuration demonstrated to provide the required three-hour fire-rated separation

between fire areas. The licensee entered this issue into their corrective action program

as Condition Report CR-WF3-2015-00540 and established an hourly fire watch as a

compensatory measure until corrective actions can be taken (Fire Impairments 15-30

and 15-31).

The failure to ensure the required separation between fire areas was a performance

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

with the protection against external events (fire) attribute of the Mitigating Systems

cornerstone and it adversely affected the cornerstone objective of ensuring the

availability, reliability, and capability of systems that respond to initiating events to

prevent undesirable consequences. The team evaluated this finding using Inspection

Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process,

dated September 20, 2013. Both emergency diesel generator rooms were equipped

with pre-action sprinkler systems which would limit temperatures near the ceiling around

the room exhaust ducts; therefore, the finding screened to Green at Section 1.4.3.C.

This finding did not have a cross-cutting aspect since it was not indicative of current

licensee performance since this fire barrier configuration was installed in the 1980s.

(Section 1R05.02.b)

• Green. The team identified a non-cited violation of License Condition 2.C.9, "Fire

Protection," for the failure to adequately correct a previous violation. Specifically, the

licensee failed to provide a bounding calculation for the amount of time available for

operators to establish component cooling water during an alternative shutdown. The

licensee developed this calculation in response to Non-cited Violation 2012007-02.

The licensee entered this issue into their corrective action program as

-2-

Condition Report CR-WF3-2015-0859 and implemented a fire impairment as a

compensatory measure.

The failure to provide a bounding calculation for the amount of time available for

operators to establish component cooling water during an alternative shutdown was a

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

was associated with the protection against external events (fire) attribute of the

Mitigating Systems cornerstone and it adversely affected the cornerstone objective of

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

events to prevent undesirable consequences. A senior reactor analyst performed a

Phase 3 evaluation to determine the risk significance of this finding since it involved a

postulated control room fire that led to control room evacuation and determined this

violation was of very low safety significance.

This finding had a cross-cutting aspect associated with resolution within the problem

identification and resolution area since the licensee failed to take effective corrective

actions to address issues in a timely manner commensurate with their safety

significance. Specifically, the team determined that the licensees corrective actions

were not effective since the licensee failed to provide a bounding calculation for the

amount of time available for operators to establish component cooling water during an

alternative shutdown (P.3). (Section 1R05.05.b.1)

• Green. The team identified a non-cited violation of License Condition 2.C.9, Fire

Protection, for the failure to periodically test and demonstrate the 8-hour capacity of the

Appendix R emergency lighting units. The licensee entered this issue into their

corrective action program as Condition Report CR-WF3-2015-00856 and operators had

flashlights available as a compensatory measure.

The failure to periodically test and demonstrate the 8-hour capacity of the Appendix R

emergency lighting units was a performance deficiency. The performance deficiency

was more than minor because it was associated with the protection against external

events (fire) attribute of the Mitigating Systems cornerstone and it adversely affected the

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

that respond to initiating events to prevent undesirable consequences. The team

evaluated this finding using Inspection Manual Chapter 0609, Appendix F, Fire

Protection Significance Determination Process, dated September 20, 2013. The team

assigned the finding a low degradation rating because it would not prevent reaching and

maintaining safe shutdown conditions in the event of a control room fire. Specifically,

the team had reasonable assurance that the emergency lighting units would provide

adequate illumination for a sufficient amount of time for operators to perform the most

time critical actions. In addition, the team determined that operators performing an

alternative shutdown had flashlights available in the Appendix R equipment lockers.

Because the team assigned a low degradation rating, this finding screened as having

very low safety significance.

This finding did not have a cross-cutting aspect since it was not indicative of present

performance in that the performance deficiency occurred more than three years ago.

(Section 1R05.08.b.1)

-3-

• Green. The team identified a non-cited violation of License Condition 2.C.9, Fire

Protection, for the failure to correct adverse conditions associated with fire protection.

Specifically, the licensee failed to correct longstanding deficiencies with the Appendix R

emergency lighting units. The licensee entered this issue into their corrective action

program as Condition Report CR-WF3-2015-00593 and operators had flashlights

available as a compensatory measure.

The failure to correct longstanding deficiencies with the Appendix R emergency lighting

units was a performance deficiency. The performance deficiency was more than minor

because it was associated with the protection against external events (fire) attribute of

the Mitigating Systems cornerstone and it adversely affected the cornerstone objective

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

events to prevent undesirable consequences. The team evaluated this finding using

Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance

Determination Process, dated September 20, 2013. The team assigned the finding a

low degradation rating because the failure to provide adequate 8-hour emergency lights

at all locations would not prevent reaching and maintaining safe shutdown conditions in

the event of a control room fire. Specifically, the team determined that operators

performing an alternative shutdown had flashlights available in the Appendix R

equipment lockers. Because the team assigned a low degradation rating, this finding

screened as having very low safety significance.

This finding had a cross-cutting aspect associated with resolution within the problem

identification and resolution area since the licensee failed to take effective corrective

actions to address issues in a timely manner commensurate with their safety

significance. Specifically, the team determined that the licensee failed to take corrective

actions to address the nonfunctional emergency lighting units in a timely manner (P.3).

(Section 1R05.08.b.2)

-4-

REPORT DETAILS

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R05 Fire Protection (71111.05T)

This report presents the results of a triennial fire protection inspection conducted in

accordance with NRC Inspection Procedure 71111.05T, Fire Protection (Triennial),

at the Waterford Steam Electric Station, Unit 3. The licensee committed to adopt a

risk-informed fire protection program in accordance with National Fire Protection

Association 805 (NFPA-805), but has not yet completed the program transition. The

team evaluated the implementation of the approved fire protection program in selected

risk-significant areas with an emphasis on the procedures, equipment, fire barriers, and

systems that ensure the post-fire capability to safely shutdown the plant.

Inspection Procedure 71111.05T requires the selection of three to five fire areas and one

or more mitigating strategies for review. The team used the Waterford Steam Electric

Station, Unit 3, Fire PRA Summary Report to select the following three risk-significant

fire areas (inspection samples) for review:

Fire Area Description

RAB 6 Electrical Penetration Room A

RAB 7 Relay Rooms (+35' Elevation)

RAB 8 Switchgear Rooms

The team evaluated the licensees fire protection program using the applicable

requirements, which included plant Technical Specifications, Operating License

Condition 2.C.(9), NRC safety evaluations, 10 CFR 50.48, and Branch Technical

Position 9.5-1. The team also reviewed related documents that included the Final Safety

Analysis Report, Section 9.5; the fire hazards analysis; and the post-fire safe shutdown

analysis. Specific documents reviewed by the team are listed in the attachment.

Three fire area inspection samples and one mitigating strategy sample were completed.

.01 Protection of Safe Shutdown Capabilities

a. Inspection Scope

The team reviewed the piping and instrumentation diagrams, safe shutdown equipment

list, safe shutdown design basis documents, and the post-fire safe shutdown analysis to

verify that the licensee properly identified the components and systems necessary to

achieve and maintain safe shutdown conditions for fires in the selected fire areas. The

team observed walkdowns of the procedures used for achieving and maintaining safe

shutdown in the event of a fire to verify that the procedures properly implemented the

safe shutdown analysis provisions.

-5-

For each of the selected fire areas, the team reviewed the separation of redundant safe

shutdown cables, equipment, and components located within the same fire area. The

team also reviewed the licensees method for meeting the requirements of

10 CFR 50.48; Branch Technical Position 9.5-1, Appendix A; and 10 CFR Part 50,

Appendix R,Section III.G. Specifically, the team evaluated whether at least one

post-fire safe shutdown success path remained free of fire damage in the event of a fire.

In addition, the team verified that the licensee met applicable license commitments.

b. Findings

No findings were identified.

.02 Passive Fire Protection

a. Inspection Scope

The team walked down accessible portions of the selected fire areas to observe the

material condition and configuration of the installed fire area boundaries (including walls,

fire doors, and fire dampers) and verify that the electrical raceway fire barriers were

appropriate for the fire hazards in the area. The team compared the installed

configurations to the approved construction details, supporting fire tests, and applicable

license commitments.

The team reviewed installation, repair, and qualification records for a sample of

penetration seals to ensure the fill material possessed an appropriate fire rating and that

the installation met the engineering design. The team also reviewed similar records for

the rated fire wraps to ensure the material possessed an appropriate fire rating and that

the installation met the engineering design.

b. Findings

Introduction. The team identified a Green non-cited violation of License

Condition 2.C.(9), Fire Protection, for the failure to ensure the required separation

between fire areas. Specifically, the licensee installed fire barriers on two ventilation

ducts which were not in a configuration demonstrated to provide the required three-hour

fire-rated separation between fire areas.

Description. The approved fire protection program required fire areas to be separated

by floors, walls, and ceilings having a three-hour fire resistance rating except as noted in

the fire area analysis. The team reviewed surveillance Procedure ME-0003-009, Fire-

Rated Walls, Floors, and Ceilings, Revision 302. The procedure identified two fire

barriers which did not require inspection because they were encapsulated in metal

flashing.

-6-

The emergency diesel generator (EDG) rooms were fire areas reactor auxiliary

building (RAB) 15 (EDG B) and RAB 16 (EDG A). These rooms were below the

ventilation mechanical room which is fire area RAB 2. The inlets to the EDG room

exhaust fans were 72x72 ducts which extended down from the ceilings and flared out

to larger openings. Fire Dampers FD-76 and FD-77 were located on the ends of the

ducts in fire area RAB 15 and RAB 16, respectively. Since the fire dampers were not in

the plane of the ceiling, the ductwork between the fire damper and the ceiling required

protection from the effects of a fire. Thermo-Lag material was installed on the ducts

between the fire damper and the ceiling. Records show that three-hour rated materials

were used; however, metal flashing was also installed encapsulating the fire barriers on

the ducts.

Thermo-Lag fire barriers are not passive insulating materials. Thermo-Lag sublimates

when exposed to high temperatures. The gases generated during the process absorb

heat which would otherwise be transferred to the item being protected. Encapsulating

the fire barriers with metal flashing restricts the release of gases. This is not a tested

configuration for Thermo-Lag fire barriers. While three-hour rated materials were used,

the effective fire resistance of the as-installed configuration is unknown.

