ML13324B133: Difference between revisions

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{{#Wiki_filter:November 20, 2013  
{{#Wiki_filter:UNITED STATE S
                            NUC LEAR REGULATOR Y C OMMI S SI ON
EA-12-257  
                                                R E G IO N I V
                                            1600 EAST LAMAR BLVD
Donna Jacobs, Vice President, Operations  
                                      AR L INGTON , TEXAS 76011- 4511
Entergy Operations, Inc.  
                                        November 20, 2013
EA-12-257
Donna Jacobs, Vice President, Operations
Entergy Operations, Inc.
Waterford Steam Electric Station, Unit 3
Killona, LA 70057-0751
SUBJECT:        WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED
                INSPECTION REPORT 05000382/2013004
Dear Ms. Jacobs:
On September 30, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Waterford Steam Electric Station, Unit 3 facility. On October 1, 2013, the
NRC inspectors discussed the results of this inspection with you and other members of your
staff. Inspectors documented the results of this inspection in the enclosed inspection report.
NRC inspectors documented two findings of very low safety significance (Green) in this report.
Further, inspectors documented a licensee-identified violation which was determined to be a
Severity Level IV in this report. All of these findings involved violations of NRC requirements.
The NRC is treating these violations as non-cited violations (NCVs) consistent with
Section 2.3.2.a of the Enforcement Policy.
In addition, the enclosed inspection report discusses a Severity Level IV violation that was
identified during the closure of unresolved item 05000382/2009010-01, documented in NRC
Inspection Report 05000382/2009010 (ML093100238). This violation was evaluated in
accordance with the NRC Enforcement Policy, dated September 1, 2009, (ML092440278)
which was in effect at the time the special inspection report was issued. In accordance with
Supplement VII, Section C.6, of that Enforcement Policy, this violation would normally be
assessed as Severity Level III. However, in accordance with the Enforcement Policy, the
severity level of an untimely report may be reduced depending on the circumstances
surrounding the matter. Since the affected components were already removed from service as
part of an unrelated manufacturers recall and no longer considered a substantial safety hazard,
the NRC concluded this violation is more appropriately assessed as Severity Level IV with a
written response required.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. If you have additional information that you
believe the NRC should consider, you may provide it in your response to the Notice. The NRCs
review of your response to the Notice will also determine whether further enforcement action is
necessary to ensure compliance with regulatory requirements.


Waterford Steam Electric Station, Unit 3
D. Jacobs                                    -2-
Killona, LA 70057-0751
If you contest the violation or significance of these NCVs, you should provide a response within
SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED INSPECTION REPORT 05000382/2013004
30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear
Dear Ms. Jacobs:
Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with
On September 30, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford Steam Electric Station, Unit 3 facility. On October 1, 2013, the NRC inspectors discussed the results of this inspection with you and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.  
copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, U.S.
Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector
at the Waterford Steam Electric Station, Unit 3 facility.
If you disagree with a cross-cutting aspect assignment or a finding not associated with a
regulatory requirement in this report, you should provide a response within 30 days of the date
of this inspection report, with the basis for your disagreement, to the Regional Administrator,
Region IV; and the NRC resident inspector at the Waterford Steam Electric Station, Unit 3
facility.
In accordance with Title 10 of the Code of Federal Regulations (10CFR) 2.390, Public
Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your
response (if any) will be available 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/ Michael R. Bloodgood for
                                                Gregory E. Werner, Acting Chief
                                                Project Branch E
                                                Division of Reactor Projects
Docket No.: 50-382
License No.: NPF-38
Enclosures:
    1. Notice of Violation EA-12-257
    2. Inspection Report 05000382/2013004
          w/Attachment: Supplemental Information
Electronic Distribution to Waterford Steam Electric Station, Unit 3


NRC inspectors documented two findings of very low safety significance (Green) in this report. 
Further, inspectors documented
a licensee-identified violation which was determined to be a Severity Level IV in this report.  All of these findings involved violations of NRC requirements. 
The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.
In addition, the enclosed inspection report discusses a Severity Level IV violation that was


identified during the closure of unres
ML13324B133
olved item 05000382/2009010-01, documented in NRC Inspection Report 05000382/2009010 (ML093100238).  This violation was evaluated in
SUNSI Rev Compl. Yes  No ADAMS                    Yes  No  Reviewer Initials    MD
accordance with the NRC Enforcement Policy, dated September 1, 2009, (ML092440278) which was in effect at the time the special inspection report was issued.  In accordance with Supplement VII, Section C.6, of that Enforcement Policy, this violation would normally be
Publicly Avail.        Yes  No Sensitive        Yes  No  Sens. Type Initials  MD
assessed as Severity Level III. However, in accordance with the Enforcement Policy, the  
SRI:DRP/E        RI:DRP/E          C:DRP/E      C:DRS/EB1    C:DRS/EB2            C:DRS/OB
severity level of an untimely report may be reduced depending on the circumstances
MDavis          CSpeer            GWerner      TFarnholtz  GMiller              VGaddy
surrounding the matter. Since the affected components were already removed from service as part of an unrelated manufacturer's recall and no longer considered a substantial safety hazard, the NRC concluded this violation is more appropriately assessed as Severity Level IV with a written response required.  
/RA/ E          /RA/ E            /RA/        /RA/        /RA/                /RA/
11/14/13        11/14/13          11/15/13    11/15/13    11/18/13            11/18/13
C:DRS/PSB1 C:DRS/PSB2 C:DRS/TSB                  C:ORA/ACES  BC:DRP/E
MHaire          JDrake            RKellar      HGepford    GWerner
/RA/            /RA/              /RA/        /RA/        /RA/MBloodgood for
11/15/13        11/18/13          11/18/13    11/18/13    11/20/2013
                                     
                                      NOTICE OF VIOLATION
Entergy Operations, Inc.                                                          Docket No: 50-382
Waterford Steam Electric Station, Unit 3                                        License No: NPF-38
                                                                                            EA-12-257
During the NRC inspection conducted from July 20-October 19, 2009, a violation of the NRC
requirements was identified. In accordance with the NRC Enforcement Policy, the violation is
listed below:
        Title 10 CFR, Part 21.21(a)(1) requires, in part, that entities subject to the regulations in
        this part shall evaluate deviations and failures to comply to identify defects associated
        with substantial safety hazards as soon as practicable, and except as provided in
        paragraph (a)(2) of this section, in all cases within 60 days of discovery, in order to
        identify a reportable defect that could create a substantial safety hazard, were it to
        remain uncorrected.
        Title 10 CFR, Part 21.21(a)(2) requires, in part, that entities subject to the regulations in
        the part shall ensure that if an evaluation of identified deviation or failure to comply
        potentially associated with a substantial safety hazard cannot be completed within
        60 days from discovery of the deviation or failure to comply, an interim report is prepared
        and submitted to the Commission. The interim report must be submitted in writing within
        60 days of discovery of the deviation of failure to comply.
        Contrary to the above, from December 14, 2008 to April 29, 2010, the licensee failed to
        evaluate deviations and failures to comply to identify defects associated with substantial
        safety hazards as soon as practicable and to submit a report or interim report within
        60 days of its discovery, in order to identify a reportable defect or failure to comply that
        could create a substantial safety hazard, were it to remain uncorrected.
        Specifically, on October 14, 2008, the licensee performed bench testing on an Agastat
        E7024PB relay with date code 0835 and noted that the relay had a loose terminal point.
        Two more relays were obtained from the warehouse; one of these also had a bad
        terminal point. On October 27, 2008, the licensee quarantined the remaining four relays
        in stock. Two of these quarantined relays were identified to have similarly deficient
        terminal points. The licensee identified these relays as defective and returned them to
        the manufacturer, for cause evaluation. All four affected relays shared a date code of
        0835. On January 28, 2009, the licensee received a report from the manufacturer,
        which did not provide a cause evaluation. On August 18, 2009, the licensee submitted
        Licensee Event Report 2009-003-00, (ML092310548). This Licensee Event Report did
        not mention the date code 0835 relays or loose terminal points. Rather, the Licensee
        Event Report described relays that failed due to incorrect adjustment of terminal blocks,
        a deviation different from that observed in the 0835 date code relays. On April 29, 2010,
        the licensee issued updated Licensee Event Report 2009003-01 (ML101230323). This
        revision to the Licensee Event Report described loose terminal points on two spare date
        code 0835 relays as one of the defects identified in its Agastat E7024PB relays. The
        April 29, 2010, Licensee Event Report revision would have met Part 21 evaluation and
        reporting requirements, but it was 501 days late.
                                            -1-                                        Enclosure 1


This is a Severity Level IV violation (Supplement VII of Enforcement Policy dated September 1,
You are required to respond to this letter and should follow the instructions specified in the  
2009).
enclosed Notice when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The NRC's review of your response to the Notice will also determine whether further enforcement action is  
Pursuant to the provisions of 10 CFR 2.201, the Waterford Steam Electric Station, Unit 3 is
necessary to ensure compliance with regulatory requirements.
hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory
UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION IV1600 EAST LAMAR BLVDARLINGTON, TEXAS 76011-4511
Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the
D. Jacobs - 2 -
Regional Administrator, Region IV, and a copy to the NRC Resident Inspector at the facility that
  If you contest the violation or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:  Document Control Desk, Washington, DC 20555-0001; with
is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of
copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, U.S.  
Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of
Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector
Violation; EA 12-257" and should include (1) the reason for the violation, or, if contested, the
at the Waterford Steam Electric Station, Unit 3 facility.  
basis for disputing the violation or severity level, (2) the corrective steps that have been taken
and the results achieved, (3) the corrective steps that will be taken, and (4) the date when full
compliance will be achieved. Your response may reference or include previous docketed
correspondence, if the correspondence adequately addresses the required response. If an
adequate reply is not received within the time specified in this Notice, an order or a Demand for
Information may be issued as to why the license should not be modified, suspended, or
revoked, or why such other action as may be proper should not be taken. Where good cause is
shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the NRCs document system (ADAMS), accessible from the
NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not
include any personal privacy, proprietary, or safeguards information so that it can be made
available to the public without redaction. If personal privacy or proprietary information is
necessary to provide an acceptable response, then please provide a bracketed copy of your
response that identifies the information that should be protected and a redacted copy of your
response that deletes such information. If you request withholding of such material, you must
specifically identify the portions of your response that you seek to have withheld and provide in
detail the bases for your claim of withholding (e.g., explain why the disclosure of information will
create an unwarranted invasion of personal privacy or provide the information required
by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial
information). If safeguards information is necessary to provide an acceptable response, please
provide the level of protection described in 10 CFR 73.21.
Dated this 20th day of November 2013
                                            -2-                                        Enclosure 1


If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date
            U.S. NUCLEAR REGULATORY COMMISSION
of this inspection report, with the basis for your disagreement, to the Regional Administrator,  
                              REGION IV
Region IV; and the NRC resident inspector at the Waterford Steam Electric Station, Unit 3  
Docket:    05000382
facility.
License:    NPF-38
In accordance with Title 10 of the Code of Federal Regulations (10CFR) 2.390, "Public
Report:    05000382/2013004
Inspections, Exemptions, Requests for Withholding," a copy of this letter, its enclosure, and your
Licensee:  Entergy Operations, Inc.
response (if any) will be available electronicall
Facility:  Waterford Steam Electric Station, Unit 3
y for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic
Location:  17265 River Road
Reading Room).  
            Killona, LA 70057
Sincerely,  
Dates:      July 1 through September 30, 2013
/RA/  Michael R. Bloodgood for
Inspectors: M. Davis, Senior Resident Inspector
Gregory E. Werner, Acting Chief  
            C. Speer, Resident Inspector
            T. Farina, Operations Engineer
            C. Steely, Operations Engineer
            L. Carson, Senior Health Physicist
            L. Ricketson, Senior Health Physicist
            C. Alldredge, Health Physicist
            N. Greene, Health Physicist
            P. Hernandez, Health Physicist
            J. ODonnell, Health Physicist
            E. Ruesch, Senior Reactor Engineer
Approved    G. Werner, Acting Chief
    By:    Project Branch E
            Division of Reactor Projects
                            -1-                    Enclosure 2


Project Branch E
                                      SUMMARY OF FINDINGS
IR 05000382/2013004; 07/01/2013 - 09/30/2013; Waterford Steam Electric Station, Unit 3,
Integrated Resident and Regional Report; Fire Protection, Post-Maintenance Testing, and Other
Activities.
The report covered a 3-month period of inspection by resident inspectors and an announced
baseline inspections by region-based inspectors. Two Green non-cited violations and one
severity level IV violation were identified. The significance of most findings is indicated by their
color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609, Significance
Determination Process. The cross-cutting aspect is determined using Inspection Manual
Chapter 0310, Components Within the Cross-Cutting Areas. Findings for which the
significance determination process does not apply may be Green or be assigned a severity level
after NRC management review. The NRC's program for overseeing the safe operation of
commercial nuclear power reactors is described in NUREG - 1649, Reactor Oversight
Process, Revision 4, dated December 2006.
A.      NRC-Identified Findings and Self-Revealing Findings
        Cornerstone: Mitigating Systems
        *  Green. The inspectors identified a non-cited violation of Waterfords Facility
            Operating License Number NPF-38, License Condition 2.C.9, because the licensee
            did not implement fire protection procedure FP-001-014, Duties of a Fire Watch.
            Specifically, the licensees fire watch personnel did not implement Section 6.5 of
            FP-001-014 to remove firefighting equipment from work areas when securing from a
            fire watch. As a result, multiple undercharged fire extinguishers were left in a fire
            area. The inspectors determined that this would affect safety-related equipment
            because it would delay the response to fires in the fire areas. The licensee entered
            this condition into their corrective action program as CR-WF3-2013-03398 and
            CR-WF3-2013-03523 for resolution. The immediate corrective actions taken to
            restore compliance included the removal of all undercharged fire extinguishers from
            deactivated posts and returning them to their proper storage location.
            The failure to implement a fire protection program procedure was a performance
            deficiency. The performance deficiency was more than minor because it was
            associated with the protection against external factors (i.e., fire) attribute of the
            Mitigating Systems Cornerstone and adversely affected the cornerstone objective of
            ensuring the availability, reliability, and capability of systems that respond to initiating
            events to prevent undesirable consequences. Specifically, the failure to remove
            undercharged fire extinguishers from work areas that contained safe shutdown
            equipment could hinder responses to fires in the fire area. The inspectors used the
            NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of
            Findings, to evaluate this issue. The initial screening directed the inspectors to use
            Appendix F, Fire Protection Significance Determination Process, to determine the
            significance of the finding. The inspectors determined that the finding had a low
            degradation rating because it reflected a fire protection program element whose
                                            -2-                                      Enclosure 2


Division of Reactor Projects
  performance and reliability would be minimally impacted. Specifically, in all cases
Docket No.:  50-382 License No.: NPF-38
  identified, there were permanent fully charged portable fire extinguishers of the
  proper type nearby. Therefore, the finding was of very low safety significance
  (Green). The inspectors concluded that the finding reflected current licensee
  performance and involved a cross-cutting aspect in the work practices component of
  the human performance area in that the licensee did not ensure supervisory and
  management oversight of work activities, including contractors, such that nuclear
  safety is supported [H.4(c)] (Section 1R05).
* Green. The inspectors identified a non-cited violation of 10 CFR Part 50,
  Appendix B, Criterion V, Instructions, Procedures, and Drawings, because the
  licensee did not accomplish activities affecting quality on a degraded safety-related
  train B component cooling water (CCW) bypass valve (CC-134B) in accordance with
  maintenance procedure EN-MA-101, Fundamentals of Maintenance. Specifically,
  the licensee did not control and perform testing on a leaking solenoid valve related to
  the operation of a safety-related bypass valve (CC-134B) after maintenance
  personnel removed the degraded equipment from service as required by Section
  5.10 of EN-MA-101. As a result, the licensee could not characterize and determine
  the cause of the leakage for the safety-related valve. The inspectors determined that
  this would challenge the safety function of the valve to provide CCW to the ultimate
  heat sink following a tornado event. The licensee entered this condition into their
  corrective action program as CR-WF3-2012-05991, CR-WF3-2012-06288, and
  CR-WF3-2013-04047. The immediate corrective actions taken to restore compliance
  included the installation of a new valve and debriefing personnel about controlling
  equipment removed from service when combining preventative and corrective
  maintenance tasks in one work order.
  The failure to control failed equipment removed from the plant to determine the
  cause in accordance with maintenance procedure requirements was a performance
  deficiency. The performance deficiency was more than minor because it was
  associated with the equipment performance attribute of the Mitigating System
  Cornerstone and adversely affected the cornerstone objective to ensure the
  availability, reliability, and capability of systems that respond to initiating events to
  prevent undesirable consequences. Specifically, the degraded condition challenged
  the safety function of the valve (CC-134B) to limit the loss of CCW through damaged
  portions of the dry cooling tower fans following a tornado-generated missile strike.
  The inspectors used the NRC Inspection Manual 0609, Attachment 4, Initial
  Characterization of Findings, to evaluate this issue. The finding required a detailed
  analysis because it was potentially risk significant for an external event (tornado).
  Therefore, the senior reactor analyst performed a bounding detailed risk evaluation.
  The senior reactor analyst determined that the finding was of very low safety
  significance (Green). The bounding change to the core damage frequency was less
  than 3E-7/year. The finding was not significant with respect to the large early
  release frequency. The dominant core damage sequences included tornado induced
  losses of offsite power, failure of the dry cooling tower pressure boundary, failure to
  isolate the damaged dry cooling tower, and failure to recover instrument air. The
  redundant train A component cooling water system combined with the tornado
                                    -3-                                       Enclosure 2


      frequency helped to reduce the risk exposure. The inspectors concluded that the
Enclosures:  1. Notice of Violation EA-12-257
      finding reflected current licensee performance and involved a cross-cutting aspect in
2. Inspection Report 05000382/2013004 w/Attachment:  Supplemental Information
      the work control component of the human performance area in that the licensee did
      not appropriately coordinate work activities by incorporating actions to address the
Electronic Distribution to Waterford Steam Electric Station, Unit 3
      impact of changes to work scope or activity on plant and human performance
      [H.3(b)] (Section 1R19).
  Cornerstone: Miscellaneous
  *   Severity Level IV. The team identified a violation of 10 CFR 21.21 that occurred
      when the licensee failed to submit a report or interim report on a deviation in a basic
      component within 60 days of discovery.
      The failure of the licensee to adequately evaluate deviations in basic components
      and to report defects is a performance deficiency. The NRCs significance
      determination process (SDP) considers the safety significance of findings by
      evaluating their potential safety consequences. This performance deficiency was of
      minor safety significance. The traditional enforcement process separately considers
      the significance of willful violations, violations that impact the regulatory process, and
      violations that result in actual safety consequences. Traditional enforcement applied
      to this finding because it involved a violation that impacted the regulatory process.
      Supplement VII to the version of the NRC Enforcement Policy that was in effect at
      the time the violation was identified provided as an example of a violation of
      significant regulatory concern (Severity Level III), An inadequate review or failure to
      review such that, if an appropriate review had been made as required, a
      10 CFR Part 21 report would have been made. Based on this example, the NRC
      determined that the violation met the criteria to be cited as a Severity Level III
      violation. However, because of the circumstances surrounding the violation,
      including the removal from service of the affected components by an unrelated
      manufacturers recall, the severity of the cited violation is being reduced to Severity
      Level IV. Cross-cutting aspects are not assigned to traditional enforcement
      violations. (Section 4OA5.2)
B. Licensee-Identified Violations
  A violation of very low safety significance (Severity Level IV), which was identified by the
  licensee, has been reviewed by the inspectors. Corrective actions taken or planned by
  the licensee have been entered into the licensees corrective action program. This
  violation and associated corrective action tracking numbers are listed in Section 4OA7 of
  this report.
                                        -4-                                      Enclosure 2


   
                                        PLANT STATUS
    
The Waterford Steam Electric Station, Unit 3, began the inspection period at 100 percent power.
On September 18, 2013, operators commenced a reactor down power to approximately
82 percent to perform maintenance on the normal level control valve 2B and the heater drain
pump B, respectively. Operators began to raise power to 100 percent the same day. The unit
maintained a 100 percent power for the remainder of the inspection period.
                                        REPORT DETAILS
1.    REACTOR SAFETY
      Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity and
      Emergency Preparedness
1R01 Adverse Weather Protection (71111.01)
      Readiness for Impending Adverse Weather Conditions
  a. Inspection Scope
      Since tropical depression Dorian was forecast in the vicinity of the facility for August 4,
      2013, the inspectors reviewed the plant personnels overall preparations and protection
      for the expected weather conditions. On August 2, 2013, the inspectors did a partial
      walkdown of the switchyard and the startup unit transformer systems because their
      functions could be affected, as a result of high winds, tornado-generated missiles, or the
      loss of offsite power. The inspectors evaluated the plant staffs preparations against site
      procedures and determined that the staffs actions were adequate. During the
      inspection, the inspectors focused on plant design features and the licensees
      procedures to respond to tornadoes and high winds. The inspectors also toured the
      plant grounds to look for any loose debris that could become missiles during a tornado.
      The inspectors evaluated operator staffing and accessibility of controls and indications
      for those systems required to control the plant. Additionally, the inspectors reviewed the
      final safety analysis report and performance requirements for the systems selected for
      inspection, and verified that operator actions were appropriate as specified by plant-
      specific procedures. The inspectors also reviewed a sample of corrective action
      program items to verify that the licensee had identified adverse weather issues at an
      appropriate threshold and entered them into the corrective action program for resolution.
      Specific documents reviewed during this inspection are listed in the attachment.
      These activities constitute completion of one sample of impending adverse weather
      conditions, as defined in Inspection Procedure 71111.01.
   b.  Findings
      No findings were identified.
                                          -5-                                        Enclosure 2


1R04 Equipment Alignment (71111.04)
    Partial Walkdown
  a. Inspection Scope
    The inspectors performed partial system walkdowns of the following risk-significant
    systems:
        *  On July 29, 2013, high pressure safety injection train B while train A was out of
            service for maintenance activities
        *  On August 20, 2013, essential chiller AB while essential chiller B was out of
            service for maintenance activities
        *  On September 5, 2013, auxiliary component cooling water train B while train A
            was out of service for maintenance activities
    The inspectors selected these systems based on their risk significance relative to the
    reactor safety cornerstones at the time they were inspected, while considering out of
    service time, inoperable or degraded conditions, recent system outages, and
    maintenance, modification, and testing. The inspectors attempted to identify any
    discrepancies that could affect the function of the system, and, therefore, potentially
    increase risk. The inspectors reviewed applicable operating procedures, system
    diagrams, final safety analysis report, technical specification requirements,
    administrative technical specifications, outstanding work orders, condition reports, and
    the impact of ongoing work activities on redundant trains of equipment in order to identify
    conditions that could have rendered the systems incapable of performing their intended
    functions. The inspectors also inspected accessible portions of the systems to verify
    system components and support equipment were aligned correctly and operable. The
    inspectors examined the material condition of the components and observed operating
    parameters of equipment to verify that there were no obvious deficiencies. The
    inspectors also verified that the licensee had properly identified and resolved equipment
    alignment problems that could cause initiating events or impact the capability of
    mitigating systems or barriers and entered them into the corrective action program with
    the appropriate significance characterization. Specific documents reviewed during this
    inspection are listed in the attachment.
    These activities constitute completion of three partial system walkdown samples, as
    defined in Inspection Procedure 71111.04.
  b. Findings
    No findings were identified.
                                        -6-                                    Enclosure 2


  ML13324B133
1R05 Fire Protection (71111.05)
SUNSI Rev Compl. Yes  No ADAMS Yes  No Reviewer Initials MD Publicly Avail.  Yes  No Sensitive Yes  No Sens. Type Initials MD
    Quarterly Fire Inspection Tours
SRI:DRP/E RI:DRP/E C:DRP/E C:DRS/EB1 C:DRS/EB2 C:DRS/OBMDavis CSpeer GWerner TFarnholtz GMiller VGaddy /RA/ E /RA/ E /RA/ /RA/ /RA/ /RA/ 11/14/13 11/14/13 11/15/13 11/15/13 11/18/13 11/18/13 C:DRS/PSB1 C:DRS/PSB2 C:DRS/TSB C:ORA/ACES
   a. Inspection Scope
BC:DRP/E  MHaire JDrake RKellar HGepford GWerner  /RA/ /RA/ /RA/ /RA/ /RA/MBloodgood for
    The inspectors conducted fire protection walkdowns that were focused on availability,
   11/15/13 11/18/13 11/18/13 11/18/13 11/20/2013 
    accessibility, and the condition of firefighting equipment in the following risk-significant
- 1 -  Enclosure 1 NOTICE OF VIOLATION
    plant areas:
Entergy Operations, Inc. Docket No:  50-382
          * On July 18, 2013, reactor auxiliary building, fire area 2, heat and ventilation
Waterford Steam Electric Station, Unit 3 License No:  NPF-38
            mechanical room
 
          *  On July 30, 2013, reactor auxiliary building, fire area 7, relay room
EA-12-257
          * On August 12, 2013, reactor auxiliary building, fire area 39, -35 foot elevation
During the NRC inspection conducted from July 20-October 19, 2009, a violation of the NRC requirements was identified.  In accordance with the NRC Enforcement Policy, the violation is listed below:  Title 10 CFR, Part 21.21(a)(1) requires, in part, that entities subject to the regulations in this part shall evaluate deviations and failures to comply to identify defects associated
            general area
with substantial safety hazards as soon as practicable, and except as provided in paragraph (a)(2) of this section, in all cases within 60 days of discovery, in order to identify a reportable defect that could create a substantial safety hazard, were it to
          * On August 27, 2013, turbine building, fire area 2, turbine building +15.00 foot
remain uncorrected. Title 10 CFR, Part 21.21(a)(2) requires, in part, that entities subject to the regulations in the part shall ensure that if an evaluation of identified deviation or failure to comply
            elevation west side area
potentially associated with a substantial safety hazard cannot be completed within
    The inspectors reviewed areas to assess if licensee personnel had implemented a fire
60 days from discovery of the deviation or failure to comply, an interim report is prepared and submitted to the Commission. The interim report must be submitted in writing within 60 days of discovery of the deviation of failure to comply. Contrary to the above, from December 14, 2008 to April 29, 2010, the licensee failed to evaluate deviations and failures to comply to identify defects associated with substantial
    protection program that adequately controlled combustibles and ignition sources within
safety hazards as soon as practicable and to submit a report or interim report within
    the plant; effectively maintained fire detection and suppression capability; maintained
60 days of its discovery, in order to identify a reportable defect or failure to comply that could create a substantial safety hazard, were it to remain uncorrected.  Specifically, on October 14, 2008, the licensee performed bench testing on an Agastat E7024PB relay with date code 0835 and noted that the relay had a loose terminal point.  Two more relays were obtained from the warehouse; one of these also had a bad terminal point.  On October 27, 2008, the licensee quarantined the remaining four relays
    passive fire protection features in good material condition; and had implemented
in stock.  Two of these quarantined relays were identified to have similarly deficient
    adequate compensatory measures for out of service, degraded or inoperable fire
terminal points.  The licensee identified these relays as "defective" and returned them to
    protection equipment, systems, or features, in accordance with the licensees fire plan.
the manufacturer, for cause evaluation.  All four affected relays shared a date code of
    The inspectors selected fire areas based on their overall contribution to internal fire risk
0835. On January 28, 2009, the licensee received a report from the manufacturer, which did not provide a cause evaluation.  On August 18, 2009, the licensee submitted Licensee Event Report 2009-003-00, (ML092310548).  This Licensee Event Report did
    as documented in the plants Individual Plant Examination of External Events with later
not mention the date code 0835 relays or loose terminal points.  Rather, the Licensee
    additional insights, their potential to affect equipment that could initiate or mitigate a
Event Report described relays that failed due to
    plant transient, or their impact on the plants ability to respond to a security event. Using
incorrect adjustment of terminal blocks, a deviation different from that observed in the 0835 date code relays. On April 29, 2010, the licensee issued updated Licensee Event Report 2009003-01 (ML101230323).  This revision to the Licensee Event Report described loose terminal points on two spare date
    the documents listed in the attachment, the inspectors verified that fire hoses and
code 0835 relays as one of the defects identified in its Agastat E7024PB relays.  The
    extinguishers were in their designated locations and available for immediate use; that
April 29, 2010, Licensee Event Report revision would have met Part 21 evaluation and reporting requirements, but it was 501 days late.  
    fire detectors and sprinklers were unobstructed; that transient material loading was
 
    within the analyzed limits; and fire doors, dampers, and penetration seals appeared to
- 2 -  Enclosure 1
    be in satisfactory condition and verified that adequate compensatory measures were put
This is a Severity Level IV violation (Supplement VII of Enforcement Policy dated September 1, 2009).  Pursuant to the provisions of 10 CFR 2.201, the Waterford Steam Electric Station, Unit 3 is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory
    in place by the licensee for out of service, degraded, or inoperable fire protection
Commission, ATTN:  Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, Region IV, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of
    equipment systems or features. The inspectors also verified that minor issues identified
Violation (Notice).  This reply should be clearly marked as a "Reply to a Notice of
    during the inspection were entered into the licensees corrective action program.
Violation; EA 12-257" and should include (1) the reason for the violation, or, if contested, the
    Specific documents reviewed during this inspection are listed in the attachment.
basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken, and (4) the date when full compliance will be achieved.  Your response may reference or include previous docketed
    These activities constitute completion of four quarterly fire protection inspection samples,
correspondence, if the correspondence adequately addresses the required response. If an
    as defined in Inspection Procedure 71111.05-05.
adequate reply is not received within the time specified in this Notice, an order or a Demand for
  b. Findings
Information may be issued as to why the license should not be modified, suspended, or
    Introduction. The inspectors identified a Green non-cited violation of Waterfords Facility
revoked, or why such other action as may be proper should not be taken.  Where good cause is
    Operating License Number NPF-38, License Condition 2.C.9, because the licensee did
shown, consideration will be given to extending the response time.  If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.  Because your response will be made available el
                                          -7-                                       Enclosure 2
ectronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not
include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction.  If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your
response that deletes such information. If you request withholding of such material, you must
specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial
information).  If safeguards information is necessary to provide an acceptable response, please
provide the level of protection described in 10 CFR 73.21.  Dated this 20
th day of November 2013
 
- 1 -  Enclosure 2
  U.S. NUCLEAR REGULATORY COMMISSION REGION IV
Docket: 05000382 License: NPF-38
Report: 05000382/2013004 Licensee: Entergy Operations, Inc. Facility: Waterford Steam Electric Station, Unit 3 Location: 17265 River Road Killona, LA 70057 Dates: July 1 through September 30, 2013 Inspectors: M. Davis, Senior Resident Inspector C. Speer, Resident Inspector T. Farina, Operations Engineer C. Steely, Operations Engineer
L. Carson, Senior Health Physicist
L. Ricketson, Senior Health Physicist
C. Alldredge, Health Physicist N. Greene, Health Physicist P. Hernandez, Health Physicist
J. O'Donnell, Health Physicist
 
E. Ruesch, Senior Reactor Engineer
Approved By: G. Werner, Acting Chief
Project Branch E
Division of Reactor Projects
 
- 2 -  Enclosure 2
SUMMARY OF FINDINGS
IR 05000382/2013004; 07/01/2013 - 09/30/2013; Waterford Steam Electric Station, Unit 3, Integrated Resident and Regional Report; Fire Protection, Post-Maintenance Testing, and Other
Activities.  The report covered a 3-month period of inspection by resident inspectors and an announced baseline inspections by region-based inspectors.  Two Green non-cited violations and one
severity level IV violation were identified.  The significance of most findings is indicated by their
color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609, "Significance Determination Process."  The cross-cutting aspect is determined using Inspection Manual Chapter 0310, "Components Within the Cross-Cutting Areas."  Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of  
 
commercial nuclear power reactors is described in NUREG - 1649, "Reactor Oversight Process," Revision 4, dated December 2006.  
A. NRC-Identified Findings and Self-Revealing Findings
    Cornerstone:  Mitigating Systems
 
* Green. The inspectors identified a non-cited violation of Waterford's Facility Operating License Number NPF-38, License Condition 2.C.9, because the licensee did not implement fire protection procedure FP-001-014, "Duties of a Fire Watch."  Specifically, the licensee's fire watch personnel did not implement Section 6.5 of  FP-001-014 to remove firefighting equipment from work areas when securing from a
fire watch.  As a result, multiple undercharged fire extinguishers were left in a fire
area.  The inspectors determined that this would affect safety-related equipment
because it would delay the response to fires in the fire areas.  The licensee entered
this condition into their corrective action program as CR-WF3-2013-03398 and CR-WF3-2013-03523 for resolution.  The immediate corrective actions taken to restore compliance included the removal of all undercharged fire extinguishers from
deactivated posts and returning them to their proper storage location. 
 
The failure to implement a fire protection program procedure was a performance deficiency.  The performance deficiency was more than minor because it was associated with the protection against external factors (i.e., fire) attribute of the
Mitigating Systems Cornerstone and adversely affected the cornerstone objective of
ensuring the availability, reliability, and capability of systems that respond to initiating
events to prevent undesirable consequences.  Specifically, the failure to remove undercharged fire extinguishers from work areas that contained safe shutdown equipment could hinder responses to fires in the fire area.  The inspectors used the
NRC Inspection Manual Chapter 0609, Attachment 4, "Initial Characterization of
Findings," to evaluate this issue.  The initial screening directed the inspectors to use
 
Appendix F, "Fire Protection Significance Determination Process," to determine the significance of the finding.  The inspectors determined that the finding had a low degradation rating because it reflected a fire protection program element whose 
- 3 -  Enclosure 2  
performance and reliability would be minimally impacted.  Specifically, in all cases identified, there were permanent fully charged portable fire extinguishers of the
proper type nearby.  Therefore, the finding was of very low safety significance (Green).  The inspectors concluded that the finding reflected current licensee performance and involved a cross-cutting aspect in the work practices component of
the human performance area in that the licensee did not ensure supervisory and
management oversight of work activities, including contractors, such that nuclear
safety is supported [H.4(c)] (Section 1R05).


* Green.  The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," because the licensee did not accomplish activities affecting quality on a degraded safety-related train B component cooling water (CCW) bypass valve (CC-134B) in accordance with
not implement fire protection procedure FP-001-014, Duties of a Fire Watch.
maintenance procedure EN-MA-101, "Fundamentals of Maintenance."  Specifically,  
Specifically, the licensees fire watch personnel did not implement section 6.5 of
the licensee did not control and perform testing on a leaking solenoid valve related to
FP-001-014 to remove firefighting equipment from work areas when securing from
the operation of a safety-related bypass valve (CC-134B) after maintenance personnel removed the degraded equipment from service as required by Section 5.10 of EN-MA-101. As a result, the licensee could not characterize and determine
a fire watch.
the cause of the leakage for the safety-related valve. The inspectors determined that  
Description. On July 18, 2013, during a walkdown of the reactor auxiliary building (RAB)
this would challenge the safety function of the valve to provide CCW to the ultimate
fire area number two, inspectors identified an undercharged and improperly stored fire
heat sink following a tornado event. The licensee entered this condition into their corrective action program as CR-WF3-2012-05991, CR-WF3-2012-06288, and CR-WF3-2013-04047. The immediate corrective actions taken to restore compliance
extinguisher in the fire area. The inspectors communicated this concern to the licensee.
included the installation of a new valve and debriefing personnel about controlling
The licensee dispatched personnel to remove the extinguisher and discovered two
equipment removed from service when
additional fire extinguishers in the same area with degraded charges. The licensee
combining preventative and corrective maintenance tasks in one work order.
initiated condition report CR-WF3-2013-03398 and removed the undercharged fire
extinguishers from the area. Upon further questioning from the inspectors, the licensee
stated that all of the uncharged fire extinguishers identified and removed from this fire
area were equipment used by fire watch personnel during recent hot work activities. The
inspectors reviewed the initial condition report, hot work permits, fire protection program
procedures EN-DC-127, Control of Hot Work and Ignition Sources, and FP-001-014,
Duties of a Fire Watch. The inspectors noted that procedure FP-001-014 required, in
part, that when a fire watch is deactivated the fire watch shall return all equipment to
their proper storage location. The inspectors determined that the licensees fire watch
personnel did not implement section 6.5.4.2 of FP-001-014 to remove firefighting
equipment from work areas when securing from a fire watch. The inspectors concluded
that this could affect the safety-related equipment located in the area because it would
delay the response to fires in the fire area by using undercharged fire extinguishers.
In addition, the inspectors noted that procedure EN-DC-127 stated, in part, that for hot
work, fire watches shall ensure that the proper fire extinguishers are available and fully
charged. The inspectors questioned if the licensee could confirm if the fire extinguishers
lost their charge after being left in the area over time or if personnel received the
extinguishers uncharged prior to establishing their fire watch. At the time the inspectors
proposed this question, the licensee could not confirm if the fire watch extinguishers
were undercharged because of the improper storage or if personnel was issued
degraded extinguishers. Due to the inspectors questioning, the licensee initiated
another condition report CR-WF3-2013-03523 and determined that no controls existed
to assure fire extinguishers were in acceptable condition prior to assigning them to fire
watches or that fire extinguishers were returned to their proper storage location. The
inspectors concluded that given the lack of controls over the fire watch extinguishers, the
licensee did not ensure supervisory and management oversight of fire watches. As a
result, the licensee established measures for tracking extinguishers prior to and after
being assigned to fire watches. Additionally, the licensee planned to conduct training for
all departments with fire watch responsibilities on procedural requirements.
Analysis. The failure to implement a fire protection program procedure was a
performance deficiency. The inspectors determined that this deficiency was reasonably
within the licensees ability to foresee and correct. The performance deficiency was
more than minor because it was associated with the protection against external factors
(i.e., fire) attribute of the Mitigating Systems Cornerstone and adversely affected the
cornerstone objective of ensuring the availability, reliability, and capability of systems
                                      -8-                                    Enclosure 2


The failure to control failed equipment removed from the plant to determine the cause in accordance with maintenance procedure requirements was a performance
that respond to initiating events to prevent undesirable consequences. Specifically, the
deficiency.  The performance deficiency was more than minor because it was
failure to remove undercharged fire extinguishers from work areas could hinder
associated with the equipment performance attribute of the Mitigating System
responses to fires in the area. The inspectors used NRC Inspection Manual
Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the degraded condition challenged
Chapter 0609, Attachment 4, Initial Characterization of Findings, to evaluate this issue.
the safety function of the valve (CC-134B) to limit the loss of CCW through damaged
The initial screening directed the inspectors to use Appendix F, Fire Protection
portions of the dry cooling tower fans following a tornado-generated missile strike. 
Significance Determination Process, to determine the significance of the finding. The
The inspectors used the NRC Inspection Manual 0609, Attachment 4, "Initial
inspectors determined that the finding had a low degradation rating because it reflected
Characterization of Findings," to evaluate this issue.  The finding required a detailed analysis because it was potentially risk significant for an external event (tornado).  Therefore, the senior reactor analyst performed a bounding detailed risk evaluation. 
a fire protection program element whose performance and reliability would be minimally
The senior reactor analyst determined that the finding was of very low safety
impacted. Specifically, in accordance with Appendix F, Attachment 2, in all cases
significance (Green).  The bounding change to the core damage frequency was less
identified, there were fully charged portable fire extinguishers of the proper type nearby.
than 3E-7/year.  The finding was not significant with respect to the large early release frequency.  The dominant core damage sequences included tornado induced losses of offsite power, failure of the dry cooling tower pressure boundary, failure to
Therefore, the finding was of very low safety significance (Green). The inspectors
isolate the damaged dry cooling tower, and failure to recover instrument air.  The
redundant train A component cooling water system combined with the tornado 
- 4 -  Enclosure 2
frequency helped to reduce the risk exposure.  The inspectors concluded that the finding reflected current licensee performance and involved a cross-cutting aspect in
the work control component of the human performance area in that the licensee did not appropriately coordinate work activities by incorporating actions to address the impact of changes to work scope or activity on plant and human performance
[H.3(b)] (Section 1R19).
 
Cornerstone: Miscellaneous
* Severity Level IV.  The team identified a violation of 10 CFR 21.21 that occurred when the licensee failed to submit a report or interim report on a deviation in a basic component within 60 days of discovery. 
The failure of the licensee to adequately evaluate deviations in basic components and to report defects is a performance deficiency.  The NRC's significance
determination process (SDP) considers the safety significance of findings by
evaluating their potential safety consequences.  This performance deficiency was of
minor safety significance.  The traditional enforcement process separately considers the significance of willful violations, violations that impact the regulatory process, and violations that result in actual safety consequences.  Traditional enforcement applied to this finding because it involved a violation that impacted the regulatory process. 
Supplement VII to the version of the NRC Enforcement Policy that was in effect at
the time the violation was identified provided as an example of a violation of
significant regulatory concern (Severity Level III), "An inadequate review or failure to review such that, if an appropriate review had been made as required, a  10 CFR Part 21 report would have been made."  Based on this example, the NRC
determined that the violation met the criteria to be cited as a Severity Level III
violation.  However, because of the circumstances surrounding the violation,
including the removal from service of the affected components by an unrelated
manufacturer's recall, the severity of the cited violation is being reduced to Severity Level IV.  Cross-cutting aspects are not assigned to traditional enforcement violations.  (Section 4OA5.2)
B. Licensee-Identified Violations
  A violation of very low safety significance (Severity Level IV), which was identified by the licensee, has been reviewed by the inspectors.  Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program.  This violation and associated corrective action tracking numbers are listed in Section 4OA7 of this report.
 
- 5 -  Enclosure 2
PLANT STATUS
The Waterford Steam Electric Station, Unit 3, began the inspection period at 100 percent power. 
On September 18, 2013, operators commenced a reactor down power to approximately 82 percent to perform maintenance on the normal level control valve 2B and the heater drain
pump B, respectively.  Operators began to raise power to 100 percent the same day.  The unit
maintained a 100 percent power for the remainder of the inspection period.
REPORT DETAILS
1. REACTOR SAFETY
 
Cornerstones:  Initiating Events, Mitigating Systems, Barrier Integrity and
Emergency Preparedness
1R01 Adverse Weather Protection (71111.01)  Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
Since tropical depression Dorian was forecast in the vicinity of the facility for August 4, 2013, the inspectors reviewed the plant personnel's overall preparations and protection for the expected weather conditions.  On August 2, 2013, the inspectors did a partial
walkdown of the switchyard and the startup unit transformer systems because their
functions could be affected, as a result of high winds, tornado-generated missiles, or the
loss of offsite power.  The inspectors evaluated the plant staff's preparations against site
procedures and determined that the staff's actions were adequate.  During the inspection, the inspectors focused on plant design features and the licensee's procedures to respond to
tornadoes and high winds.  The inspectors also toured the plant grounds to look for any loose debris that could become missiles during a tornado. 
The inspectors' evaluated operator staffing and accessibility of controls and indications
for those systems required to control the plant.  Additionally, the inspectors reviewed the final safety analysis report and performance requirements for the systems selected for inspection, and verified that operator actions were appropriate as specified by plant-
specific procedures.  The inspectors also reviewed a sample of corrective action
program items to verify that the licensee had identified adverse weather issues at an
appropriate threshold and entered them into the corrective action program for resolution. 
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of one sample of impending adverse weather
conditions, as defined in Inspection Procedure 71111.01.  b. Findings
No findings were identified.
 
- 6 -  Enclosure 2
1R04 Equipment Alignment (71111.04)  Partial Walkdown
a. Inspection Scope
The inspectors performed partial system walkdowns of the following risk-significant systems:
* On July 29, 2013, high pressure safety injection train B while train A was out of service for maintenance activities
* On August 20, 2013, essential chiller AB while essential chiller B was out of service for maintenance activities
* On September 5, 2013, auxiliary component cooling water train B while train A was out of service for maintenance activities
The inspectors selected these systems based on their risk significance relative to the
reactor safety cornerstones at the time they were inspected, while considering out of
service time, inoperable or degraded conditions, recent system outages, and
maintenance, modification, and testing.  The inspectors attempted to identify any
discrepancies that could affect the function of the system, and, therefore, potentially increase risk.  The inspectors reviewed applicable operating procedures, system diagrams, final safety analysis report, technical specification requirements,
administrative technical specifications, outstanding work orders, condition reports, and
the impact of ongoing work activities on redundant trains of equipment in order to identify
conditions that could have rendered the systems incapable of performing their intended functions.  The inspectors also inspected accessible portions of the systems to verify system components and support equipment were aligned correctly and operable.  The
inspectors examined the material condition of the components and observed operating
parameters of equipment to verify that there were no obvious deficiencies.  The
inspectors also verified that the licensee had properly identified and resolved equipment
alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program with the appropriate significance characterization.  Specific documents reviewed during this
inspection are listed in the attachment.
 
These activities constitute completion of three partial system walkdown samples, as defined in Inspection Procedure 71111.04.  b. Findings
  No findings were identified.
 
- 7 -  Enclosure 2
1R05 Fire Protection (71111.05)  Quarterly Fire Inspection Tours
a. Inspection Scope
The inspectors conducted fire protection walkdowns that were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant
plant areas:
 
* On July 18, 2013, reactor auxiliary building, fire area 2, heat and ventilation
mechanical room
* On July 30, 2013, reactor auxiliary building, fire area 7, relay room
* On August 12, 2013, reactor auxiliary building, fire area 39, -35' foot elevation general area
* On August 27, 2013, turbine building, fire area 2, turbine building +15.00' foot elevation west side area
The inspectors reviewed areas to assess if licensee personnel had implemented a fire
protection program that adequately controlled combustibles and ignition sources within
the plant; effectively maintained fire detection and suppression capability; maintained
passive fire protection features in good material condition; and had implemented adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features, in accordance with the licensee's fire plan. 
The inspectors selected fire areas based on their overall contribution to internal fire risk
as documented in the plant's Individual Plant Examination of External Events with later
additional insights, their potential to affect equipment that could initiate or mitigate a plant transient, or their impact on the plant's ability to respond to a security event.  Using the documents listed in the attachment, the inspectors verified that fire hoses and
extinguishers were in their designated locations and available for immediate use; that
fire detectors and sprinklers were unobstructed; that transient material loading was
within the analyzed limits; and fire doors, dampers, and penetration seals appeared to
be in satisfactory condition and verified that adequate compensatory measures were put in place by the licensee for out of service, degraded, or inoperable fire protection equipment systems or features.  The inspectors also verified that minor issues identified
during the inspection were entered into the licensee's corrective action program. 
Specific documents reviewed during this inspection are listed in the attachment.
 
These activities constitute completion of four quarterly fire protection inspection samples, as defined in Inspection Procedure 71111.05-05.
b. Findings
Introduction.  The inspectors identified a Green non-cited violation of Waterford's Facility Operating License Number NPF-38, License Condition 2.C.9, because the licensee did 
- 8 -  Enclosure 2
not implement fire protection procedure FP-001-014, "Duties of a Fire Watch."  Specifically, the licensee's fire watch personnel did not implement section 6.5 of FP-001-014 to remove firefighting equipment from work areas when securing from a fire watch. 
Description.  On July 18, 2013, during a walkdown of the reactor auxiliary building (RAB) fire area number two, inspectors identified an undercharged and improperly stored fire
extinguisher in the fire area.  The inspectors communicated this concern to the licensee. 
The licensee dispatched personnel to remove the extinguisher and discovered two additional fire extinguishers in the same area with degraded charges.  The licensee initiated condition report CR-WF3-2013-03398 and removed the undercharged fire
 
extinguishers from the area.  Upon further questioning from the inspectors, the licensee stated that all of the uncharged fire extinguishers identified and removed from this fire area were equipment used by fire watch personnel during recent hot work activities.  The inspectors reviewed the initial condition report, hot work permits, fire protection program procedures EN-DC-127, "Control of Hot Work and Ignition Sources," and FP-001-014,
"Duties of a Fire Watch."  The inspectors noted that procedure FP-001-014 required, in
part, that when a fire watch is deactivated the fire watch shall return all equipment to
their proper storage location.  The inspectors determined that the licensee's fire watch personnel did not implement section 6.5.4.2 of FP-001-014 to remove firefighting equipment from work areas when securing from a fire watch.  The inspectors concluded
that this could affect the safety-related equipment located in the area because it would
delay the response to fires in the fire area by using undercharged fire extinguishers.
 
In addition, the inspectors noted that procedure EN-DC-127 stated, in part, that for hot work, fire watches shall ensure that the proper fire extinguishers are available and fully charged.  The inspectors questioned if the licensee could confirm if the fire extinguishers
lost their charge after being left in the area over time or if personnel received the
extinguishers uncharged prior to establishing their fire watch.  At the time the inspectors
proposed this question, the licensee could not confirm if the fire watch extinguishers were undercharged because of the improper storage or if personnel was issued degraded extinguishers.  Due to the inspectors' questioning, the licensee initiated
another condition report CR-WF3-2013-03523 and determined that no controls existed
to assure fire extinguishers were in acceptable condition prior to assigning them to fire
watches or that fire extinguishers were returned to their proper storage location.  The
inspectors concluded that given the lack of controls over the fire watch extinguishers, the licensee did not ensure supervisory and management oversight of fire watches.  As a result, the licensee established measures for tracking extinguishers prior to and after
being assigned to fire watches.  Additionally, the licensee planned to conduct training for
all departments with fire watch responsibilities on procedural requirements.
 
Analysis.  The failure to implement a fire protection program procedure was a performance deficiency.  The inspectors determined that this deficiency was reasonably
within the licensee's ability to foresee and correct.  The performance deficiency was more than minor because it was associated with the protection against external factors
(i.e., fire) attribute of the Mitigating Systems Cornerstone and adversely affected the
cornerstone objective of ensuring the availability, reliability, and capability of systems 
- 9 -  Enclosure 2
that respond to initiating events to prevent undesirable consequences.  Specifically, the failure to remove undercharged fire extinguishers from work areas could hinder  
 
responses to fires in the area. The inspectors used NRC Inspection Manual Chapter 0609, Attachment 4, "Initial Characterization of Findings," to evaluate this issue. The initial screening directed the inspectors to use Appendix F, "Fire Protection  
Significance Determination Process," to determine the significance of the finding. The  
inspectors determined that the finding had a low degradation rating because it reflected  
a fire protection program element whose performance and reliability would be minimally  
impacted. Specifically, in accordance with Appendix F, Attachment 2, in all cases identified, there were fully charged portable fire extinguishers of the proper type nearby. Therefore, the finding was of very low safety significance (Green). The inspectors  
concluded that the finding reflected current licensee performance and involved a cross-
concluded that the finding reflected current licensee performance and involved a cross-
cutting aspect in the work practices component of human performance area in that the  
cutting aspect in the work practices component of human performance area in that the
licensee did not ensure supervisory and management oversight of work activities, including contractors, such that nuclear safety is supported [H.4(c)].  
licensee did not ensure supervisory and management oversight of work activities,
including contractors, such that nuclear safety is supported [H.4(c)].
Enforcement. Waterford's Facility Operating License Number NPF-38, License Condition 2.C.9, requires, in part, that the licensee shall implement and maintain in effect  
Enforcement. Waterfords Facility Operating License Number NPF-38, License
all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility. Final Safety Analysis Report, Section 9.5.1.6.3, specifies Procedure UNT-005-013, "Fire Protection Program," which describes responsibilities,  
Condition 2.C.9, requires, in part, that the licensee shall implement and maintain in effect
controls, and implementing requirements for the Waterford 3 Fire Protection Program. Procedure UNT-005-013, Section 5.9.2 specifies that individual fire watch activities shall  
all provisions of the approved fire protection program as described in the Final Safety
be performed in accordance with Procedure FP-001-014, "Duties of A Fire Watch."
Analysis Report for the facility. Final Safety Analysis Report, Section 9.5.1.6.3, specifies
Procedure FP-001-014, Section 6.5.4.2, states, in part, that to deactivate a fire watch post, the fire watch shall return all equipment to their proper storage location.  
Procedure UNT-005-013, Fire Protection Program, which describes responsibilities,
controls, and implementing requirements for the Waterford 3 Fire Protection Program.
Contrary to the above, as of July 2013, the licensee failed to comply with License  
Procedure UNT-005-013, Section 5.9.2 specifies that individual fire watch activities shall
Condition 2.C.9 to implement and maintain in effect all provisions of the approved fire protection program as described in the final safety analysis report for the facility and as  
be performed in accordance with Procedure FP-001-014, Duties of A Fire Watch.
approved in the Safety Evaluation Report. Specifically, fire watch personnel failed to return fire extinguishers assigned to fire watches to their proper storage location when  
Procedure FP-001-014, Section 6.5.4.2, states, in part, that to deactivate a fire watch
the fire watch personnel deactivated their fire watch posts. The licensee entered this  
post, the fire watch shall return all equipment to their proper storage location.
condition into their corrective action program as Condition Reports CR-WF3-2013-03398  
Contrary to the above, as of July 2013, the licensee failed to comply with License
and CR-WF3-2013-03523 for resolution. The immediate corrective action taken to  
Condition 2.C.9 to implement and maintain in effect all provisions of the approved fire
restore compliance was to remove and store fire watch extinguishers to their proper storage location. The planned corrective actions include establishing a tool to track the return of all equipment once personnel deactivate a fire watch post.
protection program as described in the final safety analysis report for the facility and as
approved in the Safety Evaluation Report. Specifically, fire watch personnel failed to
return fire extinguishers assigned to fire watches to their proper storage location when
the fire watch personnel deactivated their fire watch posts. The licensee entered this
condition into their corrective action program as Condition Reports CR-WF3-2013-03398
and CR-WF3-2013-03523 for resolution. The immediate corrective action taken to
restore compliance was to remove and store fire watch extinguishers to their proper
storage location. The planned corrective actions include establishing a tool to track the
return of all equipment once personnel deactivate a fire watch post.
Because this violation was of very low safety significance and the licensee entered the
issue into their corrective action program, this violation was treated as a non-cited
violation, consistent with Section 2.3.2.a of the Enforcement Policy:
(NCV 05000382/2013004-02, Failure to Implement Fire Protection Program Procedure
Requirements When Securing from a Fire Watch.
                                    -9-                                      Enclosure 2


1R06 Flood Protection Measures (71111.06)
Because this violation was of very low safety significance and the licensee entered the
  a. Inspection Scope
issue into their corrective action program, this violation was treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy: (NCV 05000382/2013004-02, "Failure to Implement Fire Protection Program Procedure
    The inspectors reviewed the final safety analysis report, the flooding analysis, and plant
Requirements When Securing from a Fire Watch."
    procedures to assess susceptibilities involving internal flooding; reviewed the corrective
 
    action program to determine if licensee personnel identified and corrected flooding
- 10 -  Enclosure 2
    problems; inspected underground bunkers/manholes to verify the adequacy of sump
1R06 Flood Protection Measures (71111.06) a. Inspection Scope
    pumps, level alarm circuits, cable splices subject to submergence, and drainage for
The inspectors reviewed the final safety analysis report, the flooding analysis, and plant procedures to assess susceptibilities involving internal flooding; reviewed the corrective  
    bunkers/manholes; and verified that operator actions for coping with flooding can
action program to determine if licensee personnel identified and corrected flooding  
    reasonably achieve the desired outcomes. The inspectors also inspected the areas
problems; inspected underground bunkers/manholes to verify the adequacy of sump  
    listed below to verify the adequacy of equipment seals located below the flood line, floor
pumps, level alarm circuits, cable splices subject to submergence, and drainage for bunkers/manholes; and verified that operator actions for coping with flooding can reasonably achieve the desired outcomes. The inspectors also inspected the areas  
    and wall penetration seals, watertight door seals, common drain lines and sumps, sump
listed below to verify the adequacy of equipment seals located below the flood line, floor  
    pumps, level alarms, and control circuits, and temporary or removable flood barriers.
and wall penetration seals, watertight door seals, common drain lines and sumps, sump  
    Specific documents reviewed during this inspection are listed in the attachment.
pumps, level alarms, and control circuits, and temporary or removable flood barriers. Specific documents reviewed during this inspection are listed in the attachment.
          * On September 16, 2013, heater drain pump B motor feeder cable
  * On September 16, 2013, heater drain pump B motor feeder cable  
          * On September 18, 2013, safeguards pump room B
  * On September 18, 2013, safeguards pump room B
    These activities constitute completion of one flood protection measure inspection sample
These activities constitute completion of one flood protection measure inspection sample  
    and one bunker/manhole sample, as defined in Inspection Procedure 71111.06-05.
and one bunker/manhole sample, as defined in Inspection Procedure 71111.06-05.  
  b. Findings
b. Findings
    No findings were identified.
No findings were identified.  
1R07 Heat Sink Performance (71111.07)
1R07 Heat Sink Performance (71111.07) a. Inspection Scope
On August 14, 2013, the inspectors reviewed licensee programs, verified performance against industry standards, and reviewed critical operating parameters and maintenance records for the essential chillers B and A/B.  The inspectors verified that performance
tests were satisfactorily conducted for heat exchangers/heat sinks and reviewed for
 
problems or errors; the licensee utilized the periodic maintenance method outlined in EPRI Report NP 7552, "Heat Exchanger Performance Monitoring Guidelines"; the licensee properly utilized bio-fouling controls; the licensee's heat exchanger inspections adequately assessed the state of cleanliness of their tubes; and the heat exchanger was
correctly categorized under 10 CFR 50.65, "Requirements for Monitoring the
Effectiveness of Maintenance at Nuclear Power Plants."  Specific documents reviewed during this inspection are listed in the attachment.
 
These activities constitute completion of two heat sink inspection sample, as defined in Inspection Procedure 71111.07-05.
 
- 11 -  Enclosure 2
b. Findings
 
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance (71111.11)
.1 Quarterly Review of Licensed Operator Requalification Program
a. Inspection Scope
On July 22, 2013, the inspectors observed a crew of licensed operators in the plant's simulator during training.  The inspectors assessed the following areas:
* Licensed operator performance
* The ability of the licensee to administer the evaluations 
* The modeling and performance of the control room simulator
* The quality of post-scenario critiques
* Follow-up actions taken by the licensee for identified discrepancies 
These activities constitute completion of one quarterly licensed operator requalification
program sample, as defined in Inspection Procedure 71111.11.  b. Findings
No findings were identified. .2 Quarterly Observation of Licensed Operator Performance
   a. Inspection Scope
   a. Inspection Scope
On September 18, 2013, the inspectors observed the performance of on-shift licensed operators in the plant's main control room. At the time of the observations, the plant was
    On August 14, 2013, the inspectors reviewed licensee programs, verified performance
in a period of heightened activity
    against industry standards, and reviewed critical operating parameters and maintenance
due to reactivity management maneuvers. The inspectors observed the operators' performance of the following activities:
    records for the essential chillers B and A/B. The inspectors verified that performance
    tests were satisfactorily conducted for heat exchangers/heat sinks and reviewed for
    problems or errors; the licensee utilized the periodic maintenance method outlined in
    EPRI Report NP 7552, Heat Exchanger Performance Monitoring Guidelines; the
    licensee properly utilized bio-fouling controls; the licensees heat exchanger inspections
    adequately assessed the state of cleanliness of their tubes; and the heat exchanger was
    correctly categorized under 10 CFR 50.65, Requirements for Monitoring the
    Effectiveness of Maintenance at Nuclear Power Plants. Specific documents reviewed
    during this inspection are listed in the attachment.
    These activities constitute completion of two heat sink inspection sample, as defined in
    Inspection Procedure 71111.07-05.
                                        - 10 -                                  Enclosure 2


* the pre-job brief
  b. Findings
* start-up activities
      No findings were identified.
* reactivity control
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
In addition, the inspectors assessed the operators' adherence to plant procedures, including conduct of operations procedure and other operations department policies. 
      (71111.11)
- 12 - Enclosure 2
.1    Quarterly Review of Licensed Operator Requalification Program
  These activities constitute completion of one quarterly licensed-operator performance
  a. Inspection Scope
sample, as defined in Inspection Procedure 71111.11.
      On July 22, 2013, the inspectors observed a crew of licensed operators in the plants
b. Findings
      simulator during training. The inspectors assessed the following areas:
No findings were identified. .3 Licensed Operator Requalification Biennial Inspection (71111.11B)
          *  Licensed operator performance
  The licensed operator requalification program involves two training cycles that are conducted over a 2-year period. In the first cycle, the annual cycle, the operators are
          *  The ability of the licensee to administer the evaluations
          *  The modeling and performance of the control room simulator
          *  The quality of post-scenario critiques
          *  Follow-up actions taken by the licensee for identified discrepancies
      These activities constitute completion of one quarterly licensed operator requalification
      program sample, as defined in Inspection Procedure 71111.11.
  b. Findings
      No findings were identified.
.2    Quarterly Observation of Licensed Operator Performance
  a. Inspection Scope
      On September 18, 2013, the inspectors observed the performance of on-shift licensed
      operators in the plants main control room. At the time of the observations, the plant was
      in a period of heightened activity due to reactivity management maneuvers. The
      inspectors observed the operators performance of the following activities:
          *  the pre-job brief
          *  start-up activities
          *  reactivity control
      In addition, the inspectors assessed the operators adherence to plant procedures,
      including conduct of operations procedure and other operations department policies.
                                          - 11 -                                Enclosure 2


administered an operating test consisting of job performance measures and simulator scenarios. In the second part of the training cycle, the biennial cycle, operators are administered an operating test and a co
      These activities constitute completion of one quarterly licensed-operator performance
mprehensive written examination.  
      sample, as defined in Inspection Procedure 71111.11.
a. Inspection Scope
  b. Findings
 
      No findings were identified.
To assess the performance effectiveness of the licensed operator requalification  
.3    Licensed Operator Requalification Biennial Inspection (71111.11B)
program, the inspectors interviewed training staff, reviewed both the operating tests and written examinations, and observed ongoing operating test activities.
      The licensed operator requalification program involves two training cycles that are
The inspectors reviewed operator performance on the written exams and operating  
      conducted over a 2-year period. In the first cycle, the annual cycle, the operators are
tests. These reviews included observations of portions of the operating tests by the  
      administered an operating test consisting of job performance measures and simulator
inspectors, as well as observing exam security measures taken during written exam administration. The operating tests obser
      scenarios. In the second part of the training cycle, the biennial cycle, operators are
ved included five job performance measures and two scenarios that were used in the current biennial requalification cycle,  
      administered an operating test and a comprehensive written examination.
administered to multiple operators. These observations allowed the inspectors to  
  a. Inspection Scope
assess the licensee's effectiveness in conducting the operating test to ensure operator  
      To assess the performance effectiveness of the licensed operator requalification
mastery of the training program content. The inspectors also reviewed medical records  
      program, the inspectors interviewed training staff, reviewed both the operating tests and
of 8 licensed operators for conformance to license conditions and the licensee's system for tracking qualifications and records of license reactivation.
      written examinations, and observed ongoing operating test activities.
The results of these examinations were reviewed to determine the effectiveness of the  
      The inspectors reviewed operator performance on the written exams and operating
licensee's appraisal of operator performance and to determine if feedback of  
      tests. These reviews included observations of portions of the operating tests by the
performance analyses into the requalification training program was being accomplished. The inspectors interviewed members of the training department and reviewed corrective actions related to operator errors to assess the responsiveness of the licensed operator  
      inspectors, as well as observing exam security measures taken during written exam
requalification program to incorporate the lessons learned from both plant and industry  
      administration. The operating tests observed included five job performance measures
events. Examination results were also assessed to determine if they were consistent  
      and two scenarios that were used in the current biennial requalification cycle,
with the guidance contained in NUREG 1021, "Operator Licensing Examination Standards for Power Reactors", Revision 9, Supplement 1, and NRC Manual  
      administered to multiple operators. These observations allowed the inspectors to
Chapter 0609, Appendix I, "Operator Requalification Human Performance Significance Determination Process."  
      assess the licensee's effectiveness in conducting the operating test to ensure operator
      mastery of the training program content. The inspectors also reviewed medical records
      of 8 licensed operators for conformance to license conditions and the licensees system
      for tracking qualifications and records of license reactivation.
      The results of these examinations were reviewed to determine the effectiveness of the
      licensees appraisal of operator performance and to determine if feedback of
      performance analyses into the requalification training program was being accomplished.
      The inspectors interviewed members of the training department and reviewed corrective
      actions related to operator errors to assess the responsiveness of the licensed operator
      requalification program to incorporate the lessons learned from both plant and industry
      events. Examination results were also assessed to determine if they were consistent
      with the guidance contained in NUREG 1021, "Operator Licensing Examination
      Standards for Power Reactors", Revision 9, Supplement 1, and NRC Manual
      Chapter 0609, Appendix I, "Operator Requalification Human Performance Significance
      Determination Process."
      In addition to the above, the inspectors reviewed examination security measures,
      simulator fidelity, existing logs of simulator deficiencies, and Problem Identification and
                                          - 12 -                                  Enclosure 2


    Resolution records related to training. The inspectors conducted a detailed review for
In addition to the above, the inspectors reviewed examination security measures, simulator fidelity, existing logs of simulator deficiencies, and Problem Identification and 
    quality of five full weeks of operating tests and one full written exam.
- 13 -  Enclosure 2
    On August 8, 2013, the licensee informed the lead inspector of the results of the written
Resolution records related to training. The inspectors conducted a detailed review for quality of five full weeks of operating tests and one full written exam.  
    examinations and operating tests for the Licensed Operator Requalification Program.
    The inspectors compared the written and operating test results to the Appendix I,
    Licensed Operator Requalification Significance Determination Process, values and
    determined that there were no findings based on these results and because the
    individuals that failed the applicable portions of their exams and/or operating tests were
    remediated, retested, and passed their retake exams prior to returning to shift.
    The inspectors completed one inspection sample of the biennial licensed operator
    requalification program.
  b. Findings
    One licensee-identified Severity Level IV NCV was evaluated during this inspection. It is
    documented in section 4OA7 of this report.
1R12 Maintenance Effectiveness (71111.12)
  a. Inspection Scope
    The inspectors evaluated degraded performance issues involving the following risk
    significant systems:
        *  On September 2, 2013, essential chiller B
        *  On September 10, 2013, control room air handling unit train A inlet damper
            (HCV-103A)
    The inspectors reviewed events such as where ineffective equipment maintenance has
    resulted in valid or invalid automatic actuations of engineered safeguards systems and
    independently verified the licensee's actions to address system performance or condition
    problems in terms of the following:
        *  Implementing appropriate work practices
        *  Identifying and addressing common cause failures
        *  Scoping of systems in accordance with 10 CFR 50.65(b)
        *  Characterizing system reliability issues for performance
        *  Charging unavailability for performance
        *  Trending key parameters for condition monitoring
                                        - 13 -                                  Enclosure 2


  On August 8, 2013, the licensee informed the lead inspector of the results of the written examinations and operating tests for the Licensed Operator Requalification Program. The inspectors compared the written and operating test results to the Appendix I,  
          * Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or -(a)(2)
"Licensed Operator Requalification Significance Determination Process," values and  
          *  Verifying appropriate performance criteria for structures, systems, and
determined that there were no findings based on these results and because the  
            components classified as having an adequate demonstration of performance
individuals that failed the applicable portions of their exams and/or operating tests were remediated, retested, and passed their retake exams prior to returning to shift.
            through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as
   
            requiring the establishment of appropriate and adequate goals and corrective
The inspectors completed one inspection sample of the biennial licensed operator
            actions for systems classified as not having adequate performance, as described
requalification program.
            in 10 CFR 50.65(a)(1)
  b. Findings
    The inspectors assessed performance issues with respect to the reliability, availability,
 
    and condition monitoring of the system. In addition, the inspectors verified maintenance
One licensee-identified Severity Level IV NCV was evaluated during this inspection.  It is documented in section 4OA7 of this report.  
    effectiveness issues were appropriately handled by a screening and identification
    process and that those issues were entered into the corrective action program with the
    appropriate significance characterization. Specific documents reviewed during this
    inspection are listed in the attachment.
    These activities constitute completion of two maintenance effectiveness samples, as
    defined in Inspection Procedure 71111.12-05.
  b  Findings
    No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
  a. Inspection Scope
    The inspectors reviewed licensee personnel's evaluation and management of plant risk
    for the maintenance and emergent work activities affecting risk-significant and safety-
    related equipment listed below to verify that the appropriate risk assessments were
    performed prior to removing equipment for work:
          * On July 31, 2013, scheduled replacement of reactor trip circuit breaker number 5
          *  On August 19, 2013, emergent maintenance on the EDG A2 compressor
            component
          * On August 21, 2013, scheduled maintenance on the component cooling water
            pump and auxiliary feedwater pump breaker with the EDG A2 and B1 air
            compressors out of service
          *  On September 3, 2013, scheduled maintenance on the switchgear ventilation
            system air handling unit AH-30A with EDG A1 air receiver out of service
    The inspectors selected these activities based on potential risk significance relative to
    the reactor safety cornerstones. As applicable for each activity, the inspectors verified
                                        - 14 -                                  Enclosure 2


1R12 Maintenance Effectiveness (71111.12) a. Inspection Scope
    that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)
The inspectors evaluated degraded performance issues involving the following risk significant systems:  
    and that the assessments were accurate and complete. When licensee personnel
* On September 2, 2013, essential chiller B  
    performed emergent work, the inspectors verified that the licensee personnel promptly
* On September 10, 2013, control room air handling unit train A inlet damper (HCV-103A)  
    assessed and managed plant risk. The inspectors reviewed the scope of maintenance
    work, discussed the results of the assessment with the licensee's probabilistic risk
The inspectors reviewed events such as where ineffective equipment maintenance has
    analyst or shift technical advisor, and verified plant conditions were consistent with the
resulted in valid or invalid automatic actuations of engineered safeguards systems and  
    risk assessment. The inspectors also reviewed the technical specification requirements
independently verified the licensee's actions to address system performance or condition problems in terms of the following:
    and inspected portions of redundant safety systems, when applicable, to verify risk
* Implementing appropriate work practices
    analysis assumptions were valid and applicable requirements were met. Specific
* Identifying and addressing common cause failures
    documents reviewed during this inspection are listed in the attachment.
* Scoping of systems in accordance with 10 CFR 50.65(b) 
    These activities constitute completion of four maintenance risk assessments and
* Characterizing system reliability issues for performance
    emergent work control inspection samples, as defined in Inspection
* Charging unavailability for performance
    Procedure 71111.13-05.
* Trending key parameters for condition monitoring 
  b. Findings
- 14 -  Enclosure 2
    No findings were identified.
  * Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or -(a)(2)
1R15 Operability Determinations and Functionality Assessments (71111.15)
* Verifying appropriate performance criteria for structures, systems, and components classified as having an adequate demonstration of performance through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as
  a. Inspection Scope
requiring the establishment of appropriate and adequate goals and corrective actions for systems classified as not having adequate performance, as described
    The inspectors reviewed the following assessments:
in 10 CFR 50.65(a)(1)
        *   On August 5, 2013, pressurizer level control system
        *    On August 15, 2013, essential chiller A/B
The inspectors assessed performance issues with respect to the reliability, availability,
        *    On August 20, 2013, main steam isolation valve number 2 steam leak
and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were appropriately handled by a screening and identification process and that those issues were entered into the corrective action program with the
        *   On August 25, 2013, control room air handling unit A inlet damper (HCV-103A)
appropriate significance characterization.  Specific documents reviewed during this
        *    On September 5, 2013, snubber pin (FWSR-60) missing
inspection are listed in the attachment.
    The inspectors selected these operability and functionality assessments based on the
    risk significance of the associated components and systems along with other factors,
    such as engineering analysis and judgment, operating experience, and performance
    history. The inspectors evaluated the technical adequacy of the evaluations to ensure
    technical specification operability was properly justified and to verify the subject
    component or system remained available such that no unrecognized increase in risk
    occurred. The inspectors compared the operability and design criteria in the appropriate
    sections of the technical specifications and final safety analysis report to the licensees
    evaluations to determine whether the components or systems were operable. Where
    compensatory measures were required to maintain operability, the inspectors
    determined whether the measures in place would function as intended and were
    properly controlled. Additionally, the inspectors reviewed a sampling of corrective action
                                        - 15 -                                    Enclosure 2


    documents to verify that the licensee was identifying and correcting any deficiencies
These activities constitute completion of two maintenance effectiveness samples, as defined in Inspection Procedure 71111.12-05.  
    associated with operability evaluations. Specific documents reviewed during this
b Findings
    inspection are listed in the attachment.
No findings were identified. 1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13) a. Inspection Scope
    These activities constitute completion of five operability evaluations inspection samples,
The inspectors reviewed licensee personnel's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were  
    as defined in Inspection Procedure 71111.15 - 05.
performed prior to removing equipment for work:
  b. Findings
    No findings were identified.
1R18 Plant Modifications (71111.18)
  .1 Temporary Modifications
  a. Inspection Scope
    To verify that the safety functions of important safety systems were not degraded, on
    August 28, 2013, the inspectors reviewed the temporary modification identified as
    EC-45995, main steam isolation valve B to repair a bonnet vent plug.
    The inspectors reviewed the temporary modification and the associated safety-
    evaluation screening against the system design bases documentation, including the final
    safety analysis report and the technical specifications, and verified that the modification
    did not adversely affect the system operability/availability. The inspectors also verified
    that the installation and restoration were consistent with the modification documents and
    that configuration control was adequate. Additionally, the inspectors verified that the
    temporary modification was identified on control room drawings, appropriate tags were
    placed on the affected equipment, and licensee personnel evaluated the combined
    effects on mitigating systems and the integrity of radiological barriers.
    These activities constitute completion of one sample for temporary plant modifications,
    as defined in Inspection Procedure 71111.18-05.
  b. Findings
    No findings were identified.
  .2 Permanent Modifications
  a. Inspection Scope
    On September 26, 2013, the inspectors reviewed key parameters associated with
    materials, replacement components, operations, flow paths, pressure boundary,
    ventilation boundary, structural, process medium properties, licensing basis, and failure
    modes for the permanent modification identified as EC-46914, main feedwater isolation
    valve A nitrogen accumulator B tubing replacement.
                                        - 16 -                                  Enclosure 2


* On July 31, 2013, scheduled replacement of reactor trip circuit breaker number 5
    The inspectors verified that modification preparation, staging, and implementation did
* On August 19, 2013, emergent maintenance on the EDG A2 compressor
    not impair emergency/abnormal operating procedure actions, key safety functions, or
component
    operator response to loss of key safety functions; post modification testing will maintain
* On August 21, 2013, scheduled maintenance on the component cooling water pump and auxiliary feedwater pump breaker with the EDG A2 and B1 air compressors out of service
    the plant in a safe configuration during testing by verifying that unintended system
* On September 3, 2013, scheduled maintenance on the switchgear ventilation system air handling unit AH-30A with EDG A1 air receiver out of service
    interactions will not occur; systems, structures and components performance
    characteristics still meet the design basis; the modification design assumptions were
The inspectors selected these activities based on potential risk significance relative to
    appropriate; the modification test acceptance criteria will be met; and licensee personnel
the reactor safety cornerstones. As applicable for each activity, the inspectors verified 
    identified and implemented appropriate corrective actions associated with permanent
- 15 -  Enclosure 2
    plant modifications. Specific documents reviewed during this inspection are listed in the
that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete.  When licensee personnel
    attachment.
performed emergent work, the inspectors verified that the licensee personnel promptly assessed and managed plant risk.  The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk
    These activities constitute completion of one sample for permanent plant modifications,
analyst or shift technical advisor, and verified plant conditions were consistent with the
    as defined in Inspection Procedure 71111.18-05.
risk assessment.  The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk
  b. Findings
analysis assumptions were valid and applicable requirements were met.  Specific documents reviewed during this inspection are listed in the attachment.
    No findings were identified.
1R19 Post-Maintenance Testing (71111.19)
These activities constitute completion of four maintenance risk assessments and
  a. Inspection Scope
emergent work control inspection samples, as defined in Inspection
    The inspectors reviewed the following post-maintenance activities to verify that
    procedures and test activities were adequate to ensure system operability and functional
    capability:
          *   On July 29, 2013, emergency feedwater to steam generator 1 backup flow
              control valve (EFW-223A)
          *  On July 30, 2013, dry cooling tower B component cooling water bypass valve
              (CC-134B)
          *   On August 1, 2013, replaced reactor trip circuit breakers
          *   On August 6, 2013, corrective maintenance on the emergency generator A1
              compressor pressure switch
          *   On September 24, 2013, replaced control room air handling unit A inlet damper
              (HCV-103A)
    The inspectors selected these activities based upon the structure, system, or
    component's ability to affect risk. The inspectors evaluated these activities for the
    following (as applicable):
          *  The effect of testing on the plant had been adequately addressed; testing was
              adequate for the maintenance performed
                                        - 17 -                                  Enclosure 2