Analysis. The failure to ensure the required separation between fire areas was a

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

was associated with the protection against external events (fire) attribute of the

Mitigating Systems cornerstone and it adversely affected the cornerstone objective of

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

events to prevent undesirable consequences. The team evaluated this finding using

Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance

Determination Process, dated September 20, 2013. The finding involved fire barrier

elements that separate one fire area from another; therefore, it was determined to be in

the fire confinement category in Inspection Manual Chapter 0609, Appendix F,

Attachment 1, Part 1: Fire Protection SDP Phase 1 Worksheet. Both EDG rooms are

equipped with pre-action sprinkler systems (fully automated suppression system) which

would limit temperatures near the ceiling around the room exhaust ducts; therefore, the

finding screened to Green in accordance with Section 1.4.3.C.

This finding did not have a cross-cutting aspect since it was not indicative of current

licensee performance since this fire barrier configuration was installed in the 1980s.

Enforcement. License Condition 2.C(9), Fire Protection, states, in part, EOI [Entergy

Operations, Inc.] shall implement and maintain in effect all provisions of the approved

fire protection program as described in the Final Safety Analysis Report for the facility

through Amendment 36 and as approved in the safety evaluation report (SER) through

Supplement 9. The Final Safety Analysis Report, Section 9.5.1.2.1, Fire Containment,

states, in part, Ductwork penetrations through fire area/zone boundary walls, floors, and

ceilings are externally sealed to provide fire resistance rating of three hours. The Final

Safety Analysis Report, Section 9.5.1.3.1, Detailed Comparison to Appendix "A" to the

Branch Technical Position APCSB 9.5-1, Revision 0, Item D.1.(j), states, in part,

Appendix R fire areas are isolated from each other by floors, walls, and ceilings having

a fire resistance rating of three hours unless noted otherwise in the Fire Area-By-Area

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Analysis. The Final Safety Analysis Report, Section 9.5.1.3.2, Fire Area-By-Fire Area

Analysis, identifies the fire area design rating of three hours for the boundaries between

fire areas RAB 2, RAB 15, and RAB 16. Contrary to the above, prior to February 13,

2015, the licensee failed to establish fire area boundaries having a fire resistance rating

of three hours. Specifically, two fire barriers protecting ventilation ducts between fire

dampers and the rooms ceilings are configured in a manner in which the fire resistance

rating is indeterminate.

Because this violation was of very low safety significance, has been entered into the

corrective action program as Condition Report CR-WF3-2015-00540, and the licensee

has established an hourly fire watch as a compensatory measure until corrective actions

can be taken, Fire Impairments 15-30 and 15-31, this violation is being treated as a

non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy:

NCV 05000382/2015007-01, Inadequate Fire Area Boundary.

.03 Active Fire Protection

a. Inspection Scope

The team reviewed the design, maintenance, testing, and operation of the fire detection

and suppression systems in the selected fire areas. The team verified the automatic

detection systems and the manual and automatic suppression systems were installed,

tested, and maintained in accordance with the National Fire Protection Association code

of record or approved deviations and that each suppression system was appropriate for

the hazards in the selected fire areas.

The team performed a walkdown of accessible portions of the detection and suppression

systems in the selected fire areas. The team also performed a walkdown of major

system support equipment in other areas (e.g., fire pumps) to assess the material

condition of these systems and components.

The team reviewed the electric and diesel fire pumps flow and pressure tests to verify

that the pumps met their design requirements. The team also reviewed the fire water

supply system flow and pressure tests to verify that the system capability met the design

requirements.

The team assessed the fire brigade capabilities by reviewing training, qualification, and

drill critique records. The team also reviewed pre-fire plans and smoke removal plans

for the selected fire areas to determine if appropriate information was provided to fire

brigade members and plant operators to identify safe shutdown equipment and

instrumentation and to facilitate suppression of a fire that could impact post-fire safe

shutdown capability. In addition, the team inspected fire brigade equipment to determine

operational readiness for fire-fighting.

The team observed an unannounced fire drill and subsequent drill critique on

February 12, 2015, using the guidance contained in Inspection Procedure 71111.05AQ,

Fire Protection Annual/Quarterly. The team observed fire brigade members fight a

simulated fire in fire area RAB 15, EDG room B. The team verified that the licensee

-8-

identified problems, openly discussed them in a self-critical manner at the drill debrief,

and identified appropriate corrective actions. Specific attributes evaluated were (1)

proper wearing of turnout gear and self-contained breathing apparatus; (2) proper use

and layout of fire hoses; (3) employment of appropriate fire-fighting techniques; (4)

sufficient fire-fighting equipment was brought to the scene; (5) effectiveness of fire

brigade leader communications, command, and control; (6) search for victims and

propagation of the fire into other areas; (7) smoke removal operations; (8) utilization of

pre-planned strategies; (9) adherence to the pre-planned drill scenario; and (10) drill

objectives.

b. Findings

No findings were identified.

.04 Protection From Damage From Fire Suppression Activities

a. Inspection Scope

The team performed plant walkdowns and document reviews to verify that redundant

trains of systems required for hot shutdown, which are located in the same fire area,

would not be subject to damage from fire suppression activities or from the rupture or

inadvertent operation of fire suppression systems. Specifically, the team verified:

• A fire in one of the selected fire areas would not directly, through production of

smoke, heat, or hot gases, cause activation of suppression systems that could

potentially damage all redundant safe shutdown trains.

• A fire in one of the selected fire areas or the inadvertent actuation or rupture of a

fire suppression system would not directly cause damage to all redundant trains

(e.g., sprinkler-caused flooding of other than the locally affected train).

• Adequate drainage is provided in areas protected by water suppression systems.

b. Findings

No findings were identified.

.05 Alternative Shutdown Capability

a. Inspection Scope

Review of Methodology

The team reviewed the safe shutdown analysis, operating procedures, piping and

instrumentation drawings, electrical drawings, the Final Safety Analysis Report, and

other supporting documents to verify that hot and cold shutdown could be achieved and

maintained from outside the control room for fires that require evacuation of the control

room, with or without offsite power available.

-9-

The team conducted plant walkdowns to verify that the plant configuration was

consistent with the description contained in the safe shutdown and fire hazards

analyses. The team focused on ensuring the adequacy of systems selected for

reactivity control, reactor coolant makeup, reactor decay heat removal, process

monitoring instrumentation, and support systems functions.

The team also verified that the systems and components credited for shutdown would

remain free from fire damage. Finally, the team verified that the transfer of control from

the control room to the alternative shutdown location would not be affected by

fire-induced circuit faults (e.g., by the provision of separate fuses and power supplies for

alternative shutdown control circuits).

Review of Operational Implementation

The team verified that licensed and non-licensed operators received training on

alternative shutdown procedures. The team also verified that sufficient personnel to

perform a safe shutdown were trained and available on-site at all times, exclusive of

those assigned as fire brigade members.

The team performed a timed walkdown of the alternative shutdown procedure with

licensed and non-licensed operators to determine the adequacy of the procedure. The

team verified that the operators could reasonably be expected to perform specific

actions within the time required to maintain plant parameters within specified limits.

Time critical actions that were verified included restoring electrical power, establishing

control at the remote shutdown panels, establishing reactor coolant makeup, and

establishing decay heat removal.

The team also reviewed the periodic testing of the alternative shutdown transfer

capability and instrumentation and control functions to verify that the tests were

adequate to demonstrate the functionality of the alternative shutdown capability.

b. Findings

.1 Introduction. The team identified a Green non-cited violation of License Condition 2.C.9,

Fire Protection, for the failure to adequately correct a previous violation. Specifically,

the licensee failed to provide a bounding calculation for the amount of time available for

operators to establish component cooling water during an alternative shutdown. The

licensee developed this calculation in response to Non-cited Violation 2012007-02.

Description. During the 2012 triennial fire protection inspection, the team identified a

violation for the failure to perform a safe shutdown design calculation. Specifically, the

team determined that the licensee failed to calculate the amount of time available for

operators to establish component cooling water to a running emergency diesel generator

that was providing power to safe shutdown components during an alternative shutdown.

The team documented this issue as Non-cited Violation 2012007-02, Failure to

Calculate Adequate Cooling Provided to Diesel Generator B within Required Time.

- 10 -

The licensee entered this issue into their corrective action program as Condition

Report 2012-00818.

In response to this violation, the licensee developed Engineering Change EC-36621,

Evaluate Impacts of Operating the Emergency Diesel Generators (EDGs) Without

Component Cooling Water. This engineering change revised Calculation EC-M12-001,

Emergency Diesel Generator with no CCW Flow, which determined the amount of time

that an emergency diesel generator could run without component cooling water during

an alternative shutdown prior to being damaged.

In Calculation EC-M12-001, the licensee first determined a worst case emergency diesel

generator load of 3.23 megawatt (MW) for an alternative shutdown without component

cooling water. The licensee then estimated the heat load for a running emergency

diesel generator by fitting a second order polynomial to empirical data. The licensee

estimated a heat load of approximately 5.65 MBTU/hr. when an emergency diesel

generator carried a load of 3.23 MW. Using this heat load of 5.65 MBTU/hr., the

licensee calculated an emergency diesel generator could run for 10 minutes without

component cooling water and not be damaged. The licensee used this result to support

the 10-minute time-critical action for operators to establish component cooling water

during an alternative shutdown.

The team reviewed Calculation EC-M12-001 and noted the empirical data demonstrated

the heat load near 3.23 MW was greater than the estimated heat load from the best fit

polynomial regression. The team concluded that the licensees calculation was not

bounding and operators had less than 10 minutes available to establish component

cooling water during an alternative shutdown. During the timed walkdown of the

alternative shutdown procedure, the team determined that it would take operators

approximately 11 minutes to establish component cooling water.

Analysis. The failure to provide an appropriate bounding calculation for the amount of

time available for operators to establish component cooling water during an alternative

shutdown was a performance deficiency. The performance deficiency was more than

minor because it was associated with the protection against external events (fire)

attribute of the Mitigating Systems cornerstone and it adversely affected the cornerstone

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

initiating events to prevent undesirable consequences. The team evaluated this finding

using Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance

Determination Process, dated September 20, 2013, because it affected the ability to

reach and maintain safe shutdown conditions in case of a fire. A senior reactor analyst

performed a Phase 3 evaluation to determine the risk significance of this finding since it

involved a postulated control room fire that led to control room evacuation.