Procedure 71111.13-05.
          *  Acceptance criteria were clear and demonstrated operational readiness; test
b. Findings
              instrumentation was appropriate
No findings were identified.
      The inspectors evaluated the activities against the technical specifications, the final
      safety analysis report, 10 CFR Part 50 requirements, licensee procedures, and various
1R15 Operability Determinations and Functionality Assessments (71111.15) a. Inspection Scope
      NRC generic communications to ensure that the test results adequately ensured that the
The inspectors reviewed the following assessments:
      equipment met the licensing basis and design requirements. In addition, the inspectors
* On August 5, 2013, pressurizer level control system
      reviewed corrective action documents associated with post-maintenance tests to
* On August 15, 2013, essential chiller A/B
      determine whether the licensee was identifying problems and entering them in the
* On August 20, 2013, main steam isolation valve number 2 steam leak 
      corrective action program and that the problems were being corrected commensurate
* On August 25, 2013, control room air handling unit A inlet damper (HCV-103A)
      with their importance to safety. Specific documents reviewed during this inspection are
* On September 5, 2013, snubber pin (FWSR-60) missing
      listed in the attachment.
The inspectors selected these operability and functionality assessments based on the
      These activities constitute completion of five post-maintenance testing inspection
risk significance of the associated components and systems along with other factors, such as engineering analysis and judgment, operating experience, and performance history.  The inspectors evaluated the technical adequacy of the evaluations to ensure  
      samples, as defined in Inspection Procedure 71111.19-05.
technical specification operability was properly justified and to verify the subject
  b. Findings
component or system remained available such that no unrecognized increase in risk occurred.  The inspectors compared the operability and design criteria in the appropriate
.1    Failure to Control Failed Equipment Removed from the Plant in Accordance with
sections of the technical specifications and final safety analysis report to the licensee's evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors  
      Procedure Requirements
determined whether the measures in place would function as intended and were
      Introduction. The inspectors identified a Green non-cited violation of 10 CFR Part 50,
properly controlled.  Additionally, the inspectors reviewed a sampling of corrective action
      Appendix B, Criterion V, Instructions, Procedures, and Drawings, because the
- 16 -  Enclosure 2
      licensee did not control and determine the extent of leaking safety-related bypass valve
documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Specific documents reviewed during this  
      associated with the dry cooling tower B component cooling water solenoid valve
inspection are listed in the attachment.  
      (CC-134B) after maintenance personnel removed the degraded equipment from service
These activities constitute completion of five operability evaluations inspection samples,  
      as required by Section 5.10 of EN-MA-101.
as defined in Inspection Procedure 71111.15 - 05.  
      Description. On October 31, 2012, the licensee conducted a post-maintenance leak test
b. Findings
      on the actuator for a safety-related air operate solenoid valve CC-134B. During the
No findings were identified.  
      process of conducting the leak test, maintenance personnel identified air coming from
1R18 Plant Modifications (71111.18) .1 Temporary Modifications
      the exhaust vent port of a solenoid valve associated with the operation of CC-134B. The
a. Inspection Scope
      licensee replaced the valve on November 1, 2012, and restored valve CC-134B to an
To verify that the safety functions of important safety systems were not degraded, on August 28, 2013, the inspectors reviewed the temporary modification identified as 
      operable status. However, the licensee did not retain the original solenoid valve for
EC-45995, main steam isolation valve B to repair a bonnet vent plug.  
      testing to determine the cause or extent of the leakage. Without supporting information
The inspectors reviewed the temporary modification and the associated safety-
      regarding the leak rate or cause, the licensee assumed that CC-134B and its air
evaluation screening against the system design bases documentation, including the final
      accumulator were inoperable from October 20, 2011, the dates of the last satisfactory
safety analysis report and the technical specifications, and verified that the modification
      leak test, until November 1, 2012, when maintenance personnel replaced the valve.
did not adversely affect the system operability/availability. The inspectors also verified that the installation and restoration were consistent with the modification documents and that configuration control was adequate.  Additionally, the inspectors verified that the  
      The licensee initiated a condition report and performed an apparent cause evaluation.
temporary modification was identified on control room drawings, appropriate tags were
      The inspectors performed a review of the apparent cause evaluation, the event timeline,
placed on the affected equipment, and licensee personnel evaluated the combined
      work orders, and maintenance history of valve CC-134B. The licensee determined that
effects on mitigating systems and the integrity of radiological barriers.  
      the valve leakage could have adversely affected the backup air accumulator inventory.
These activities constitute completion of one sample for temporary plant modifications, as defined in Inspection Procedure 71111.18-05.  
      However, the licensee did not retain the leaking valve to perform any testing. As a
b. Findings
      result, the licensee could not characterize and determine the cause of the leakage for
No findings were identified.
      the safety-related valve. The inspectors determined that the licensee did not accomplish
.2 Permanent Modifications
                                        - 18 -                                  Enclosure 2
a. Inspection Scope
On September 26, 2013, the inspectors reviewed key parameters associated with materials, replacement components, operations, flow paths, pressure boundary,
ventilation boundary, structural, process medium properties, licensing basis, and failure modes for the permanent modification identified as EC-46914, main feedwater isolation valve A nitrogen accumulator B tubing replacement.  


 
activities in accordance with maintenance procedure EN-MA-101, Fundamentals of
- 17 - Enclosure 2
Maintenance. Section 5.10, Control of Failed Plant Equipment, of EN-MA-101,
The inspectors verified that modification preparation, staging, and implementation did not impair emergency/abnormal operating procedure actions, key safety functions, or
requires, in part, that the licensee control failed equipment removed from the plant to
operator response to loss of key safety functions; post modification testing will maintain the plant in a safe configuration during testing by verifying that unintended system interactions will not occur; systems, structures and components' performance characteristics still meet the design basis; the modification design assumptions were
determine necessary testing to establish the cause of the failure.
appropriate; the modification test acceptance criteria will be met; and licensee personnel  
As a part of the review of the apparent cause evaluation, the inspectors also noted that
identified and implemented appropriate corrective actions associated with permanent
an incomplete work order contributed to discarding the solenoid valve prior to testing.
plant modifications. Specific documents reviewed during this inspection are listed in the  
The licensee combined a corrective maintenance with a preventative maintenance task
attachment.  
into the existing work order for CC-134B during the replacement of the solenoid valve.
This led to an error-trap, as explicit instructions for retaining failed parts were not a part
These activities constitute completion of one sample for permanent plant modifications,
of the preventative maintenance tasks. The immediate corrective actions taken to
as defined in Inspection Procedure 71111.18-05.  
restore compliance included the installation of a new valve and debriefing personnel
about controlling equipment removed from service when combining preventative and
b. Findings
corrective maintenance tasks in one work order. The licensee entered this condition into
No findings were identified.  
their corrective action program as Condition Reports CR-WF3-2012-05991 and
1R19 Post-Maintenance Testing (71111.19) a. Inspection Scope
CR-WF3-2012-06288. However, inspectors questioned the effectiveness of the original
The inspectors reviewed the following post-maintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional
corrective action by the licensee to have personnel briefed on the effects of combining
capability:
preventative and corrective maintenance tasks in a work order. The inspectors felt that
a briefing did not provide an adequate barrier to prevent this from happening again. As
a result, the licensee initiated CR-HQN-2013-00709 and CR-WF3-2013-04047 to
determine additional corrective actions to address the error trap. The inspectors
determined that the licensee did not appropriately coordinate work activities by
incorporating actions to address the impact of changes to work scope on the plant and
human performance.
Analysis. The failure to control failed equipment removed from the plant to determine
the cause was a performance deficiency. The inspectors determined that this deficiency
was reasonably within the licensees ability to foresee and correct. The performance
deficiency was more than minor because it was associated with the equipment
performance attribute of the Mitigating System Cornerstone and adversely affected the
cornerstone objective to ensure the availability, reliability, and capability of systems that
respond to initiating events to prevent undesirable consequences. Specifically, the
degraded condition challenged the safety function of valve CC-134B to limit the loss of
component cooling water through damaged portions of the dry cooling towers following a
tornado-generated missile strike.
The inspectors used NRC Inspection Manual Chapter 0609, Attachment 4, Initial
Characterization of Findings, and Appendix A, The Significance Determination Process
(SDP) for Findings At-Power, to evaluate this issue. The inspectors determined that the
finding required a detailed analysis because it was potentially risk significant for an
external event (tornado) based on using Exhibit 4, External Events Screening
Questions. Therefore, the senior reactor analyst performed the following bounding
detailed risk evaluation:
Tornado Statistics: About one out of every three tornadoes (29 percent) is classified as
"strong." Strong tornadoes have an average path length of 9 miles and a path width of
200 yards (approximately 1 square mile of land affected). Although very rare
                                    - 19 -                                      Enclosure 2


* On July 29, 2013, emergency feedwater to steam generator 1 backup flow control valve (EFW-223A)  
(about 2 percent are violent), violent tornadoes can last for hours. Average path lengths
* On July 30, 2013, dry cooling tower B component cooling water bypass valve (CC-134B)  
and widths are 26 miles and 425 yards, respectively.
* On August 1, 2013, replaced reactor trip circuit breakers
Since the strong tornadoes can affect approximately 1 square mile, weaker tornadoes,
* On August 6, 2013, corrective maintenance on the emergency generator A1 compressor pressure switch 
on average, would affect significantly less than 1 square mile. Most tornadoes are of the
* On September 24, 2013, replaced control room air handling unit A inlet damper (HCV-103A)  
weaker variety. Violent tornadoes can affect approximately 6 to 7 square miles (on
The inspectors selected these activities based upon the structure, system, or
average), but are relatively rare. Therefore, the analyst assumed that the average
component's ability to affect risk. The inspectors evaluated these activities for the  
tornado would affect 1 square mile of land.
following (as applicable):
The average number of tornadoes in Louisiana per year was 27.
The total area for the state of Louisiana was 51,840 square miles.
Plant Area: For this risk evaluation, the analyst assumed that the Waterford-3 nuclear
island and switchyard occupied one square mile of land. This was conservative, in that
this equipment occupies less than one square mile.
The analyst conservatively assumed that a tornado within a 1 square mile area would
cause a loss of offsite power and cause physical damage to the train B dry cooling tower
train. This in turn would cause the B component cooling water train to fail. Because the
dry cooling towers are at least partially protected from missiles by the surrounding
building, this is a very conservative assumption. Not all tornadoes will result in
damaging this equipment.
Tornado Frequency: The frequency of a tornado hitting the Waterford-3 nuclear island
and switchyard was therefore:
        = 27 tornadoes/year / 51840 sq miles = 5.2E-4/yr.
Calculations: The analyst used the NRCs Waterford-3 Standardized Plant Analysis
Risk (SPAR) model, Revision 8.16, with a truncation limit of E-11, to evaluate this
finding. The analyst assumed a full year exposure period.
The analyst calculated the incremental conditional core damage probability (ICCDP)
considering a loss of offsite power (LOOP) coincident with the failure of the train B
component cooling water system. To account for an earlier finding at Waterford-3, the
analyst set the basic event for alternate room cooling to 1.0. The analyst used this
adjustment in both the nominal case (no performance deficiency) and the current case
(with the performance deficiency). In addition, for both cases the analyst set the basic
event for a LOOP to 1.0. The analyst solved only the LOOP sequences. The nominal
case CCDP was 2.15E-4.
For the current case calculation, the analyst additionally set the basic events for the
B and AB (swing) motor driven component cooling water pumps to 1.0. The resultant
CCDP was 5.9E-3.
                                    - 20 -                                  Enclosure 2


* The effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed 
The initial ICCDP was therefore the difference between the nominal and current case
- 18 - Enclosure 2  
CCDPs = 5.7E-3.
  * Acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate
The analyst considered recovery of the instrument air system. As noted in Licensee
Event Report 2012-007, dated December 31, 2012, operators could recover an
The inspectors evaluated the activities against the technical specifications, the final safety analysis report, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the  
instrument air compressor and power the unit from an operable running emergency
equipment met the licensing basis and design requirements. In addition, the inspectors
diesel generator. The resident inspectors had reviewed these procedures and estimated
reviewed corrective action documents associated with post-maintenance tests to  
that it may take 2.0 hours to perform this action. The analyst assumed a non-recovery
determine whether the licensee was identifying problems and entering them in the
probability of 0.1 for this action. The nominal non-recovery probability as specified in
corrective action program and that the problems were being corrected commensurate with their importance to safety. Specific documents reviewed during this inspection are listed in the attachment.
NUREG/CR-6883, The SPAR-H Human Reliability Analysis Method, was 1.1E-2.
Therefore, 0.1 was conservative when compared to 1.1E-2. The resultant ICCDP,
considering recovery, was 5.7E-4.
The change to the core damage frequency (delta CDF) was the tornado frequency
multiplied by the ICCDP = 5.2E-4/yr * 5.7E-4 = 2.9E-7/yr.
The dominant core damage sequences included tornado induced losses of offsite power,
failure of the dry cooling tower pressure boundary, failure to isolate the damaged dry
cooling tower, and failure to recovery instrument air. The redundant train A component
cooling water system combined with the tornado frequency helped to reduce the risk
exposure.
Large Early Release Frequency (LERF): To address the contribution to conditional large
early release frequency, the analyst used NRC Inspection Manual Chapter 0609,
Appendix H, Containment Integrity Significance Determination Process, dated May 6,
2004. The finding was not significant to LERF because it did not directly affect the
steam generator tube rupture or the intersystem loss of coolant accident sequences.
The inspectors concluded that the finding reflected current licensee performance and
involved a cross-cutting aspect in the work control component of the human
performance area in that the licensee did not appropriately coordinate work activities by
incorporating actions to address the impact changes to work scope or activity on plant
and human performance [H.3(b)].
Enforcement. Title 10 of CFR, Part 50, Appendix B, Criterion V, Instructions,
Procedures, and Drawings, requires, in part, that activities affecting quality shall be
prescribed by documented instructions, procedures, or drawings, of a type appropriate to
the circumstances and shall be accomplished in accordance with these instructions,
procedures, or drawings. Specifically, Section 5.10, Control of Failed Plant Equipment
of maintenance procedure EN-MA-101, Fundamentals of Maintenance, requires, in
part, that it be determined whether the component should be tested to establish cause
of failure before it is scrapped.
Contrary to the above, on November 1, 2012, the licensee did not accomplish activities
in accordance with maintenance procedure requirements. Specifically, the licensee did
not control failed plant equipment to determine whether the component should be tested
to establish the cause of failure before it was scrapped. The licensee discarded the
                                    - 21 -                                  Enclosure 2


    solenoid valve prior to performing any analysis to determine the cause or severity of the
These activities constitute completion of five post-maintenance testing inspection
    valves failure. Consequently, the licensee assumed that the valve was unable to fulfill
samples, as defined in Inspection Procedure 71111.19-05.
    its safety function if called upon after a tornado-generated missile strike on dry cooling
b. Findings
    tower train B. The licensee entered this condition into their corrective action program
.1 Failure to Control Failed Equipment Removed from the Plant in Accordance with Procedure Requirements
    as Condition Reports CR-WF3-2012-05991, CR-WF3-2012-06288, and
  Introduction.  The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," because the licensee did not control and determine the extent of leaking safety-related bypass valve associated with the dry cooling tower B component cooling water solenoid valve  
    CR-WF3-2013-04047 for resolution. Although corrective actions are on-going, the
(CC-134B) after maintenance personnel removed the degraded equipment from service
    immediate corrective action taken to restore compliance included replacing the leaking
as required by Section 5.10 of EN-MA-101.
    valve and to brief personnel about the potential problems regarding combining
 
    preventative and corrective maintenance tasks in one work order.
    Because this violation was of very low safety significance and the licensee entered the
Description.  On October 31, 2012, the licensee conducted a post-maintenance leak test on the actuator for a safety-related air operate solenoid valve CC-134B.  During the process of conducting the leak test, maintenance personnel identified air coming from
    issue into their corrective action program, this violation was treated as a non-cited
the exhaust vent port of a solenoid valve associated with the operation of CC-134B.  The
    violation, consistent with Section 2.3.2.a of the Enforcement Policy:
licensee replaced the valve on November 1, 2012, and restored valve CC-134B to an
    NCV 05000382/2013004-03, Failure to Accomplish Activities Affecting Quality on a
operable status.  However, the licensee did not retain the original solenoid valve for testing to determine the cause or extent of the leakage. Without supporting information regarding the leak rate or cause, the licensee assumed that CC-134B and its air
    Degraded Safety-Related Solenoid Valve In Accordance With Procedure Requirements.
accumulator were inoperable from October 20, 2011, the dates of the last satisfactory
1R22 Surveillance Testing (71111.22)
leak test, until November 1, 2012, when maintenance personnel replaced the valve. 
  a. Inspection Scope
 
    The inspectors selected risk-significant surveillance activities based on risk information
The licensee initiated a condition report and performed an apparent cause evaluation.  The inspectors performed a review of the apparent cause evaluation, the event timeline,
    and reviewed the final safety analysis report, procedure requirements, and technical
work orders, and maintenance history of valve CC-134B.  The licensee determined that
    specifications to ensure that the surveillance activities listed below demonstrated that the
the valve leakage could have adversely affected the backup air accumulator inventory. 
    systems, structures, and/or components tested were capable of performing their
However, the licensee did not retain the leaking valve to perform any testing.  As a
    intended safety functions. The inspectors either witnessed or reviewed test data to
result, the licensee could not characterize and determine the cause of the leakage for the safety-related valve.  The inspectors determined that the licensee did not accomplish 
    verify that the significant surveillance test attributes were adequate to address the
- 19 -  Enclosure 2
    following:
activities in accordance with maintenance procedure EN-MA-101, "Fundamentals of Maintenance".  Section 5.10, Control of Failed Plant Equipment, of EN-MA-101,
          *  Preconditioning
requires, in part, that the licensee control failed equipment removed from the plant to determine necessary testing to establish the cause of the failure. 
          *   Evaluation of testing impact on the plant
          *  Acceptance criteria
As a part of the review of the apparent cause evaluation, the inspectors also noted that
          *  Test equipment
an incomplete work order contributed to discarding the solenoid valve prior to testing. 
          *  Procedures
The licensee combined a corrective maintenance with a preventative maintenance task
          *   Jumper/lifted lead controls
into the existing work order for CC-134B during the replacement of the solenoid valve.  This led to an error-trap, as explicit instructions for retaining failed parts were not a part
          *  Test data
of the preventative maintenance tasks. The immediate corrective actions taken to restore compliance included the installation of a new valve and debriefing personnel
          *  Testing frequency and method demonstrated technical specification operability
about controlling equipment removed from service when combining preventative and
          *   Test equipment removal
corrective maintenance tasks in one work order.  The licensee entered this condition into their corrective action program as Condition Reports CR-WF3-2012-05991 and  CR-WF3-2012-06288. However, inspectors questioned the effectiveness of the original
          *  Restoration of plant systems
corrective action by the licensee to have personnel briefed on the effects of combining  
                                          - 22 -                                 Enclosure 2
preventative and corrective maintenance tasks in a work order. The inspectors felt that
a briefing did not provide an adequate barrier to prevent this from happening again.  As a result, the licensee initiated CR-HQN-2013-00709 and CR-WF3-2013-04047 to determine additional corrective actions to address the error trap.  The inspectors
determined that the licensee did not appropriately coordinate work activities by
incorporating actions to address the impact of changes to work scope on the plant and
 
human performance.  
 
Analysis. The failure to control failed equipment removed from the plant to determine the cause was a performance deficiency.  The inspectors determined that this deficiency
was reasonably within the licensee's ability to foresee and correct.  The performance
deficiency was more than minor because it was associated with the equipment
performance attribute of the Mitigating System Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.  Specifically, the
degraded condition challenged the safety function of valve CC-134B to limit the loss of component cooling water through damaged portions of the dry cooling towers following a  
tornado-generated missile strike.  
 
The inspectors used NRC Inspection Manual Chapter 0609, Attachment 4, "Initial Characterization of Findings," and Appendix A, "The Significance Determination Process
(SDP) for Findings At-Power," to evaluate this issue.  The inspectors determined that the
finding required a detailed analysis because it was potentially risk significant for an
external event (tornado) based on using
Exhibit 4, "External Events Screening Questions".  Therefore, the senior reactor analyst performed the following bounding
detailed risk evaluation:
 
Tornado Statistics: About one out of every three tornadoes (29 percent) is classified as "strong." Strong tornadoes have an average path length of 9 miles and a path width of 200 yards (approximately 1 square mile of land affected).  Although very rare 
- 20 -  Enclosure 2
(about 2 percent are violent), violent tornadoes can last for hours.  Average path lengths and widths are 26 miles and 425 yards, respectively. 
Since the strong tornadoes can affect approximately 1 square mile, weaker tornadoes, on average, would affect significantly less than 1 square mile.  Most tornadoes are of the weaker variety.  Violent tornadoes can affect approximately 6 to 7 square miles (on average), but are relatively rare.  Therefore, the analyst assumed that the average tornado would affect 1 square mile of land. 
The average number of tornadoes in Louisiana per year was 27. 
The total area for the state of Louisiana was 51,840 square miles. 
Plant Area:  For this risk evaluation, the analyst assumed that the Waterford-3 nuclear island and switchyard occupied one square mile of land.  This was conservative, in that this equipment occupies less than one square mile.  
 
The analyst conservatively assumed that a tornado within a 1 square mile area would
cause a loss of offsite power and cause physical damage to the train B dry cooling tower train.  This in turn would cause the B component cooling water train to fail.  Because the dry cooling towers are at least partially protected from missiles by the surrounding
building, this is a very conservative assumption.  Not all tornadoes will result in
 
damaging this equipment.
 
    
Tornado Frequency:  The frequency of a tornado hitting the Waterford-3 nuclear island
and switchyard was therefore:
   = 27 tornadoes/year / 51840 sq miles = 5.2E-4/yr.
Calculations: 
The analyst used the NRC's Waterford-3 Standardized Plant Analysis Risk (SPAR) model, Revision 8.16, with a truncation limit of E-11, to evaluate this finding.  The analyst assumed a full year exposure period.    
 
The analyst calculated the incremental conditional core damage probability (ICCDP)
considering a loss of offsite power (LOOP) coincident with the failure of the train B
component cooling water system.  To account for an earlier finding at Waterford-3, the analyst set the basic event for alternate room cooling to 1.0.  The analyst used this adjustment in both the nominal case (no performance deficiency) and the current case
(with the performance deficiency).  In addition, for both cases the analyst set the basic
event for a LOOP to 1.0.  The analyst solved only the LOOP sequences.  The nominal
case CCDP was 2.15E-4.
For the current case calculation, the analyst additionally set the basic events for the 
B and AB (swing) motor driven component cooling water pumps to 1.0.  The resultant
CCDP was 5.9E-3.


 
        *  Fulfillment of ASME Code requirements
- 21 -  Enclosure 2
        *   Updating of performance indicator data
The initial ICCDP was therefore the difference between the nominal and current case CCDPs = 5.7E-3.
        *   Engineering evaluations, root causes, and bases for returning tested systems,
 
            structures, and components not meeting the test acceptance criteria were correct
The analyst considered recovery of the instrument air system.  As noted in Licensee Event Report 2012-007, dated December 31, 2012, operators could recover an
        *   Reference setting data
instrument air compressor and power the unit from an operable running emergency
        *   Annunciators and alarms setpoints
diesel generator.  The resident inspectors had reviewed these procedures and estimated
    The inspectors also verified that licensee personnel identified and implemented any
that it may take 2.0 hours to perform this action.  The analyst assumed a non-recovery
    needed corrective actions associated with the surveillance testing.
probability of 0.1 for this action.  The nominal non-recovery probability as specified in NUREG/CR-6883, "The SPAR-H Human Reliability Analysis Method," was 1.1E-2.  Therefore, 0.1 was conservative when compared to 1.1E-2.  The resultant ICCDP,
        *   On August 6, 2013, surveillance test on containment vacuum relief train A control
considering recovery, was 5.7E-4.
            valve CVR-201A (in-service test)
 
        *   On August 19, 2013, surveillance test on auxiliary component cooling water
            pump B (in-service test)
The change to the core damage frequency (delta CDF) was the tornado frequency multiplied by the ICCDP = 5.2E-4/yr * 5.7E-4 = 2.9E-7/yr.
        *   On August 22, 2013, surveillance test on containment cooling fans
        *   On August 28, 2013, surveillance test on low pressure safety injection pump A
The dominant core damage sequences included tornado induced losses of offsite power,
        *   On September 9, 2013, surveillance test on component cooling water pump A/B
failure of the dry cooling tower pressure boundary, failure to isolate the damaged dry
    Specific documents reviewed during this inspection are listed in the attachment.
cooling tower, and failure to recovery instrument air.  The redundant train A component cooling water system combined with the tornado frequency helped to reduce the risk
    These activities constitute completion of five surveillance testing inspection samples, as
exposure.
    defined in Inspection Procedure 71111.22-05.
 
Large Early Release Frequency (LERF):  To address the contribution to conditional large early release frequency, the analyst used NRC Inspection Manual Chapter 0609,
Appendix H, "Containment Integrity Significance Determination Process," dated May 6, 2004.  The finding was not significant to LERF because it did not directly affect the steam generator tube rupture or the intersystem loss of coolant accident sequences.
 
The inspectors concluded that the finding reflected current licensee performance and
involved a cross-cutting aspect in the work control component of the human performance area in that the licensee did not appropriately coordinate work activities by incorporating actions to address the impact changes to work scope or activity on plant
 
and human performance [H.3(b)].
 
Enforcement.  Title 10 of CFR, Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions,
procedures, or drawings.  Specifically, Section 5.10, "Control of Failed Plant Equipment"
of maintenance procedure EN-MA-101, "Fundamentals of Maintenance," requires, in
part, that it be determined "whether the component should be tested to establish cause of failure before it is scrapped."
Contrary to the above, on November 1, 2012, the licensee did not accomplish activities
in accordance with maintenance procedure requirements.  Specifically, the licensee did
not control failed plant equipment to determine whether the component should be tested
to establish the cause of failure before it was scrapped.  The licensee discarded the 
- 22 -  Enclosure 2
solenoid valve prior to performing any analysis to determine the cause or severity of the
valve's failure.  Consequently, the licensee assumed that the valve was unable to fulfill its safety function if called upon after a tornado-generated missile strike on dry cooling tower train B.  The licensee entered this condition into their corrective action program as Condition Reports CR-WF3-2012-05991, CR-WF3-2012-06288, and 
CR-WF3-2013-04047 for resolution.  Although corrective actions are on-going, the
immediate corrective action taken to restore compliance included replacing the leaking
valve and to brief personnel about the potential problems regarding combining
preventative and corrective maintenance tasks in one work order. 
Because this violation was of very low safety significance and the licensee entered the
issue into their corrective action program, this violation was treated as a non-cited
violation, consistent with Section 2.3.2.a of the Enforcement Policy: 
NCV 05000382/2013004-03, "Failure to Accomplish Activities Affecting Quality on a Degraded Safety-Related Solenoid Valve In Accordance With Procedure Requirements."
1R22 Surveillance Testing (71111.22) a. Inspection Scope
 
The inspectors selected risk-significant surveillance activities based on risk information
and reviewed the final safety analysis report, procedure requirements, and technical specifications to ensure that the surveillance activities listed below demonstrated that the systems, structures, and/or components tested were capable of performing their
intended safety functions.  The inspectors either witnessed or reviewed test data to
verify that the significant surveillance test attributes were adequate to address the
following: 
 
* Preconditioning
* Evaluation of testing impact on the plant
* Acceptance criteria
* Test equipment
* Procedures
* Jumper/lifted lead controls
* Test data
* Testing frequency and method demonstrated technical specification operability
* Test equipment removal
* Restoration of plant systems 
- 23 -  Enclosure 2
   * Fulfillment of ASME Code requirements  
* Updating of performance indicator data  
* Engineering evaluations, root causes, and bases for returning tested systems, structures, and components not meeting the test acceptance criteria were correct  
* Reference setting data  
* Annunciators and alarms setpoints  
The inspectors also verified that licensee personnel identified and implemented any needed corrective actions associated with the surveillance testing.
* On August 6, 2013, surveillance test on containment vacuum relief train A control valve CVR-201A (in-service test)  
* On August 19, 2013, surveillance test on auxiliary component cooling water pump B (in-service test)  
* On August 22, 2013, surveillance test on containment cooling fans  
* On August 28, 2013, surveillance test on low pressure safety injection pump A  
* On September 9, 2013, surveillance test on component cooling water pump A/B  
Specific documents reviewed during this inspection are listed in the attachment.  
These activities constitute completion of five surveillance testing inspection samples, as  
defined in Inspection Procedure 71111.22-05.
b. Findings
No findings were identified. 
Cornerstone:  Emergency Preparedness 1EP6 Drill Evaluation (71114.06)  Training Observations
a. Inspection Scope
The inspectors observed a simulator training evolution for licensed operators on  July 22, 2013, this required emergency plan implementation by a licensee operations crew.  This evolution was planned to be evaluated and included in performance indicator 
- 24 -  Enclosure 2
data regarding drill and exercise performance.  The inspectors observed event classification and notification activities performed by the crew.  The inspectors also
attended the post evolution critique for the scenario.  The focus of the inspectors' activities was to note any weaknesses and deficiencies in the crew's performance and ensure that the licensee evaluators noted the same issues and entered them into the
corrective action program.  As part of the inspection, the inspectors reviewed the
scenario package and other documents listed in the attachment. 
 
These activities constitute completion of one training observation sample, as defined in Inspection Procedure 71114.06-05.
   b. Findings
   b. Findings
No findings were identified.  
    No findings were identified.
    Cornerstone: Emergency Preparedness
2. RADIATION SAFETY Cornerstone: Public Radiation Safety and Occupational Radiation Safety 2RS01 Radiological Hazard Assessment and Exposure Controls (71124.01) a. Inspection Scope
1EP6 Drill Evaluation (71114.06)
 
    Training Observations
This area was inspected to:  (1) review and assess licensee's performance in assessing
  a. Inspection Scope
the radiological hazards in the workplace associated with licensed activities and the implementation of appropriate radiation monitoring and exposure control measures for both individual and collective exposures, (2) verify the licensee is properly identifying
    The inspectors observed a simulator training evolution for licensed operators on
and reporting Occupational Radiation Safety Cornerstone performance indicators, and
    July 22, 2013, this required emergency plan implementation by a licensee operations
(3) identify those performance deficiencies that were reportable as a performance
    crew. This evolution was planned to be evaluated and included in performance indicator
indicator and which may have represented a substantial potential for overexposure of the worker. The inspectors used the requirements in 10 CFR Part 20, the technical specifications, and the licensee's procedures required by technical specifications as criteria for determining compliance.  During the inspection, the inspectors interviewed the radiation protection manager, radiation protection supervisors, and radiation workers.  The
                                        - 23 -                                   Enclosure 2
inspectors performed walkdowns of various portions of the plant, performed independent radiation dose rate measurements and reviewed the following items:
* Performance indicator events and associated documentation reported by the licensee in the Occupational Radiation Safety Cornerstone
* The hazard assessment program, including a review of the licensee's evaluations of changes in plant operations and radiological surveys to detect dose rates, airborne radioactivity, and surface contamination levels
 
- 25 -  Enclosure 2
* Instructions and notices to workers, including labeling or marking containers of radioactive material, radiation work permits, actions for electronic dosimeter alarms, and changes to radiological conditions
* Programs and processes for control of sealed sources and release of potentially contaminated material from the radiologically controlled area, including survey performance, instrument sensitivity, release criteria, procedural guidance, and sealed source accountability
* Radiological hazards control and work coverage, including the adequacy of surveys, radiation protection job coverage, and contamination controls; the use of electronic dosimeters in high noise areas; dosimetry placement; airborne
radioactivity monitoring; controls for highly activated or contaminated materials
(non-fuel) stored within spent fuel and other storage pools; and posting and physical controls for high radiation areas and very high radiation areas
* Radiation worker and radiation protection technician performance with respect to radiation protection work requirements
* Emergency contingencies in place during the steam generator replacement activities 
* Project staffing and training plans for t
he previous steam generator replacement activities 
* Audits, self-assessments, and corrective action documents related to radiological hazard assessment and exposure controls
since the last inspection
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of the one required sample as defined in
Inspection Procedure 71124.01-05.
b. Findings
  No findings were identified. 2RS02 Occupational ALARA Planning and Controls (71124.02) a. Inspection Scope
  This area was inspected to assess performance with respect to maintaining occupational
individual and collective radiation exposures as low as is reasonably achievable (ALARA).  The inspectors used the requirements in 10 CFR Part 20, the technical specifications, and the licensee's procedures required by technical specifications as criteria for determining compliance.  During the inspection, the inspectors interviewed licensee personnel and reviewed the following items: 
- 26 - Enclosure 2  
* Site-specific ALARA procedures and collective exposure history, including the current 3-year rolling average, site-specific trends in collective exposures, and source-term measurements


* ALARA work activity evaluations/post job reviews, exposure estimates, and exposure mitigation requirements 
      data regarding drill and exercise performance. The inspectors observed event
* The methodology for estimating work activity exposures, the intended dose outcome, the accuracy of dose rate and man-hour estimates, and intended versus actual work activity doses and the reasons for any inconsistencies 
      classification and notification activities performed by the crew. The inspectors also
* Records detailing the historical trends and current status of tracked plant source terms and contingency plans for expected changes in the source term due to changes in plant fuel performance issues or changes in plant primary chemistry
      attended the post evolution critique for the scenario. The focus of the inspectors
* Radiation worker and radiation protection technician performance during work activities in radiation areas, airborne radioactivity areas, or high radiation areas
      activities was to note any weaknesses and deficiencies in the crews performance and
* Audits, self-assessments, and corrective action documents related to ALARA planning and controls since the last inspection  
      ensure that the licensee evaluators noted the same issues and entered them into the
Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.02-05. b. Findings
      corrective action program. As part of the inspection, the inspectors reviewed the
  No findings were identified. 2RS05 Radiation Monitoring Instrumentation (71124.05) a. Inspection Scope
      scenario package and other documents listed in the attachment.
  This area was inspected to verify the licensee is assuring the accuracy and operability of  
      These activities constitute completion of one training observation sample, as defined in
radiation monitoring instruments that are used to:  (1) monitor areas, materials, and  
      Inspection Procedure 71114.06-05.
workers to ensure a radiologically safe work environment; and (2) detect and quantify radioactive process streams and effluent releases. The inspectors used the requirements in 10 CFR Part 20, the technical specifications, and the licensee's
  b. Findings
procedures required by technical specifications as criteria for determining compliance.
      No findings were identified.
During the inspection, the inspectors interviewed licensee personnel, performed walkdowns of various portions of the plant, and reviewed the following items:  
2.    RADIATION SAFETY
* Selected plant configurations and alignments of process, postaccident, and effluent monitors with descriptions in the Final Safety Analysis Report and the offsite dose calculation manual 
      Cornerstone: Public Radiation Safety and Occupational Radiation Safety
 