For the control room, the senior reactor analyst assigned a generic fire ignition frequency

for the main control board (FIFMCB) from NUREG/CR-6850, Table 6-1, Fire Frequency

Bins and Generic Frequencies. The analyst multiplied the fire ignition frequency by a

severity factor (SF) and a non-suppression probability indicating that operators failed to

extinguish the fire within 20 minutes, assuming a 2-minute detection that required a

- 11 -

control room evacuation (NPCRE). The resulting control room evacuation frequency (FCR)

was:

FCR = FIFMCB * SF * NPCRE

= 2.5E-3/year * 0.1 * 1.3E-2

= 3.25E-6/year

The main control board had a total of 12 panels. The analyst determined that only a fire

in one of these panels (CP-8) could lead to the loss of component cooling water to the

emergency diesel generator. Therefore, a bounding change in core damage frequency

for a control room fire that leads to evacuation and the loss of the emergency diesel

generator (FCRE+EDG) was determined to be:

FCR+EDG = FCR * (1 / 12)

= 3.25E-6/year * (1 / 12)

= 2.7E-7/year

For the cable vault, the senior reactor analyst limited the risk determination to transient

and hot work fires since there were no fixed ignition sources in the cable vault. The

senior reactor analyst assigned a low likelihood rating for transients and hot work

activities in the cable vault. The senior reactor analyst then assigned a fire ignition

frequency for transients (FIFCV-TR) and hot work activities (FIFCV-HW) from Inspection

Manual Chapter 0609, Appendix F, Attachment 4.

The senior reactor analyst determined that the floor area of the cable vault was

5778.5 square feet. The senior reactor analyst assigned a screening weighting

factor (W) of 0.1 for transient and hot work fires. The senior reactor analyst noted that

the cable vault had smoke detectors and a pre-action automatic sprinkler system. The

senior reactor analyst assigned a nominal failure probability of the sprinkler system

(PSPR) from Inspection Manual Chapter 0609, Appendix F, Task 2.7.4.

The senior reactor analyst calculated a bounding change in core damage frequency for a

cable vault fire that leads to evacuation and the loss of the emergency diesel generator

(FCV+EDG) was determined to be:

FCV+EDG = (FIFTR + FIFHW) * W * NPSPR

= (5.5E-5/year + 2.3E-5/year) * 0.1 * 0.05

= 3.9E-7/year

Since fires in the control room are independent of fires in the cable vault, the senior

reactor analyst calculated a bounding total change in core damage frequency (CDFTOT)

for the performance deficiency by adding the change in core damage frequencies for the

- 12 -

control room and cable vault calculated above. The senior reactor analyst calculated a

bounding total change in core damage frequency of:

CDFTOT = FCR+EDG + FCV+EDG

= 2.7E-7/year + 3.9E-7/year

= 6.6E-7/year

This change in core damage frequency was considered to be bounding since it

assumed:

• A fire in any of the applicable main control board panels or the cable vault areas

would cause a loss of offsite power and a loss of component cooling water,

resulting in a loss of the emergency diesel generator;

• The conditional core damage probability given a control room fire with evacuation

and the loss of the emergency diesel generator was equal to one, and

• The performance deficiency accounted for the entire change in core damage

frequency (i.e., the baseline core damage frequency for this event was zero).

In accordance with the guidance in Inspection Manual Chapter 0609, Appendix H,

Containment Integrity Significance Determination Process, dated May 6, 2004, the

senior reactor analyst screened the performance deficiency for its potential risk

contribution to large early release frequency since the bounding change in core damage

frequency provided a risk significance estimate greater than 1E-7/yr. Given that

Waterford has a large dry containment and that control room evacuation sequences do

not include steam generator tube ruptures or intersystem loss of coolant accidents, the

analyst determined that this example was not significant with respect to large early

release frequency. The analyst determined this example was of very low risk

significance (Green).

This finding had a cross-cutting aspect associated with Resolution within the Problem

Identification and Resolution area since the licensee failed to take effective corrective

actions to address issues in a timely manner commensurate with their safety

significance. Specifically, the team determined that the licensees corrective actions

were not effective since the licensee failed to provide a bounding calculation for the

amount of time available for operators to establish component cooling water during an

alternative shutdown (P.3).

Enforcement. License Condition 2.C.9, Fire Protection, states, in part, that the licensee

shall implement and maintain in effect all provisions of the approved fire protection

program as described in the Final Safety Analysis Report for the facility through

Amendment 36 and as approved in the Safety Evaluation Report through Supplement 9.

Final Safety Analysis Report, Section 9.5.1.3.1.C, states that the fire protection program

quality assurance program is documented in Procedure UNT-005-013, Fire Protection

- 13 -

Program. Procedure UNT-005-013, Section 5.8.8, states, in part, that conditions

adverse to quality relating to the fire protection program will be identified and corrected.

Contrary to the above, from September 5, 2012, to April 15, 2015, the licensee failed to

implement and maintain in effect all provisions of the approved fire protection program.

Specifically, the licensee failed to correct a condition adverse to fire protection since the

licensee failed to perform an appropriate bounding calculation for the amount of time

available for operators to establish component cooling water during an alternative

shutdown. The licensee developed this calculation as a corrective action for Non-cited

Violation 2012007-02, Failure to Calculate Adequate Cooling Provided to Diesel

Generator B within Required Time.

The licensee entered this issue into their corrective action program as Condition

Report CR-WF3-2015-00859 and implemented Fire Impairment 15-045 as a

compensatory measure. Because this violation was of very low safety significance and

has been entered into the corrective action program, this violation is being treated as a

non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy:

NCV 05000382/2015007-02, Failure to Provide a Bounding Calculation for Time Critical

Actions.

.2 Introduction. The team identified a violation of Technical Specification 6.8.1.f for the

failure to implement and maintain adequate written procedures covering fire protection

program implementation. Specifically, the team identified four examples where the

licensee failed to maintain an alternative shutdown procedure that successfully mitigated

all postulated alternative shutdown scenarios. This finding affects 10 CFR 50.48 and

has been screened and determined to warrant enforcement discretion per the Interim

Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues

(10 CFR 50.48).

Description. The licensee used Procedure OP-901-502, Evacuation of Control Room

and Subsequent Plant Shutdown, Revision 28, to shut down the reactor from the

remote shutdown panel in the event a control room or cable vault fire required

evacuation of the control room. This alternative shutdown procedure provided steps for

operators to transfer control of the credited safe shutdown equipment away from the

control room to the remote shutdown panel and to achieve and maintain safe shutdown

conditions from the remote shutdown panel.

The team performed a timed walkdown of the alternative shutdown procedure. Based

on the walkdown results, the team determined that the alternative shutdown procedure

was not adequate to ensure that operators could successfully mitigate all postulated

alternative shutdown scenarios. In particular, the team identified the following four

scenarios where operators may not be able to achieve and maintain a safe shutdown:

Example 1: Potential Loss of Credited Safe Shutdown Pumps

The first scenario involved fire damage resulting in blown fuses for either the component

cooling water or emergency feedwater pumps. In this scenario, the team determined the

operators would be unable to control the affected pump from the remote shutdown

- 14 -

panel, but the operators would be able to control the affected pump by manually

operating the breakers that supplied power to the motors. The team noted that the

alternative shutdown procedure did not provide any steps for operators to manually

operate the breakers to control these pumps, which were required for safe shutdown.

Example 2: Potential Spurious Opening of the Atmospheric Dump Valves

The second scenario involved the spurious actuation of two atmospheric dump valves.

The team noted that the licensee previously had a 10-minute requirement for operators

to mitigate the spurious actuation of two atmospheric dump valves by taking manual

control of an open atmospheric dump valve locally and then manually closing the valve.

The team determined that the alternative shutdown procedure provided steps for

operators to manually close an open atmospheric dump valve; however, the licensee

removed the 10-minute requirement for operators to be able to perform this action.

The licensee removed the 10-minute requirement based on its understanding that the

spurious actuation of only one atmospheric dump valve was required to be analyzed and

mitigated. The team referred to guidance in Regulatory Guide 1.189, Revision 2, which

stated, in part, after control of the plant is achieved by the alternative or dedicated

shutdown system, single or multiple spurious actuations that could occur in the fire-

affected area should be considered...

The team reviewed the licensees method for isolating the atmospheric dump valves

from the effects of a control room or cable vault fire. The team determined that the

circuits responsible for isolating the atmospheric dump valves were located within the

control room complex and, therefore, could not be relied upon to isolate the atmospheric

dump valves in the event of a control room fire. The team concluded that the licensee

should have maintained the 10-minute requirement in the alternative shutdown

procedure for operators to manually close a spuriously open atmospheric dump valve.

During the timed walkdown of the alternative shutdown procedure, the team determined

that it would take operators approximately 13 minutes to close a spuriously open

atmospheric dump valve.

Example 3: Potential Spurious Opening of a Pressurizer Spray Valve

The third scenario involved the spurious opening of a pressurizer spray valve. In this

scenario, the open pressurizer spray valve results in a rapid depressurization of the

reactor coolant system, which could negatively impact the ability to achieve and maintain

natural circulation.

The licensee considered this scenario in the safe shutdown analysis. The licensee did

not perform an analysis or calculation to determine the amount of time operators had

available to mitigate this scenario. Instead, the licensee used engineering judgment to

specify that operators had 10 minutes available to secure the spurious spray flow.

The team was concerned that the 10-minute limit may not be sufficient to ensure that

operators could achieve and maintain natural circulation. In response to the teams

- 15 -

concern, the licensee modeled this scenario on the simulator. The team noted that the

use of the simulator was not a preferred method; however, it provided a reasonable

estimate for the amount of time available.

The results of the simulator run indicated that the reactor coolant system would reach

saturation pressure in less than 8 minutes. Once the reactor coolant system reaches

saturation pressure, voiding begins in the reactor coolant system. This voiding could

then negatively impact the ability to achieve and maintain natural circulation.

The team determined that the alternative shutdown procedure provided steps for

operators to trip the reactor coolant pumps, which would mitigate this scenario by

eliminating flow through the pressurizer spray valves. During the timed walkdown of

the alternative shutdown procedure, the team determined that it would take operators

approximately 9 minutes and 15 seconds to trip all of the reactor coolant pumps.

Scenario 4: Potential Overfilling of the Steam Generators

The fourth scenario involved the potential overfilling of the steam generators. In this

scenario, the open main steam isolation valves continue to provide steam to the turbine-

driven main feedwater pumps, which continue to inject feedwater into the steam

generators until they overfill.

The team noted that the action to close the main steam isolation valves prior to

evacuating the control room was an operator action within the fire area. The team

determined that this action was not credited in the plants approved fire protection

program; therefore, the operators must take action outside of the control room to ensure

that the main steam isolation valves were closed.

Because the licensee did not have an analysis establishing a time limit, the team was

concerned the operators may not perform this action prior to main feedwater overfilling

the steam generators. In response to the teams concern, the licensee modeled this

scenario on the simulator. The team noted that the use of the simulator was not a

preferred method; however, it provided a reasonable estimate for the amount of time

available.

The results of the simulator run indicated that the continued injection of main feedwater

at full flow could overfill the steam generators in approximately 2 minutes and

30 seconds. The team noted that overfilling the steam generators would negatively

impact the ability to remove decay heat.

The team determined that the alternative shutdown procedure provided steps for

operators to close the main steam isolation valves from outside the control room, which

would mitigate this scenario by eliminating steam flow to the turbine-driven main

feedwater pumps. During the timed walkdown of the alternative shutdown procedure,

the team determined that it would take operators approximately 4 minutes and

30 seconds to close all of the main steam isolation valves.

- 16 -

Analysis. The failure to implement and maintain adequate written procedures covering

fire protection program implementation was a performance deficiency. The performance

deficiency was more than minor because it was associated with the procedure quality

attribute of the Mitigating Systems cornerstone and it adversely affected the cornerstone

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

initiating events to prevent undesirable consequences. A senior reactor analyst

performed a calculation to bound the risk significance of this finding. The senior reactor

analyst determined that the finding was not of high safety significance. As discussed

below, the team consulted the NRC Enforcement Policy, Section 9.1, Enforcement

Discretion for Certain Fire Protection Issues (10 CFR 50.48), to determine if the

noncompliance was eligible for enforcement discretion.

This finding did not have a cross-cutting aspect because it qualified for enforcement

discretion.

Enforcement. Technical Specification 6.8.1.f states that written procedures shall be

established, implemented, and maintained covering fire protection program

implementation. Licensee Procedure OP-901-502, Evacuation of Control Room and

Subsequent Plant Shutdown, Revision 28, implemented alternative shutdown outside of

the control room. Contrary to the above, prior to April 15, 2015, the licensee failed to

implement and maintain written procedures covering fire protection program

implementation. Specifically, the team identified four scenarios where the licensee failed

to ensure that the alternative shutdown procedure was adequate to ensure that

operators could mitigate all postulated alternative shutdown scenarios.

Because the licensee committed to adopting National Fire Protection Association

Standard 805, Performance-Based Standard for Fire Protection for Light Water Reactor

Electric Generating Plants, and has committed to changing their fire protection program

license basis to comply with 10 CFR 50.48(c) by submitting a license amendment

request to the NRC, this violation was eligible for enforcement discretion as described in

Section 9.1 of the Enforcement Policy, Enforcement Discretion for Certain Fire

Protection Issues (10 CFR 50.48).

Specifically, the team determined that the licensee: (1) would have identified the

violation in light of the defined scope, thoroughness, and schedule of its transition to

10 CFR 50.48(c) because the licensee was performing new analyses and revising the

alternative shutdown procedure for the transition to NFPA-805; (2) the licensee will

correct the violation after completing its transition to 10 CFR 50.48(c) and took

immediate corrective action and compensatory measures within a reasonable time

commensurate with the risk significance of the issue following identification; (3) routine

licensee efforts were not likely to have previously identified the violation; (4) the violation

was not willful; and (5) the team determined that this violation was not of high safety

significance. The finding also met additional discretion criteria established in

Section 11.05.b of Inspection Manual Chapter 0305, Operating Reactor Assessment

Program.

- 17 -

The licensee entered these issues into its corrective action program as Condition

Reports CR-WF3-2015-00833, CR-WF3-2015-00857, CR-WF3-2015-00858,

CR-WF3-2015-01871, CR-WF3-2015-01872, and CR-WF3-2015-01873, and

implemented Fire Impairments15-041 through 15-045 as compensatory measures.

Since all the criteria for the use of enforcement discretion were met, the NRC is

exercising enforcement discretion to not cite this violation in accordance with the

Interim Enforcement Policy regarding Enforcement Discretion For Certain Fire

Protection Issues (10 CFR 50.48). This use of enforcement discretion is documented

in the Enforcement Tracking System as EA-2015-077.

.06 Circuit Analysis

a. Inspection Scope

The team reviewed the post-fire safe shutdown analysis to verify that the licensee

identified the circuits that may impact the ability to achieve and maintain safe shutdown.

The team verified, on a sample basis, that the licensee properly identified the cables for

equipment required to achieve and maintain hot shutdown conditions in the event of a

fire in the selected fire areas. The team verified that these cables were either

adequately protected from the potentially adverse effects of fire damage or were

analyzed to show that fire-induced circuit faults (e.g., hot shorts, open circuits, and

shorts to ground) would not prevent safe shutdown.

The teams evaluation focused on the cables of selected components from the reactor

coolant system, refueling water storage tank, component cooling water, auxiliary

component cooling water, main steam isolation, atmospheric steam dumps, emergency

feed water, emergency diesel, low pressure safety injection, and chemical volume and

control system. For the sample of components selected, the team reviewed electrical

elementary and block diagrams and identified power, control, and instrument cables

necessary to support their operation. In addition, the team reviewed cable routing

information to verify that fire protection features were in place as needed to satisfy the

separation requirements specified in the fire protection license basis. Specific

components reviewed by the team are listed in the attachment.

b. Findings

No findings were identified.

.07 Communications

a. Inspection Scope

The team inspected the contents of designated emergency storage lockers and

reviewed the alternative shutdown procedure to verify that portable radio

communications and fixed emergency communications systems were available,

operable, and adequate for the performance of designated activities. The team verified

the capability of the communication systems to support the operators in the conduct and

coordination of their required actions. The team also verified that the design and

- 18 -

location of communications equipment such as repeaters and transmitters would not

cause a loss of communications during a fire. The team discussed system design,

testing, and maintenance with the system engineer.

b. Findings

No findings were identified.

.08 Emergency Lighting

a. Inspection Scope

The team reviewed the portion of the emergency lighting system required for alternative

shutdown to verify that it was adequate to support the performance of manual actions

required to achieve and maintain hot shutdown conditions and to illuminate access and

egress routes to the areas where manual actions would be required. The team

evaluated the locations and positioning of the emergency lights during a walkdown of the

alternative shutdown procedure.

The team verified that the licensee installed emergency lights with an 8-hour capacity,

maintained the emergency light batteries in accordance with manufacturer

recommendations, and tested and performed maintenance in accordance with plant

procedures and industry practices.

b. Findings

.1 Introduction. The team identified a Green non-cited violation of License Condition 2.C.9,

Fire Protection, for the failure to periodically test and demonstrate the 8-hour capacity

of the Appendix R emergency lighting units.

Description. In 2004, the licensee discontinued the performance of 8-hour discharge

tests for the Appendix R emergency lighting units. Specifically, the licensee removed

the requirement to perform the discharge tests from Procedure ME-004-445, Self

Contained Battery Powered Emergency Lighting Unit. In lieu of performing discharge

tests, the licensee implemented a preventive maintenance program that replaced the

emergency lighting unit batteries every three years.

The licensee documented their justification in Engineering Request ER-W3-2004-0222,

Alternative Methodology for Appendix R 8-Hour Battery Powered Emergency Light

Testing, Revision 0. This engineering request referenced guidance contained in

EPRI TR-106826, Battery Performance Monitoring by Internal Ohmic Measurements.

The team reviewed the engineering request and the EPRI report and determined that the

licensee incorrectly applied the results of the EPRI report. Specifically, the team noted

that the objective of the EPRI report was to determine the extent to which internal ohmic

measurements could replace or reduce the frequency of discharge tests for emergency

lighting units. Based on the favorable test results, EPRI recommended using internal

ohmic measurements in lieu of discharge tests for two types of emergency lighting units.

- 19 -

The team noted that the licensee did not use either of these two types of emergency

lighting units, nor did the EPRI report recommend discontinuing discharge tests for any

other types of emergency lighting units.

In addition to referencing the EPRI report, the licensee made the following statements

regarding the discharge tests:

• No specific regulatory or OEM requirement was found that requires the 8-hour

discharge test.

• The 8-hour capacity of the unit is a design function which is applicable to

component selection and does not require periodic re-verification.

• The units self-diagnostic circuit monitors the battery capacity which is the

equivalent to the current discharge test.

The team reviewed the fire protection program described in Procedure UNT-005-013,

Fire Protection Program, Revision 12, and determined that it required the licensee to

periodically test the emergency lighting units to ensure that the equipment will function

properly and continue to meet their design criteria (i.e., have an 8-hour battery capacity).

The team noted that the licensee failed to consider this requirement when changing

Procedure ME-004-445. Finally, the team reviewed the licensees justification and the

vendors information and did not find evidence to support the statement that the units

self-diagnostic circuit monitoring was sufficient to demonstrate the required 8-hour

battery capacity.

Analysis. The failure to periodically test and demonstrate the 8-hour capacity of the

Appendix R emergency lighting units was a performance deficiency. The performance

deficiency was more than minor because it was associated with the protection against

external events (fire) attribute of the Mitigating Systems cornerstone and it adversely

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

of systems that respond to initiating events to prevent undesirable consequences.

The team evaluated this finding using Inspection Manual Chapter 0609, Appendix F,

Fire Protection Significance Determination Process, dated September 20, 2013,

because it affected the ability to reach and maintain safe shutdown conditions in case of

a fire. The team assigned the finding to the post-fire safe shutdown category since it

impacted the alternate shutdown element. The team assigned the finding a low

degradation rating because the failure to periodically test and demonstrate the 8-hour

capacity of the Appendix R emergency lighting units would not prevent reaching and

maintaining safe shutdown conditions in the event of a control room fire. Specifically,

the team had reasonable assurance that the emergency lighting units would provide

adequate illumination for a sufficient amount of time for operators to perform the most

time critical actions. In addition, the team determined that operators performing an

alternative shutdown had flashlights available in the Appendix R equipment lockers.

Because the team assigned a low degradation rating, in accordance with Inspection

Manual Chapter 0609, Appendix F, Step 1.3.1.B, this finding screened as having very

low safety significance (Green).

- 20 -

This finding did not have a cross-cutting aspect since it was not indicative of present

performance in that the performance deficiency occurred more than three years ago.