2RS01 Radiological Hazard Assessment and Exposure Controls (71124.01)
- 27 -  Enclosure 2
  a. Inspection Scope
* Select instrumentation, including effluent monitoring instrument, portable survey instruments, area radiation monitors, continuous air monitors, personnel
      This area was inspected to: (1) review and assess licensees performance in assessing
contamination monitors, portal monitors, and small article monitors to examine their configurations and source checks
      the radiological hazards in the workplace associated with licensed activities and the
* Calibration and testing of process and effluent monitors, laboratory instrumentation, whole body counters, postaccident monitoring instrumentation, portal monitors, personnel contaminati
      implementation of appropriate radiation monitoring and exposure control measures for
on monitors, small article monitors, portable survey instruments, area radiation monitors, electronic dosimetry, air
      both individual and collective exposures, (2) verify the licensee is properly identifying
      and reporting Occupational Radiation Safety Cornerstone performance indicators, and
      (3) identify those performance deficiencies that were reportable as a performance
      indicator and which may have represented a substantial potential for overexposure of
      the worker.
      The inspectors used the requirements in 10 CFR Part 20, the technical specifications,
      and the licensees procedures required by technical specifications as criteria for
      determining compliance. During the inspection, the inspectors interviewed the radiation
      protection manager, radiation protection supervisors, and radiation workers. The
      inspectors performed walkdowns of various portions of the plant, performed independent
      radiation dose rate measurements and reviewed the following items:
      *       Performance indicator events and associated documentation reported by the
              licensee in the Occupational Radiation Safety Cornerstone
      *       The hazard assessment program, including a review of the licensees evaluations
              of changes in plant operations and radiological surveys to detect dose rates,
              airborne radioactivity, and surface contamination levels
                                          - 24 -                                  Enclosure 2


samplers, continuous air monitors
      *        Instructions and notices to workers, including labeling or marking containers of
* Audits, self-assessments, and corrective action documents related to radiation
              radioactive material, radiation work permits, actions for electronic dosimeter
monitoring instrumentation
              alarms, and changes to radiological conditions
since the last inspection
      *        Programs and processes for control of sealed sources and release of potentially
Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.05-05.  
              contaminated material from the radiologically controlled area, including survey
b. Findings
              performance, instrument sensitivity, release criteria, procedural guidance, and
 
              sealed source accountability
No findings were identified.  
      *        Radiological hazards control and work coverage, including the adequacy of
              surveys, radiation protection job coverage, and contamination controls; the use of
              electronic dosimeters in high noise areas; dosimetry placement; airborne
              radioactivity monitoring; controls for highly activated or contaminated materials
              (non-fuel) stored within spent fuel and other storage pools; and posting and
              physical controls for high radiation areas and very high radiation areas
      *        Radiation worker and radiation protection technician performance with respect to
              radiation protection work requirements
      *        Emergency contingencies in place during the steam generator replacement
              activities
      *        Project staffing and training plans for the previous steam generator replacement
              activities
      *       Audits, self-assessments, and corrective action documents related to radiological
              hazard assessment and exposure controls since the last inspection
      Specific documents reviewed during this inspection are listed in the attachment.
      These activities constitute completion of the one required sample as defined in
      Inspection Procedure 71124.01-05.
  b. Findings
      No findings were identified.
2RS02 Occupational ALARA Planning and Controls (71124.02)
  a.  Inspection Scope
      This area was inspected to assess performance with respect to maintaining occupational
      individual and collective radiation exposures as low as is reasonably achievable
      (ALARA). The inspectors used the requirements in 10 CFR Part 20, the technical
      specifications, and the licensees procedures required by technical specifications as
      criteria for determining compliance. During the inspection, the inspectors interviewed
      licensee personnel and reviewed the following items:
                                          - 25 -                                  Enclosure 2


  2RS06 Radioactive Gaseous and Liquid Effluent Treatment (71124.06) a. Inspection Scope
      *      Site-specific ALARA procedures and collective exposure history, including the
  This area was inspected to: (1) ensure the gaseous and liquid effluent processing
              current 3-year rolling average, site-specific trends in collective exposures, and
              source-term measurements
      *      ALARA work activity evaluations/post job reviews, exposure estimates, and
              exposure mitigation requirements
      *      The methodology for estimating work activity exposures, the intended dose
              outcome, the accuracy of dose rate and man-hour estimates, and intended
              versus actual work activity doses and the reasons for any inconsistencies
      *      Records detailing the historical trends and current status of tracked plant source
              terms and contingency plans for expected changes in the source term due to
              changes in plant fuel performance issues or changes in plant primary chemistry
      *      Radiation worker and radiation protection technician performance during work
              activities in radiation areas, airborne radioactivity areas, or high radiation areas
      *      Audits, self-assessments, and corrective action documents related to ALARA
              planning and controls since the last inspection
      Specific documents reviewed during this inspection are listed in the attachment.
      These activities constitute completion of the one required sample as defined in
      Inspection Procedure 71124.02-05.
  b. Findings
      No findings were identified.
2RS05 Radiation Monitoring Instrumentation (71124.05)
  a. Inspection Scope
      This area was inspected to verify the licensee is assuring the accuracy and operability of
      radiation monitoring instruments that are used to: (1) monitor areas, materials, and
      workers to ensure a radiologically safe work environment; and (2) detect and quantify
      radioactive process streams and effluent releases. The inspectors used the
      requirements in 10 CFR Part 20, the technical specifications, and the licensees
      procedures required by technical specifications as criteria for determining compliance.
      During the inspection, the inspectors interviewed licensee personnel, performed
      walkdowns of various portions of the plant, and reviewed the following items:
      *      Selected plant configurations and alignments of process, postaccident, and
              effluent monitors with descriptions in the Final Safety Analysis Report and the
              offsite dose calculation manual
                                          - 26 -                                    Enclosure 2


systems are maintained so radiological discharges are properly mitigated, monitored, and evaluated with respect to public exposure; (2) ensure abnormal radioactive gaseous  
      *        Select instrumentation, including effluent monitoring instrument, portable survey
or liquid discharges and conditions, when effluent radiation monitors are out-of-service, are controlled in accordance with the applicable regulatory requirements and licensee procedures; (3) verify the licensee's quality control program ensures the radioactive  
              instruments, area radiation monitors, continuous air monitors, personnel
effluent sampling and analysis requirements are satisfied so discharges of radioactive  
              contamination monitors, portal monitors, and small article monitors to examine
materials are adequately quantified and evaluated; and (4) verify the adequacy of public  
              their configurations and source checks
dose projections resulting from radioactive effluent discharges. The inspectors used the requirements in 10 CFR Part 20; 10 CFR Part 50, Appendices A and I; 40 CFR Part 190; the Offsite Dose Calculation Manual, and licensee procedures required by the Technical  
      *        Calibration and testing of process and effluent monitors, laboratory
Specifications as criteria for determining compliance. The inspectors interviewed licensee personnel and reviewed and/or observed the following items:  
              instrumentation, whole body counters, postaccident monitoring instrumentation,
              portal monitors, personnel contamination monitors, small article monitors,
              portable survey instruments, area radiation monitors, electronic dosimetry, air
              samplers, continuous air monitors
      *      Audits, self-assessments, and corrective action documents related to radiation
              monitoring instrumentation since the last inspection
      Specific documents reviewed during this inspection are listed in the attachment.
      These activities constitute completion of the one required sample as defined in
      Inspection Procedure 71124.05-05.
  b.  Findings
      No findings were identified.
2RS06 Radioactive Gaseous and Liquid Effluent Treatment (71124.06)
  a.  Inspection Scope
      This area was inspected to: (1) ensure the gaseous and liquid effluent processing
      systems are maintained so radiological discharges are properly mitigated, monitored,
      and evaluated with respect to public exposure; (2) ensure abnormal radioactive gaseous
      or liquid discharges and conditions, when effluent radiation monitors are out-of-service,
      are controlled in accordance with the applicable regulatory requirements and licensee
      procedures; (3) verify the licensees quality control program ensures the radioactive
      effluent sampling and analysis requirements are satisfied so discharges of radioactive
      materials are adequately quantified and evaluated; and (4) verify the adequacy of public
      dose projections resulting from radioactive effluent discharges. The inspectors used the
      requirements in 10 CFR Part 20; 10 CFR Part 50, Appendices A and I; 40 CFR Part 190;
      the Offsite Dose Calculation Manual, and licensee procedures required by the Technical
      Specifications as criteria for determining compliance. The inspectors interviewed
      licensee personnel and reviewed and/or observed the following items:
      *        Radiological effluent release reports since the previous inspection and reports
              related to the effluent program issued since the previous inspection, if any
      *        Effluent program implementing procedures, including sampling, monitor setpoint
              determinations and dose calculations
                                          - 27 -                                Enclosure 2


* Radiological effluent release reports since the previous inspection and reports related to the effluent program issued since the previous inspection, if any
* Equipment configuration and flow paths of selected gaseous and liquid discharge
* Effluent program implementing procedures, including sampling, monitor setpoint determinations and dose calculations
  system components, filtered ventilation system material condition, and significant
 
  changes to their effluent release points, if any, and associated 10 CFR 50.59
- 28 -  Enclosure 2
  reviews
* Equipment configuration and flow paths of selected gaseous and liquid discharge system components, filtered ventilation system material condition, and significant changes to their effluent release points, if any, and associated 10 CFR 50.59  
* Selected portions of the routine processing and discharge of radioactive gaseous
  and liquid effluents (including sample collection and analysis)
* Controls used to ensure representative sampling and appropriate compensatory
  sampling
* Results of the inter-laboratory comparison program
* Effluent stack flow rates
* Surveillance test results of technical specification-required ventilation effluent
  discharge systems since the previous inspection
* Significant changes in reported dose values, if any
* A selection of radioactive liquid and gaseous waste discharge permits
* Part 61 analyses and methods used to determine which isotopes are included in
  the source term
* Offsite dose calculation manual changes, if any
* Meteorological dispersion and deposition factors
* Latest land use census
* Records of abnormal gaseous or liquid tank discharges, if any
* Groundwater monitoring results
* Changes to the licensees written program for indentifying and controlling
  contaminated spills/leaks to groundwater, if any
* Identified leakage or spill events and entries made into 10 CFR 50.75 (g)
  records, if any, and associated evaluations of the extent of the contamination and
  the radiological source term
* Offsite notifications, and reports of events associated with spills, leaks, or
  groundwater monitoring results, if any
                              - 28 -                                    Enclosure 2


reviews  * Selected portions of the routine processing and discharge of radioactive gaseous and liquid effluents (including sample collection and analysis)  
      *     Audits, self-assessments, reports, and corrective action documents related to
  * Controls used to ensure representative sampling and appropriate compensatory
              radioactive gaseous and liquid effluent treatment since the last inspection
sampling 
      Specific documents reviewed during this inspection are listed in the attachment.
* Results of the inter-laboratory comparison program  
      These activities constitute completion of the one required sample, as defined in
* Effluent stack flow rates 
      Inspection Procedure 71124.06-05.
* Surveillance test results of technical specification-required ventilation effluent discharge systems  since the previous inspection
  b.  Findings
* Significant changes in reported dose values, if any
      No findings were identified.
* A selection of radioactive liquid and gaseous waste discharge permits 
2RS07 Radiological Environmental Monitoring Program (71124.07)
* Part 61 analyses and methods used to determine which isotopes are included in the source term 
  a. Inspection Scope
* Offsite dose calculation manual changes, if any
      This area was inspected to: (1) ensure that the radiological environmental monitoring
* Meteorological dispersion and deposition factors 
      program verifies the impact of radioactive effluent releases to the environment and
* Latest land use census 
      sufficiently validates the integrity of the radioactive gaseous and liquid effluent release
* Records of abnormal gaseous or liquid tank discharges, if any
      program; (2) verify that the radiological environmental monitoring program is
* Groundwater monitoring results
      implemented consistent with the licensees technical specifications and/or offsite dose
* Changes to the licensee's written program for indentifying and controlling contaminated spills/leaks to groundwater, if any
      calculation manual, and to validate that the radioactive effluent release program meets
* Identified leakage or spill events and entries made into 10 CFR 50.75 (g) records, if any, and associated evaluations of the extent of the contamination and the radiological source term
      the design objective contained in Appendix I to 10 CFR Part 50; and (3) ensure that the
      radiological environmental monitoring program monitors non-effluent exposure
      pathways, is based on sound principles and assumptions, and validates that doses to
      members of the public are within the dose limits of 10 CFR Part 20 and
      40 CFR Part 190, as applicable. The inspectors reviewed and/or observed the following
      items:
      *       Annual environmental monitoring reports and offsite dose calculation manual
      *       Selected air sampling and thermoluminescence dosimeter monitoring stations
      *       Collection and preparation of environmental samples
              Operability, calibration, and maintenance of meteorological instruments
      *       Selected events documented in the annual environmental monitoring report
              which involved a missed sample, inoperable sampler, lost thermo luminescence
              dosimeter, or anomalous measurement
      *       Selected structures, systems, or components that may contain licensed material
              and has a credible mechanism for licensed material to reach ground water
      *       Records required by 10 CFR 50.75(g)
                                          - 29 -                                    Enclosure 2


* Offsite notifications
    *     Significant changes made by the licensee to the offsite dose calculation manual
, and reports of events associated with spills, leaks, or
            as the result of changes to the land census or sampler station modifications since
groundwater monitoring results, if any
            the last inspection
 
    *     Calibration and maintenance records for selected air samplers and
- 29 -  Enclosure 2
            environmental sample radiation measurement instrumentation
* Audits, self-assessments, reports, and corrective action documents related to radioactive gaseous and liquid effluent treatment
    *     Inter-laboratory comparison program results
since the last inspection 
    *     Audits, self-assessments, reports, and corrective action documents related to the
Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of the one required sample, as defined in Inspection Procedure 71124.06-05.  b. Findings
            radiological environmental monitoring program since the last inspection
  No findings were identified.  2RS07 Radiological Environmental Monitoring Program (71124.07) a. Inspection Scope
    Specific documents reviewed during this inspection are listed in the attachment.
  This area was inspected to:  (1) ensure that the radiological environmental monitoring program verifies the impact of radioactive effluent releases to the environment and sufficiently validates the integrity of the radioactive gaseous and liquid effluent release
    These activities constitute completion of the one required sample as defined in
program; (2) verify that the radiological environmental monitoring program is implemented consistent with the licensee's technical specifications and/or offsite dose
    Inspection Procedure 71124.07-05.
calculation manual, and to validate that the radioactive effluent release program meets the design objective contained in Appendix I to 10 CFR Part 50; and (3) ensure that the radiological environmental monitoring pr
ogram monitors non-effluent exposure pathways, is based on sound principles and assumptions, and validates that doses to
members of the public are within the dose limits of 10 CFR Part 20 and  40 CFR Part 190, as applicable.  The inspectors reviewed and/or observed the following
items: * Annual environmental monitoring reports and offsite dose calculation manual 
* Selected air sampling and thermoluminescence dosimeter monitoring stations
* Collection and preparation of environmental samples
Operability, calibration, and maintenance of meteorological instruments
* Selected events documented in the annual environmental monitoring report which involved a missed sample, inoperable sampler, lost thermo luminescence dosimeter, or anomalous measurement
* Selected structures, systems, or components that may contain licensed material and has a credible mechanism for licensed material to reach ground water
* Records required by 10 CFR 50.75(g) 
 
- 30 -  Enclosure 2
* Significant changes made by the licensee to the offsite dose calculation manual as the result of changes to the land census or sampler station modifications since the last inspection  
* Calibration and maintenance records for selected air samplers and environmental sample radiation measurement instrumentation  
* Inter-laboratory comparison program results  
* Audits, self-assessments, reports, and co
rrective action documents related to the radiological environmental monitoring program since the last inspection
Specific documents reviewed during this inspection are listed in the attachment.  
 
These activities constitute completion of the one required sample as defined in  
Inspection Procedure 71124.07-05.  
b. Findings
  No findings were identified.
2RS08 Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage, and Transportation (71124.08) a. Inspection Scope
  This area was inspected to verify the effectiveness of the licensee's programs for processing, handling, storage, and transportation of radioactive material.  The inspectors used the requirements of 10 CFR Parts 20, 61, and 71 and Department of
Transportation regulations contained in 49 CFR Parts 171-180 for determining
compliance. The inspectors interviewed licensee personnel and reviewed the following
items: * The solid radioactive waste system description, process control program, and the scope of the licensee's audit program
  * Control of radioactive waste storage areas including container labeling/marking and monitoring containers for deformation or signs of waste decomposition
  * Changes to the liquid and solid waste processing system configuration including a review of waste processing equipment that is not operational or abandoned in
place  * Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides
 
- 31 -  Enclosure 2
* Processes for waste classification including use of scaling factors and 10 CFR Part 61 analysis
  * Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and preparation of the disposal manifest
  * Audits, self-assessments, reports, and corrective action reports radioactive solid waste processing, and radioactive material handling, storage, and transportation
  performed since the last inspection
  Specific documents reviewed during this inspection are listed in the attachment.
  These activities constitute completion of the one required sample as defined in Inspection Procedure 71124.08-05. b. Findings
  No findings were identified. 
4. OTHER ACTIVITIES Cornerstones:  Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and
Security Protection 4OA1 Performance Indicator Verification (71151) .1 Data Submission Issue
a. Inspection Scope
The inspectors performed a review of the performance indicator data submitted by the licensee for the second Quarter 2013 performance indicators for any obvious
inconsistencies prior to its public release in accordance with Inspection Manual Chapter 0608, "Performance Indicator Program."
This review was performed as part of the inspectors' normal plant status activities and,
as such, did not constitute a separate inspection sample. 
b. Findings
No findings were identified. 
 
- 32 -  Enclosure 2
.2 Safety System Functional Failures (MS05)
a. Inspection Scope
The inspectors sampled licensee submittals for the safety system functional failures performance indicator for the period from the fourth quarter 2012 through the
 
second quarter 2013.  To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in
NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, and NUREG-1022, "Event Reporting Guidelines 10 CFR 50.72 and 50.73."  The inspectors reviewed the licensee's operator
narrative logs, operability assessments, maintenance rule records, maintenance work orders, issue reports, event reports, and
NRC integrated inspection reports for the period of October 2012
through September
2013 to validate the accuracy of the submittals.  The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none
were identified.  Specific documents reviewed are described in the attachment to this report.
 
These activities constitute completion of one safety system functional failures sample, as defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
.3 Mitigating Systems Performance Index - Residual Heat Removal System (MS09)
a. Inspection Scope
The inspectors sampled licensee submittals for the mitigating systems performance index - residual heat removal system performance indicator for the period from the third
quarter 2012 through the third quarter 2013.  To determine the accuracy of the
performance indicator data reported during those periods, the inspectors used definitions
and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6.  The inspectors reviewed the licensee's operator narrative logs, issue reports, mitigating
systems performance index derivation reports, event reports, and NRC integrated inspection reports for the period of July 2012
through September 2013 to validate the accuracy of the submittals.  The inspectors reviewed the
mitigating systems performance index component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance.  The inspectors also
reviewed the licensee's issue report database to determine if any problems had been
identified with the performance indicator data collected or transmitted for this indicator
and none were identified.  Specific documents reviewed are described in the attachment to this report.
These activities constitute completion of one mitigating systems performance index -
residual heat removal system sample, as defined in Inspection Procedure 71151-05. 
- 33 -  Enclosure 2
   b. Findings
   b. Findings
No findings were identified.  
    No findings were identified.
.4 Mitigating Systems Performance Index - Cooling Water Systems (MS10)
2RS08 Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage,
a. Inspection Scope
      and Transportation (71124.08)
The inspectors sampled licensee submittals for the mitigating systems performance
  a. Inspection Scope
index - cooling water systems performance indicator for the period from the third
    This area was inspected to verify the effectiveness of the licensees programs for
quarter 2012 through the third quarter 2013. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance
    processing, handling, storage, and transportation of radioactive material. The inspectors
Indicator Guideline," Revision 6. The inspectors reviewed the licensee's operator
    used the requirements of 10 CFR Parts 20, 61, and 71 and Department of
narrative logs, issue reports, mitigating
    Transportation regulations contained in 49 CFR Parts 171-180 for determining
systems performance index derivation reports, event reports, and NRC integrated inspection reports for the period of July 2012
    compliance. The inspectors interviewed licensee personnel and reviewed the following
through September 2013 to validate the accuracy of the submittals.  The inspectors reviewed the mitigating systems performance index component risk coefficient to determine if it had changed by more than 25 percent in value since the previous inspection, and if so, that  
    items:
the change was in accordance with applicable NEI guidance.  The inspectors also
    *      The solid radioactive waste system description, process control program, and the
reviewed the licensee's issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified.  Specific documents reviewed are described in the attachment
            scope of the licensees audit program
to this report.
    *      Control of radioactive waste storage areas including container labeling/marking
            and monitoring containers for deformation or signs of waste decomposition
    *      Changes to the liquid and solid waste processing system configuration including
            a review of waste processing equipment that is not operational or abandoned in
            place
    *      Radio-chemical sample analysis results for radioactive waste streams and use of
            scaling factors and calculations to account for difficult-to-measure radionuclides
                                      - 30 -                                  Enclosure 2


      *      Processes for waste classification including use of scaling factors and
These activities constitute completion of one mitigating systems performance index -
            10 CFR Part 61 analysis
cooling water system sample, as defined in Inspection Procedure 71151-05.
      *      Shipment packaging, surveying, labeling, marking, placarding, vehicle checking,
b. Findings
            driver instructing, and preparation of the disposal manifest
No findings were identified.
      *      Audits, self-assessments, reports, and corrective action reports radioactive solid
.5 Occupational Exposure Control Effectiveness (OR01)
            waste processing, and radioactive material handling, storage, and transportation
a. Inspection Scope
            performed since the last inspection
  Cornerstone:  Occupational Radiation Safety
      Specific documents reviewed during this inspection are listed in the attachment.
The inspectors reviewed performance indicator data for the fourth quarter 2012 through the third quarter 2013
      These activities constitute completion of the one required sample as defined in
.  The objective of the inspection was to determine the accuracy and completeness of the performance indicator data reported during these periods.  The inspectors used the definitions and clarifying notes contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6, as criteria for determining whether the licensee was in compliance.   
      Inspection Procedure 71124.08-05.
- 34 -  Enclosure 2
  b. Findings
The inspectors reviewed corrective action program records associated with high radiation area (greater than 1 rem/hr) and very high radiation area nonconformances. 
      No findings were identified.
The inspectors reviewed radiological, controlled area exit transactions greater than  100 mrem.  The inspectors also conducted walkdowns of high radiation areas (greater than 1 rem/hr) and very high radiation area entrances to determine the adequacy of the controls of these areas. These activities constitute completion of the occupational exposure control effectiveness sample as defined in Inspection Procedure 71151-05. b. Findings
4.   OTHER ACTIVITIES
  No findings were identified. .6 Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (PR01)
      Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency
a. Inspection Scope
      Preparedness, Public Radiation Safety, Occupational Radiation Safety, and
  Cornerstone:  Public Radiation Safety
      Security Protection
The inspectors reviewed performance indicator data for fourth quarter 2012 through the third quarter 2013. The objective of the inspection was to determine the accuracy and completeness of the performance indicator data reported during these periods.  The inspectors used the definitions and clarifying notes contained in NEI Document 99-02,  
4OA1 Performance Indicator Verification (71151)
"Regulatory Assessment Performance Indicator Guideline," Revision 6, as criteria for determining whether the licensee was in compliance.  The inspectors reviewed the licensee's corrective action program records and selected individual annual or special reports to identify potential occurrences such as
.1    Data Submission Issue
unmonitored, uncontrolled, or improperly calculated effluent releases that may have
  a. Inspection Scope
impacted offsite dose.  These activities constitute completion of the radiological effluent technical specifications/offsite dose calculation manual radiological effluent occurrences sample as defined in Inspection Procedure 71151-05. b. Findings
      The inspectors performed a review of the performance indicator data submitted by the
  No findings were identified. 4OA2 Problem Identification and Resolution (71152) .1 Routine Review of Identification and Resolution of Problems
      licensee for the second Quarter 2013 performance indicators for any obvious
a. Inspection Scope
      inconsistencies prior to its public release in accordance with Inspection Manual
As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities 
      Chapter 0608, Performance Indicator Program.
- 35 - Enclosure 2  
      This review was performed as part of the inspectors normal plant status activities and,
and plant status reviews to verify that they were being entered into the licensee's corrective action program at an appropriate threshold, that adequate attention was being
      as such, did not constitute a separate inspection sample.
given to timely corrective actions, and that adverse trends were identified and addressed.  The inspectors reviewed attributes that included the complete and accurate identification of the problem; the timely correction, commensurate with the safety
  b. Findings
significance; the evaluation and disposition of performance issues, generic implications,
      No findings were identified.
common causes, contributing factors, root causes, extent of condition reviews, and
                                          - 31 -                                 Enclosure 2
previous occurrences reviews; and the classification, prioritization, focus, and timeliness
of corrective actions.  Minor issues entered into the licensee's corrective action program because of the inspectors' observations are included in the attached list of documents reviewed.


.2    Safety System Functional Failures (MS05)
These routine reviews for the identification and resolution of problems did not constitute
  a. Inspection Scope
any additional inspection samples. Instead, by procedure, they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.  
      The inspectors sampled licensee submittals for the safety system functional failures
      performance indicator for the period from the fourth quarter 2012 through the
c. Findings
      second quarter 2013. To determine the accuracy of the performance indicator data
  No findings were identified.  
      reported during those periods, the inspectors used definitions and guidance contained in
.2 Daily Corrective Action Program Reviews
      NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,
a. Inspection Scope
      Revision 6, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73."
In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of
      The inspectors reviewed the licensees operator narrative logs, operability assessments,
items entered into the licensee's corrective action program. The inspectors  
      maintenance rule records, maintenance work orders, issue reports, event reports, and
accomplished this through review of the station's daily corrective action documents.  
      NRC integrated inspection reports for the period of October 2012 through September
      2013 to validate the accuracy of the submittals. The inspectors also reviewed the
      licensees issue report database to determine if any problems had been identified with
      the performance indicator data collected or transmitted for this indicator and none were
      identified. Specific documents reviewed are described in the attachment to this report.
      These activities constitute completion of one safety system functional failures sample, as
      defined in Inspection Procedure 71151-05.
  b. Findings
      No findings were identified.
.3    Mitigating Systems Performance Index - Residual Heat Removal System (MS09)
  a. Inspection Scope
      The inspectors sampled licensee submittals for the mitigating systems performance
      index - residual heat removal system performance indicator for the period from the third
      quarter 2012 through the third quarter 2013. To determine the accuracy of the
      performance indicator data reported during those periods, the inspectors used definitions
      and guidance contained in NEI Document 99-02, Regulatory Assessment Performance
      Indicator Guideline, Revision 6. The inspectors reviewed the licensees operator
      narrative logs, issue reports, mitigating systems performance index derivation reports,
      event reports, and NRC integrated inspection reports for the period of July 2012 through
      September 2013 to validate the accuracy of the submittals. The inspectors reviewed the
      mitigating systems performance index component risk coefficient to determine if it had
      changed by more than 25 percent in value since the previous inspection, and if so, that
      the change was in accordance with applicable NEI guidance. The inspectors also
      reviewed the licensees issue report database to determine if any problems had been
      identified with the performance indicator data collected or transmitted for this indicator
      and none were identified. Specific documents reviewed are described in the attachment
      to this report.
      These activities constitute completion of one mitigating systems performance index -
      residual heat removal system sample, as defined in Inspection Procedure 71151-05.
                                          - 32 -                                  Enclosure 2


  b. Findings
The inspectors performed these daily reviews as part of their daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.
      No findings were identified.
b. Findings
.4    Mitigating Systems Performance Index - Cooling Water Systems (MS10)
No findings were identified.  
  a. Inspection Scope
.3 In-depth Review of Operator Workarounds
      The inspectors sampled licensee submittals for the mitigating systems performance
a. Inspection Scope
      index - cooling water systems performance indicator for the period from the third quarter
On August 14, 2013, during a review of items entered in the licensee's corrective action program, the inspectors reviewed operator workarounds and burdens. The inspectors  
      2012 through the third quarter 2013. To determine the accuracy of the performance
considered the following during the review of the licensee's actions: (1) complete and accurate identification of problems in a timely manner; (2) evaluation and disposition of operability/reportability issues; (3) consideration of extent of condition, generic
      indicator data reported during those periods, the inspectors used definitions and
implications, common cause, and previous occurrences; (4) classification and
      guidance contained in NEI Document 99-02, Regulatory Assessment Performance
prioritization of the resolution of the problem; (5) identification of root and contributing 
      Indicator Guideline, Revision 6. The inspectors reviewed the licensees operator
- 36 - Enclosure 2  
      narrative logs, issue reports, mitigating systems performance index derivation reports,
causes of the problem; (6) identification of corrective actions; and (7) completion of corrective actions in a timely manner.
      event reports, and NRC integrated inspection reports for the period of July 2012 through
      September 2013 to validate the accuracy of the submittals. The inspectors reviewed the
      mitigating systems performance index component risk coefficient to determine if it had
      changed by more than 25 percent in value since the previous inspection, and if so, that
      the change was in accordance with applicable NEI guidance. The inspectors also
      reviewed the licensees issue report database to determine if any problems had been
      identified with the performance indicator data collected or transmitted for this indicator
      and none were identified. Specific documents reviewed are described in the attachment
      to this report.
      These activities constitute completion of one mitigating systems performance index -
      cooling water system sample, as defined in Inspection Procedure 71151-05.
  b. Findings
      No findings were identified.
.5    Occupational Exposure Control Effectiveness (OR01)
  a. Inspection Scope
      Cornerstone: Occupational Radiation Safety
      The inspectors reviewed performance indicator data for the fourth quarter 2012 through
      the third quarter 2013. The objective of the inspection was to determine the accuracy
      and completeness of the performance indicator data reported during these periods. The
      inspectors used the definitions and clarifying notes contained in NEI Document 99-02,
      Regulatory Assessment Performance Indicator Guideline, Revision 6, as criteria for
      determining whether the licensee was in compliance.
                                          - 33 -                                 Enclosure 2


These activities constitute completion of one in-depth problem identification and resolution sample as defined in Inspection Procedure 71152-05 b. Findings
      The inspectors reviewed corrective action program records associated with high
No findings were identified.  
      radiation area (greater than 1 rem/hr) and very high radiation area nonconformances.
4OA3 Follow-up of Events and Notices of Enforcement Discretion (71153)
      The inspectors reviewed radiological, controlled area exit transactions greater than
.1 (Closed) Licensee Event Report 05000382/2012-007-00, Inoperability Of A Safety Related Valve Due To Backup Air Accumulator Leakage
      100 mrem. The inspectors also conducted walkdowns of high radiation areas (greater
  On October 10, 2012, during refueling outage RFO-18, the licensee identified a dual
      than 1 rem/hr) and very high radiation area entrances to determine the adequacy of the
solenoid valve CC ISV0134B1/B2 associated with train B dry cooling tower component
      controls of these areas.
cooling water bypass valve CC-134B was leaking air through the solenoid valve exhaust
      These activities constitute completion of the occupational exposure control effectiveness
vent port.  Following replacement of the solenoid valve, the licensee discarded it without
      sample as defined in Inspection Procedure 71151-05.
determining the cause or rate of leakage.  The licensee determined on November 1, 2012, that the solenoid valve leakage could have adversely affected the backup air accumulator relied on to allow valve CC-134B to fulfill its safety function in the event that
  b. Findings
a tornado-generated missile damaged the train B dry cooling tower. The licensee
      No findings were identified.
concluded that the valve may have been inoperable since the last accumulator leak test
.6    Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual
because the rate of the leakage was unknown.  As part of the review of this event, the inspectors identified a Green non-cited violation 05000382/2013004-03, "Failure to accomplish activities affecting quality on a degraded safety-related solenoid valve in
      Radiological Effluent Occurrences (PR01)
accordance with procedure requirements."  The inspectors documented this violation of
  a. Inspection Scope
NRC requirements in Section 1R19 of this repor
      Cornerstone: Public Radiation Safety
t.  This licensee event report is closed.
      The inspectors reviewed performance indicator data for fourth quarter 2012 through the
4OA5 Other Activities .1 (Closed) Temporary Instruction 2515/185, "Follow-up on the Industry's Ground Water Protection Initiative"
      third quarter 2013. The objective of the inspection was to determine the accuracy and
a. Inspection Scope
      completeness of the performance indicator data reported during these periods. The
  The ground water protection program was inspected September 16-19, 2013, to
      inspectors used the definitions and clarifying notes contained in NEI Document 99-02,
determine whether the licensee had implemented the program elements which were found to be incomplete when previously reviewed during NRC Inspection Report
      Regulatory Assessment Performance Indicator Guideline, Revision 6, as criteria for
05000382/2012003.  Inspectors interviewed cognizant licensee personnel and performed walk-downs.  b. Findings
      determining whether the licensee was in compliance.
  The following element had been implement
      The inspectors reviewed the licensees corrective action program records and selected
ed since the previous review: 
      individual annual or special reports to identify potential occurrences such as
- 37 -  Enclosure 2
      unmonitored, uncontrolled, or improperly calculated effluent releases that may have
* Element 1.4.a - Establish written procedures outlining the decision making process for remediation of leaks and spills or other instances of inadvertent releases. The following element had not been implemented since the previous review and is documented in the corrective action document listed with the element:
      impacted offsite dose.
* Element 1.3.f - Establish a long-term program for preventative maintenance of ground water wells (CR-HQN-2013-00861).  This element lacked an implementing procedure or process.  Additionally, the appropriateness for
      These activities constitute completion of the radiological effluent technical
preventative maintenance in relation to the specific type of ground water wells
      specifications/offsite dose calculation manual radiological effluent occurrences sample
has yet to be determined.  .2 (Closed) Unresolved Item 05000382/2009010-01, "Failures to Evaluate Adverse Conditions for Reportability to the NRC"
      as defined in Inspection Procedure 71151-05.
  On October 19, 2009, the NRC completed a special inspection at the Waterford 3
  b. Findings
initiated in response to a series of failures of safety-related Agastat timing relays. During
      No findings were identified.
this inspection, the team identified two examples in which the licensee failed to adequately review a deviation observed in specific batches of relays to determine
4OA2 Problem Identification and Resolution (71152)
whether the deviations were required to be reported to the NRC. The first of these examples involved a number of relays from the same manufacturing lot (date code 9948) that, after being installed in the plant, were determined to be unreliable, thus deviating
.1    Routine Review of Identification and Resolution of Problems
from procurement requirements. The second of these examples involved several relays
  a. Inspection Scope
from a different manufacturing lot (date code 0835) that also did not conform to
      As part of the various baseline inspection procedures discussed in previous sections of
specifications; however, the deviation of the date code 0835 relays was discovered during bench testing prior to installation.  On November 5, 2009, the NRC issued inspection report 05000382/2009010, documenting an unresolved item pending a
      this report, the inspectors routinely reviewed issues during baseline inspection activities
determination of whether the licensee's failures to evaluate and report the deviations
                                          - 34 -                                  Enclosure 2
constituted violations of one or more of the reporting requirements contained in
10 CFR Part 21, 10 CFR 50.72, and 10 CFR 50.73.


The NRC has determined that these deviations in basic components were not evaluated in accordance with 10 CFR 21.21(a)(1).  Further, the NRC determined that had the  
      and plant status reviews to verify that they were being entered into the licensees
licensee evaluated the deviations, it would have concluded that the deviations
      corrective action program at an appropriate threshold, that adequate attention was being
constituted defects as defined in 10 CFR 21.3. Where Part 21 applies, such defects are
      given to timely corrective actions, and that adverse trends were identified and
required to be reported to the NRC in accordance with 10 CFR 21.21(d)(1).  
      addressed. The inspectors reviewed attributes that included the complete and accurate
The NRC is developing new guidance to clarify the reporting requirements of  
      identification of the problem; the timely correction, commensurate with the safety
10 CFR Part 21 including whether in-service failure of installed parts-those subject to the  
      significance; the evaluation and disposition of performance issues, generic implications,
reporting requirements in Part 50 (§§ 50.72 and 50.73)-are also subject to the evaluation
      common causes, contributing factors, root causes, extent of condition reviews, and
and reporting requirements of Part 21.  See Task Interface Agreement (TIA) 2010-003
      previous occurrences reviews; and the classification, prioritization, focus, and timeliness
(ML11319A134).  However, Part 21 evaluation and reporting criteria continue to apply to basic components that are not installed.  Therefore, section 4OA5.2 below documents a violation of 10 CFR Part 21 for only the date code 0835 relays, in which the deviations
      of corrective actions. Minor issues entered into the licensees corrective action program
were discovered prior to installation of the components.  No violation will be issued for
      because of the inspectors observations are included in the attached list of documents
the licensee's failure to evaluate the installed relays in accordance with Part 21
      reviewed.
      These routine reviews for the identification and resolution of problems did not constitute
      any additional inspection samples. Instead, by procedure, they were considered an
      integral part of the inspections performed during the quarter and documented in
      Section 1 of this report.
  c. Findings
      No findings were identified.
.2    Daily Corrective Action Program Reviews
  a. Inspection Scope
      In order to assist with the identification of repetitive equipment failures and specific
      human performance issues for follow-up, the inspectors performed a daily screening of
      items entered into the licensees corrective action program. The inspectors
      accomplished this through review of the stations daily corrective action documents.
      The inspectors performed these daily reviews as part of their daily plant status
      monitoring activities and, as such, did not constitute any separate inspection samples.
  b. Findings
      No findings were identified.
.3    In-depth Review of Operator Workarounds
  a. Inspection Scope
      On August 14, 2013, during a review of items entered in the licensees corrective action
      program, the inspectors reviewed operator workarounds and burdens. The inspectors
      considered the following during the review of the licensees actions: (1) complete and
      accurate identification of problems in a timely manner; (2) evaluation and disposition of
      operability/reportability issues; (3) consideration of extent of condition, generic
      implications, common cause, and previous occurrences; (4) classification and
      prioritization of the resolution of the problem; (5) identification of root and contributing
                                          - 35 -                                    Enclosure 2


requirements. 
      causes of the problem; (6) identification of corrective actions; and (7) completion of
- 38 -  Enclosure 2
      corrective actions in a timely manner.
  .3 Failures to perform evaluations and make a report as required by 10 CFR Part 21
      These activities constitute completion of one in-depth problem identification and
  Introduction.  The team identified a Severity Level IV violation of 10 CFR 21.21 that occurred when the licensee failed to complete an evaluation of a deviation in a basic component within 60 days of discovery.  
      resolution sample as defined in Inspection Procedure 71152-05
Description.  On October 14, 2008, while replacing a failed Agastat E7024PB relay, maintenance personnel noted that the replacement relay obtained from the warehouse
  b. Findings
had a loose terminal point.  Two more relays were obtained from the warehouse; one of
      No findings were identified.
these also had a bad terminal point.  On October 27, 2008, the licensee quarantined the remaining four relays in stock. Two of these were identified to have similarly deficient terminal points. All four affected relays shared a date code of 0835.  The licensee
4OA3 Follow-up of Events and Notices of Enforcement Discretion (71153)
identified these relays as defective.  On November 4, 2008, the licensee issued a
.1    (Closed) Licensee Event Report 05000382/2012-007-00, Inoperability Of A Safety
corrective action request to Tyco Electronics requesting an investigation into the cause,
      Related Valve Due To Backup Air Accumulator Leakage
extent of condition, potential reporting, and development of corrective and preventive action for the Agastat E7024PB relays with date code 0835 noted to have defective
      On October 10, 2012, during refueling outage RFO-18, the licensee identified a dual
terminal points. On November 11, 2008, the licensee incorrectly determined that the deficiencies with the four 0835 date code relays were the same condition as had been previously captured in Condition Report CR-WF3-2008-4765.  This condition report had been written for date
      solenoid valve CC ISV0134B1/B2 associated with train B dry cooling tower component
code 0804 relays that had failed in service on September 11 and October 13, 2008.  The
      cooling water bypass valve CC-134B was leaking air through the solenoid valve exhaust
licensee incorrectly documented in Condition Report CR-WF3-2008-4782 that a
      vent port. Following replacement of the solenoid valve, the licensee discarded it without
reportability evaluation for that previous condition would satisfy the requirements to
      determining the cause or rate of leakage. The licensee determined on November 1,
evaluate the October 14 deficiencies for reportability. On November 25, 2008, Tyco Electronics issued a 10 CFR 21 report regarding an Agastat E7024PB relay, date code 0813, which was manufactured with an incorrect recycle spring.  Coincident with this Part 21 report, on November 26, 2008, Tyco
      2012, that the solenoid valve leakage could have adversely affected the backup air
Electronics issued a recall of Agastat E7024PB relays with date codes ranging from
      accumulator relied on to allow valve CC-134B to fulfill its safety function in the event that
0808 through 0835.  This recall included seven relays with a 0835 date code that had
      a tornado-generated missile damaged the train B dry cooling tower. The licensee
been sold to the Waterford 3 and two which had been procured by the Waterford 3 from another station. Four of these recalled relays were the subject of the November 4, 2008, corrective action request issued to Tyco by the licensee.  It was later determined that none of the relays procured by the Waterford 3 had an incorrect recycle spring installed. On January 28, 2009, the Waterford 3 received an evaluation from Tyco Electronics which identified misadjusted terminal blocks as the cause of the failures of the two 0804
      concluded that the valve may have been inoperable since the last accumulator leak test
date code relays, a different failure mechanism than that initially identified for the 0835 relays. The Tyco Electronics report did not provide an evaluation for the 0835 relays.  In August 2009, the licensee issued Licensee Event Report (LER) 2009-003-00 (ML092310548).  This LER did not mention relay 0835 or loose terminal points.  It instead discussed incorrect adjustment of terminal blocks.  In April 2010, the licensee issued an updated LER 2009-003-01 (ML101230323).  This revision discussed relay 0835 and listed loose terminal points on two spare relays as a Part 21-reportable defect.   
      because the rate of the leakage was unknown. As part of the review of this event, the
- 39 -  Enclosure 2
      inspectors identified a Green non-cited violation 05000382/2013004-03, Failure to
The NRC identified that the licensee had failed to evaluate the loose terminal points on the four relays with date code 0835 in accordance with 10 CFR Part 21.  Though the
      accomplish activities affecting quality on a degraded safety-related solenoid valve in
licensee's initial actions to have the vendor perform an evaluation may have been appropriate, it was the licensee's responsibility and obligation under Part 21 to complete such an evaluation within 60 days of the initial discovery, or issue an interim report within 60 days of the initial discovery. The initial LER or Part 21 report should have been made in December 2008 (60 days after the date of discovery in October 2008).  However, the Part 21 report that describes relay 0835 was made approximately 16 months later (April 2010). 
      accordance with procedure requirements. The inspectors documented this violation of
Analysis.  The failure of the licensee to adequately evaluate deviations in basic components and to report defects is a performance deficiency.  The NRC's significance
      NRC requirements in Section 1R19 of this report. This licensee event report is closed.
determination process (SDP) considers the safety significance of findings by evaluating their potential safety consequences.  This performance deficiency was of minor safety significance. The traditional enforcement process separately considers the significance
4OA5 Other Activities
of willful violations, violations that impact the regulatory process, and violations that
.1    (Closed) Temporary Instruction 2515/185, Follow-up on the Industrys Ground Water
result in actual safety consequences.  Traditional enforcement applied to this finding
      Protection Initiative
because it involved a violation that impacted the regulatory process.  Supplement VII to
  a. Inspection Scope
the version of the NRC Enforcement Policy that was in effect at the time the violation was identified provided as an example of a violation of significant regulatory concern (Severity Level III), "An inadequate review or failure to review such that, if an appropriate
      The ground water protection program was inspected September 16-19, 2013, to
review had been made as required, a 10 CFR Part 21 report would have been made." 
      determine whether the licensee had implemented the program elements which were
Based on this example, the NRC determined that the violation met the criteria to be cited
      found to be incomplete when previously reviewed during NRC Inspection Report
as a Severity Level III violation.  However, in accordance with the Enforcement Policy, because the affected components were already removed from service as part of an unrelated manufacturer's recall, the severity of the cited violation is being assessed as
      05000382/2012003. Inspectors interviewed cognizant licensee personnel and
Severity Level IV.  Cross-cutting aspects are not assigned to traditional enforcement violations.
      performed walk-downs.
Enforcement. Title 10, CFR Part 21.21(a)(1) requires, in part, that entities subject to the regulations in this part shall evaluate deviations and failures to comply to identify defects
  b. Findings
associated with substantial safety hazards as soon as practicable except as provided in paragraph (a)(2) of this section, and in all cases within 60 days of discovery, in order to identify a reportable defect that could create a substantial safety hazard, were it to  
      The following element had been implemented since the previous review:
remain uncorrected. Title 10 CFR, Part 21.21(a)(2) requires, in part, that entities subject to the regulations in the part shall ensure that if an evaluation of identified deviation or failure to comply
                                        - 36 -                                    Enclosure 2
potentially associated with a substantial safety hazard cannot be completed within
60 days from discovery of the deviation or failure to comply, an interim report is prepared
and submitted to the Commission.  The interim report must be submitted in writing within
60 days of discovery of the deviation of failure to comply. Contrary to the above, from December 14, 2008, to April 29, 2010, the licensee failed to evaluate deviations and failures to comply to identify defects associated with substantial
safety hazards as soon as practicable and to submit a report or interim report within 
- 40 -  Enclosure 2
60 days of its discovery, in order to identify a reportable defect or failure to comply that could create a substantial safety hazard, were it to remain uncorrected.   Specifically, on October 14, 2008, the licensee performed bench test on an
Agastat E7024PB relay with date code 0835 and noted that the relay had a loose
terminal point.  Two more relays were obtained from the warehouse; one of these also had a bad terminal point.  On October 27, 2008, the licensee quarantined the remaining four relays in stock.  Two of these quarantined relays were identified to have similarly
deficient terminal points.  The licensee identified these relays as "defective" and returned


them to the manufacturer, Tyco Electronics, for cause evaluation. All four affected relays shared a date code of 0835. On January 28, 2009, the licensee received a report from the manufacturer, which had failed to perform the required evaluation.  On August 18, 2009, the licensee submitted LER 2009-003-00, (ML092310548). This LER
        *  Element 1.4.a - Establish written procedures outlining the decision making
did not mention the date code 0835 relays or loose terminal points.  Rather, the LER
            process for remediation of leaks and spills or other instances of inadvertent
described relays that failed due to incorrect adjustment of terminal blocks, a deviation  
            releases.
different from that observed in the 0835 date code relays. On April 29, 2010, the  
  The following element had not been implemented since the previous review and is
licensee issued updated LER 2009003-01 (ML101230323).  This revision to the LER described loose terminal points on two spare date code 0835 relays as one of the defects identified in its Agastat E7024PB relays.  The April 29, 2010, LER revision would
  documented in the corrective action document listed with the element:
have met Part 21 evaluation and reporting requirements, but it was 501 days late: 
        *  Element 1.3.f - Establish a long-term program for preventative maintenance of
VIO 05000382/2013004-01, "Failure to Make a Report Required by 10 CFR 21.21."
            ground water wells (CR-HQN-2013-00861). This element lacked an
4OA6 Meetings, Including Exit Exit Meeting Summary
            implementing procedure or process. Additionally, the appropriateness for
The inspectors debriefed Mr. Carl Rich, Director of Nuclear Safety Assurance, and other members of the licensee's staff of the results of the licensed operator requalification
            preventative maintenance in relation to the specific type of ground water wells
program inspection on July 25, 2013, and telephonically exited with Mr. Carl Rich and other staff members on August 19, 2013. The licensee representatives acknowledged
            has yet to be determined.
the findings presented.  The inspectors asked the licensee whether any materials
.2 (Closed) Unresolved Item 05000382/2009010-01, Failures to Evaluate Adverse
examined during the inspection should be c
  Conditions for Reportability to the NRC
onsidered proprietary. No proprietary information was identified.
  On October 19, 2009, the NRC completed a special inspection at the Waterford 3
On September 19, 2013, the inspectors presented the results of the radiation safety
  initiated in response to a series of failures of safety-related Agastat timing relays. During
inspections to Ms. D. Jacobs, Vice President, Operations, and other members of the
  this inspection, the team identified two examples in which the licensee failed to
licensee staff. The licensee acknowledged the issues presented. The inspector asked
  adequately review a deviation observed in specific batches of relays to determine
the licensee whether any materials examined during the inspection should be considered proprietary.  No proprietary information was identified.  On October 1, 2013, the inspectors presented the inspection results to Ms. D. Jacobs, Vice President, Operations, and other members of the licensee staff. The licensee acknowledged the issues presented.  The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No
  whether the deviations were required to be reported to the NRC. The first of these
proprietary information was identified.
  examples involved a number of relays from the same manufacturing lot (date code 9948)
  that, after being installed in the plant, were determined to be unreliable, thus deviating
  from procurement requirements. The second of these examples involved several relays
  from a different manufacturing lot (date code 0835) that also did not conform to
  specifications; however, the deviation of the date code 0835 relays was discovered
  during bench testing prior to installation. On November 5, 2009, the NRC issued
  inspection report 05000382/2009010, documenting an unresolved item pending a
  determination of whether the licensees failures to evaluate and report the deviations
  constituted violations of one or more of the reporting requirements contained in
  10 CFR Part 21, 10 CFR 50.72, and 10 CFR 50.73.
  The NRC has determined that these deviations in basic components were not evaluated
  in accordance with 10 CFR 21.21(a)(1). Further, the NRC determined that had the
  licensee evaluated the deviations, it would have concluded that the deviations
  constituted defects as defined in 10 CFR 21.3. Where Part 21 applies, such defects are
  required to be reported to the NRC in accordance with 10 CFR 21.21(d)(1).
  The NRC is developing new guidance to clarify the reporting requirements of
  10 CFR Part 21 including whether in-service failure of installed parts-those subject to the
  reporting requirements in Part 50 (§§ 50.72 and 50.73)-are also subject to the evaluation
  and reporting requirements of Part 21. See Task Interface Agreement (TIA) 2010-003
  (ML11319A134). However, Part 21 evaluation and reporting criteria continue to apply to
  basic components that are not installed. Therefore, section 4OA5.2 below documents a
  violation of 10 CFR Part 21 for only the date code 0835 relays, in which the deviations
  were discovered prior to installation of the components. No violation will be issued for
  the licensees failure to evaluate the installed relays in accordance with Part 21
  requirements.
                                        - 37 -                                  Enclosure 2


 
.3 Failures to perform evaluations and make a report as required by 10 CFR Part 21
- 41 -  Enclosure 2
  Introduction. The team identified a Severity Level IV violation of 10 CFR 21.21 that
On November 19, 2013, a re-exit was held with Mr. John Jarrell, Regulatory Assurance Manager, and other members of your staff. The purpose of this re-exit was to further
  occurred when the licensee failed to complete an evaluation of a deviation in a basic
discuss the violations contained in the report.  
  component within 60 days of discovery.
4OA7 Licensee-Identified Violations The following violation of very low safety significance (SL-IV) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the  
  Description. On October 14, 2008, while replacing a failed Agastat E7024PB relay,
NRC Enforcement Policy for being dispositioned as a Non-Cited Violation.  
  maintenance personnel noted that the replacement relay obtained from the warehouse
  had a loose terminal point. Two more relays were obtained from the warehouse; one of
  these also had a bad terminal point. On October 27, 2008, the licensee quarantined the
  remaining four relays in stock. Two of these were identified to have similarly deficient
  terminal points. All four affected relays shared a date code of 0835. The licensee
  identified these relays as defective. On November 4, 2008, the licensee issued a
  corrective action request to Tyco Electronics requesting an investigation into the cause,
  extent of condition, potential reporting, and development of corrective and preventive
  action for the Agastat E7024PB relays with date code 0835 noted to have defective
  terminal points.
  On November 11, 2008, the licensee incorrectly determined that the deficiencies with the
  four 0835 date code relays were the same condition as had been previously captured in
  Condition Report CR-WF3-2008-4765. This condition report had been written for date
  code 0804 relays that had failed in service on September 11 and October 13, 2008. The
  licensee incorrectly documented in Condition Report CR-WF3-2008-4782 that a
  reportability evaluation for that previous condition would satisfy the requirements to
  evaluate the October 14 deficiencies for reportability.
  On November 25, 2008, Tyco Electronics issued a 10 CFR 21 report regarding an
  Agastat E7024PB relay, date code 0813, which was manufactured with an incorrect
  recycle spring. Coincident with this Part 21 report, on November 26, 2008, Tyco
  Electronics issued a recall of Agastat E7024PB relays with date codes ranging from
  0808 through 0835. This recall included seven relays with a 0835 date code that had
  been sold to the Waterford 3 and two which had been procured by the Waterford 3 from
  another station. Four of these recalled relays were the subject of the November 4, 2008,
  corrective action request issued to Tyco by the licensee. It was later determined that
  none of the relays procured by the Waterford 3 had an incorrect recycle spring installed.
  On January 28, 2009, the Waterford 3 received an evaluation from Tyco Electronics
  which identified misadjusted terminal blocks as the cause of the failures of the two 0804
  date code relays, a different failure mechanism than that initially identified for the 0835
  relays. The Tyco Electronics report did not provide an evaluation for the 0835 relays.
  In August 2009, the licensee issued Licensee Event Report (LER) 2009-003-00
  (ML092310548). This LER did not mention relay 0835 or loose terminal points. It
  instead discussed incorrect adjustment of terminal blocks. In April 2010, the licensee
  issued an updated LER 2009-003-01 (ML101230323). This revision discussed relay
  0835 and listed loose terminal points on two spare relays as a Part 21-reportable defect.
                                      - 38 -                                    Enclosure 2


The NRC identified that the licensee had failed to evaluate the loose terminal points on
Title 10 CFR, Part 55.9, "Completeness and Accuracy of Information," requires that "information provided to the Commission by an applicant for a license or by a licensee - shall be complete and accurate in all material respects."  Contrary to the above, on
the four relays with date code 0835 in accordance with 10 CFR Part 21. Though the
September 13, 2012, an NRC Form 396, "Certifi
licensees initial actions to have the vendor perform an evaluation may have been
cation of Medical Examination by Facility Licensee," was submitted to the NRC for a licensed operator applicant with inaccurate
appropriate, it was the licensees responsibility and obligation under Part 21 to complete
information.  Specifically, a restriction for corrective lenses was omitted, even though the applicant's medical exam stated that the individual required corrective lenses.  An operating license was granted by the NRC to the individual without a corrective lens restriction. The error was identified during the operator's subsequent annual medical
such an evaluation within 60 days of the initial discovery, or issue an interim report within
examination in July 2013, after which the operator reported to licensing that an additional restriction was being placed on his license though his vision had not changed. The
60 days of the initial discovery.
licensee confirmed that the operator had not performed any licensed duties and a revised NRC Form 396 was submitted to Region IV on July 29, 2013. The licensee documented the deficiency in Condition Report 2013-03181. The submission of  
The initial LER or Part 21 report should have been made in December 2008 (60 days
inaccurate information to the NRC is a violation.  The violation was evaluated using the
after the date of discovery in October 2008). However, the Part 21 report that describes
relay 0835 was made approximately 16 months later (April 2010).
Analysis. The failure of the licensee to adequately evaluate deviations in basic
components and to report defects is a performance deficiency. The NRCs significance
determination process (SDP) considers the safety significance of findings by evaluating
their potential safety consequences. This performance deficiency was of minor safety
significance. The traditional enforcement process separately considers the significance
of willful violations, violations that impact the regulatory process, and violations that
result in actual safety consequences. Traditional enforcement applied to this finding
because it involved a violation that impacted the regulatory process. Supplement VII to
the version of the NRC Enforcement Policy that was in effect at the time the violation
was identified provided as an example of a violation of significant regulatory concern
(Severity Level III), An inadequate review or failure to review such that, if an appropriate
review had been made as required, a 10 CFR Part 21 report would have been made.
Based on this example, the NRC determined that the violation met the criteria to be cited
as a Severity Level III violation. However, in accordance with the Enforcement Policy,
because the affected components were already removed from service as part of an
unrelated manufacturers recall, the severity of the cited violation is being assessed as
Severity Level IV. Cross-cutting aspects are not assigned to traditional enforcement
violations.
Enforcement. Title 10, CFR Part 21.21(a)(1) requires, in part, that entities subject to the
regulations in this part shall evaluate deviations and failures to comply to identify defects
associated with substantial safety hazards as soon as practicable except as provided in
paragraph (a)(2) of this section, and in all cases within 60 days of discovery, in order to
identify a reportable defect that could create a substantial safety hazard, were it to
remain uncorrected.
Title 10 CFR, Part 21.21(a)(2) requires, in part, that entities subject to the regulations in
the part shall ensure that if an evaluation of identified deviation or failure to comply
potentially associated with a substantial safety hazard cannot be completed within
60 days from discovery of the deviation or failure to comply, an interim report is prepared
and submitted to the Commission. The interim report must be submitted in writing within
60 days of discovery of the deviation of failure to comply.
Contrary to the above, from December 14, 2008, to April 29, 2010, the licensee failed to
evaluate deviations and failures to comply to identify defects associated with substantial
safety hazards as soon as practicable and to submit a report or interim report within
                                      - 39 -                                    Enclosure 2


traditional enforcement process because it
    60 days of its discovery, in order to identify a reportable defect or failure to comply that
impacted the NRC's ability to perform its regulatory function. The violation was determined to be Severity Level IV because it fits
    could create a substantial safety hazard, were it to remain uncorrected.
the example of Enforcement Policy Section 6.4.d.1(d), "Violation Examples:  Licensed Reactor Operators."  This section states, "SL IV violations involve , for example - an individual operator who met ANSI/ANS 3.4, Section 5, as certified on NRC Form 396,  
    Specifically, on October 14, 2008, the licensee performed bench test on an
required by Title 10, Part CFR 55.23, but failed to report a condition that would have
    Agastat E7024PB relay with date code 0835 and noted that the relay had a loose
required a license restriction to establish or maintain medical qualification based on
    terminal point. Two more relays were obtained from the warehouse; one of these also
having the undisclosed medical condition."  In this case, the individual operator did report the condition to the licensee, but the licensee failed to include that information in its original license application to the NRC.  
    had a bad terminal point. On October 27, 2008, the licensee quarantined the remaining
 
    four relays in stock. Two of these quarantined relays were identified to have similarly
  A1-1 Attachment SUPPLEMENTAL INFORMATION
    deficient terminal points. The licensee identified these relays as defective and returned
  KEY POINTS OF CONTACT
    them to the manufacturer, Tyco Electronics, for cause evaluation. All four affected
  Licensee Personnel    D. Jacobs, Vice President, Operations  
    relays shared a date code of 0835. On January 28, 2009, the licensee received a report
K. Cook, General Manager, Plant Operations  
    from the manufacturer, which had failed to perform the required evaluation. On
    August 18, 2009, the licensee submitted LER 2009-003-00, (ML092310548). This LER
    did not mention the date code 0835 relays or loose terminal points. Rather, the LER
    described relays that failed due to incorrect adjustment of terminal blocks, a deviation
    different from that observed in the 0835 date code relays. On April 29, 2010, the
    licensee issued updated LER 2009003-01 (ML101230323). This revision to the LER
    described loose terminal points on two spare date code 0835 relays as one of the
    defects identified in its Agastat E7024PB relays. The April 29, 2010, LER revision would
    have met Part 21 evaluation and reporting requirements, but it was 501 days late:
    VIO 05000382/2013004-01, Failure to Make a Report Required by 10 CFR 21.21.
4OA6 Meetings, Including Exit
    Exit Meeting Summary
    The inspectors debriefed Mr. Carl Rich, Director of Nuclear Safety Assurance, and other
    members of the licensee's staff of the results of the licensed operator requalification
    program inspection on July 25, 2013, and telephonically exited with Mr. Carl Rich and
    other staff members on August 19, 2013. The licensee representatives acknowledged
    the findings presented. The inspectors asked the licensee whether any materials
    examined during the inspection should be considered proprietary. No proprietary
    information was identified.
    On September 19, 2013, the inspectors presented the results of the radiation safety
    inspections to Ms. D. Jacobs, Vice President, Operations, and other members of the
    licensee staff. The licensee acknowledged the issues presented. The inspector asked
    the licensee whether any materials examined during the inspection should be
    considered proprietary. No proprietary information was identified.
    On October 1, 2013, the inspectors presented the inspection results to Ms. D. Jacobs,
    Vice President, Operations, and other members of the licensee staff. The licensee
    acknowledged the issues presented. The inspector asked the licensee whether any
    materials examined during the inspection should be considered proprietary. No
    proprietary information was identified.
                                        - 40 -                                    Enclosure 2


S. Adams, Senior Manager, Production  D. Boan, Supervisor, Radiation Protection J. Briggs, Superintendent, Electrical Maintenance 
    On November 19, 2013, a re-exit was held with Mr. John Jarrell, Regulatory Assurance
K. Crissman, Senior Manager, Maintenance
    Manager, and other members of your staff. The purpose of this re-exit was to further
D. Frey, Manager, Radiation Protection
    discuss the violations contained in the report.
R. Gilmore, Manager, Systems and Components W. Hardin, Senior Licensing Specialist, Licensing
4OA7 Licensee-Identified Violations
A. James, Manager, Security 
    The following violation of very low safety significance (SL-IV) was identified by the
    licensee and is a violation of NRC requirements which meets the criteria of the
    NRC Enforcement Policy for being dispositioned as a Non-Cited Violation.
    Title 10 CFR, Part 55.9, Completeness and Accuracy of Information, requires that
    information provided to the Commission by an applicant for a license or by a licensee
    shall be complete and accurate in all material respects. Contrary to the above, on
    September 13, 2012, an NRC Form 396, Certification of Medical Examination by Facility
    Licensee, was submitted to the NRC for a licensed operator applicant with inaccurate
    information. Specifically, a restriction for corrective lenses was omitted, even though the
    applicants medical exam stated that the individual required corrective lenses. An
    operating license was granted by the NRC to the individual without a corrective lens
    restriction. The error was identified during the operators subsequent annual medical
    examination in July 2013, after which the operator reported to licensing that an additional
    restriction was being placed on his license though his vision had not changed. The
    licensee confirmed that the operator had not performed any licensed duties and a
    revised NRC Form 396 was submitted to Region IV on July 29, 2013. The licensee
    documented the deficiency in Condition Report 2013-03181. The submission of
    inaccurate information to the NRC is a violation. The violation was evaluated using the
    traditional enforcement process because it impacted the NRCs ability to perform its
    regulatory function. The violation was determined to be Severity Level IV because it fits
    the example of Enforcement Policy Section 6.4.d.1(d), Violation Examples: Licensed
    Reactor Operators. This section states, SL IV violations involve, for example  an
    individual operator who met ANSI/ANS 3.4, Section 5, as certified on NRC Form 396,
    required by Title 10, Part CFR 55.23, but failed to report a condition that would have
    required a license restriction to establish or maintain medical qualification based on
    having the undisclosed medical condition. In this case, the individual operator did
    report the condition to the licensee, but the licensee failed to include that information in
    its original license application to the NRC.
                                          - 41 -                                  Enclosure 2


B. Lanka, Director, Engineering  
                                SUPPLEMENTAL INFORMATION
                                  KEY POINTS OF CONTACT
Licensee Personnel
D. Jacobs, Vice President, Operations
K. Cook, General Manager, Plant Operations
S. Adams, Senior Manager, Production
D. Boan, Supervisor, Radiation Protection
J. Briggs, Superintendent, Electrical Maintenance
K. Crissman, Senior Manager, Maintenance
D. Frey, Manager, Radiation Protection
R. Gilmore, Manager, Systems and Components
W. Hardin, Senior Licensing Specialist, Licensing
A. James, Manager, Security
B. Lanka, Director, Engineering
N. Lawless Manager, Chemistry
B. Lindsey, Senior Manager, Operations
M. Mason, Senior Licensing Specialist, Licensing
M. Mills, Manager, Nuclear Oversight
W. McKinney Manager, Performance Improvement
S.W. Meiklejohn, Superintendent, I & C Maintenance
B. Pellegrin, Manager, Regulatory Assurance
G. Pierce, Manager, Training
R. Porter, Manager, Design & Program Engineering
D. Reider, Supervisor, Quality Assurance
C. Rich, Jr., Director, Regulatory & Performance Improvement
J. Russo, Supervisor, Design Engineering
J. Signorelli, Supervisor, Simulator Support
R. Simpson, Superintendent, Licensed Operator Requalification
P. Stanton, Supervisor, Design Engineering
J. Williams, Senior Licensing Specialist
                                              A1-1            Attachment


N. Lawless Manager, Chemistry
                LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
05000382-2013004-01    VIO      Failure to Make a Report Required by 10 CFR 21.21
                                  (Section 4OA5)
Opened and Closed
05000382-2013004-02    NCV      Failure to Implement Fire Protection Program Procedure
                                  Requirements When Securing from a Fire Watch
                                  (Section 1R05)
05000382-2013004-03    NCV      Failure to Accomplish Activities Affecting Quality on a
                                  Degraded Safety-Related Solenoid Valve In Accordance With
                                  Procedure Requirements (Section 1R19)
Closed
05000382/2012-007-00    LER      Inoperability of a Safety Related Valve Due to Backup Air
                                  Accumulator Leakage
05000382/2009010-01    URI      Failure to Evaluate Adverse Conditions for Reportability to the
                                  NRC (Section 4OA5)
                          LIST OF DOCUMENTS REVIEWED
Section 1R01: Adverse Weather Protection
PROCEDURES/DOCUMENTS
  NUMBER                                TITLE                                REVISION
OP-901-521      Severe Weather and Flooding                                          309
ENS-EP-302      Severe Weather Response                                              11
Section 1R04: Equipment Alignment
PROCEDURES/DOCUMENTS
  NUMBER                                TITLE                                REVISION
OP-009-008      Safety Injection System                                              33
OP-002-004      Chilled Water System                                                311
OP-002-001      Auxiliary Component Cooling Water                                    305
                                            A1-2


B. Lindsey, Senior Manager, Operations M. Mason, Senior Licensing Specialist, Licensing M. Mills, Manager, Nuclear Oversight 
Section 1R05: Fire Protection
W. McKinney Manager, Performance Improvement
PROCEDURES/DOCUMENTS
S.W. Meiklejohn, Superintendent, I & C Maintenance 
  NUMBER                                TITLE                      REVISION
B. Pellegrin, Manager, Regulatory Assurance
UNT-005-013      Fire Protection Program                                12
FP-001-014      Duties of a Fire Watch                                16
RAB 2-001        Prefire Strategy Elevation +46.00 RAB HVAC            12
                Equipment Room
RAB 7-001        Prefire Strategy Elevation +35.00 RAB HVAC Relay      9
                Room
RAB 39-001      Prefire Strategy Elevation -35.00 RAB General Area    11
FP-001-018      Pre Fire Strategies, Development and Revision        301
NS-TB-002        Prefire Strategy Turbing Building +15.00 West          2
CONDITION REPORTS
CR-WF3-2013-03523      CR-WF3-2013-03398
Section 1R06: Flood Protection Measures
PROCEDURES/DOCUMENTS
  NUMBER                                TITLE                      REVISION
EN-DC-346        Cable Reliability Program                              5
MNQ3-5          Flooding Analysis Outside Containment                  4
W3F1-2007-0017 Response to Generic Letter 2007-01                      0
W3F1-2009-0066 Clarification of Response to Generic Letter 2007-01      0
SEP-UIP-WF3      Underground Components Inspection Plan                  1
WORK ORDERS
WO 227249
Section 1R07: Heat Sink Performance
PROCEDURES/DOCUMENTS
    NUMBER                                TITLE                    REVISION
EN-DC-316          Heat Exchanger Performance and Condition            3
                                            A1-3


G. Pierce, Manager, Training
Section 1R07: Heat Sink Performance
R. Porter, Manager, Design & Program Engineering
PROCEDURES/DOCUMENTS
D. Reider, Supervisor, Quality Assurance
      NUMBER                              TITLE                        REVISION
C. Rich, Jr., Director, Regulatory & Performance Improvement
                  Monitoring
J. Russo, Supervisor, Design Engineering
PE-001-004        Heat Exchanger Performance                                  2
J. Signorelli, Supervisor, Simulator Support  R. Simpson, Superintendent, Licensed Operator Requalification 
SEP-HX-WF3-001    Waterfords Generic Letter 89-13 Heat Exchanger            0
P. Stanton, Supervisor, Design Engineering
                  Test Basis
J. Williams, Senior Licensing Specialist
Section 1R11: Licensed Operator Requalification Program
 
PROCEDURES/DOCUMENTS
 
    NUMBER                               TITLE                         REVISION/
  A1-2 LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
                                                                            DATE
Opened 05000382-2013004-01 VIO Failure to Make a Report Required by 10 CFR 21.21 (Section 4OA5)
EN-OP-115        Conduct of Operations                                        12
Opened and Closed
EN-TQ-114        Licensed Operator Requalification Training Program            8
  05000382-2013004-02 NCV Failure to Implement Fire Protection Program Procedure Requirements When Securing from a Fire Watch (Section 1R05)
                Description
05000382-2013004-03 NCV Failure to Accomplish Activities Affecting Quality on a Degraded Safety-Related Solenoid Valve In Accordance With
TM-OP-100        Operations Training Manual                                  24
Procedure Requirements (Section 1R19)
ANSI/ANS-3.4-   Medical Certification and Monitoring of Personnel      April 29, 1983
Closed  05000382/2012-007-00 LER Inoperability of a Safety Related Valve Due to Backup Air Accumulator Leakage
1983            Requiring Operator Licenses for Nuclear Power Plants
05000382/2009010-01 URI Failure to Evaluate Adverse Conditions for Reportability to the NRC (Section 4OA5)
ANSI/ANS-3.5-    Nuclear Power Plant Simulators for Use in Operator  September 4, 2009
LIST OF DOCUMENTS REVIEWED
2009            Training and Examination
Section 1R01:  Adverse Weather ProtectionPROCEDURES/DOCUMENTS
ACAD 07-001     Guidelines for the Continuing Training of Licensed    January 2007
NUMBER TITLE REVISION OP-901-521 Severe Weather and Flooding 309
                Personnel
ENS-EP-302 Severe Weather Response 11
EN-TQ-217        Examination Security                                          2
OI-024-000      Maintaining Active SRO/RO Status                            306
Section 1R04:  Equipment Alignment
EN-NS-112        Medical Program                                              11
PROCEDURES/DOCUMENTS
TM-OP-100        Operations Training Manual                                  24
NUMBER TITLE REVISION OP-009-008 Safety Injection System 33
MISCELLANEOUS DOCUMENTS
OP-002-004 Chilled Water System 311
    NUMBER                              TITLE                            DATE
OP-002-001 Auxiliary Component Cooling Water 305
  WSIM-DIR-003-   Steady State Test - 20%, 70%, 100%                      May 5, 2013
 
  ANNUALTESTS
  A1-3 Section 1R05:  Fire Protection
  Att. 4.1
PROCEDURES/DOCUMENTS
  WSIM-DIR-003-   Manual Reactor Trip                                    May 5, 2013
NUMBER TITLE REVISION UNT-005-013 Fire Protection Program 12 FP-001-014 Duties of a Fire Watch 16
ANNUALTESTS
RAB 2-001 Prefire Strategy Elevation +46.00' RAB HVAC
  Att. 4.2
Equipment Room
                                            A1-4
12 RAB 7-001 Prefire Strategy Elevation +35.00' RAB HVAC Relay
Room 9 RAB 39-001 Prefire Strategy Elevation -35.00' RAB General Area 11 FP-001-018 Pre Fire Strategies, Development and Revision 301
NS-TB-002 Prefire Strategy Turbing Building +15.00' West 2
  CONDITION REPORTS
  CR-WF3-2013-03523 CR-WF3-2013-03398 
Section 1R06: Flood Protection Measures
  PROCEDURES/DOCUMENTS
  NUMBER TITLE REVISION EN-DC-346 Cable Reliability Program 5 MNQ3-5 Flooding Analysis Outside Containment 4 W3F1-2007-0017 Response to Generic Letter 2007-01 0
W3F1-2009-0066 Clarification of Response to Generic Letter 2007-01 0 SEP-UIP-WF3 Underground Components Inspection Plan 1
  WORK ORDERS
  WO 227249   


  Section 1R07: Heat Sink Performance PROCEDURES/DOCUMENTS
  WSIM-DIR-003- Trip of any single RCP                                May 15, 2013
  NUMBER TITLE REVISION EN-DC-316 Heat Exchanger Performance and Condition 3  
ANNUALTESTS
  A1-4  Section 1R07:  Heat Sink Performance PROCEDURES/DOCUMENTS
Att. 4.6
NUMBER TITLE REVISION Monitoring PE-001-004 Heat Exchanger Performance 2 SEP-HX-WF3-001 Waterford's Generic Letter 89-13 Heat Exchanger Test Basis
  WWEX-LOR-     2011 LOR Biennial RO Exam Week 4                      August 4, 2011
0 Section 1R11:  Licensed Operator Requalification Program PROCEDURES/DOCUMENTS
  11044R
NUMBER TITLE REVISION/
WWEX-LOR-     2011 LOR Biennial RO Exam Week 4 (Remedial)          August 18, 2011
DATE EN-OP-115 Conduct of Operations
  11046R
12 EN-TQ-114
N/A            2013 LOR Cycle Written Exam Question Matrix            July 23, 2013
Licensed Operator Requalification Training Program Description
WWEX-LOR-       2013 LOR Biennial RO Exam Week 2                       July 18, 2013
8 TM-OP-100 Operations Training Manual 24 ANSI/ANS-3.4-
13042R
1983 Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants April 29, 1983 ANSI/ANS-3.5-
TQF-201-IM06    Academic Review Board Recommendation                November 14, 2011
2009 Nuclear Power Plant Simulators for Use in Operator Training and Examination September 4, 2009 ACAD 07-001 Guidelines for the Continuing Training of Licensed
N/A            Simulator Differences List                              July 22, 2013
Personnel
DR-08-0158      Simulator Discrepancy Report                            July 28, 2008
January 2007 EN-TQ-217 Examination Security 2 OI-024-000 Maintaining Active SRO/RO Status 306
DR-13-0056      Simulator Discrepancy Report                            April 3, 2013
EN-NS-112 Medical Program 11
DR-10-0239      Simulator Discrepancy Report                        September 23, 2010
TM-OP-100 Operations Training Manual 24
DR-13-0048      Simulator Discrepancy Report                          March 26, 2013
MISCELLANEOUS DOCUMENTS
DR-13-0044      Simulator Discrepancy Report                          March 25, 2013
NUMBER TITLE DATE WSIM-DIR-003-ANNUALTESTS
DR-12-0166      Simulator Discrepancy Report                          December 5, 2012
N/A            Scenarios, LOR Annual Op Tests Weeks 1-6 (18)          July 22, 2013
N/A            JPMs, LOR Annual Op Tests Weeks 1-6 (36)                July 22, 2013
N/A            2013 Annual Exam Schedule, Weeks 1-6                    July 22, 2013
TQF-210-DD03    LOR Simulator Crew Performance Evaluation Report -     July 25, 2013
                Crews A and 3 (6)
W-OPS-LOR-      Requal Training Attendance Records for 2012            July 22, 2013
2012-Cycles 1-6 Cycles 1-6
CONDITION REPORTS
CR-WF3-2013-03181    CR-WF3-2013-03441      CR-WF3-2013-00747    CR-WF3-2013-00961
CR-HQN-2013-00708    CR-WF3-2013-02266      CR-WF3-2013-03522
                                          A1-5


Att. 4.1 Steady State Test - 20%, 70%, 100% May 5, 2013 WSIM-DIR-003-ANNUALTESTS
Section 1R12: Maintenance Effectiveness
Att. 4.2 Manual Reactor Trip May 5, 2013
PROCEDURES/DOCUMENTS
  A1-5  WSIM-DIR-003-ANNUALTESTS
    NUMBER                              TITLE                        REVISION
ECM97-006      Design Basis for CCW Makeup                                1
CONDITION REPORTS
CR-WF3-2013-02876 CR-WF3-2013-3170          CR-WF3-2013-3245    CR-WF3-2013-2897
WORK ORDERS
WO 354081            WO 355051              WO 322052
Section 1R13: Maintenance Risk Assessment and Emergent Work Controls
PROCEDURES/DOCUMENTS
    NUMBER                              TITLE                        REVISION
EN-WM-104      On Line Risk Assessment                                    7
                Integrated Risk Summary Form for Week of 7/29/13          0
                8/4/13
                Integrated Risk Summary Form for Week of 9/02/13          0
                9/8/13
OI-037-000      Operations Risk Assessment Guideline                    304
CONDITION REPORTS
CR-WF3-2013-03574
Section 1R15: Operability Determinations and Functionality Assessments
PROCEDURES/DOCUMENTS
    NUMBER                              TITLE                        REVISION
EN-LI-108      Event Notification and Reporting                          8
EN-OP-104      Operability Determinations                                6
EC 46218        Provide Minimum Wall Thickness Data for Degraded          0
                Piping Identified in CR-WF3-2012-3855
PS-S-004        Thermal Expansion Evaluation of Low Temperature            1
                Piping Systems
EN-PS-S-021-W  Design Guide for Pipe Stress Analysis                      0
                                          A1-6