Enforcement. License Condition 2.C.9, Fire Protection, states, in part, that the licensee

shall implement and maintain in effect all provisions of the approved fire protection

program as described in the Final Safety Analysis Report for the facility through

Amendment 36 and as approved in the Safety Evaluation Report through Supplement 9.

Final Safety Analysis Report, Section 9.5.1.3.1.C, states that the fire protection program

quality assurance program is documented in Procedure UNT-005-013, Fire Protection

Program. Procedure UNT-005-013, Step 5.8.5.2.d, states that fire protection

equipment, emergency lighting, and communication equipment are tested periodically to

assure that the equipment will function properly and continue to meet the design criteria.

Contrary to the above, from April 15, 2004, to April 15, 2015, the licensee failed to

implement a provision of the approved fire protection program. Specifically, the licensee

failed to periodically test the emergency lights to assure that the lights will function

properly and continue to meet their design criteria.

The licensee entered this issue into their corrective action program as Condition

Report CR-WF3-2015-00856 and operators have flashlights available as a

compensatory measure. Because this violation was of very low safety significance and

has been entered into the corrective action program, this violation is being treated as a

non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy:

NCV 05000382/2015007- 03, Failure to Periodically Test Emergency Lighting Units.

.2 Introduction. The team identified a Green non-cited violation of License Condition 2.C.9,

Fire Protection, for the failure to correct adverse conditions associated with fire

protection. Specifically, the licensee failed to correct long-standing deficiencies with the

Appendix R emergency lighting units.

Descriptions. During the teams walkdown of the alternative shutdown procedure and

subsequent discussions with the licensees engineering staff, the team identified three

Appendix R emergency lighting units with longstanding deficiencies that had not been

corrected. At the time of inspection, three lights remained nonfunctional for

approximately 3 to 6 years. The three impaired emergency lighting units were:

• LTE-EBLT-324-8B - This light was located in the remote shutdown room. This

light was identified as impaired on January 9, 2009, in Work Request 151869.

This work request was scheduled to be completed on August 26, 2015. No

condition report was generated at the time of discovery.

• LTE-EBLT-321-20B - This light was located near the main steam isolation valve

area. This light was first identified as impaired on March 2, 2010, in Condition

Report CR-WF3-2010-01369. This light was scheduled to be repaired under

Work Request 192775. This work request was scheduled to be completed on

July 14, 2015.

- 21 -

• LTE-EBLT-320-14E - This light was located near the main steam isolation

valve area. This light was first identified as impaired on February 16, 2012, in

Condition Report CR-WF3-2012-00840. This light was scheduled to be repaired

under Work Request 264052. At the time this finding was identified, a

completion date for this work request has not been scheduled.

The team determined that there was no practical reason for the lights to have not been

repaired in a timely manner.

Analysis. The failure to correct long-standing deficiencies with the Appendix R

emergency lighting units was a performance deficiency. The performance deficiency

was more than minor because it was associated with the protection against external

events (fire) attribute of the Mitigating Systems cornerstone and it adversely affected

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

that respond to initiating events to prevent undesirable consequences. The team

evaluated this finding using Inspection Manual Chapter 0609, Appendix F, Fire

Protection Significance Determination Process, dated September 20, 2013, because it

affected the ability to reach and maintain safe shutdown conditions in case of a fire. The

team assigned the finding to the post-fire safe shutdown category since it impacted the

alternate shutdown (control room abandonment) element. The team assigned the

finding a low degradation rating because the failure to provide adequate 8-hour

emergency lights at all locations would not prevent reaching and maintaining safe

shutdown conditions in the event of a control room fire. Specifically, the team

determined that operators performing an alternative shutdown had flashlights available

in the Appendix R equipment lockers. Because the team assigned a low degradation

rating in accordance with Inspection Manual Chapter 0609, Appendix F, Step 1.3.1.B,

this finding screened as having very low safety significance (Green).

This finding had a cross-cutting aspect associated with resolution within the problem

identification and resolution area since the licensee failed to take effective corrective

actions to address issues in a timely manner commensurate with their safety

significance. Specifically, the team determined that the licensee failed to take corrective

actions to address the nonfunctional emergency lighting units in a timely manner (P.3).

Enforcement. License Condition 2.C.9, Fire Protection, states, in part, that the licensee

shall implement and maintain in effect all provisions of the approved fire protection

program as described in the Final Safety Analysis Report for the facility through

Amendment 36 and as approved in the Safety Evaluation Report through Supplement 9.

Final Safety Analysis Report, Section 9.5.1.3.1.C, states that the fire protection program

quality assurance program is documented in Procedure UNT-005-013, Fire Protection

Program. Procedure UNT-005-013, Section 5.8.8, states, in part, that conditions

adverse to quality relating to the fire protection program will be identified and corrected.

Contrary to the above, from 2009 to April 15, 2015, the licensee failed to implement and

maintain in effect all provisions of the approved fire protection program. Specifically, the

licensee failed to correct long-standing deficiencies with the Appendix R emergency

lighting units.

- 22 -

The licensee entered this issue into their corrective action program as Condition

Report CR-WF3-2015-00593 and operators had flashlights available as a compensatory

measure. Because this violation was of very low safety significance and has been

entered into the corrective action program, this violation is being treated as a non-cited

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

NCV 05000382/2015007-04, Failure to Correct Long Standing Deficiencies with the

Appendix R Emergency Lighting Units.

.09 Cold Shutdown Repairs

a. Inspection Scope

The team evaluated whether the licensee identified repairs needed to reach and

maintain cold shutdown and had dedicated repair procedures, equipment, and materials

to accomplish these repairs. Using these procedures, the team evaluated whether these

components could be repaired in time to bring the plant to cold shutdown within the

timeframes specified in their design and licensing bases. The team reviewed whether

the repair equipment, components, tools, and materials needed for the repairs were

available and accessible on site.

b. Findings

No findings were identified.

.10 Compensatory Measures

a. Inspection Scope

The team verified that compensatory measures were implemented for out-of-service,

degraded, or inoperable fire protection and post-fire safe shutdown equipment, systems,

or features (e.g., detection and suppression systems and equipment; passive fire

barriers; or pumps, valves, or electrical devices providing safe shutdown functions). The

team also verified that the short-term compensatory measures compensated for the

degraded function or feature until appropriate corrective action could be taken and that

the licensee was effective in returning the equipment to service in a reasonable period of

time.

The team reviewed operator manual actions credited for achieving hot shutdown for fires

that do not require an alternative shutdown. The team verified that operators could

reasonably be expected to perform the actions within the applicable shutdown time

requirements. The team reviewed these operator manual actions using the guidance

contained in NUREG-1852, Demonstrating the Feasibility and Reliability of Operator

Manual Actions in Response to Fire, dated October 2007.

b. Findings

No findings were identified.

- 23 -

.11 Review and Documentation of Fire Protection Program Changes

a. Inspection Scope

The team reviewed changes which occurred from February 17, 2012, to April 15, 2015,

to the approved fire protection program. The team verified that the changes did not

constitute an adverse effect on the ability to safely shutdown.

b. Findings

No findings were identified.

.12 Control of Transient Combustibles and Ignition Sources

a. Inspection Scope

The team reviewed the licensees approved fire protection program, implementing

procedures, and programs for the control of ignition sources and transient combustibles.

The team assessed the licensees effectiveness in preventing fires and in controlling

combustible loading within limits established in the fire hazards analysis. The team

performed plant walkdowns to independently verify that transient combustibles and

ignition sources were being properly controlled in accordance with the administrative

controls.

b. Findings

No findings were identified.

.13 Alternative Mitigation Strategy Inspection Activities

a. Inspection Scope

The team reviewed the licensees implementation of guidance and strategies intended to

maintain or restore core, containment, and spent fuel pool cooling capabilities under the

circumstances associated with loss of large areas of the plant due to explosions or fire

as required by Section B.5.b of the Interim Compensatory Measures Order, EA-02-026,

dated February 25, 2002, and 10 CFR 50.54(hh)(2).

The team reviewed the strategies to verify that the licensee continued to maintain and

implement procedures, maintain and test equipment necessary to properly implement

the strategies, and ensure station personnel were knowledgeable and capable of

implementing the procedures. The team performed a visual inspection of portable

equipment used to implement the strategy to ensure the availability and material

readiness of the equipment, including the adequacy of portable pump trailer hitch

attachments, and verify the availability of onsite vehicles capable of towing the portable

pump. The team assessed the offsite ability to obtain fuel for the portable pump and

foam used for firefighting efforts. The team reviewed the following strategies described

- 24 -

in Procedure S-SAMG-1, Loss of Large Areas of the Plant Due To Fire/Explosion,

Revision 16:

• Fill of the Spent Fuel Pool

o Normal Make Up and Make Up from Fire Protection

o Make Up from Portable Pump

o Other Make Up Methods

o Leakage Mitigations

o Internal Spray

o Air Cooling

o External Spray

o Containing Run Off

• Containment Flooding Injection Using Portable Pump.

The team completed two samples.

b. Findings

No findings were identified.

4. OTHER ACTIVITIES [OA]

4OA2 Identification and Resolution of Problems

Corrective Actions for Fire Protection Deficiencies

a. Inspection Scope

The team selected a sample of condition reports associated with the licensee's fire

protection program to verify that the licensee had an appropriate threshold for identifying

deficiencies. The team reviewed the corrective actions proposed and implemented to

verify that they were effective in correcting identified deficiencies. The team evaluated

the quality of recent engineering evaluations through a review of condition reports,

calculations, and other documents during the inspection.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

The team presented the preliminary inspection results to Mr. M. Chisum, Site Vice President,

and other members of the licensee staff at a debrief meeting on February 13, 2015. The

licensee acknowledged the findings presented.

- 25 -

The team presented the inspection results to Mr. B. Lanka, Director, Engineering, and other

members of the licensee staff in a telephonic exit meeting on April 15, 2015. The licensee

acknowledged the findings presented.

The inspectors verified that no proprietary information was retained by the inspectors.