Att. 4.6 Trip of any single RCP May 15, 2013 WWEX-LOR-11044R 2011 LOR Biennial RO Exam Week 4 August 4, 2011 WWEX-LOR-11046R 2011 LOR Biennial RO Exam Week 4 (Remedial) August 18, 2011 N/A 2013 LOR Cycle Written Exam Question Matrix July 23, 2013 WWEX-LOR-13042R 2013 LOR Biennial RO Exam Week 2 July 18, 2013 TQF-201-IM06 Academic Review Board Recommendation November 14, 2011 N/A Simulator Differences List July 22, 2013
Section 1R15: Operability Determinations and Functionality Assessments
DR-08-0158 Simulator Discrepancy Report July 28, 2008
PROCEDURES/DOCUMENTS
DR-13-0056 Simulator Discrepancy Report April 3, 2013  
    NUMBER                                TITLE                            REVISION
DR-10-0239 Simulator Discrepancy Report September 23, 2010
OP-100-014      Technical Specifications and Technical Requirement          313
DR-13-0048 Simulator Discrepancy Report March 26, 2013  
                Compliance
DR-13-0044 Simulator Discrepancy Report March 25, 2013  
OI-037-000      Operations Risk Assessment Guideline                        304
DR-12-0166 Simulator Discrepancy Report December 5, 2012
EN-CS-S-008-     Pipe Wall Thinning Structural Evaluation                      0
N/A Scenarios, LOR Annual Op Tests Weeks 1-6 (18) July 22, 2013
MULTI
N/A JPMs, LOR Annual Op Tests Weeks 1-6 (36) July 22, 2013
CONDITION REPORTS
N/A 2013 Annual Exam Schedule, Weeks 1-6 July 22, 2013
CR-WF3-2013-03641      CR-WF3-2013-02876      CR-WF3-2013-03170      CR-WF3-2013-03245
TQF-210-DD03 LOR Simulator Crew Performance Evaluation Report - Crews "A" and "3" (6)  
CR-WF3-2013-03855      CR-WF3-2013-4098
July 25, 2013
Section 1R18: Plant Modifications
W-OPS-LOR-
PROCEDURES/DOCUMENTS
2012-Cycles 1-6 Requal Training Attendance Records for 2012 
    NUMBER                                TITLE                            REVISION
Cycles 1-6
EC 45995        Main Steam Isolation Valve B to Repair a Bonnet Vent          0
                Plug
EC 46914        Main Feedwater Isolation Valve A Nitrogen                    0
                Accumulator B tubing replacement
Section 1R19: Post-Maintenance Testing
PROCEDURES/DOCUMENTS
    NUMBER                                TITLE                            REVISION
EC 38218        Operability Input for CR-WF3-2012-2870, ACC-                 0
                126A(B) Potential Leakage
EC-M90-013      Auxiliary Component Cooling Water (ACCW) Jockey              0
                Pump Analysis
EN-WM-107        Post Maintenance Testing                                      4
MI-005-211      Calibration of Control Valves and Accessories                8
MI-005-211      Calibration of Control Valves and Accessories                9
MN(Q)9-50        ACCW System Resistance                                        2
OP-002-001      Auxiliary Component Cooling Water                            305
OP-903-006      Reactor Trip Circuit Breaker Test                            10
                                            A1-7


July 22, 2013 CONDITION REPORTS
Section 1R18: Plant Modifications
  CR-WF3-2013-03181 CR-WF3-2013-03441 CR-WF3-2013-00747 CR-WF3-2013-00961 CR-HQN-2013-00708 CR-WF3-2013-02266 CR-WF3-2013-03522 
PROCEDURES/DOCUMENTS
 
  NUMBER                                TITLE                            REVISION
  A1-6  Section 1R12: Maintenance Effectiveness PROCEDURES/DOCUMENTS
OP-903-050      Component Cooling Water and Auxiliary Component              28
NUMBER TITLE REVISION ECM97-006 Design Basis for CCW Makeup 1
                Cooling Water Pump and Valve Operability Test
OP-903-065      Emergency Diesel Generator and Subgroup Relay                307
                Operability Verification
OP-903-118      Primary Auxiliaries Quarterly IST Valve Tests                31
OP-903-119      Secondary Auxiliaries Quarterly IST Valve Test              18
STA-001-005      Leakage Testing of Air and Nitrogen Accumulators for        310
                Safety Related Valves
TD-M120.0045    Masoneilan Instruction Manual 2034 for Electro-              0
                Pneumatic Positioner Models 8012 & 8012-1-C &
                8012-2-C & 8012-3-C
TD-M120.0055    Masoneilan Instruction Manual ES-5000 for Electro-            1
                Pneumatic Positioner Models 8012 & 8012-2-C &
                8012-3-C & 8012-5-C & 8012-6-C
W3-DBD-14        Safety Related Air Operated Valves                          301
CONDITION REPORTS
CR-WF3-2013-00451    CR-WF3-2013-00447        CR-WF3-2013-00491    CR-HQN-2013-00709
CR-WF3-2012-05991    CR-WF3-2012-03280        CR-WF3-2012-02870    CR-WF3-2013-04290
CR-WF3-2013-04332    CR-WF3-2013-04324        CR-WF3-2013-04274    CR-WF3-2012-02870
CR-WF3-2012-03217    CR-WF3-2010-03602        CR-WF3-2013-04047
WORK ORDERS
WO 52486712          WO 360921
Section 1R22: Surveillance Testing
PROCEDURES/DOCUMENTS
  NUMBER                                 TITLE                           REVISION
EC 18218        Change CVRIDPIS5220A & B Setpoints                            0
EC 18219        Replace CVRIDPIS5220A, B CVRIDPIS5221A,                        0
                B Design Basis
OP-903-050      Component Cooling Water and Auxiliary Component              28
                                            A1-8


CONDITION REPORTS
Section 1R22: Surveillance Testing
CR-WF3-2013-02876 CR-WF3-2013-3170 CR-WF3-2013-3245 CR-WF3-2013-2897
PROCEDURES/DOCUMENTS
  NUMBER                                TITLE                      REVISION
                Cooling Water Pump and Valve Operability Test
OP-903-120      Containment and Miscellaneous Systems Quarterly        15
                IST Valve Tests
W3-DBD-04        Design Basis Document: Component Cooling Water,      302
                Auxiliary Component Cooling Water
SD-CCS          Containment Cooling and Ventilation System              7
                Description
OP-903-037      Containment Cooling Fan Operability Verification      6
OP-903-037      Safety Injection Pump Operability Verification        19
WORK ORDERS
WORK ORDERS
WO 354081 WO 355051 WO 322052 
WO 227323            WO 5251325
Section 1R13: Maintenance Risk Assessment and Emergent Work Controls PROCEDURES/DOCUMENTS
Section 1EP6: Drill Evaluation
NUMBER TITLE REVISION EN-WM-104 On Line Risk Assessment 7
PROCEDURES/DOCUMENTS
Integrated Risk Summary Form for Week of 7/29/13
  NUMBER                               TITLE                       REVISION
8/4/13 0  Integrated Risk Summary Form for Week of 9/02/13
EP              Emergency Plan                                        44
9/8/13 0 OI-037-000 Operations' Risk Assessment Guideline 304
EP-001-001      Recognition and Classification of Emergency            30
CONDITION REPORTS
                Conditions
  CR-WF3-2013-03574   
2RS1 Radiological Hazard Assessment and Exposure Controls (71124.01)
Section 1R15:  Operability Determinations and Functionality Assessments
PROCEDURES/DOCUMENTS
PROCEDURES/DOCUMENTS
  NUMBER                               TITLE                       REVISION
NUMBER TITLE REVISION EN-LI-108 Event Notification and Reporting 8
EN-RP-101      Access Control for Radiologically Controlled Areas      7
EN-OP-104 Operability Determinations 6
EN-RP-106-01    Radiological Survey Guidelines                          0
EC 46218 Provide Minimum Wall Thickness Data for Degraded
EN-RP-108      Radiation Protection Postings                          13
Piping Identified in CR-WF3-2012-3855
EN-RP-121      Radioactive Material Control                            7
0 PS-S-004 Thermal Expansion Evaluation of Low Temperature
EN-RP-143      Source Control                                             9
Piping Systems
                                          A1-9
1 EN-PS-S-021-W Design Guide for Pipe Stress Analysis 0 
  A1-7  Section 1R15:  Operability Determinations and Functionality Assessments
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION OP-100-014 Technical Specifications and Technical Requirement
Compliance
313 OI-037-000 Operations' Risk Assessment Guideline 304 EN-CS-S-008-MULTI Pipe Wall Thinning Structural Evaluation 0
CONDITION REPORTS
  CR-WF3-2013-03641 CR-WF3-2013-02876 CR-WF3-2013-03170 CR-WF3-2013-03245
CR-WF3-2013-03855 CR-WF3-2013-4098 
Section 1R18:  Plant Modifications
PROCEDURES/DOCUMENTS  NUMBER TITLE REVISION EC 45995 Main Steam Isolation Valve B to Repair a Bonnet Vent
Plug 0 EC 46914 Main Feedwater Isolation Valve A Nitrogen
Accumulator B tubing replacement
0  Section 1R19:  Post-Maintenance Testing
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION EC 38218 Operability Input for CR-WF3-2012-2870, ACC-126A(B) Potential Leakage
0 EC-M90-013 Auxiliary Component Cooling Water (ACCW) Jockey Pump Analysis
0 EN-WM-107 Post Maintenance Testing 4 MI-005-211 Calibration of Control Valves and Accessories 8 MI-005-211 Calibration of Control Valves and Accessories 9 MN(Q)9-50 ACCW System Resistance 2
OP-002-001 Auxiliary Component Cooling Water 305
OP-903-006 Reactor Trip Circuit Breaker Test 10 
  A1-8  Section 1R18:  Plant Modifications
PROCEDURES/DOCUMENTS  NUMBER TITLE REVISION OP-903-050 Component Cooling Water and Auxiliary Component Cooling Water Pump and Valve Operability Test
28 OP-903-065 Emergency Diesel Generator and Subgroup Relay Operability Verification
307 OP-903-118 Primary Auxiliaries Quarterly IST Valve Tests 31 OP-903-119 Secondary Auxiliaries Quarterly IST Valve Test 18 STA-001-005 Leakage Testing of Air and Nitrogen Accumulators for Safety Related Valves
310 TD-M120.0045
Masoneilan Instruction Manual 2034 for Electro-Pneumatic Positioner Models 8012 & 8012-1-C &


8012-2-C & 8012-3-C
AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES
0 TD-M120.0055 Masoneilan Instruction Manual ES-5000 for Electro-Pneumatic Positioner Models 8012 & 8012-2-C &
  NUMBER                             TITLE                         DATE
 
QA-14115-2011- Quality Assurance Audit - Combined Radiation     November 16, 2011
8012-3-C & 8012-5-C & 8012-6-C
W3-1          Protection and Radwaste
1 W3-DBD-14 Safety Related Air Operated Valves 301
CONDITION REPORTS
CONDITION REPORTS
CR-WF3-2013-2256   CR-WF3-2013-3086       CR-WF3-2013-6848 CR-WF3-2012-06131
  CR-WF3-2013-00451 CR-WF3-2013-00447 CR-WF3-2013-00491 CR-HQN-2013-00709
CR-WF3-2012-0622
CR-WF3-2012-05991 CR-WF3-2012-03280 CR-WF3-2012-02870 CR-WF3-2013-04290
CR-WF3-2013-04332 CR-WF3-2013-04324 CR-WF3-2013-04274 CR-WF3-2012-02870
CR-WF3-2012-03217 CR-WF3-2010-03602 CR-WF3-2013-04047 
WORK ORDERS
  WO 52486712 WO 360921 
Section 1R22:  Surveillance Testing PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION EC 18218 Change CVRIDPIS5220A & B Setpoints 0
EC 18219 Replace CVRIDPIS5220A, B CVRIDPIS5221A, B Design Basis
0 OP-903-050 Component Cooling Water and Auxiliary Component 28 
  A1-9  Section 1R22:  Surveillance Testing PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION Cooling Water Pump and Valve Operability Test OP-903-120 Containment and Mi
scellaneous Systems Quarterly IST Valve Tests
15 W3-DBD-04 Design Basis Document: Component Cooling Water, Auxiliary Component Cooling Water
302 SD-CCS Containment Cooling and Ventilation System Description
7 OP-903-037 Containment Cooling Fan Operability Verification 6 OP-903-037 Safety Injection Pump Operability Verification 19
  WORK ORDERS
  WO 227323 WO 5251325  Section 1EP6:  Drill Evaluation
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION EP Emergency Plan 44 EP-001-001 Recognition and Classification of Emergency
Conditions
30  2RS1 Radiological Hazard Assessment and Exposure Controls (71124.01) PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION EN-RP-101 Access Control for Radiologically Controlled Areas 7
EN-RP-106-01 Radiological Survey Guidelines 0
EN-RP-108 Radiation Protection Postings 13
EN-RP-121 Radioactive Material Control 7
EN-RP-143 Source Control 9
 
  A1-10  AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES
  NUMBER TITLE DATE   QA-14115-2011-
W3-1 Quality Assurance Audit - Combined Radiation Protection and Radwaste November 16, 2011  
CONDITION REPORTS
   
CR-WF3-2013-2256 CR-WF3-2013-3086
CR-WF3-2013-6848
CR-WF3-2012-06131
CR-WF3-2012-0622    
RADIATION SURVEY RECORDS
RADIATION SURVEY RECORDS
  NUMBER TITLE DATE WF3-1212-1262 Reactor Containment Building +46-foot December 23, 2012  
  NUMBER                             TITLE                         DATE
WF3-1210-0434 Reactor Coolant Pump 2B October 20, 2012  
WF3-1212-1262 Reactor Containment Building +46-foot           December 23, 2012
WF3-1211-1617 Reactor Coolant Pump 2B November 24, 2012  
WF3-1210-0434 Reactor Coolant Pump 2B                           October 20, 2012
WF3-1210-0719 Reactor Coolant Pump 2B October 24, 2012  
WF3-1211-1617 Reactor Coolant Pump 2B                         November 24, 2012
WF3-1210-0365 Reactor Coolant Pump 1A October 18, 2012 WF3-1210-0626 Reactor Cavity +21-foot October 23, 2012 WF3-1210-0560 Reactor Containment Building October 22, 2012  
WF3-1210-0719 Reactor Coolant Pump 2B                           October 24, 2012
WF3-1210-0502 Lower Reactor Cavity October 21, 2012  
WF3-1210-0365 Reactor Coolant Pump 1A                           October 18, 2012
WF3-1211-1720 Reactor Coolant Pump 1B November 26, 2012  
WF3-1210-0626 Reactor Cavity +21-foot                           October 23, 2012
WF3-1211-1722 No. 1 Steam Generator Platform November 26, 2012 WF3-1211-1822 D Ring November 27, 2012  
WF3-1210-0560 Reactor Containment Building                     October 22, 2012
WF3-1210-0502 Lower Reactor Cavity                             October 21, 2012
WF3-1211-1720 Reactor Coolant Pump 1B                         November 26, 2012
WF3-1211-1722 No. 1 Steam Generator Platform                   November 26, 2012
WF3-1211-1822 D Ring                                           November 27, 2012
AIR SAMPLE RECORDS
AIR SAMPLE RECORDS
  NUMBER TITLE DATE 112512-003 Reactor Coolant Pump 2B November 24, 2012  
  NUMBER                             TITLE                         DATE
112512-007 Reactor Coolant Pump 2B November 24, 2012  
112512-003     Reactor Coolant Pump 2B                         November 24, 2012
4022475 HP Lapel Sample - Upper Cavity October 20, 2012  
112512-007     Reactor Coolant Pump 2B                         November 24, 2012
4022484 HP Lapel Sample - Canal October 20, 2012  
4022475       HP Lapel Sample - Upper Cavity                   October 20, 2012
5019973 HP Lapel Sample - Canal Under Reactor October 20, 2012 5019974 HP Lapel Sample - Canal Under Reactor October 20, 2012  
4022484       HP Lapel Sample - Canal                           October 20, 2012
SEALED SOURCE INVENTORY AND LEAK TESTS
5019973       HP Lapel Sample - Canal Under Reactor             October 20, 2012
  NUMBER DATE 310182 July 2, 2013  
5019974       HP Lapel Sample - Canal Under Reactor             October 20, 2012
SEALED SOURCE INVENTORY AND LEAK TESTS
  NUMBER                                                             DATE
310182                                                             July 2, 2013
                                        A1-10


 
  2RS2 Occupational ALARA Planning and Controls (71124.02)
  A1-11 2RS2 Occupational ALARA Planning and Controls (71124.02) PROCEDURES/DOCUMENTS
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION EN-RP-105 Radiological Work Permits 012 EN-RP-110 ALARA Program 011  
    NUMBER                               TITLE                             REVISION
EN-RP-110-03 Collective Radiation Exposure (CRE) Reduction  
EN-RP-105     Radiological Work Permits                                     012
Guidelines  
EN-RP-110     ALARA Program                                                 011
002 EN-RP-110-04 Radiation Protection Risk Assessment Process 002 EN-RP-110-05 ALARA Planning and Controls 002 EN-RP-110-06 Outage Dose Estimation and Tracking 001  
EN-RP-110-03   Collective Radiation Exposure (CRE) Reduction                 002
                Guidelines
EN-RP-110-04   Radiation Protection Risk Assessment Process                 002
EN-RP-110-05   ALARA Planning and Controls                                   002
EN-RP-110-06   Outage Dose Estimation and Tracking                           001
  RADIATION WORK PERMIT ALARA PACKAGES
  RADIATION WORK PERMIT ALARA PACKAGES
  NUMBER TITLE DATE  2012-0414 SI-109 "A" and "B" Refurbishing/Repair  
    NUMBER                               TITLE                               DATE
February 25, 2013  
  2012-0414       SI-109 A and B Refurbishing/Repair               February 25, 2013
  2012-0515 RCP 2B Motor Removal and Replacement.
  2012-0515       RCP 2B Motor Removal and Replacement.                 January 10, 2013
January 10, 2013  
  2012-0915       RSG Reactor Coolant System (RCS) Cutting and           January 8, 2013
  2012-0915 RSG Reactor Coolant System (RCS) Cutting and Welding. 
                Welding.
January 8, 2013
  2012-0916       RSG Pipe End Decontamination (PED) Activities and     January 25, 2013
  2012-0916 RSG Pipe End Decontamination (PED) Activities and  
                Support Activities
Support Activities
  2012-0917       RSG Steam Generator Removal/Installation Activities   February 18, 2013
 
                and Support. Including Rigging Activities
January 25, 2013
  2012-0924       RSG Support Structure / Restraints Modifications       February 7, 2013
  2012-0917 RSG Steam Generator Removal/Installation Activities and Support. Including Rigging Activities  
 
February 18, 2013
  2012-0924 RSG Support Structure / Restraints Modifications  
February 7, 2013  
  CONDITION REPORTS
  CONDITION REPORTS
    CR-W3-2012-06441 CR-W3-2012-06446 CR-W3-2012-06502 CR-W3-2012-06515 CR-W3-2012-06543 CR-W3-2012-06593 CR-W3-2012-06660 CR-W3-2012-06770  
CR-W3-2012-06441     CR-W3-2012-06446       CR-W3-2012-06502     CR-W3-2012-06515
CR-W3-2012-06778 CR-W3-2012-06843 CR-W3-2012-06877 CR-W3-2012-06879  
CR-W3-2012-06543     CR-W3-2012-06593       CR-W3-2012-06660     CR-W3-2012-06770
CR-W3-2012-07150 CR-W3-2012-07289 CR-W3-2012-07493 CR-W3-2013-00306  
CR-W3-2012-06778     CR-W3-2012-06843       CR-W3-2012-06877     CR-W3-2012-06879
CR-W3-2013-00344  
CR-W3-2012-07150     CR-W3-2012-07289       CR-W3-2012-07493     CR-W3-2013-00306
 
CR-W3-2013-00344
  A1-12  SURVEYS 
                                          A1-11
WF3-1210-0855 WF3-1210-0859 WF3-1210-0932 WF3-1210-0880 WF3-1211-0112 WF3-1211-0194 WF3-1211-0572 WF3-1211-0948 WF3-1211-1122 WF3-1211-1113 WF3-1211-1116 WF3-1211-1175
WF3-1211-1189 WF3-1211-1313 WF3-1211-1332 WF3-1211-1508
WF3-1211-1571 WF3-1211-1822 WF3-1211-1907 WF3-1212-0179
WF3-1212-0812 WF3-1212-0912 


  MISCELLANEOUS DOCUMENTS
  SURVEYS
  NUMBER TITLE DATE  CR-W3-2013-
WF3-1210-0855        WF3-1210-0859          WF3-1210-0932        WF3-1210-0880
00250 LT - Apparent Cause Evaluation Report Refuel 18  
WF3-1211-0112        WF3-1211-0194          WF3-1211-0572        WF3-1211-0948
Dose Goal Exceeded May 13, 2013  Refuel 18 Outage ALARA Report
WF3-1211-1122        WF3-1211-1113          WF3-1211-1116        WF3-1211-1175
WF3-1211-1189        WF3-1211-1313          WF3-1211-1332        WF3-1211-1508
WF3-1211-1571        WF3-1211-1822          WF3-1211-1907        WF3-1212-0179
WF3-1212-0812        WF3-1212-0912
MISCELLANEOUS DOCUMENTS
    NUMBER                               TITLE                               DATE
  CR-W3-2013-     LT - Apparent Cause Evaluation Report Refuel 18         May 13, 2013
  00250          Dose Goal Exceeded
                Refuel 18 Outage ALARA Report
  2RS5 Radiation Monitoring Instrumentation (71124.05)
  2RS5 Radiation Monitoring Instrumentation (71124.05)
  PROCEDURES/DOCUMENTS
  PROCEDURES/DOCUMENTS
  NUMBER TITLE REVISION  MI-005-906 Radiation Monitoring System Desk Guide 002  
    NUMBER                               TITLE                             REVISION
  MI-003-387 Condenser Vacuum Pump Discharge Wide Range  
  MI-005-906     Radiation Monitoring System Desk Guide                       002
Noble Gas Radiation Monitor Channel Calibration  
  MI-003-387     Condenser Vacuum Pump Discharge Wide Range                     12
(PRMIR0002)  
                Noble Gas Radiation Monitor Channel Calibration
                (PRMIR0002)
MI-003-461      Boric Acid Condensate Discharge Liquid Effluent                12
                Radiation Monitor Channel Calibration (PRMIR0627)
MI-003-371      Fuel Handling Building Ventilation System Emergency          306
                Exhaust High Range Noble Gas Radiation Monitor
                Channel Calibration (PRMIR3032)
MI-003-391      Component Cooling Water System A or B Liquid                  306
                Radiation Monitor Channel Calibration (PRMIR7050A
                or B)
CE-003-321      Use of EG&G Ortec Gamma Spectroscopy System                  303
EN-CY-110      Chemistry Gamma Spectroscopy System Operation                  2
CE-003-332      Use of the Beckman LS6500                                      2
EN-RP-301      Radiation Protection Instrument Control                        5
                                          A1-12


12 MI-003-461 Boric Acid Condensate Discharge Liquid Effluent Radiation Monitor Channel Calibration (PRMIR0627)
    NUMBER                               TITLE                               REVISION
12 MI-003-371 Fuel Handling Building Ventilation System Emergency Exhaust High Range Noble Gas Radiation Monitor
  EN-RP-303-01     Automated Contamination Monitor Performance                     0
 
                  Testing
Channel Calibration (PRMIR3032)
  AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES
 
    NUMBER                               TITLE                                 DATE
306 MI-003-391 Component Cooling Water System A or B Liquid Radiation Monitor Channel Calibration (PRMIR7050A
QS-2012-W3-     Quality Assurance Surveillance Report                     May 15, 2012
 
008
or B)
QA-14/15-2011-   Quality Assurance Audit                               November 10, 2011
306 CE-003-321 Use of EG&G Ortec Gamma Spectroscopy System 303
W3-1
EN-CY-110 Chemistry Gamma Spectroscopy System Operation 2
CE-003-332 Use of the Beckman LS6500 2
EN-RP-301 Radiation Protection Instrument Control 5
 
  A1-13  NUMBER TITLE REVISION  EN-RP-303-01 Automated Contamination Monitor Performance Testing 0 AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES
  NUMBER TITLE DATE  
QS-2012-W3-
008
Quality Assurance Surveillance Report May 15, 2012 QA-14/15-2011-
W3-1 Quality Assurance Audit November 10, 2011  
  CONDITION REPORTS
  CONDITION REPORTS
   
2013-04550           2013-04559             2013-04552             2013-04551
2013-04550 2013-04559 2013-04552 2013-04551  
2012-04918
2012-04918  
 
  RADIATION MONITORING SYSTEM CALIBRATION RECORDS
  RADIATION MONITORING SYSTEM CALIBRATION RECORDS
  WO# NUMBER TITLE DATE  52321504 PRMIR7050A, Cal CCW System Rad Monitor per  
  WO# NUMBER                             TITLE                                 DATE
MI-003-391  
  52321504         PRMIR7050A, Cal CCW System Rad Monitor per               March 1, 2012
  March 1, 2012 52321537 PRMIR0002, Calibrate Electronics as per MI-003-387 August, 2012  
                  MI-003-391
  52321563 PRMIR0627, Cal Boric Acid Cond Disch Liquid Mon  
  52321537         PRMIR0002, Calibrate Electronics as per MI-003-387       August, 2012
MI-003-461  
  52321563         PRMIR0627, Cal Boric Acid Cond Disch Liquid Mon           July 2, 2012
  July 2, 2012 52324842 PRMIR0002, Calibrate Flow Portion per MI003-387 October 15, 2012  
                  MI-003-461
  52335214 PRMIR3032, Calibrate Electronics as per MI-003-371 January 10, 2013  
  52324842         PRMIR0002, Calibrate Flow Portion per MI003-387         October 15, 2012
  52358658 PRMIR3032, Calibrate Flow Portion per MI-003-371 June 3, 2013  
  52335214         PRMIR3032, Calibrate Electronics as per MI-003-371     January 10, 2013
  52358658         PRMIR3032, Calibrate Flow Portion per MI-003-371         June 3, 2013
  PROCEDURES/DOCUMENTS
  PROCEDURES/DOCUMENTS
   NUMBER TITLE REVISION CE-003-300 Preparation of Liquid Samples for Radiological Chemical  
   NUMBER                                 TITLE                               REVISION
Analysis  
CE-003-300     Preparation of Liquid Samples for Radiological Chemical         008
008 
                Analysis
  A1-14  PROCEDURES/DOCUMENTS
                                          A1-13
  NUMBER TITLE REVISION  CE-003-509 Routine Filter Replacement and Grab Sampling on PIG
Monitors and WRGMS


  302 CE-003-512 Liquid Radioactive Waste Release Permit (Manual) 001  
  PROCEDURES/DOCUMENTS
CE-003-513 Gaseous Radioactive Waste Release Permit (Manual) 303  
NUMBER                                  TITLE                      REVISION
CE-003-514 Liquid Radioactive Waste Release Permit (Computer) 301  
CE-003-509    Routine Filter Replacement and Grab Sampling on PIG      302
CE-003-515 Gaseous Radioactive Waste Release Permit (Computer) 303  
              Monitors and WRGMS
CE-003-516 Calculation and Adjustment of Radiation Monitor  
CE-003-512     Liquid Radioactive Waste Release Permit (Manual)         001
Setpoints  
CE-003-513     Gaseous Radioactive Waste Release Permit (Manual)         303
302  CE-003-700 General Grab Sampling Techniques 306  
CE-003-514     Liquid Radioactive Waste Release Permit (Computer)       301
EN-CY-102 Laboratory Analytical Quality Control 004  
CE-003-515     Gaseous Radioactive Waste Release Permit (Computer)       303
EN-CY-108 Monitoring of Nonradioactive Systems 005  
CE-003-516     Calculation and Adjustment of Radiation Monitor           302
EN-CY-113 Response to Contaminated Spills/Leaks 007  
              Setpoints
MM-003-044 Shield Building Ventilation System Surveillance 301  
CE-003-700     General Grab Sampling Techniques                         306
MM-003-045 Control Room Air Conditioning 304  
EN-CY-102     Laboratory Analytical Quality Control                     004
MM-003-046 Controlled Ventilation Area System Surveillance 301  
EN-CY-108     Monitoring of Nonradioactive Systems                     005
UNT-005-014 Offsite Dose Calculation Manual 303  
EN-CY-113     Response to Contaminated Spills/Leaks                     007
AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES
MM-003-044     Shield Building Ventilation System Surveillance           301
  NUMBER TITLE DATE   22873 Audit of GEL Laboratories December 13, 2011  
MM-003-045     Control Room Air Conditioning                             304
WLO-2013-00016 Pre-NRC Inspection Focused Assessment May 3, 2012  
MM-003-046     Controlled Ventilation Area System Surveillance           301
23428 Exelon Nuclear Audit of NUCON International, Inc. March 11, 2013  
UNT-005-014   Offsite Dose Calculation Manual                           303
 
AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES
  A1-15  CONDITION REPORTS
    NUMBER                                 TITLE                       DATE
   
22873           Audit of GEL Laboratories                         December 13, 2011
CR-WF3-2012-00910 CR-WF3-2012-01284 CR-WF3-2012-02107 CR-WF3-2012-02240 CR-WF3-2012-02491 CR-WF3-2012-03509 CR-WF3-2012-03956 CR-WF3-2012-04363 CR-WF3-2012-04571 CR-WF3-2012-04840 CR-WF3-2012-04995 CR-WF3-2012-05597
WLO-2013-00016 Pre-NRC Inspection Focused Assessment                 May 3, 2012
CR-WF3-2012-06182 CR-WF3-2012-06551 CR-WF3-2013-00282 CR-WF3-2013-00318
23428           Exelon Nuclear Audit of NUCON International, Inc.   March 11, 2013
CR-WF3-2013-00677 CR-WF3-2013-02795 CR-WF3-2013-03087 CR-WF3-2013-04547
                                            A1-14
LO-WLO-2013-00016   


CONDITION REPORTS
CR-WF3-2012-00910        CR-WF3-2012-01284      CR-WF3-2012-02107      CR-WF3-2012-02240
CR-WF3-2012-02491        CR-WF3-2012-03509      CR-WF3-2012-03956      CR-WF3-2012-04363
CR-WF3-2012-04571        CR-WF3-2012-04840      CR-WF3-2012-04995      CR-WF3-2012-05597
CR-WF3-2012-06182        CR-WF3-2012-06551      CR-WF3-2013-00282      CR-WF3-2013-00318
CR-WF3-2013-00677        CR-WF3-2013-02795      CR-WF3-2013-03087      CR-WF3-2013-04547
LO-WLO-2013-00016
  10 CFR 50.75(g) CONDITION REPORTS
  10 CFR 50.75(g) CONDITION REPORTS
 
CR-WF3-2011-06065       CR-WF3-2012-02705
CR-WF3-2011-06065 CR-WF3-2012-02705   
EFFLUENT RELEASE PERMITS
PERMIT NO            TYPE                    RELEASE SYSTEM                      DATE
W3LB2012-147        Liquid      Boric Acid Condensate Tank B (BWM)          July 25, 2012
W3LC2012-202        Liquid      Turbine Building Industrial Waste Tank   September 26, 2012
                                (TBIWS)
W3LB2013-066        Liquid      Waste Condensate Tank B (LWM)                April 2, 2013
W3GC2012-079        Gaseous    Plant Stack                                June 27, 2012
EFFLUENT RELEASE PERMITS
PERMIT NO            TYPE                    RELEASE SYSTEM                      DATE
W3GB2013-050        Gaseous    Containment                                  May 9, 2013
W3GC2013-057        Gaseous    Fuel Handling Building                      May 13, 2013
IN-PLACE FILTER TESTING RECORDS
  WORK ORDER                SYSTEM              TRAIN            TEST              DATE
52434436        Shield Building Ventilation      B    Charcoal absorber  December 19, 2012
52321632        Shield Building Ventilation      A    HEPA Filter        February 10, 2012
52351427        Control Room Emergency          B    Charcoal absorber    March 29, 2013
                Filtration Unit
52331428        Control Room Emergency          B    HEPA Filter          March 27, 2013
                Filtration Unit
                                            A1-15


EFFLUENT RELEASE PERMITS
52376581       Controlled Ventilation Area     B   HEPA Filter         June 25, 2013
  PERMIT NO TYPE RELEASE SYSTEM DATE   
52376581       Controlled Ventilation Area     B   Charcoal absorber   June 29, 2013
W3LB2012-147 Liquid Boric Acid Condensate Tank B (BWM) July 25, 2012
W3LC2012-202 Liquid Turbine Building Industrial Waste Tank (TBIWS)
September 26, 2012W3LB2013-066 Liquid Waste Condensate Tank B (LWM) April 2, 2013
W3GC2012-079 Gaseous Plant Stack June 27, 2012
EFFLUENT RELEASE PERMITS
  PERMIT NO TYPE RELEASE SYSTEM DATE  W3GB2013-050 Gaseous Containment May 9, 2013
W3GC2013-057 Gaseous Fuel Handling Building May 13, 2013
IN-PLACE FILTER TESTING RECORDS
  WORK ORDER SYSTEM TRAIN TEST DATE 52434436 Shield Building Ventilation B Charcoal absorber December 19, 201252321632 Shield Building Ventilation A HEPA Filter February 10, 2012
52351427 Control Room Emergency Filtration Unit B Charcoal absorber March 29, 2013 52331428 Control Room Emergency Filtration Unit B HEPA Filter March 27, 2013 
  A1-16  52376581 Controlled Ventilation Area B HEPA Filter June 25, 2013 52376581 Controlled Ventilation Area B Charcoal absorber June 29, 2013  
  MISCELLANEOUS DOCUMENTS
  MISCELLANEOUS DOCUMENTS
  NUMBER TITLE DATE     2011 Annual Radiological Effluent Release Report April 30, 2012  
    NUMBER                                 TITLE                             DATE
  2012 Annual Radiological Effluent Release Report April 30, 2013  
                2011 Annual Radiological Effluent Release Report         April 30, 2012
  Intra-Laboratory Comparison Results 2011   EC-10953 Engineering Change for Modified Release Path to Circulating Water System  
                2012 Annual Radiological Effluent Release Report         April 30, 2013
                Intra-Laboratory Comparison Results                             2011
EC-10953       Engineering Change for Modified Release Path to           May 11, 2009
                Circulating Water System
EC-28466        Engineering Change for Circulating Water System Piping      In Progress
                Rerouting
2RS7 Radiological Environmental Monitoring Program (71124.07)
PROCEDURES/DOCUMENTS
    NUMBER                                  TITLE                          REVISION
CE-003-522      Meteorological Data Collection and Processing                  4
CE-003-523      Meteorological Monitoring Program                              1
CE-003-525      REMP Evaluations and Reports                                  301
CE-003-526      Collection and Preparation of REMP Liquid Samples              302
CE-003-527      Collection of Milk Samples                                      1
CE-003-528      Collection of Sediment Samples                                  1
CE-003-529      Collection of Vegetation Samples                                1
CE-003-530      Collection and Preparation of Fish Sample                      1
CE-003-531      Collection and Preparation of REMP Air Samples                  1
CE-003-532      Preparation and Distribution of REMP Thermoluminescent        301
                  Dosimeters
CE-003-533      REMP Shipping                                                  1
CE-003-534      Land Use Census                                                2
                                          A1-16


May 11, 2009 EC-28466 Engineering Change for Circulating Water System Piping
  ESP-8-069       Radiological Environmental Analytical Services                 00
Rerouting
UNT-005-014     Offsite Dose Calculation Manual                               303
In Progress
PROCEDURES/DOCUMENTS
2RS7 Radiological Environmental Monitoring Program (71124.07) PROCEDURES/DOCUMENTS
    NUMBER                                 TITLE                           REVISION
NUMBER TITLE REVISION CE-003-522 Meteorological Data Collection and Processing 4
EN-QV-108       QA Surveillance Process                                         9
CE-003-523 Meteorological Monitoring Program 1
EN-QV-109       Audit Process                                                 24
CE-003-525 REMP Evaluations and Reports 301
                Quality Assurance Program Manual                               24
CE-003-526 Collection and Preparation of REMP Liquid Samples 302
AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES
CE-003-527 Collection of Milk Samples 1
    NUMBER                                 TITLE                         REVISION
CE-003-528 Collection of Sediment Samples 1
    EN-LI-104   Pre-NRC Inspection Focused Assessment -                       9
CE-003-529 Collection of Vegetation Samples 1
                Effluents and Environmental
CE-003-530 Collection and Preparation of Fish Sample 1
  CONDITION REPORTS
CE-003-531 Collection and Preparation of REMP Air Samples 1
CR-WF3-2012-1360     CR-WF3-2012-2737       CR-WF3-2012-2942     CR-WF3-2012-4067
CE-003-532 Preparation and Distribution of REMP Thermoluminescent
CR-WF3-2012-4281     CR-WF3-2012-4296       CR-WF3-2012-4385     CR-WF3-2012-4408
Dosimeters
CR-WF3-2012-7354     CR-WF3-2012-7487       CR-WF3-2013-1967     CR-WF3-2013-2941
301 CE-003-533 REMP Shipping 1 CE-003-534 Land Use Census 2 
  A1-17 ESP-8-069 Radiological Environmental Analytical Services 00 UNT-005-014 Offsite Dose Calculation Manual 303  
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION EN-QV-108 QA Surveillance Process 9  
EN-QV-109 Audit Process 24  
Quality Assurance Program Manual 24 AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES
  NUMBER TITLE REVISION EN-LI-104 Pre-NRC Inspection Focused Assessment - Effluents and Environmental  
9 CONDITION REPORTS
   
CR-WF3-2012-1360 CR-WF3-2012-2737 CR-WF3-2012-2942 CR-WF3-2012-4067  
CR-WF3-2012-4281
CR-WF3-2012-4296
CR-WF3-2012-4385 CR-WF3-2012-4408 CR-WF3-2012-7354 CR-WF3-2012-7487 CR-WF3-2013-1967 CR-WF3-2013-2941  
  CALIBRATION AND MAINTENANCE RECORDS
  CALIBRATION AND MAINTENANCE RECORDS
   
  NUMBER                                   TITLE                           DATE
NUMBER TITLE DATE  
WO-WF3-52410699         Primary Met Tower Calibration Package         October 2012
WO-WF3-52410699 Primary Met Tower Calibration Package October 2012 WO-WF3-52447365 Primary Met Tower Calibration Package May 2013 WO-WF3-52431357 Secondary Met Tower Calibration Package February 2012  
WO-WF3-52447365         Primary Met Tower Calibration Package           May 2013
WO-WF3-52469672 Secondary Met Tower Calibration Package August 2013  
WO-WF3-52431357         Secondary Met Tower Calibration Package       February 2012
   
WO-WF3-52469672         Secondary Met Tower Calibration Package         August 2013
MISCELLANEOUS DOCUMENTS
  MISCELLANEOUS DOCUMENTS
    TITLE DATE  
                                        TITLE                             DATE
Annual Radiological Environmental Operating Report 2011 Annual Radiological Environmental Operating Report 2012  
                Annual Radiological Environmental Operating Report         2011
Annual Radioactive Effluent Release Report 2011 Annual Radioactive Effluent Release Report 2012 Annual Meteorological Monitoring Program Report 2011  
                Annual Radiological Environmental Operating Report         2012
Annual Meteorological Monitoring Program Report 2012  
                Annual Radioactive Effluent Release Report                 2011
                Annual Radioactive Effluent Release Report                 2012
                Annual Meteorological Monitoring Program Report           2011
                Annual Meteorological Monitoring Program Report           2012
                                          A1-17


 
  2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,
  A1-18 2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation (71124.08) PROCEDURES/DOCUMENTS
        and Transportation (71124.08)
     NUMBER TITLE REVISION  
PROCEDURES/DOCUMENTS
      EN-RP-121 Radioactive Material Control 7 EN-RW-102 Radioactive Shipping Procedure 10  
     NUMBER                                   TITLE                         REVISION
EN-RW-104 Scaling Factors 3  
EN-RP-121       Radioactive Material Control                                   7
RW-002-200 Collection & Packaging of Solid Radwaste  303 RW-002-210 Radioactive Waste Solidification & Dewatering 301 RW-002-240 Package and Handling Radwaste DAW 300  
EN-RW-102       Radioactive Shipping Procedure                                 10
RW-002-300 Blowdown Demineralizer Resin Transfer 300  
EN-RW-104       Scaling Factors                                                 3
RW-002-200       Collection & Packaging of Solid Radwaste                     303
  RW-002-210       Radioactive Waste Solidification & Dewatering                 301
RW-002-240       Package and Handling Radwaste DAW                             300
RW-002-300       Blowdown Demineralizer Resin Transfer                         300
AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES
    NUMBER                                  TITLE                            DATE
NUPIC Audit No.  Energy Solutions Mega Audit                            November 23, 2012
2012-011
EN-LI-104        Pre-Assessment Radioactive Solid Waste Processing        April 24, 2012
                  and Radioactive Material Handling, Storage, and
                  Transportation
QA-14/15-        Quality Assurance Audit Report: Radiation              October 11, 2011
20011-GGNS-1    Protection/Radwaste
CONDITION REPORTS
CR-WF3-2011-07711    CR-WF3-2012-03042        CR-WF3-2012-07168  CR-WF3-2013-00508
CR-WF3-2013-01253    CR-WF3-2013-01682        CR-WF3-2013-02905  CR-WF3-2013-03335
CR-WF3-2013-03952    CR-WF3-2013-04553        CR-WF3-2013-04556  CR-WF3-2013-04557
CR-HQN-2013-00858    CR-HQN-2013-00859
RADIOACTIVE MATERIAL AND WASTE SHIPMENTS
    NUMBER                                  TITLE                            DATE
11-1010          Bead Resin and Dry Active Waste, Oak Ridge, TN          June 23, 2011
11-1011          LWM Resin, Oak Ridge, TN                                August 22, 2011
11-1011          Dewatered Resin, Studsvik Erwin, TN                  September 21, 2011
11-3024          Lead Blankets, 3-Mile Island, Harrisburg, PA          February 25, 2011
12-1008          Dry Active Waste, Energy Solutions, Oak Ridge, TN        June 21,2012
12-1009          SGBD Resin, Energy Solutions, Oak Ridge, TN            October 24, 2012
12-3049          Empty Fuel Cask, Energy Solutions, Oak Ridge, TN        August 9, 2012
                                            A1-18


MISCELLANEOUS DOCUMENTS
AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES
  NUMBER                                 TITLE                       REVISION / DATE
  NUMBER TITLE DATE   NUPIC Audit No.
FSAR Chapter    WSES Updated Final Safety Analysis Report                  12
2012-011  Energy Solutions Mega Audit November 23, 2012 EN-LI-104 Pre-Assessment Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and  
11
FSAR Chapter    WSES Updated Final Safety Analysis Report                  12
12
                2012 Annual Radiological Effluent Release Report      April 30, 2012
                2011 Annual Radiological Effluent Release Report      April 30, 2013
Section 4OA1: Performance Indicator Verification
PROCEDURES/DOCUMENTS
  NUMBER                                TITLE                          REVISION
EN-LI-104       Performance Indicator Process                                6
EN-FAP-OM-005 Nuclear Performance Indicator Process                          0
ECH-NE-09-      Waterford 3 Mitigating System Performance Index Basis        2
00036          Document
MISCELLANEOUS DOCUMENTS
  NUMBER                                TITLE                          REVISION
NEI 99-02      Regulatory Assessment Performance Indicator Guideline        6
Section 4OA2: Identification and Resolution of Problems
PROCEDURES/DOCUMENTS
  NUMBER                                TITLE                          REVISION
EN-LI-102      Corrective Action Process                                    20
EN-LI-119      Apparent Cause Evaluation (ACE) Process                      16
Section 4OA3: Event Follow-Up
PROCEDURES/DOCUMENTS
  NUMBER                                TITLE                          REVISION
LER            Inoperability Of A Safety Related Valve Due To Backup        0
05000382/2012-  Air Accumulator Leakage
007-00
                                          A1-19


Transportation 
Section 4OA5: Other Activities
 
PROCEDURES/DOCUMENTS
April 24, 2012 
    NUMBER                             TITLE                           REVISION
QA-14/15-20011-GGNS-1 
EN-CY-109     Sampling and Analysis of Groundwater Monitoring Wells       2
Quality Assurance Audit Report: Radiation
EN-CY-111     Radiological Ground Water Monitoring Program                 2
Protection/Radwaste 
October 11, 2011 
CONDITION REPORTS
 
CR-WF3-2011-07711 CR-WF3-2012-03042 CR-WF3-2012-07168 CR-WF3-2013-00508
CR-WF3-2013-01253 CR-WF3-2013-01682 CR-WF3-2013-02905 CR-WF3-2013-03335 CR-WF3-2013-03952 CR-WF3-2013-04553 CR-WF3-2013-04556 CR-WF3-2013-04557 CR-HQN-2013-00858 CR-HQN-2013-00859 
 
RADIOACTIVE MATERIAL AND WASTE SHIPMENTS
    NUMBER TITLE DATE    11-1010 Bead Resin and Dry Active Waste, Oak Ridge, TN  June 23, 2011
11-1011 LWM Resin, Oak Ridge, TN August 22, 2011
11-1011 Dewatered Resin, Studsvik Erwin, TN September 21, 2011
11-3024 Lead Blankets, 3-Mile Island, Harrisburg, PA February 25, 2011 12-1008 Dry Active Waste, Energy Solutions, Oak Ridge, TN June 21,2012 12-1009 SGBD Resin, Energy Solutions, Oak Ridge, TN October 24, 2012
12-3049 Empty Fuel Cask, Energy Solutions, Oak Ridge, TN August 9, 2012
 
  A1-19  MISCELLANEOUS DOCUMENTS
NUMBER  TITLE  REVISION / DATE
FSAR Chapter 11 WSES Updated Final Safety Analysis Report 12 FSAR Chapter
12 WSES Updated Final Safety Analysis Report 12  2012 Annual Radiological Effluent Release Report April 30, 2012  2011 Annual Radiological Effluent Release Report April 30, 2013 Section 4OA1:  Performance Indicator VerificationPROCEDURES/DOCUMENTS
NUMBER TITLE REVISION EN-LI-104 Performance Indicator Process 6
EN-FAP-OM-005 Nuclear Performance Indicator Process 0
ECH-NE-09-
00036 Waterford 3 Mitigating System Performance Index Basis Document 2 MISCELLANEOUS DOCUMENTS
NUMBER TITLE REVISION NEI 99-02 Regulatory Assessment Performance Indicator Guideline 6
Section 4OA2:  Identification and Resolution of Problems 
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION EN-LI-102 Corrective Action Process 20 EN-LI-119 Apparent Cause Evaluation (ACE) Process 16
Section 4OA3:  Event Follow-Up PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION LER 05000382/2012-
007-00 Inoperability Of A Safety Related Valve Due To Backup Air Accumulator Leakage
0 
  A1-20  Section 4OA5: Other Activities
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION   EN-CY-109 Sampling and Analysis of Groundwater Monitoring Wells 2  
EN-CY-111 Radiological Ground Water Monitoring Program 2  
CONDITION REPORTS
CONDITION REPORTS
    CR-HQN-2012-00676 CR-HQN-2012-00673 CR-HQN-2013-00861
CR-HQN-2012-00676   CR-HQN-2012-00673     CR-HQN-2013-00861
MISCELLANEOUS DOCUMENTS
MISCELLANEOUS DOCUMENTS
NUMBER TITLE REVISION/
  NUMBER                               TITLE                           REVISION/
DATE LO-WTHQN-2011-123 Focused Self-Assessment Report - NEI 07-07 Compliance - Waterford-3 November 30, 2011  NEI Ground Water Protection Initiative NEI Peer Assessment Report  December 9, 2009 Ground Water Monitoring Plan - Entergy Nuclear Waterford-3 Station  
                                                                          DATE
2
LO-WTHQN-     Focused Self-Assessment Report - NEI 07-07           November 30, 2011
2011-123      Compliance - Waterford-3
              NEI Ground Water Protection Initiative NEI Peer       December 9, 2009
              Assessment Report
              Ground Water Monitoring Plan - Entergy Nuclear               2
              Waterford-3 Station
                                        A1-20
}}
}}

Latest revision as of 12:03, 4 November 2019

IR 05000382-13-004; on 07/01/2013 - 09/30/2013; Waterford Steam Electric Station, Unit 3, Integrated Resident and Regional Report; Fire Protection, Post-Maintenance Testing, and Other Activities
ML13324B133
Person / Time
Site: Waterford Entergy icon.png
Issue date: 11/20/2013
From: Greg Werner
NRC/RGN-IV/DRP/RPB-E
To: Jacobs D
Entergy Operations
References
EA-12-257 IR-13-004
Download: ML13324B133 (66)
v • d • e


See also: IR 05000382/2013004

Text

UNITED STATE S

NUC LEAR REGULATOR Y C OMMI S SI ON

R E G IO N I V

1600 EAST LAMAR BLVD

AR L INGTON , TEXAS 76011- 4511

November 20, 2013

EA-12-257

Donna Jacobs, Vice President, Operations

Entergy Operations, Inc.

Waterford Steam Electric Station, Unit 3

Killona, LA 70057-0751

SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED

INSPECTION REPORT 05000382/2013004

Dear Ms. Jacobs:

On September 30, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an

inspection at your Waterford Steam Electric Station, Unit 3 facility. On October 1, 2013, the

NRC inspectors discussed the results of this inspection with you and other members of your

staff. Inspectors documented the results of this inspection in the enclosed inspection report.

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

Further, inspectors documented a licensee-identified violation which was determined to be a

Severity Level IV in this report. All of these findings involved violations of NRC requirements.

The NRC is treating these violations as non-cited violations (NCVs) consistent with

Section 2.3.2.a of the Enforcement Policy.

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

identified during the closure of unresolved item 05000382/2009010-01, documented in NRC

Inspection Report 05000382/2009010 (ML093100238). This violation was evaluated in

accordance with the NRC Enforcement Policy, dated September 1, 2009, (ML092440278)

which was in effect at the time the special inspection report was issued. In accordance with

Supplement VII, Section C.6, of that Enforcement Policy, this violation would normally be

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

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

surrounding the matter. Since the affected components were already removed from service as

part of an unrelated manufacturers recall and no longer considered a substantial safety hazard,

the NRC concluded this violation is more appropriately assessed as Severity Level IV with a

written response required.

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

enclosed Notice when preparing your response. If you have additional information that you

believe the NRC should consider, you may provide it in your response to the Notice. The NRCs

review of your response to the Notice will also determine whether further enforcement action is

necessary to ensure compliance with regulatory requirements.

D. Jacobs -2-

If you contest the violation or significance of these NCVs, you should provide a response within

30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with

copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, U.S.

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

at the Waterford Steam Electric Station, Unit 3 facility.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a

regulatory requirement in this report, you should provide a response within 30 days of the date

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

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

facility.

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

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

response (if any) will be available 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/ Michael R. Bloodgood for

Gregory E. Werner, Acting Chief

Project Branch E

Division of Reactor Projects

Docket No.: 50-382

License No.: NPF-38

Enclosures:

1. Notice of Violation EA-12-257

2. Inspection Report 05000382/2013004

w/Attachment: Supplemental Information

Electronic Distribution to Waterford Steam Electric Station, Unit 3

ML13324B133

SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials MD

Publicly Avail. Yes No Sensitive Yes No Sens. Type Initials MD

SRI:DRP/E RI:DRP/E C:DRP/E C:DRS/EB1 C:DRS/EB2 C:DRS/OB

MDavis CSpeer GWerner TFarnholtz GMiller VGaddy

/RA/ E /RA/ E /RA/ /RA/ /RA/ /RA/

11/14/13 11/14/13 11/15/13 11/15/13 11/18/13 11/18/13

C:DRS/PSB1 C:DRS/PSB2 C:DRS/TSB C:ORA/ACES BC:DRP/E

MHaire JDrake RKellar HGepford GWerner

/RA/ /RA/ /RA/ /RA/ /RA/MBloodgood for

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

NOTICE OF VIOLATION

Entergy Operations, Inc. Docket No: 50-382

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

EA-12-257

During the NRC inspection conducted from July 20-October 19, 2009, a violation of the NRC

requirements was identified. In accordance with the NRC Enforcement Policy, the violation is

listed below:

Title 10 CFR, Part 21.21(a)(1) requires, in part, that entities subject to the regulations in

this part shall evaluate deviations and failures to comply to identify defects associated

with substantial safety hazards as soon as practicable, and except as provided in

paragraph (a)(2) of this section, in all cases within 60 days of discovery, in order to

identify a reportable defect that could create a substantial safety hazard, were it to

remain uncorrected.

Title 10 CFR, Part 21.21(a)(2) requires, in part, that entities subject to the regulations in

the part shall ensure that if an evaluation of identified deviation or failure to comply

potentially associated with a substantial safety hazard cannot be completed within

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

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

60 days of discovery of the deviation of failure to comply.

Contrary to the above, from December 14, 2008 to April 29, 2010, the licensee failed to

evaluate deviations and failures to comply to identify defects associated with substantial

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

60 days of its discovery, in order to identify a reportable defect or failure to comply that

could create a substantial safety hazard, were it to remain uncorrected.

Specifically, on October 14, 2008, the licensee performed bench testing on an Agastat

E7024PB relay with date code 0835 and noted that the relay had a loose terminal point.

Two more relays were obtained from the warehouse; one of these also had a bad

terminal point. On October 27, 2008, the licensee quarantined the remaining four relays

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

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

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

0835. On January 28, 2009, the licensee received a report from the manufacturer,

which did not provide a cause evaluation. On August 18, 2009, the licensee submitted

Licensee Event Report 2009-003-00, (ML092310548). This Licensee Event Report did

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

Event Report described relays that failed due to incorrect adjustment of terminal blocks,

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

the licensee issued updated Licensee Event Report 2009003-01 (ML101230323). This

revision to the Licensee Event Report described loose terminal points on two spare date

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

April 29, 2010, Licensee Event Report revision would have met Part 21 evaluation and

reporting requirements, but it was 501 days late.

-1- Enclosure 1

This is a Severity Level IV violation (Supplement VII of Enforcement Policy dated September 1,

2009).

Pursuant to the provisions of 10 CFR 2.201, the Waterford Steam Electric Station, Unit 3 is

hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory

Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the

Regional Administrator, Region IV, and a copy to the NRC Resident Inspector at the facility that

is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of

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

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

basis for disputing the violation or severity level, (2) the corrective steps that have been taken

and the results achieved, (3) the corrective steps that will be taken, and (4) the date when full

compliance will be achieved. Your response may reference or include previous docketed

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

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

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

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

shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response, with

the basis for your denial, to the Director, Office of Enforcement, United States Nuclear

Regulatory Commission, Washington, DC 20555-0001.

Because your response will be made available electronically for public inspection in the NRC

Public Document Room or from the NRCs document system (ADAMS), accessible from the

NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not

include any personal privacy, proprietary, or safeguards information so that it can be made

available to the public without redaction. If personal privacy or proprietary information is

necessary to provide an acceptable response, then please provide a bracketed copy of your

response that identifies the information that should be protected and a redacted copy of your

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

specifically identify the portions of your response that you seek to have withheld and provide in

detail the bases for your claim of withholding (e.g., explain why the disclosure of information will

create an unwarranted invasion of personal privacy or provide the information required

by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial

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

provide the level of protection described in 10 CFR 73.21.

Dated this 20th day of November 2013

-2- Enclosure 1

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000382

License: NPF-38

Report: 05000382/2013004

Licensee: Entergy Operations, Inc.

Facility: Waterford Steam Electric Station, Unit 3

Location: 17265 River Road

Killona, LA 70057

Dates: July 1 through September 30, 2013

Inspectors: M. Davis, Senior Resident Inspector

C. Speer, Resident Inspector

T. Farina, Operations Engineer

C. Steely, Operations Engineer

L. Carson, Senior Health Physicist

L. Ricketson, Senior Health Physicist

C. Alldredge, Health Physicist

N. Greene, Health Physicist

P. Hernandez, Health Physicist

J. ODonnell, Health Physicist

E. Ruesch, Senior Reactor Engineer

Approved G. Werner, Acting Chief

By: Project Branch E

Division of Reactor Projects

-1- Enclosure 2

SUMMARY OF FINDINGS

IR 05000382/2013004; 07/01/2013 - 09/30/2013; Waterford Steam Electric Station, Unit 3,

Integrated Resident and Regional Report; Fire Protection, Post-Maintenance Testing, and Other

Activities.

The report covered a 3-month period of inspection by resident inspectors and an announced

baseline inspections by region-based inspectors. Two Green non-cited violations and one

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

color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609, Significance

Determination Process. The cross-cutting aspect is determined using Inspection Manual

Chapter 0310, Components Within the Cross-Cutting Areas. Findings for which the

significance determination process does not apply may be Green or be assigned a severity level

after NRC management review. The NRC's program for overseeing the safe operation of

commercial nuclear power reactors is described in NUREG - 1649, Reactor Oversight

Process, Revision 4, dated December 2006.

A. NRC-Identified Findings and Self-Revealing Findings

Cornerstone: Mitigating Systems

  • Green. The inspectors identified a non-cited violation of Waterfords Facility

Operating License Number NPF-38, License Condition 2.C.9, because the licensee

did not implement fire protection procedure FP-001-014, Duties of a Fire Watch.

Specifically, the licensees fire watch personnel did not implement Section 6.5 of

FP-001-014 to remove firefighting equipment from work areas when securing from a

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

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

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

this condition into their corrective action program as CR-WF3-2013-03398 and

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

restore compliance included the removal of all undercharged fire extinguishers from

deactivated posts and returning them to their proper storage location.

The failure to implement a fire protection program procedure was a performance

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

associated with the protection against external factors (i.e., fire) attribute of the

Mitigating Systems Cornerstone and adversely affected the cornerstone objective of

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

events to prevent undesirable consequences. Specifically, the failure to remove

undercharged fire extinguishers from work areas that contained safe shutdown

equipment could hinder responses to fires in the fire area. The inspectors used the

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

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

Appendix F, Fire Protection Significance Determination Process, to determine the

significance of the finding. The inspectors determined that the finding had a low

degradation rating because it reflected a fire protection program element whose

-2- Enclosure 2

performance and reliability would be minimally impacted. Specifically, in all cases

identified, there were permanent fully charged portable fire extinguishers of the

proper type nearby. Therefore, the finding was of very low safety significance

(Green). The inspectors concluded that the finding reflected current licensee

performance and involved a cross-cutting aspect in the work practices component of

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

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

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

Appendix B, Criterion V, Instructions, Procedures, and Drawings, because the

licensee did not accomplish activities affecting quality on a degraded safety-related

train B component cooling water (CCW) bypass valve (CC-134B) in accordance with

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

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

the operation of a safety-related bypass valve (CC-134B) after maintenance

personnel removed the degraded equipment from service as required by Section

5.10 of EN-MA-101. As a result, the licensee could not characterize and determine

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

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

heat sink following a tornado event. The licensee entered this condition into their

corrective action program as CR-WF3-2012-05991, CR-WF3-2012-06288, and

CR-WF3-2013-04047. The immediate corrective actions taken to restore compliance

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

equipment removed from service when combining preventative and corrective

maintenance tasks in one work order.

The failure to control failed equipment removed from the plant to determine the

cause in accordance with maintenance procedure requirements was a performance

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

associated with the equipment performance attribute of the Mitigating System

Cornerstone and adversely affected the cornerstone objective to ensure the

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

prevent undesirable consequences. Specifically, the degraded condition challenged

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

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

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

Characterization of Findings, to evaluate this issue. The finding required a detailed

analysis because it was potentially risk significant for an external event (tornado).

Therefore, the senior reactor analyst performed a bounding detailed risk evaluation.

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

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

than 3E-7/year. The finding was not significant with respect to the large early

release frequency. The dominant core damage sequences included tornado induced

losses of offsite power, failure of the dry cooling tower pressure boundary, failure to

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

redundant train A component cooling water system combined with the tornado

-3- Enclosure 2

frequency helped to reduce the risk exposure. The inspectors concluded that the

finding reflected current licensee performance and involved a cross-cutting aspect in

the work control component of the human performance area in that the licensee did

not appropriately coordinate work activities by incorporating actions to address the

impact of changes to work scope or activity on plant and human performance

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

Cornerstone: Miscellaneous

when the licensee failed to submit a report or interim report on a deviation in a basic

component within 60 days of discovery.

The failure of the licensee to adequately evaluate deviations in basic components

and to report defects is a performance deficiency. The NRCs significance

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

evaluating their potential safety consequences. This performance deficiency was of

minor safety significance. The traditional enforcement process separately considers

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

violations that result in actual safety consequences. Traditional enforcement applied

to this finding because it involved a violation that impacted the regulatory process.

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

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

significant regulatory concern (Severity Level III), An inadequate review or failure to

review such that, if an appropriate review had been made as required, a

10 CFR Part 21 report would have been made. Based on this example, the NRC

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

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

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

manufacturers recall, the severity of the cited violation is being reduced to Severity

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

violations. (Section 4OA5.2)

B. Licensee-Identified Violations

A violation of very low safety significance (Severity Level IV), which was identified by the

licensee, has been reviewed by the inspectors. Corrective actions taken or planned by

the licensee have been entered into the licensees corrective action program. This

violation and associated corrective action tracking numbers are listed in Section 4OA7 of

this report.

-4- Enclosure 2

PLANT STATUS

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

On September 18, 2013, operators commenced a reactor down power to approximately

82 percent to perform maintenance on the normal level control valve 2B and the heater drain

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

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

REPORT DETAILS

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity and

Emergency Preparedness

1R01 Adverse Weather Protection (71111.01)

Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

Since tropical depression Dorian was forecast in the vicinity of the facility for August 4,

2013, the inspectors reviewed the plant personnels overall preparations and protection

for the expected weather conditions. On August 2, 2013, the inspectors did a partial

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

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

loss of offsite power. The inspectors evaluated the plant staffs preparations against site

procedures and determined that the staffs actions were adequate. During the

inspection, the inspectors focused on plant design features and the licensees

procedures to respond to tornadoes and high winds. The inspectors also toured the

plant grounds to look for any loose debris that could become missiles during a tornado.

The inspectors evaluated operator staffing and accessibility of controls and indications

for those systems required to control the plant. Additionally, the inspectors reviewed the

final safety analysis report and performance requirements for the systems selected for

inspection, and verified that operator actions were appropriate as specified by plant-

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

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

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

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

These activities constitute completion of one sample of impending adverse weather

conditions, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

-5- Enclosure 2

1R04 Equipment Alignment (71111.04)

Partial Walkdown

a. Inspection Scope

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

systems:

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

service for maintenance activities

  • On August 20, 2013, essential chiller AB while essential chiller B was out of

service for maintenance activities

  • On September 5, 2013, auxiliary component cooling water train B while train A

was out of service for maintenance activities

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

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

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

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

discrepancies that could affect the function of the system, and, therefore, potentially

increase risk. The inspectors reviewed applicable operating procedures, system

diagrams, final safety analysis report, technical specification requirements,

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

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

conditions that could have rendered the systems incapable of performing their intended

functions. The inspectors also inspected accessible portions of the systems to verify

system components and support equipment were aligned correctly and operable. The

inspectors examined the material condition of the components and observed operating

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

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

alignment problems that could cause initiating events or impact the capability of

mitigating systems or barriers and entered them into the corrective action program with

the appropriate significance characterization. Specific documents reviewed during this

inspection are listed in the attachment.

These activities constitute completion of three partial system walkdown samples, as

defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

-6- Enclosure 2

1R05 Fire Protection (71111.05)

Quarterly Fire Inspection Tours

a. Inspection Scope

The inspectors conducted fire protection walkdowns that were focused on availability,

accessibility, and the condition of firefighting equipment in the following risk-significant

plant areas:

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

mechanical room

  • On July 30, 2013, reactor auxiliary building, fire area 7, relay room
  • On August 12, 2013, reactor auxiliary building, fire area 39, -35 foot elevation

general area

  • On August 27, 2013, turbine building, fire area 2, turbine building +15.00 foot

elevation west side area

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

protection program that adequately controlled combustibles and ignition sources within

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

passive fire protection features in good material condition; and had implemented

adequate compensatory measures for out of service, degraded or inoperable fire

protection equipment, systems, or features, in accordance with the licensees fire plan.

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

as documented in the plants Individual Plant Examination of External Events with later

additional insights, their potential to affect equipment that could initiate or mitigate a

plant transient, or their impact on the plants ability to respond to a security event. Using

the documents listed in the attachment, the inspectors verified that fire hoses and

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

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

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

be in satisfactory condition and verified that adequate compensatory measures were put

in place by the licensee for out of service, degraded, or inoperable fire protection

equipment systems or features. The inspectors also verified that minor issues identified

during the inspection were entered into the licensees corrective action program.

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

These activities constitute completion of four quarterly fire protection inspection samples,

as defined in Inspection Procedure 71111.05-05.

b. Findings

Introduction. The inspectors identified a Green non-cited violation of Waterfords Facility

Operating License Number NPF-38, License Condition 2.C.9, because the licensee did

-7- Enclosure 2

not implement fire protection procedure FP-001-014, Duties of a Fire Watch.

Specifically, the licensees fire watch personnel did not implement section 6.5 of

FP-001-014 to remove firefighting equipment from work areas when securing from

a fire watch.

Description. On July 18, 2013, during a walkdown of the reactor auxiliary building (RAB)

fire area number two, inspectors identified an undercharged and improperly stored fire

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

The licensee dispatched personnel to remove the extinguisher and discovered two

additional fire extinguishers in the same area with degraded charges. The licensee

initiated condition report CR-WF3-2013-03398 and removed the undercharged fire

extinguishers from the area. Upon further questioning from the inspectors, the licensee

stated that all of the uncharged fire extinguishers identified and removed from this fire

area were equipment used by fire watch personnel during recent hot work activities. The

inspectors reviewed the initial condition report, hot work permits, fire protection program

procedures EN-DC-127, Control of Hot Work and Ignition Sources, and FP-001-014,

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

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

their proper storage location. The inspectors determined that the licensees fire watch

personnel did not implement section 6.5.4.2 of FP-001-014 to remove firefighting

equipment from work areas when securing from a fire watch. The inspectors concluded

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

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

In addition, the inspectors noted that procedure EN-DC-127 stated, in part, that for hot

work, fire watches shall ensure that the proper fire extinguishers are available and fully

charged. The inspectors questioned if the licensee could confirm if the fire extinguishers

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

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

proposed this question, the licensee could not confirm if the fire watch extinguishers

were undercharged because of the improper storage or if personnel was issued

degraded extinguishers. Due to the inspectors questioning, the licensee initiated

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

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

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

inspectors concluded that given the lack of controls over the fire watch extinguishers, the

licensee did not ensure supervisory and management oversight of fire watches. As a

result, the licensee established measures for tracking extinguishers prior to and after

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

all departments with fire watch responsibilities on procedural requirements.

Analysis. The failure to implement a fire protection program procedure was a

performance deficiency. The inspectors determined that this deficiency was reasonably

within the licensees ability to foresee and correct. The performance deficiency was

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

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

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

-8- Enclosure 2

that respond to initiating events to prevent undesirable consequences. Specifically, the

failure to remove undercharged fire extinguishers from work areas could hinder

responses to fires in the area. The inspectors used NRC Inspection Manual

Chapter 0609, Attachment 4, Initial Characterization of Findings, to evaluate this issue.

The initial screening directed the inspectors to use Appendix F, Fire Protection

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

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

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

impacted. Specifically, in accordance with Appendix F, Attachment 2, in all cases

identified, there were fully charged portable fire extinguishers of the proper type nearby.

Therefore, the finding was of very low safety significance (Green). The inspectors

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

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

licensee did not ensure supervisory and management oversight of work activities,

including contractors, such that nuclear safety is supported H.4(c).

Enforcement. Waterfords Facility Operating License Number NPF-38, License

Condition 2.C.9, requires, in part, that the licensee shall implement and maintain in effect

all provisions of the approved fire protection program as described in the Final Safety

Analysis Report for the facility. Final Safety Analysis Report, Section 9.5.1.6.3, specifies

Procedure UNT-005-013, Fire Protection Program, which describes responsibilities,

controls, and implementing requirements for the Waterford 3 Fire Protection Program.

Procedure UNT-005-013, Section 5.9.2 specifies that individual fire watch activities shall

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

Procedure FP-001-014, Section 6.5.4.2, states, in part, that to deactivate a fire watch

post, the fire watch shall return all equipment to their proper storage location.

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

Condition 2.C.9 to implement and maintain in effect all provisions of the approved fire

protection program as described in the final safety analysis report for the facility and as

approved in the Safety Evaluation Report. Specifically, fire watch personnel failed to

return fire extinguishers assigned to fire watches to their proper storage location when

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

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

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

restore compliance was to remove and store fire watch extinguishers to their proper

storage location. The planned corrective actions include establishing a tool to track the

return of all equipment once personnel deactivate a fire watch post.

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

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

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

(NCV 05000382/2013004-02, Failure to Implement Fire Protection Program Procedure

Requirements When Securing from a Fire Watch.

-9- Enclosure 2

1R06 Flood Protection Measures (71111.06)

a. Inspection Scope

The inspectors reviewed the final safety analysis report, the flooding analysis, and plant

procedures to assess susceptibilities involving internal flooding; reviewed the corrective

action program to determine if licensee personnel identified and corrected flooding

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

pumps, level alarm circuits, cable splices subject to submergence, and drainage for

bunkers/manholes; and verified that operator actions for coping with flooding can

reasonably achieve the desired outcomes. The inspectors also inspected the areas

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

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

pumps, level alarms, and control circuits, and temporary or removable flood barriers.

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

  • On September 16, 2013, heater drain pump B motor feeder cable
  • On September 18, 2013, safeguards pump room B

These activities constitute completion of one flood protection measure inspection sample

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

b. Findings

No findings were identified.

1R07 Heat Sink Performance (71111.07)

a. Inspection Scope

On August 14, 2013, the inspectors reviewed licensee programs, verified performance

against industry standards, and reviewed critical operating parameters and maintenance

records for the essential chillers B and A/B. The inspectors verified that performance

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

problems or errors; the licensee utilized the periodic maintenance method outlined in

EPRI Report NP 7552, Heat Exchanger Performance Monitoring Guidelines; the

licensee properly utilized bio-fouling controls; the licensees heat exchanger inspections

adequately assessed the state of cleanliness of their tubes; and the heat exchanger was

correctly categorized under 10 CFR 50.65, Requirements for Monitoring the

Effectiveness of Maintenance at Nuclear Power Plants. Specific documents reviewed

during this inspection are listed in the attachment.

These activities constitute completion of two heat sink inspection sample, as defined in

Inspection Procedure 71111.07-05.

- 10 - Enclosure 2

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

(71111.11)

.1 Quarterly Review of Licensed Operator Requalification Program

a. Inspection Scope

On July 22, 2013, the inspectors observed a crew of licensed operators in the plants

simulator during training. The inspectors assessed the following areas:

  • Licensed operator performance
  • The ability of the licensee to administer the evaluations
  • The modeling and performance of the control room simulator
  • The quality of post-scenario critiques
  • Follow-up actions taken by the licensee for identified discrepancies

These activities constitute completion of one quarterly licensed operator requalification

program sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Quarterly Observation of Licensed Operator Performance

a. Inspection Scope

On September 18, 2013, the inspectors observed the performance of on-shift licensed

operators in the plants main control room. At the time of the observations, the plant was

in a period of heightened activity due to reactivity management maneuvers. The

inspectors observed the operators performance of the following activities:

  • the pre-job brief
  • start-up activities
  • reactivity control

In addition, the inspectors assessed the operators adherence to plant procedures,

including conduct of operations procedure and other operations department policies.

- 11 - Enclosure 2

These activities constitute completion of one quarterly licensed-operator performance

sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.3 Licensed Operator Requalification Biennial Inspection (71111.11B)

The licensed operator requalification program involves two training cycles that are

conducted over a 2-year period. In the first cycle, the annual cycle, the operators are

administered an operating test consisting of job performance measures and simulator

scenarios. In the second part of the training cycle, the biennial cycle, operators are

administered an operating test and a comprehensive written examination.

a. Inspection Scope

To assess the performance effectiveness of the licensed operator requalification

program, the inspectors interviewed training staff, reviewed both the operating tests and

written examinations, and observed ongoing operating test activities.

The inspectors reviewed operator performance on the written exams and operating

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

inspectors, as well as observing exam security measures taken during written exam

administration. The operating tests observed included five job performance measures

and two scenarios that were used in the current biennial requalification cycle,

administered to multiple operators. These observations allowed the inspectors to

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

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

of 8 licensed operators for conformance to license conditions and the licensees system

for tracking qualifications and records of license reactivation.

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

licensees appraisal of operator performance and to determine if feedback of

performance analyses into the requalification training program was being accomplished.

The inspectors interviewed members of the training department and reviewed corrective

actions related to operator errors to assess the responsiveness of the licensed operator

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

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

with the guidance contained in NUREG 1021, "Operator Licensing Examination

Standards for Power Reactors", Revision 9, Supplement 1, and NRC Manual

Chapter 0609, Appendix I, "Operator Requalification Human Performance Significance

Determination Process."

In addition to the above, the inspectors reviewed examination security measures,

simulator fidelity, existing logs of simulator deficiencies, and Problem Identification and

- 12 - Enclosure 2

Resolution records related to training. The inspectors conducted a detailed review for

quality of five full weeks of operating tests and one full written exam.

On August 8, 2013, the licensee informed the lead inspector of the results of the written

examinations and operating tests for the Licensed Operator Requalification Program.

The inspectors compared the written and operating test results to the Appendix I,

Licensed Operator Requalification Significance Determination Process, values and

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

individuals that failed the applicable portions of their exams and/or operating tests were

remediated, retested, and passed their retake exams prior to returning to shift.

The inspectors completed one inspection sample of the biennial licensed operator

requalification program.

b. Findings

One licensee-identified Severity Level IV NCV was evaluated during this inspection. It is

documented in section 4OA7 of this report.

1R12 Maintenance Effectiveness (71111.12)

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk

significant systems:

  • On September 2, 2013, essential chiller B
  • On September 10, 2013, control room air handling unit train A inlet damper

(HCV-103A)

The inspectors reviewed events such as where ineffective equipment maintenance has

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

independently verified the licensee's actions to address system performance or condition

problems in terms of the following:

  • Implementing appropriate work practices
  • Identifying and addressing common cause failures
  • Characterizing system reliability issues for performance
  • Charging unavailability for performance
  • Trending key parameters for condition monitoring

- 13 - Enclosure 2

  • Verifying appropriate performance criteria for structures, systems, and

components classified as having an adequate demonstration of performance

through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as

requiring the establishment of appropriate and adequate goals and corrective

actions for systems classified as not having adequate performance, as described

in 10 CFR 50.65(a)(1)

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

and condition monitoring of the system. In addition, the inspectors verified maintenance

effectiveness issues were appropriately handled by a screening and identification

process and that those issues were entered into the corrective action program with the

appropriate significance characterization. Specific documents reviewed during this

inspection are listed in the attachment.