- 26 -

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

D. Becker, Fire Protection Engineer, Design Engineering

J. Briggs, Acting Manager, Maintenance

B. Briner, System Engineer, Systems Engineering

W. Carey, Manager, Emergency Planning

M. Chisum, Site Vice President

S. Cooper, Reactor Operator, Operations

J. Crews, Supervisor, Systems Engineering

W. Crowley, Senior Reactor Operator, Operations

R. Gilmore, Manager, Entergy Systems & Component engineering

A. Harris, Consultant, Projects

J. Hashim, Fire Protection Engineer, Systems Engineering

M. Haydel, Manager, Design & Programs Engineering

J. Jarrell, Manager, Regulatory Assurance

J. Lanci, Preventative Maintenance Program Owner

B. Lanka, Director, Engineering

B. Lindsey, Senior Manager, Operations

J. MacArthur, Senior Nuclear Auxiliary Operator, Operations

J. McBrayer, Licensing Administration Specialist

W. Mc Kinney, Manager, Training

S. Meiklejohn, Licensing Specialist, Regulatory Assurance

M. Mills, Manager, Nuclear Oversight

L. Morgan, Senior Nuclear Auxiliary Operator, Operations

S. Nelson, Operations, Fire Marshal

R. Osbom, Manager, Performance Improvement

B. Pellegrin, Senior Manager, Production

C. Rich, Director, Regulatory Assurance

M. Richey, General Manager, Operations

J. Thompson, Senior Technical Instructor, Training

R. Tran, Electrical Engineer, Design Engineering

NRC Personnel

Frances Ramirez, Senior Resident Inspector

A-1 Attachment

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000382/2015007-01 NCV Inadequate Fire Area Boundary (Section 1R05.02.b)

Failure to Provide a Bounding Calculation for Time Critical

05000382/2015007-02 NCV

Actions (Section 1R05.05.b.1)

Failure to Periodically Test Emergency Lighting Units05000382/2015007-03 NCV

(Section 1R05.08.b.1)

Failure to Correct Long Standing Deficiencies with the

05000382/2015007-04 NCV Appendix R Emergency Lighting Units

(Section 1R05.08.b.2)

A-2

LIST OF DOCUMENTS REVIEWED

Cable Routing Data Components

30294A 30360C 30702G 31055C

30294A 30360D 30702L 31055G

30294B 30360E 30709B 31055N

30294B 30360F 30709C 31058B

30294C 30375A 30709D 31058C

30294C 30375C 30709E 31058D

30294D 30375F 30709F 31058E

30294D 30375G 30709P 31533A

30294E 30375H 30931A 31533B

30294E 30375J 30931B 31533C

30295A 30375K 30931C 31533D

30295B 30375L 30931D 31547B

30295C 30375M 30931E 31549B

30295D 30375N 30932A 31661C

30295E 30375Q 30932B 32377J

30300A 30381F 30932C 32377L

30300C 30381G 30932L 32377M

30300C 30381H 30933A 32377N

30300H 30381J 30933B 32377P

30300J 30381K 30933C 32377U

30300J 30382F 30933D 32388B

30300N 30382G 30933E 32390B

30327C 30382H 30933F 32391C

30327D 30382J 30933H 32391D

30327E 30382K 30934A 32391E

30360A 30700L 30934B 32391H

30360B 30700N 31055B

Calculations

Number Title Revision

CN-TDA-10-2 Westinghouse Calculation - Waterford 3 Appendix R 1

Fire Analysis Report.

EC-F00-026 Post Fire Safe Shutdown Analysis (Appendix R 3

Revalidation)

EC-M12-001 Emergency Diesel Generator with no CCW Flow 0

EC-41765 DC Circuits Proper Polarity 0

ECS98-001 EOP Action Value Basis Document. 4

A-3

Calculations

Number Title Revision

PRA-W3-05-007 Waterford 3 Fire PRA Summary Report 2

WCAP-16175-P-A Model for Failure of RCP Seals Given Loss of Seal 0

Cooling in CE NSSS Plants.

Condition Reports (CR-WF3-xxxx-xxxxx)

2000-01144 2014-00971 2015-00563* 2015-00833*

2003-02441 2014-01635 2015-00572* 2015-00843*

2010-01369 2014-02841 2015-00576* 2015-00856*

2010-04136 2014-03620 2015-00578* 2015-00857*

2010-05237 2014-03896 2015-00592* 2015-00858*

2011-06349 2014-05185 2015-00593* 2015-00859*

2012-00550 2014-05264 2015-00595* 2015-01871*

2012-00840 2014-05393 2015-00540* 2015-01872*

2013-00089 2014-05546 2015-00625* 2015-01873*

2013-01644 2014-05875 2015-00682*

2013-05723 2015-00528* 2015-00736*

• Issued as a result of inspection activities.

Drawings

Number Title Revision

B289 Sheet 109 Power Distribution and Motor Data 120V DC 16

Distribution Panel 3B-DC-S

B289 Sheet 147 Power Distribution and Motor Data 120V Distribution 13

Panel No. 390-SA

B289 Sheet 147A Power Distribution and Motor Data 120V Distribution 12

Panel No. 390-SA

B289 Sheet 148 Power Distribution and Motor Data 120V Distribution 18

Panel No. 391-SB

B289 Sheet 148A Power Distribution and Motor Data 120V Distribution 10

Panel No. 391-SB

B424 Sheet 210S Control Wiring Diagram Steam Generator 1 Pressure 15

Sheet 1

B424 Sheet 211S Control Wiring Diagram Steam Generator 1 Pressure 11

Sheet 2

A-4

Drawings

Number Title Revision

B424 Sheet 212S Control Wiring Diagram Steam Generator 1 Level 12

Sheet 1

B424 Sheet 213S Control Wiring Diagram Steam Generator 1 Level 8

Sheet 2

B424 Sheet 278S Control Wiring Diagram Sub-Cooled Margin Monitor 13

Channel A Instrumentation

B424 Sheet XLII Typical Breaker Trip and Closing Circuits 4

B424 Sheet E327 Control Wiring Diagram Volume Control Tank 8

Discharge Valve 2CH-V123A/B

B424 Sheet 294 Pressurizer Auxiliary Spray Valve ICH-E2505A (for 8

CVCI SV-0216A)

B424 Sheet 295 Pressurizer Auxiliary Spray Valve ICH-E2505B (for 12

CVCI SV-0216B)

B424 Sheet 300 Letdown Stop Valve 1CH-F1516 A/B (for CVCI SV- 16

0101)

B424 Sheet 301 Letdown Containment Isolation Valve 1CH-F2501 A/B 17

(for CVCI SV-0103)

B424 Sheet 327 Volume Control Tank Discharge Valve 2CH-V123 A/B 19

(for CVCI SV-0183)

B424 Sheet 357 Reactor Makeup Stop Valve 3 CH-F 117 A/B (for CVCI 9

SV-0510)

B424 Sheet 360 Refueling Water to Charging Pumps Valve 3CH-V121 13

A/B (for CVCI SV-0507)

B424 Sheet 375 Control Wiring Diagram Charging Pump B 20

B424 Sheet E375-1 Control Wiring Diagram Charging Pump B Sheet 1 of 2 11

B424 Sheet E375-2 Control Wiring Diagram Charging Pump B Sheet 2 of 2 6

B424 Sheet 380 Charging Pumps Header Discharge Valve 2CH-F1529 13

A/B (for CVCI SV-0209)

B424 Sheet 381 Charging Line to Loop 1A Shutoff Valve ICH-E2503A 16

(for CVCI SV-0218A)

A-5

Drawings

Number Title Revision

B424 Sheet 382 Charging Line to Loop 2A Shutoff Valve ICH-E2504B 15

(for CVCI SV-0218B)

B424 Sheet 535 Control Wiring Diagram Low Pressure Safety Injection 13

Pump B

B424 Sheet 595 Control Wiring Diagram Component RCS Loop 2 23

Shutdown Cooling Isolation Valve 1SI-1504A

B424 Sheet 596 Control Wiring Diagram Component RCS Loop 2 30

Shutdown Cooling Isolation Valve 1SI-1503A

B424 Sheet 700 Control Wiring Diagram Component Cooling Water 12

Pumps Common Circuit

B424 Sheet 702 Control Wiring Diagram Component Cooling Water 16

Pump A Header Isolation Valves 3CC-F110 A/B and

3CC-F114 A/B

B424 Sheet 703 Control Wiring Diagram Component Cooling Water 16

Pump B Header Isolation Valves 3CC-F111 A/B and

3CC-F115 A/B

B424 Sheet 709 Control Wiring Diagram Component Cooling Water 14

Pump B

B424 Sheet E709 Control Wiring Diagram Component Cooling Water 7

Pump B

B424 Sheet 781 Control Wiring Diagram Dry Tower Fan Number 1 11

B424 Sheet 782 Control Wiring Diagram Dry Tower Fan Number 2 13

B424 Sheet 783 Control Wiring Diagram Dry Tower Fan Number 3 12

B424 Sheet 784 Control Wiring Diagram Dry Tower Fan Number 4 13

B424 Sheet 785 Control Wiring Diagram Dry Tower Fan Number 5 12

B424 Sheet 786 Control Wiring Diagram Dry Tower Fan Number 6 12

B424 Sheet 787 Control Wiring Diagram Dry Tower Fan Number 7 13

B424 Sheet 788 Control Wiring Diagram Dry Tower Fan Number 8 13

B424 Sheet 789 Control Wiring Diagram Dry Tower Fan Number 9 11

A-6

Drawings

Number Title Revision

B424 Sheet 790 Control Wiring Diagram Dry Tower Fan Number 10 11

B424 Sheet 791 Control Wiring Diagram Dry Tower Fan Number 11 11

B424 Sheet 792 Control Wiring Diagram Dry Tower Fan Number 12 14

B424 Sheet 793 Control Wiring Diagram Dry Tower Fan Number 13 12

B424 Sheet 794 Control Wiring Diagram Dry Tower Fan Number 14 11

B424 Sheet 795 Control Wiring Diagram Dry Tower Fan Number 15 14

B424 Sheet 799 Control Wiring Diagram Dry Tower B Isolation Valve 17

3CC-B203B and Bypass Valve 3CC-B262B

B424 Sheet 802 Control Wiring Diagram Auxiliary Component Cooling 15

Water Pump B

B424 Sheet 804 Control Wiring Diagram Auxiliary Component Cooling 3

Water Pump B Discharge Line Isolation Valve 3CC-

B289B

B424 Sheet 852 Control Wiring Diagram Component Cooling Water 22

Makeup Pump B

B424 Sheet 931 Control Wiring Diagram Reactor Coolant System Vent 13

Valves Sheet 1

B424 Sheet 932 Control Wiring Diagram Reactor Coolant System Vent 17

Valves Sheet 2

B424 Sheet 933 Control Wiring Diagram Reactor Coolant System Vent 13

Valves Sheet 3

B424 Sheet 934 Control Wiring Diagram Reactor Coolant System Vent 8

Valves Sheet 4

B424 Sheet 1027 Control Wiring Diagram Equipment Room Cooler AH- 12

26 (3B-SB)

B424 Sheet 1042 Control Wiring Diagram Diesel Generator B Room 15

Vent System

B424 Sheet 1043 Control Wiring Diagram Diesel Generator B Room 13

Exhaust Fan E-26 (3B-SB)

B424 Sheet 1055 Control Wiring Diagram Water Chiller Compressor 21

A-7

Drawings

Number Title Revision

WC-1 (3B-SB)

B424 Sheet 1056 Control Wiring Diagram Water Chiller Compressor 11

WC-1 (3B-SB) Oil Pump and Hot Gas Bypass Valve

B424 Sheet 1058 Control Wiring Diagram Water Chilled Water Pump P-1 16

(3B-SB)

B424 Sheet 1065 Control Wiring Diagram Water Chiller Compressor 18

WC-1 (3C-SAB)

B424 Sheet 1066 Control Wiring Diagram Water Chiller WC-1 (3C-SAB) 13

Oil Pump and Hot Gas Bypass Valve

B424 Sheet 1068 Control Wiring Diagram Chilled Water Pump P-1 (3C- 18

SAB)

B424 Sheet 1119 Control Wiring Diagram RAB HVAC Equipment Room 15

Supply Fan AH-13 (3B-SB)

B424 Sheet 1122 Control Wiring Diagram RAB HVAC Equipment Room 10

Exhaust Fan E-41 (3B-SB)

B424 Sheet 1165 Control Wiring Diagram Control Room Air Handler Unit 23

AH-12 (3A-SA)

B424 Sheet 1167 Control Wiring Diagram Control Room Air Handler Unit 19

AH-14 (3B-SB)

B424 Sheet 1509S Control Wiring Diagram Steam Generator 1 Level 8

(Wide Range) and EFW Flow

B424 Sheet 1525S Control Wiring Diagram Steam Generator 2 Level 7

(Wide Range) and EFW Flow

B424 Sheet 1533 Control Wiring Diagram Emergency Feedwater Pump 14

B

B424 Sheet E1533 Control Wiring Diagram Emergency Feedwater Pump 7

B

B424 Sheet E1547 Control Wiring Diagram Steam Generator 1 11

Emergency Feed Water Isolation Valve 2FW-V847B

B424 Sheet E1549 Control Wiring Diagram Steam Generator 2 12

Emergency Feed Water Isolation Valve 2FW-V850B

A-8

Drawings

Number Title Revision

B424 Sheet 1551 Control Wiring Diagram Steam Generator 1 6

Emergency Feed Water Control Valves 2FW-852A and

2FW-851B

B424 Sheet 1551 Control Wiring Diagram Steam Generator 1 2

Emergency Feed Water Control Valves 2FW-852A and

2FW-851B Sheet A

B424 Sheet 1643 Control Wiring Diagram SGI Main Steam Atmospheric 12

Dump Valve 2MS-PM629A

B424 Sheet 1646 Control Wiring Diagram Steam Line 1 Isolation Valve 16

2MS-V602A Sheet 1

B424 Sheet E1646 Control Wiring Diagram Steam Line 1 Isolation Valve 6

2MS-V602A

B424 Sheet 1647 Control Wiring Diagram Steam Line 1 Isolation Valve 21

2MS-V602A Sheet 2

B424 Sheet A1647 Control Wiring Diagram Steam Line 1 Isolation Valve 6

2MS-V602A Hydraulic System

B424 Sheet 1658 Control Wiring Diagram SG2 Main Steam Atmospheric 17

Dump Valve 2MS-PM630B

B424 Sheet 1661 Control Wiring Diagram Steam Line 2 Isolation Valve 16

2MS-V604B Sheet 1

B424 Sheet E1661 Control Wiring Diagram Steam Line 2 Isolation Valve 6

2MS-V604B

B424 Sheet 1662 Control Wiring Diagram Steam Line 2 Isolation Valve 22

2MS-V604B Sheet 2

B424 Sheet A1662 Control Wiring Diagram Steam Line 2 Isolation Valve 8

2MS-Y604B Hydraulic System

B424 Sheet 2365 Control Wiring Diagram Diesel Generator B Generator 11

Control Interface Sheet 1

B424 Sheet 2366 Control Wiring Diagram Diesel Generator B Generator 7

Control Interface Sheet 2

B424 Sheet 2367 Control Wiring Diagram Diesel Generator B Generator 14

Control Interface Sheet 3

A-9

Drawings

Number Title Revision

B424 Sheet 2368 Control Wiring Diagram Diesel Generator B Engine 16

Control Interface Sheet 1

B424 Sheet 2369 Control Wiring Diagram Diesel Generator B Engine 7

Control Interface Sheet 2

B424 Sheet 2370 Control Wiring Diagram Diesel Generator B Engine 8

Control Interface Sheet 3

B424 Sheet 2374 Control Wiring Diagram Diesel Generator B Engine 13

Control Interface Sheet 7

B424 Sheet 2377 Control Wiring Diagram Diesel Generator Breaker 19

B424 Sheet E2377 Control Wiring Diagram Diesel Generator Breaker 7

B424 Sheet 2388 Control Wiring Diagram 4.16 KV Bus 3B3-S 13

Undervoltage Relays Sheet 2

B424 Sheet 2390 Control Wiring Diagram 480V Bus 3B31-S 17

Undervoltage Relays Sheet 2

B424 Sheet 2391 Control Wiring Diagram Sequencer B Sheet 1 18

B424 Sheet E2391 Control Wiring Diagram Sequencer B Sheet 1 4

B424 Sheet 2924 Control Wiring Diagram Annunciator Display Cabinet C 14

CP-35

B424 Sheet 2939 Control Wiring Diagram Isolation Switch Development 4

Auxiliary Panel 2B

B424 Sheet 2942 Control Wiring Diagram Transfer Switch Development 16

Auxiliary Panel 2

G - 127 Plot Plan 35

G - 160, SD-CC-02 CCW System Flow Path and Services

Pg. 98

G161, Sheet 1 Flow Diagram - Fire, Make-Up & Domestic Water 35

Systems

G161, Sheet 2 Flow Diagram - Fire, Make-Up & Domestic Water

Systems

G161, Sheet 3 Flow Diagram - Fire, Make-Up & Domestic Water 31

A-10

Drawings

Number Title Revision

Systems

G161, Sheet 4 Flow Diagram - Fire, Make-Up & Domestic Water

Systems

G161, Sheet 5 Flow Diagram - Fire, Make-Up & Domestic Water 5

Systems

G161, Sheet 6 Flow Diagram - Fire, Make-Up & Domestic Water

Systems

G161, Sheet 7 Flow Diagram - Fire, Make-Up & Domestic Water

Systems

G-169, SD-FS-01, Fuel Pool Cooling and Purification System 6

Figure 1

G - 205 Sheet 1-12 Yard Piping 28

G285 Main One Line Diagram 19

G286 Key Auxiliary One Line Diagram 17

G287 Sheet 1 125 VDC and 120 VAC One line Diagram 21

G285 Main One Line Diagram 19

G287 Sheet 2 125 VDC and 120 VAC One line Diagram 3

G5-553-110 Sheet 2 Control Schematic (Starting Sequence Control) 17

G-1356 Fire Protection Cooling Towers - Plan 1

Fire Protection Reactor Auxiliary Building Plan

G-1357 2

El. - 35.00

G-1358 Fire Protection Reactor Building and Wing Area Plan 2

Elevation +21.00

G-1359 Fire Protection Reactor Auxiliary Building Plan 2

Elevation +21.00

G-1360 Fire Protection Reactor Auxiliary Building Plan 2

Elevation +46.00

A-11

Drawings

Number Title Revision

G-1364 Fire Protection Reactor Auxiliary Building Plan 0

Elevation +7.00 and Sections E-E and F-F

G-1367 Fire Protection Reactor Bldg. & Wing Area Plan 1

El. - 35.00 & El. - 4.00

G-1368 Fire Protection Reactor Bldg. & Wing Area Plan 2

El. + 21.00

G-1369 Fire Protection Reactor Bldg. & Wing Area Plan 0

El. + 46.00

G-1370 Fire Protection Turbine Bldg. Ground Floor Plan 2

El. 15.00

G-1371 Fire Protection Turbine Bldg. Mezzanine Floor Plan 2

El. +40.00

G-1372 Fire Protection Turbine Bldg. Operating Floor Plan 0

El. +67.00

G-1375 Fire Protection Reactor Auxiliary Building Plan 1

Elevation +35.00

SD-FP-21, Figure 1, Fire Protection System-Simplified Diagram 7

Pg. 56

SD-FP-21, Figure 2. Fire Water System 7

Pg. 57

SD-FP-21, Figure 3, Fire Pump Arrangement 7

Pg. 58

SD-FP-21, Figure 21, Outside Fire Protection System 7

Pg. 76

5817-5404 Isometric Drop Details Systems FP-M18 and 19 Cable 4

Penetration Area A and B

5817-5407 System FP-M18 Cable Penetration Area 6

5817-5408 Systems FP-M18 thru 19 Cable Penetration Areas 6

5817-5409 Systems FP-M11 thru 19 Cable Penetration - Vault 10

Areas

A-12

Drawings

Number Title Revision

5817-6309 RAB Relay Room Multi Cycle Sprinkler 7

Systems FP-M29

5817-6337 RAB Multi Cycle Sprinkler Systems FP-M30 9

5817-6382 RAB Sprinkler System FP-M25B and M30A 9

Switchgear Area B

5817-6385 RAB Sprinkler System FP-M25B (FP-39) Switchgear 8

Area B

Engineering Changes

Revision/

Number Title

Date

EC-21260 Add Sprinklers Under Hatch HC-1 on Elevation RAB - 0

35.00 to Comply With Final Safety Analysis Report

(FSAR)

EC-31611 Westinghouse - Fire Analysis Report April 30,

2013

EC-31827 Replace Obsolete EDG Sequencer Relays (B Train) 0

EC-32284 SI-405B Is Not Operable Manually 0

EC-36621 Evaluate Impacts of Operating the Emergency Diesel 0

Generators (EDGS) Without Component Cooling Water

EC-39570 Establish Documentation and/or Perform Evaluation for 0

Fire Dampers Installed In Non-Safety Related HVAC

Ducts to Justify Their Fire Barrier Capability

EC-41765 DC Circuits Proper Polarity 0

EC-41839 Detector 39-04 Requirements for Hemyc Wrap 0

EC-52360 13-210 & 13-211 Fire Impairment Closure 0

EC-53759 CR-WF3-2014-5546 Operability Input on Bent Sprinkler 0

Deflectors

A-13

Engineering Information Records

Number Title Revision

EC-1617 This ER Evaluates Hose Size and Pump Size 0

Requirements to Implement the B.5.B.Water Makeup,

Spray, and Portable Pump Strategies.

EC-31611 Westinghouse - Fire Analysis Report 0

Engineering Request

Number Title Revision

ER-W3-2004-0222 Alternative Methodology for Appendix R 8-Hour Battery 0

Powered Emergency Light Testing

Engineering Standard

Number Title Revision

EN-FP-S-001-Multi Appendix R Emergency Lighting Units 1

Fire Impairments

13-0116 14-0249 14-0312 15-043*

13-0185 14-0277 14-0322 15-044*

14-0160 14-0287 15-041* 15-045*

14-0244 14-0299 15-042*

• Issued as a result of inspection activities.

Licensing Correspondence

Number Title Date

NUREG-0787 Safety Evaluation Report Related to the Operation of July 1981

Waterford Steam Electric Station, Unit Number 3

NUREG-0787 Safety Evaluation Report Related to the Operation of October

Waterford Steam Electric Station, Unit Number 3 1981

Supplement No. 1

NUREG-0787 Safety Evaluation Report Related to the Operation of January

Waterford Steam Electric Station, Unit Number 3 1983

Supplement No. 2

A-14

Licensing Correspondence

Number Title Date

NUREG-0787 Safety Evaluation Report Related to the Operation of April 1982

Waterford Steam Electric Station, Unit Number 3

Supplement No. 3

NUREG-0787 Safety Evaluation Report Related to the Operation of June 1983

Waterford Steam Electric Station, Unit Number 3

Supplement No. 5

NUREG-0787 Safety Evaluation Report Related to the Operation of June 1984

Waterford Steam Electric Station, Unit Number 3

Supplement No. 6

NUREG-0787 Safety Evaluation Report Related to the Operation of September

Waterford Steam Electric Station, Unit Number 3 1984

Supplement No. 7

NUREG-0787 Safety Evaluation Report Related to the Operation of December

Waterford Steam Electric Station, Unit Number 3 1984

Supplement No. 8

NUREG-0787 Safety Evaluation Report Related to the Operation of March 1985

Waterford Steam Electric Station, Unit Number 3

Supplement No. 10

Miscellaneous Documents

Revision

Number Title

Date

Engineering Report WF3 Code Compliance Report for NFPA 72D 0

WF3-FP-10-00006 Standard for the Installation, Maintenance and Use of

Proprietary Signaling Systems for Watchman, Fire

Alarm and Supervisory Service, 1975 Edition

Engineering Report WF3 Code Compliance Report for NFPA 72E 0

WF3-FP-10-00007 Automatic Fire Detectors, 1974 Edition

Engineering Report WF3 Code Compliance Report for NFPA 13 Standard 0

WF3-FP-10-00013 for Installation of Sprinkler Systems 1976 Edition

Engineering Report WF3 Code Compliance Report for NFPA 20 0

WF3-FP-10-00015 Centrifugal Fire Pumps 1972 Edition

Engineering Report Expert Panel for Addressing Multiple Spurious 1

WF3-FP-11-00002 Operations Report

Engineering Report Evaluation of Fire Area Boundaries 0

WF3-FP-13

A-15

Miscellaneous Documents

Revision

Number Title

Date

Entergy Transition Transition to 10 CFR 50.48© - NFPA 805 November

Report Performance-Based Standard for Fire Protection for 2011

Light Water Reactor Electric Generating Plants, 2001

Edition

Final Safety Analysis Fire Protection System 308

Report, Section 9.5.1

Letter: I. Nygren to Letter of Agreement, Ochsner Medical Center. January 4,

R. Perry Subject: Ochsner Flight Care Availability. 2012

Letter: N. Chauncey Letter of Agreement, Williams Fire & Hazard October 31,

to R. Perry Control, lnc. Subject: Fire Response to Waterford 3. 2011

Letter: T. Burns to G. Letter of Agreement, Southland Fire and Safety May 11,

Fey Equipment. Subject: Availability to fill SCBA bottles 2011

during emergencies at Waterford 3

LO-WLO-2014-0029 2015 Pre NRC Triennial Fire Protection Assessment 0

LOA HVFD Letter of Agreement, Hahnville Fire Department June 26,

2011

Prefire Strategy Elevation +35.00 RAB Electrical Penetration Area A 8

RAB 6-001

Prefire Strategy Elevation +35.00 RAB Relay Room 11

RAB 7-001

Prefire Strategy Switchgear Room A 10

RAB 8A-001

Prefire Strategy Switchgear Room B 12

RAB 8B, E, F-001

Prefire Strategy Switchgear Room A/B 11

RAB 8C-001

QA-9-2012-WF3-1 Fire Protection Audit March 13,

2012

QA-9-2014-W3-01 Fire Protection Audit March 14,

2014

A-16

Miscellaneous Documents

Revision

Number Title

Date

Retype A9.02 Thermo-Lag Installed to Tested Fire Barrier Evaluation 2

(GL 86-10 Evaluation)

Technical Fire Detection Instrumentation 126

Requirements

Manual,

Section 3/4.3.3.8

Technical Fire Suppression Water Systems 126

Requirements

Manual,

Section 3/4.7.10

Technical Fire Rated Assemblies 91

Requirements

Manual,

Section 3/4.7.11

Technical Essential Services Chilled Water Systems Chillers - 128

Requirements Appendix R

Manual,

Section 3/4.7.12

Technical Boration Systems Charging Pumps - Appendix R 128

Requirements

Manual,

Section 3/4.1.2

WDLA-NAO-B5b Dynamic Learning Activity - B5b Walkdown 0

WLP-EMCT-SAMG PowerPoint Presentation - Sever Accident Mitigation 0

Guidelines (SAMG) Electrical Overview

WLP-EMT2-SAMG PowerPoint Presentation - Sever Accident Mitigation. 2

WLP-EP-SAM00 PowerPoint Presentation - Severe Accident 8

Management Guidelines

WLP-EP-SAM00 PowerPoint Presentation - Severe Accident 13

Management Guidelines

WLP-EP-SSAMG01 PowerPoint Presentation - B5B / Extensive Damage 4

Mitigation / Security Threat

WLP-ESPC-FRGB5B PowerPoint Presentation - Functional Recovery 0

Guidelines and B.5.b.

A-17

Miscellaneous Documents

Revision

Number Title

Date

WLP-ICT2-SAMG PowerPoint Presentation - Sever Accident 3

Management Guidelines

WLP-MMT2-B.5.B PowerPoint Presentation - Godwin HL4M B.5.B Pump 4

WLP-OPS-SAM00 PowerPoint Presentation - Sever Accident Mitigating 10

Guidelines

WLP-OPS-SAM00 PowerPoint Presentation - Sever Accident 17

Management Guidelines

WLP-OPS-SSAMG00 PowerPoint Presentation - Introduction to S-SAMG-01 5

WPCS-EP-PROG Emergency Planning Training Program and Course 6

Summary

WPCS-EP-PROG Emergency Planning Training Program and Course 6

Summary.

Procedures

Number Title Revision

EN-DC-127 Control of Hot Work and Ignition Sources 15

EN-DC-128 Fire Protection Impact Reviews 8

EN-DC-161 Control of Combustibles 11

EN-DC-330 Fire Protection Program 4

EN-TQ-125 Fire Brigade Drills 2

FP-001-014 Duties of a Firewatch 18

FP-001-015 Fire Protection System Impairments 310

FP-001-018 Pre Fire Strategies, Development and Revision 302

FP-001-019 Fire Brigade Equipment 307

FP-001-020 Fire Emergency/Fire Report 307

ME-003-002 Fire Detection Supervisory Circuit Functional Test 307

ME-003-004 Fire Dampers 7

A-18

Procedures

Number Title Revision

ME-003-006 Fire Barrier Penetration Seals 305

ME-003-009 Fire Rated Walls, Floors, and Ceilings 302

ME-003-017 Cerberus Pyrotronics Thermal Fire Detector Testing 306

ME-004-445 Self-Contained Battery Powered Emergency Lighting 305

Unit

MM-003-021 Sprinkler System Inspection (Safety Areas) 10

NTP-202 Fire Protection Training 302

OP-009-004 Fire Protection 316

OP-009-005 Shutdown Cooling 35

OP-901-120 Pressurized Pressure Control Malfunction 302

OP-901-502 Evacuation of Control Room and Subsequent Plant 27

Shutdown

OP 901-502-01 Time Critical Task Resource Management for Control 1

Room Evacuation

OP-901-503 Isolation Panel Fire 309

OP-901-524 Fire in Areas Affecting Safe Shutdown 12

OP-903-053 Fire Protection System Pump Operability Test 18

OP-903-054 Fire Protection Valve Lineup check 10

OP-903-055 Fire Main and Hydrant Flush 11

OP-903-056 Fire Protection Functional Test 309

OP-903-057 Fire Protection System Flow Test 17

OP-903-126 Functional Testing of LCP-43 7

OP-904-005 Sprinkler and Spray Systems Alarm Test 13

OP-904-019 OCA Fire Protection System Main Pump Test 2

PMC-003-002 Installation and Rework of Penetration Seals, Conduit 4

Seals, Fire Breaks and Water Barriers

A-19

Procedures

Number Title Revision

S-SAMG-01 Severe Accident Management Guidelines - Loss of 12

Large Areas of the Plant due to Fire/Explosion

S-SAMG-01 Severe Accident Management Guidelines - Loss of 15

Large Areas of the Plant due to Fire/Explosion

S-SAMG-01 Severe Accident Management Guidelines - Loss of 16

Large Areas of the Plant due to Fire/Explosion

UNT-005-013 Fire Protection Program 12

Work Orders

00151869 52217545 52371388 52512964

00270990 52283342 52374001 52517633

00280756 52208382 52409924 52522454

00351003 52245794 52413005 52529715

00040984 52256546 52416793 52558563

00047410 52282108 52418265 52558938

165991-01 52293694 52418445 52561107

364896-02 52321722 52449369 52582154

51563178 52321723 52461010 526039

51679870 52332839 52479133

52029678 52335332 52488473

A-20