These activities constitute completion of two maintenance effectiveness samples, as

defined in Inspection Procedure 71111.12-05.

b Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)

a. Inspection Scope

The inspectors reviewed licensee personnel's evaluation and management of plant risk

for the maintenance and emergent work activities affecting risk-significant and safety-

related equipment listed below to verify that the appropriate risk assessments were

performed prior to removing equipment for work:

  • On July 31, 2013, scheduled replacement of reactor trip circuit breaker number 5
  • On August 19, 2013, emergent maintenance on the EDG A2 compressor

component

  • On August 21, 2013, scheduled maintenance on the component cooling water

pump and auxiliary feedwater pump breaker with the EDG A2 and B1 air

compressors out of service

  • On September 3, 2013, scheduled maintenance on the switchgear ventilation

system air handling unit AH-30A with EDG A1 air receiver out of service

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

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

- 14 - Enclosure 2

that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)

and that the assessments were accurate and complete. When licensee personnel

performed emergent work, the inspectors verified that the licensee personnel promptly

assessed and managed plant risk. The inspectors reviewed the scope of maintenance

work, discussed the results of the assessment with the licensee's probabilistic risk

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

risk assessment. The inspectors also reviewed the technical specification requirements

and inspected portions of redundant safety systems, when applicable, to verify risk

analysis assumptions were valid and applicable requirements were met. Specific

documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of four maintenance risk assessments and

emergent work control inspection samples, as defined in Inspection

Procedure 71111.13-05.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments (71111.15)

a. Inspection Scope

The inspectors reviewed the following assessments:

  • On August 5, 2013, pressurizer level control system
  • On August 15, 2013, essential chiller A/B
  • On August 25, 2013, control room air handling unit A inlet damper (HCV-103A)
  • On September 5, 2013, snubber pin (FWSR-60) missing

The inspectors selected these operability and functionality assessments based on the

risk significance of the associated components and systems along with other factors,

such as engineering analysis and judgment, operating experience, and performance

history. The inspectors evaluated the technical adequacy of the evaluations to ensure

technical specification operability was properly justified and to verify the subject

component or system remained available such that no unrecognized increase in risk

occurred. The inspectors compared the operability and design criteria in the appropriate

sections of the technical specifications and final safety analysis report to the licensees

evaluations to determine whether the components or systems were operable. Where

compensatory measures were required to maintain operability, the inspectors

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

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

- 15 - Enclosure 2

documents to verify that the licensee was identifying and correcting any deficiencies

associated with operability evaluations. Specific documents reviewed during this

inspection are listed in the attachment.

These activities constitute completion of five operability evaluations inspection samples,

as defined in Inspection Procedure 71111.15 - 05.

b. Findings

No findings were identified.

1R18 Plant Modifications (71111.18)

.1 Temporary Modifications

a. Inspection Scope

To verify that the safety functions of important safety systems were not degraded, on

August 28, 2013, the inspectors reviewed the temporary modification identified as

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

The inspectors reviewed the temporary modification and the associated safety-

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

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

did not adversely affect the system operability/availability. The inspectors also verified

that the installation and restoration were consistent with the modification documents and

that configuration control was adequate. Additionally, the inspectors verified that the

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

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

effects on mitigating systems and the integrity of radiological barriers.

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

as defined in Inspection Procedure 71111.18-05.

b. Findings

No findings were identified.

.2 Permanent Modifications

a. Inspection Scope

On September 26, 2013, the inspectors reviewed key parameters associated with

materials, replacement components, operations, flow paths, pressure boundary,

ventilation boundary, structural, process medium properties, licensing basis, and failure

modes for the permanent modification identified as EC-46914, main feedwater isolation

valve A nitrogen accumulator B tubing replacement.

- 16 - Enclosure 2

The inspectors verified that modification preparation, staging, and implementation did

not impair emergency/abnormal operating procedure actions, key safety functions, or

operator response to loss of key safety functions; post modification testing will maintain

the plant in a safe configuration during testing by verifying that unintended system

interactions will not occur; systems, structures and components performance

characteristics still meet the design basis; the modification design assumptions were

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

identified and implemented appropriate corrective actions associated with permanent

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

attachment.

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

as defined in Inspection Procedure 71111.18-05.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing (71111.19)

a. Inspection Scope

The inspectors reviewed the following post-maintenance activities to verify that

procedures and test activities were adequate to ensure system operability and functional

capability:

control valve (EFW-223A)

  • On July 30, 2013, dry cooling tower B component cooling water bypass valve

(CC-134B)

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

compressor pressure switch

  • On September 24, 2013, replaced control room air handling unit A inlet damper

(HCV-103A)

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

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

following (as applicable):

  • The effect of testing on the plant had been adequately addressed; testing was

adequate for the maintenance performed

- 17 - Enclosure 2

  • Acceptance criteria were clear and demonstrated operational readiness; test

instrumentation was appropriate

The inspectors evaluated the activities against the technical specifications, the final

safety analysis report, 10 CFR Part 50 requirements, licensee procedures, and various

NRC generic communications to ensure that the test results adequately ensured that the

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

reviewed corrective action documents associated with post-maintenance tests to

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

corrective action program and that the problems were being corrected commensurate

with their importance to safety. Specific documents reviewed during this inspection are

listed in the attachment.

These activities constitute completion of five post-maintenance testing inspection

samples, as defined in Inspection Procedure 71111.19-05.

b. Findings

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

Procedure Requirements

Introduction. The inspectors identified a Green non-cited violation of 10 CFR Part 50,

Appendix B, Criterion V, Instructions, Procedures, and Drawings, because the

licensee did not control and determine the extent of leaking safety-related bypass valve

associated with the dry cooling tower B component cooling water solenoid valve

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

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

Description. On October 31, 2012, the licensee conducted a post-maintenance leak test

on the actuator for a safety-related air operate solenoid valve CC-134B. During the

process of conducting the leak test, maintenance personnel identified air coming from

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

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

operable status. However, the licensee did not retain the original solenoid valve for

testing to determine the cause or extent of the leakage. Without supporting information

regarding the leak rate or cause, the licensee assumed that CC-134B and its air

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

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

The licensee initiated a condition report and performed an apparent cause evaluation.

The inspectors performed a review of the apparent cause evaluation, the event timeline,

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

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

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

result, the licensee could not characterize and determine the cause of the leakage for

the safety-related valve. The inspectors determined that the licensee did not accomplish

- 18 - Enclosure 2

activities in accordance with maintenance procedure EN-MA-101, Fundamentals of

Maintenance. Section 5.10, Control of Failed Plant Equipment, of EN-MA-101,

requires, in part, that the licensee control failed equipment removed from the plant to

determine necessary testing to establish the cause of the failure.

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

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

The licensee combined a corrective maintenance with a preventative maintenance task

into the existing work order for CC-134B during the replacement of the solenoid valve.

This led to an error-trap, as explicit instructions for retaining failed parts were not a part

of the preventative maintenance tasks. The immediate corrective actions taken to

restore compliance included the installation of a new valve and debriefing personnel

about controlling equipment removed from service when combining preventative and

corrective maintenance tasks in one work order. The licensee entered this condition into

their corrective action program as Condition Reports CR-WF3-2012-05991 and

CR-WF3-2012-06288. However, inspectors questioned the effectiveness of the original

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

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

a briefing did not provide an adequate barrier to prevent this from happening again. As

a result, the licensee initiated CR-HQN-2013-00709 and CR-WF3-2013-04047 to

determine additional corrective actions to address the error trap. The inspectors

determined that the licensee did not appropriately coordinate work activities by

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

human performance.

Analysis. The failure to control failed equipment removed from the plant to determine

the cause was a performance deficiency. The inspectors determined that this deficiency

was reasonably within the licensees ability to foresee and correct. The performance

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

performance attribute of the Mitigating System Cornerstone and adversely affected the

cornerstone objective to ensure the availability, reliability, and capability of systems that

respond to initiating events to prevent undesirable consequences. Specifically, the

degraded condition challenged the safety function of valve CC-134B to limit the loss of

component cooling water through damaged portions of the dry cooling towers following a

tornado-generated missile strike.

The inspectors used NRC Inspection Manual Chapter 0609, Attachment 4, Initial

Characterization of Findings, and Appendix A, The Significance Determination Process

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

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

external event (tornado) based on using Exhibit 4, External Events Screening

Questions. Therefore, the senior reactor analyst performed the following bounding

detailed risk evaluation:

Tornado Statistics: About one out of every three tornadoes (29 percent) is classified as

"strong." Strong tornadoes have an average path length of 9 miles and a path width of

200 yards (approximately 1 square mile of land affected). Although very rare

- 19 - Enclosure 2

(about 2 percent are violent), violent tornadoes can last for hours. Average path lengths

and widths are 26 miles and 425 yards, respectively.

Since the strong tornadoes can affect approximately 1 square mile, weaker tornadoes,

on average, would affect significantly less than 1 square mile. Most tornadoes are of the

weaker variety. Violent tornadoes can affect approximately 6 to 7 square miles (on

average), but are relatively rare. Therefore, the analyst assumed that the average

tornado would affect 1 square mile of land.

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

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

Plant Area: For this risk evaluation, the analyst assumed that the Waterford-3 nuclear

island and switchyard occupied one square mile of land. This was conservative, in that

this equipment occupies less than one square mile.

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

cause a loss of offsite power and cause physical damage to the train B dry cooling tower

train. This in turn would cause the B component cooling water train to fail. Because the

dry cooling towers are at least partially protected from missiles by the surrounding

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

damaging this equipment.

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

and switchyard was therefore:

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

Calculations: The analyst used the NRCs Waterford-3 Standardized Plant Analysis

Risk (SPAR) model, Revision 8.16, with a truncation limit of E-11, to evaluate this

finding. The analyst assumed a full year exposure period.

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

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

component cooling water system. To account for an earlier finding at Waterford-3, the

analyst set the basic event for alternate room cooling to 1.0. The analyst used this

adjustment in both the nominal case (no performance deficiency) and the current case

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

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

case CCDP was 2.15E-4.

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

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

CCDP was 5.9E-3.

- 20 - Enclosure 2

The initial ICCDP was therefore the difference between the nominal and current case

CCDPs = 5.7E-3.

The analyst considered recovery of the instrument air system. As noted in Licensee

Event Report 2012-007, dated December 31, 2012, operators could recover an

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

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

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

probability of 0.1 for this action. The nominal non-recovery probability as specified in

NUREG/CR-6883, The SPAR-H Human Reliability Analysis Method, was 1.1E-2.

Therefore, 0.1 was conservative when compared to 1.1E-2. The resultant ICCDP,

considering recovery, was 5.7E-4.

The change to the core damage frequency (delta CDF) was the tornado frequency

multiplied by the ICCDP = 5.2E-4/yr * 5.7E-4 = 2.9E-7/yr.

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

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

cooling tower, and failure to recovery instrument air. The redundant train A component

cooling water system combined with the tornado frequency helped to reduce the risk

exposure.

Large Early Release Frequency (LERF): To address the contribution to conditional large

early release frequency, the analyst used NRC Inspection Manual Chapter 0609,

Appendix H, Containment Integrity Significance Determination Process, dated May 6,

2004. The finding was not significant to LERF because it did not directly affect the

steam generator tube rupture or the intersystem loss of coolant accident sequences.

The inspectors concluded that the finding reflected current licensee performance and

involved a cross-cutting aspect in the work control component of the human

performance area in that the licensee did not appropriately coordinate work activities by

incorporating actions to address the impact changes to work scope or activity on plant

and human performance H.3(b).

Enforcement. Title 10 of CFR, Part 50, Appendix B, Criterion V, Instructions,

Procedures, and Drawings, requires, in part, that activities affecting quality shall be

prescribed by documented instructions, procedures, or drawings, of a type appropriate to

the circumstances and shall be accomplished in accordance with these instructions,

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

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

part, that it be determined whether the component should be tested to establish cause

of failure before it is scrapped.

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

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

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

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

- 21 - Enclosure 2

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

valves failure. Consequently, the licensee assumed that the valve was unable to fulfill

its safety function if called upon after a tornado-generated missile strike on dry cooling

tower train B. The licensee entered this condition into their corrective action program

as Condition Reports CR-WF3-2012-05991, CR-WF3-2012-06288, and

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

immediate corrective action taken to restore compliance included replacing the leaking

valve and to brief personnel about the potential problems regarding combining

preventative and corrective maintenance tasks in one work order.

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

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

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

NCV 05000382/2013004-03, Failure to Accomplish Activities Affecting Quality on a

Degraded Safety-Related Solenoid Valve In Accordance With Procedure Requirements.

1R22 Surveillance Testing (71111.22)

a. Inspection Scope

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

and reviewed the final safety analysis report, procedure requirements, and technical

specifications to ensure that the surveillance activities listed below demonstrated that the

systems, structures, and/or components tested were capable of performing their

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

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

following:

  • Preconditioning
  • Evaluation of testing impact on the plant
  • Acceptance criteria
  • Test equipment
  • Procedures
  • Jumper/lifted lead controls
  • Test data
  • Testing frequency and method demonstrated technical specification operability
  • Test equipment removal
  • Restoration of plant systems

- 22 - Enclosure 2

  • Fulfillment of ASME Code requirements
  • Updating of performance indicator data
  • Engineering evaluations, root causes, and bases for returning tested systems,

structures, and components not meeting the test acceptance criteria were correct

  • Reference setting data

The inspectors also verified that licensee personnel identified and implemented any

needed corrective actions associated with the surveillance testing.

  • On August 6, 2013, surveillance test on containment vacuum relief train A control

valve CVR-201A (in-service test)

  • On August 19, 2013, surveillance test on auxiliary component cooling water

pump B (in-service test)

  • On August 22, 2013, surveillance test on containment cooling fans
  • On August 28, 2013, surveillance test on low pressure safety injection pump A
  • On September 9, 2013, surveillance test on component cooling water pump A/B

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

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

defined in Inspection Procedure 71111.22-05.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation (71114.06)

Training Observations

a. Inspection Scope

The inspectors observed a simulator training evolution for licensed operators on

July 22, 2013, this required emergency plan implementation by a licensee operations

crew. This evolution was planned to be evaluated and included in performance indicator

- 23 - Enclosure 2

data regarding drill and exercise performance. The inspectors observed event

classification and notification activities performed by the crew. The inspectors also

attended the post evolution critique for the scenario. The focus of the inspectors

activities was to note any weaknesses and deficiencies in the crews performance and

ensure that the licensee evaluators noted the same issues and entered them into the

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

scenario package and other documents listed in the attachment.

These activities constitute completion of one training observation sample, as defined in

Inspection Procedure 71114.06-05.

b. Findings

No findings were identified.

2. RADIATION SAFETY

Cornerstone: Public Radiation Safety and Occupational Radiation Safety

2RS01 Radiological Hazard Assessment and Exposure Controls (71124.01)

a. Inspection Scope

This area was inspected to: (1) review and assess licensees performance in assessing

the radiological hazards in the workplace associated with licensed activities and the

implementation of appropriate radiation monitoring and exposure control measures for

both individual and collective exposures, (2) verify the licensee is properly identifying

and reporting Occupational Radiation Safety Cornerstone performance indicators, and

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

indicator and which may have represented a substantial potential for overexposure of

the worker.

The inspectors used the requirements in 10 CFR Part 20, the technical specifications,

and the licensees procedures required by technical specifications as criteria for

determining compliance. During the inspection, the inspectors interviewed the radiation

protection manager, radiation protection supervisors, and radiation workers. The

inspectors performed walkdowns of various portions of the plant, performed independent

radiation dose rate measurements and reviewed the following items:

  • Performance indicator events and associated documentation reported by the

licensee in the Occupational Radiation Safety Cornerstone

  • The hazard assessment program, including a review of the licensees evaluations

of changes in plant operations and radiological surveys to detect dose rates,

airborne radioactivity, and surface contamination levels

- 24 - Enclosure 2

  • Instructions and notices to workers, including labeling or marking containers of

radioactive material, radiation work permits, actions for electronic dosimeter

alarms, and changes to radiological conditions

  • Programs and processes for control of sealed sources and release of potentially

contaminated material from the radiologically controlled area, including survey

performance, instrument sensitivity, release criteria, procedural guidance, and

sealed source accountability

  • Radiological hazards control and work coverage, including the adequacy of

surveys, radiation protection job coverage, and contamination controls; the use of

electronic dosimeters in high noise areas; dosimetry placement; airborne

radioactivity monitoring; controls for highly activated or contaminated materials

(non-fuel) stored within spent fuel and other storage pools; and posting and

physical controls for high radiation areas and very high radiation areas

  • Radiation worker and radiation protection technician performance with respect to

radiation protection work requirements

activities

  • Project staffing and training plans for the previous steam generator replacement

activities

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

hazard assessment and exposure controls since the last inspection

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

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

Inspection Procedure 71124.01-05.

b. Findings

No findings were identified.

2RS02 Occupational ALARA Planning and Controls (71124.02)

a. Inspection Scope

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

individual and collective radiation exposures as low as is reasonably achievable

(ALARA). The inspectors used the requirements in 10 CFR Part 20, the technical

specifications, and the licensees procedures required by technical specifications as

criteria for determining compliance. During the inspection, the inspectors interviewed

licensee personnel and reviewed the following items:

- 25 - Enclosure 2

  • Site-specific ALARA procedures and collective exposure history, including the

current 3-year rolling average, site-specific trends in collective exposures, and

source-term measurements

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

exposure mitigation requirements

  • The methodology for estimating work activity exposures, the intended dose

outcome, the accuracy of dose rate and man-hour estimates, and intended

versus actual work activity doses and the reasons for any inconsistencies

  • Records detailing the historical trends and current status of tracked plant source

terms and contingency plans for expected changes in the source term due to

changes in plant fuel performance issues or changes in plant primary chemistry

  • Radiation worker and radiation protection technician performance during work

activities in radiation areas, airborne radioactivity areas, or high radiation areas

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

planning and controls since the last inspection

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

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

Inspection Procedure 71124.02-05.

b. Findings

No findings were identified.

2RS05 Radiation Monitoring Instrumentation (71124.05)

a. Inspection Scope

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

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

workers to ensure a radiologically safe work environment; and (2) detect and quantify

radioactive process streams and effluent releases. The inspectors used the

requirements in 10 CFR Part 20, the technical specifications, and the licensees

procedures required by technical specifications as criteria for determining compliance.

During the inspection, the inspectors interviewed licensee personnel, performed

walkdowns of various portions of the plant, and reviewed the following items:

  • Selected plant configurations and alignments of process, postaccident, and

effluent monitors with descriptions in the Final Safety Analysis Report and the

offsite dose calculation manual

- 26 - Enclosure 2

  • Select instrumentation, including effluent monitoring instrument, portable survey

instruments, area radiation monitors, continuous air monitors, personnel

contamination monitors, portal monitors, and small article monitors to examine

their configurations and source checks

  • Calibration and testing of process and effluent monitors, laboratory

instrumentation, whole body counters, postaccident monitoring instrumentation,

portal monitors, personnel contamination monitors, small article monitors,

portable survey instruments, area radiation monitors, electronic dosimetry, air

samplers, continuous air monitors

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

monitoring instrumentation since the last inspection

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

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

Inspection Procedure 71124.05-05.

b. Findings

No findings were identified.

2RS06 Radioactive Gaseous and Liquid Effluent Treatment (71124.06)

a. Inspection Scope

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

systems are maintained so radiological discharges are properly mitigated, monitored,

and evaluated with respect to public exposure; (2) ensure abnormal radioactive gaseous

or liquid discharges and conditions, when effluent radiation monitors are out-of-service,

are controlled in accordance with the applicable regulatory requirements and licensee

procedures; (3) verify the licensees quality control program ensures the radioactive

effluent sampling and analysis requirements are satisfied so discharges of radioactive

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

dose projections resulting from radioactive effluent discharges. The inspectors used the

requirements in 10 CFR Part 20; 10 CFR Part 50, Appendices A and I; 40 CFR Part 190;

the Offsite Dose Calculation Manual, and licensee procedures required by the Technical

Specifications as criteria for determining compliance. The inspectors interviewed

licensee personnel and reviewed and/or observed the following items:

  • Radiological effluent release reports since the previous inspection and reports

related to the effluent program issued since the previous inspection, if any

  • Effluent program implementing procedures, including sampling, monitor setpoint

determinations and dose calculations

- 27 - Enclosure 2

  • Equipment configuration and flow paths of selected gaseous and liquid discharge

system components, filtered ventilation system material condition, and significant

changes to their effluent release points, if any, and associated 10 CFR 50.59

reviews

  • Selected portions of the routine processing and discharge of radioactive gaseous

and liquid effluents (including sample collection and analysis)

  • Controls used to ensure representative sampling and appropriate compensatory

sampling

  • Results of the inter-laboratory comparison program
  • Effluent stack flow rates
  • Surveillance test results of technical specification-required ventilation effluent

discharge systems since the previous inspection

  • Significant changes in reported dose values, if any
  • A selection of radioactive liquid and gaseous waste discharge permits
  • Part 61 analyses and methods used to determine which isotopes are included in

the source term

  • Meteorological dispersion and deposition factors
  • Latest land use census
  • Records of abnormal gaseous or liquid tank discharges, if any
  • Groundwater monitoring results
  • Changes to the licensees written program for indentifying and controlling

contaminated spills/leaks to groundwater, if any

records, if any, and associated evaluations of the extent of the contamination and

the radiological source term

  • Offsite notifications, and reports of events associated with spills, leaks, or

groundwater monitoring results, if any

- 28 - Enclosure 2

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

radioactive gaseous and liquid effluent treatment since the last inspection

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

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

Inspection Procedure 71124.06-05.

b. Findings

No findings were identified.

2RS07 Radiological Environmental Monitoring Program (71124.07)

a. Inspection Scope

This area was inspected to: (1) ensure that the radiological environmental monitoring

program verifies the impact of radioactive effluent releases to the environment and

sufficiently validates the integrity of the radioactive gaseous and liquid effluent release

program; (2) verify that the radiological environmental monitoring program is

implemented consistent with the licensees technical specifications and/or offsite dose

calculation manual, and to validate that the radioactive effluent release program meets

the design objective contained in Appendix I to 10 CFR Part 50; and (3) ensure that the

radiological environmental monitoring program monitors non-effluent exposure

pathways, is based on sound principles and assumptions, and validates that doses to

members of the public are within the dose limits of 10 CFR Part 20 and

40 CFR Part 190, as applicable. The inspectors reviewed and/or observed the following

items:

  • Selected air sampling and thermoluminescence dosimeter monitoring stations
  • Collection and preparation of environmental samples

Operability, calibration, and maintenance of meteorological instruments

  • Selected events documented in the annual environmental monitoring report

which involved a missed sample, inoperable sampler, lost thermo luminescence

dosimeter, or anomalous measurement

  • Selected structures, systems, or components that may contain licensed material

and has a credible mechanism for licensed material to reach ground water

- 29 - Enclosure 2

as the result of changes to the land census or sampler station modifications since

the last inspection

  • Calibration and maintenance records for selected air samplers and

environmental sample radiation measurement instrumentation

  • Inter-laboratory comparison program results
  • Audits, self-assessments, reports, and corrective action documents related to the

radiological environmental monitoring program since the last inspection

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

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

Inspection Procedure 71124.07-05.

b. Findings

No findings were identified.

2RS08 Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage,

and Transportation (71124.08)

a. Inspection Scope

This area was inspected to verify the effectiveness of the licensees programs for

processing, handling, storage, and transportation of radioactive material. The inspectors

used the requirements of 10 CFR Parts 20, 61, and 71 and Department of

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

compliance. The inspectors interviewed licensee personnel and reviewed the following

items:

scope of the licensees audit program

  • Control of radioactive waste storage areas including container labeling/marking

and monitoring containers for deformation or signs of waste decomposition

  • Changes to the liquid and solid waste processing system configuration including

a review of waste processing equipment that is not operational or abandoned in

place

  • Radio-chemical sample analysis results for radioactive waste streams and use of

scaling factors and calculations to account for difficult-to-measure radionuclides

- 30 - Enclosure 2

  • Processes for waste classification including use of scaling factors and

10 CFR Part 61 analysis

  • Shipment packaging, surveying, labeling, marking, placarding, vehicle checking,

driver instructing, and preparation of the disposal manifest

  • Audits, self-assessments, reports, and corrective action reports radioactive solid

waste processing, and radioactive material handling, storage, and transportation

performed since the last inspection

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

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

Inspection Procedure 71124.08-05.

b. Findings

No findings were identified.

4. OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency

Preparedness, Public Radiation Safety, Occupational Radiation Safety, and

Security Protection

4OA1 Performance Indicator Verification (71151)

.1 Data Submission Issue

a. Inspection Scope

The inspectors performed a review of the performance indicator data submitted by the

licensee for the second Quarter 2013 performance indicators for any obvious

inconsistencies prior to its public release in accordance with Inspection Manual

Chapter 0608, Performance Indicator Program.

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

as such, did not constitute a separate inspection sample.

b. Findings

No findings were identified.

- 31 - Enclosure 2

.2 Safety System Functional Failures (MS05)

a. Inspection Scope

The inspectors sampled licensee submittals for the safety system functional failures

performance indicator for the period from the fourth quarter 2012 through the

second quarter 2013. To determine the accuracy of the performance indicator data

reported during those periods, the inspectors used definitions and guidance contained in

NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline,

Revision 6, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73."

The inspectors reviewed the licensees operator narrative logs, operability assessments,

maintenance rule records, maintenance work orders, issue reports, event reports, and

NRC integrated inspection reports for the period of October 2012 through September

2013 to validate the accuracy of the submittals. The inspectors also reviewed the

licensees issue report database to determine if any problems had been identified with

the performance indicator data collected or transmitted for this indicator and none were

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

These activities constitute completion of one safety system functional failures sample, as

defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

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

a. Inspection Scope

The inspectors sampled licensee submittals for the mitigating systems performance

index - residual heat removal system performance indicator for the period from the third

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

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

and guidance contained in NEI Document 99-02, Regulatory Assessment Performance

Indicator Guideline, Revision 6. The inspectors reviewed the licensees operator

narrative logs, issue reports, mitigating systems performance index derivation reports,

event reports, and NRC integrated inspection reports for the period of July 2012 through

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

mitigating systems performance index component risk coefficient to determine if it had

changed by more than 25 percent in value since the previous inspection, and if so, that

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

reviewed the licensees issue report database to determine if any problems had been

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

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

to this report.

These activities constitute completion of one mitigating systems performance index -

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

- 32 - Enclosure 2

b. Findings

No findings were identified.

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

a. Inspection Scope

The inspectors sampled licensee submittals for the mitigating systems performance

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

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

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

guidance contained in NEI Document 99-02, Regulatory Assessment Performance

Indicator Guideline, Revision 6. The inspectors reviewed the licensees operator

narrative logs, issue reports, mitigating systems performance index derivation reports,

event reports, and NRC integrated inspection reports for the period of July 2012 through

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

mitigating systems performance index component risk coefficient to determine if it had

changed by more than 25 percent in value since the previous inspection, and if so, that

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

reviewed the licensees issue report database to determine if any problems had been

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

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

to this report.

These activities constitute completion of one mitigating systems performance index -

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

b. Findings

No findings were identified.

.5 Occupational Exposure Control Effectiveness (OR01)

a. Inspection Scope

Cornerstone: Occupational Radiation Safety

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

the third quarter 2013. The objective of the inspection was to determine the accuracy

and completeness of the performance indicator data reported during these periods. The

inspectors used the definitions and clarifying notes contained in NEI Document 99-02,

Regulatory Assessment Performance Indicator Guideline, Revision 6, as criteria for

determining whether the licensee was in compliance.

- 33 - Enclosure 2

The inspectors reviewed corrective action program records associated with high

radiation area (greater than 1 rem/hr) and very high radiation area nonconformances.

The inspectors reviewed radiological, controlled area exit transactions greater than

100 mrem. The inspectors also conducted walkdowns of high radiation areas (greater

than 1 rem/hr) and very high radiation area entrances to determine the adequacy of the

controls of these areas.

These activities constitute completion of the occupational exposure control effectiveness

sample as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

.6 Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual

Radiological Effluent Occurrences (PR01)

a. Inspection Scope

Cornerstone: Public Radiation Safety

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

third quarter 2013. The objective of the inspection was to determine the accuracy and

completeness of the performance indicator data reported during these periods. The

inspectors used the definitions and clarifying notes contained in NEI Document 99-02,

Regulatory Assessment Performance Indicator Guideline, Revision 6, as criteria for

determining whether the licensee was in compliance.

The inspectors reviewed the licensees corrective action program records and selected

individual annual or special reports to identify potential occurrences such as

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

impacted offsite dose.

These activities constitute completion of the radiological effluent technical

specifications/offsite dose calculation manual radiological effluent occurrences sample

as defined in Inspection Procedure 71151-05.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution (71152)

.1 Routine Review of Identification and Resolution of Problems

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of

this report, the inspectors routinely reviewed issues during baseline inspection activities

- 34 - Enclosure 2

and plant status reviews to verify that they were being entered into the licensees

corrective action program at an appropriate threshold, that adequate attention was being

given to timely corrective actions, and that adverse trends were identified and

addressed. The inspectors reviewed attributes that included the complete and accurate

identification of the problem; the timely correction, commensurate with the safety

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

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

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

of corrective actions. Minor issues entered into the licensees corrective action program

because of the inspectors observations are included in the attached list of documents

reviewed.

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

any additional inspection samples. Instead, by procedure, they were considered an

integral part of the inspections performed during the quarter and documented in

Section 1 of this report.

c. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific

human performance issues for follow-up, the inspectors performed a daily screening of

items entered into the licensees corrective action program. The inspectors

accomplished this through review of the stations daily corrective action documents.

The inspectors performed these daily reviews as part of their daily plant status

monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings were identified.

.3 In-depth Review of Operator Workarounds

a. Inspection Scope

On August 14, 2013, during a review of items entered in the licensees corrective action

program, the inspectors reviewed operator workarounds and burdens. The inspectors

considered the following during the review of the licensees actions: (1) complete and

accurate identification of problems in a timely manner; (2) evaluation and disposition of

operability/reportability issues; (3) consideration of extent of condition, generic

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

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

- 35 - Enclosure 2

causes of the problem; (6) identification of corrective actions; and (7) completion of

corrective actions in a timely manner.

These activities constitute completion of one in-depth problem identification and

resolution sample as defined in Inspection Procedure 71152-05

b. Findings

No findings were identified.

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

.1 (Closed) Licensee Event Report 05000382/2012-007-00, Inoperability Of A Safety

Related Valve Due To Backup Air Accumulator Leakage

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

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

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

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

determining the cause or rate of leakage. The licensee determined on November 1,

2012, that the solenoid valve leakage could have adversely affected the backup air

accumulator relied on to allow valve CC-134B to fulfill its safety function in the event that

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

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

because the rate of the leakage was unknown. As part of the review of this event, the

inspectors identified a Green non-cited violation 05000382/2013004-03, Failure to

accomplish activities affecting quality on a degraded safety-related solenoid valve in

accordance with procedure requirements. The inspectors documented this violation of

NRC requirements in Section 1R19 of this report. This licensee event report is closed.

4OA5 Other Activities

.1 (Closed) Temporary Instruction 2515/185, Follow-up on the Industrys Ground Water

Protection Initiative

a. Inspection Scope

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

determine whether the licensee had implemented the program elements which were

found to be incomplete when previously reviewed during NRC Inspection Report 05000382/2012003. Inspectors interviewed cognizant licensee personnel and

performed walk-downs.

b. Findings

The following element had been implemented since the previous review:

- 36 - Enclosure 2

  • Element 1.4.a - Establish written procedures outlining the decision making

process for remediation of leaks and spills or other instances of inadvertent

releases.

The following element had not been implemented since the previous review and is

documented in the corrective action document listed with the element:

  • Element 1.3.f - Establish a long-term program for preventative maintenance of

ground water wells (CR-HQN-2013-00861). This element lacked an

implementing procedure or process. Additionally, the appropriateness for

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

has yet to be determined.

.2 (Closed) Unresolved Item 05000382/2009010-01, Failures to Evaluate Adverse

Conditions for Reportability to the NRC

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

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

this inspection, the team identified two examples in which the licensee failed to

adequately review a deviation observed in specific batches of relays to determine

whether the deviations were required to be reported to the NRC. The first of these

examples involved a number of relays from the same manufacturing lot (date code 9948)

that, after being installed in the plant, were determined to be unreliable, thus deviating

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

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

specifications; however, the deviation of the date code 0835 relays was discovered

during bench testing prior to installation. On November 5, 2009, the NRC issued

inspection report 05000382/2009010, documenting an unresolved item pending a

determination of whether the licensees failures to evaluate and report the deviations

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

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

The NRC has determined that these deviations in basic components were not evaluated

in accordance with 10 CFR 21.21(a)(1). Further, the NRC determined that had the

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

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

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

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

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

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

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

(ML11319A134). However, Part 21 evaluation and reporting criteria continue to apply to

basic components that are not installed. Therefore, section 4OA5.2 below documents a

violation of 10 CFR Part 21 for only the date code 0835 relays, in which the deviations

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

the licensees failure to evaluate the installed relays in accordance with Part 21

requirements.

- 37 - Enclosure 2

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

Introduction. The team identified a Severity Level IV violation of 10 CFR 21.21 that

occurred when the licensee failed to complete an evaluation of a deviation in a basic

component within 60 days of discovery.

Description. On October 14, 2008, while replacing a failed Agastat E7024PB relay,

maintenance personnel noted that the replacement relay obtained from the warehouse

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

these also had a bad terminal point. On October 27, 2008, the licensee quarantined the

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

terminal points. All four affected relays shared a date code of 0835. The licensee

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

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

extent of condition, potential reporting, and development of corrective and preventive

action for the Agastat E7024PB relays with date code 0835 noted to have defective

terminal points.

On November 11, 2008, the licensee incorrectly determined that the deficiencies with the

four 0835 date code relays were the same condition as had been previously captured in

Condition Report CR-WF3-2008-4765. This condition report had been written for date

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

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

reportability evaluation for that previous condition would satisfy the requirements to

evaluate the October 14 deficiencies for reportability.

On November 25, 2008, Tyco Electronics issued a 10 CFR 21 report regarding an

Agastat E7024PB relay, date code 0813, which was manufactured with an incorrect

recycle spring. Coincident with this Part 21 report, on November 26, 2008, Tyco

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

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

been sold to the Waterford 3 and two which had been procured by the Waterford 3 from

another station. Four of these recalled relays were the subject of the November 4, 2008,

corrective action request issued to Tyco by the licensee. It was later determined that

none of the relays procured by the Waterford 3 had an incorrect recycle spring installed.

On January 28, 2009, the Waterford 3 received an evaluation from Tyco Electronics

which identified misadjusted terminal blocks as the cause of the failures of the two 0804

date code relays, a different failure mechanism than that initially identified for the 0835

relays. The Tyco Electronics report did not provide an evaluation for the 0835 relays.

In August 2009, the licensee issued Licensee Event Report (LER) 2009-003-00

(ML092310548). This LER did not mention relay 0835 or loose terminal points. It

instead discussed incorrect adjustment of terminal blocks. In April 2010, the licensee

issued an updated LER 2009-003-01 (ML101230323). This revision discussed relay

0835 and listed loose terminal points on two spare relays as a Part 21-reportable defect.

- 38 - Enclosure 2

The NRC identified that the licensee had failed to evaluate the loose terminal points on

the four relays with date code 0835 in accordance with 10 CFR Part 21. Though the

licensees initial actions to have the vendor perform an evaluation may have been

appropriate, it was the licensees responsibility and obligation under Part 21 to complete

such an evaluation within 60 days of the initial discovery, or issue an interim report within

60 days of the initial discovery.

The initial LER or Part 21 report should have been made in December 2008 (60 days

after the date of discovery in October 2008). However, the Part 21 report that describes

relay 0835 was made approximately 16 months later (April 2010).

Analysis. The failure of the licensee to adequately evaluate deviations in basic

components and to report defects is a performance deficiency. The NRCs significance

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

their potential safety consequences. This performance deficiency was of minor safety

significance. The traditional enforcement process separately considers the significance

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

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

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

the version of the NRC Enforcement Policy that was in effect at the time the violation

was identified provided as an example of a violation of significant regulatory concern

(Severity Level III), An inadequate review or failure to review such that, if an appropriate

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

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

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

because the affected components were already removed from service as part of an

unrelated manufacturers recall, the severity of the cited violation is being assessed as

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

violations.

Enforcement. Title 10, CFR Part 21.21(a)(1) requires, in part, that entities subject to the

regulations in this part shall evaluate deviations and failures to comply to identify defects

associated with substantial safety hazards as soon as practicable except as provided in

paragraph (a)(2) of this section, and in all cases within 60 days of discovery, in order to

identify a reportable defect that could create a substantial safety hazard, were it to

remain uncorrected.

Title 10 CFR, Part 21.21(a)(2) requires, in part, that entities subject to the regulations in

the part shall ensure that if an evaluation of identified deviation or failure to comply

potentially associated with a substantial safety hazard cannot be completed within

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

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

60 days of discovery of the deviation of failure to comply.

Contrary to the above, from December 14, 2008, to April 29, 2010, the licensee failed to

evaluate deviations and failures to comply to identify defects associated with substantial

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

- 39 - Enclosure 2

60 days of its discovery, in order to identify a reportable defect or failure to comply that

could create a substantial safety hazard, were it to remain uncorrected.

Specifically, on October 14, 2008, the licensee performed bench test on an

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

terminal point. Two more relays were obtained from the warehouse; one of these also

had a bad terminal point. On October 27, 2008, the licensee quarantined the remaining

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

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

them to the manufacturer, Tyco Electronics, for cause evaluation. All four affected

relays shared a date code of 0835. On January 28, 2009, the licensee received a report

from the manufacturer, which had failed to perform the required evaluation. On

August 18, 2009, the licensee submitted LER 2009-003-00, (ML092310548). This LER

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

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

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

licensee issued updated LER 2009003-01 (ML101230323). This revision to the LER

described loose terminal points on two spare date code 0835 relays as one of the

defects identified in its Agastat E7024PB relays. The April 29, 2010, LER revision would

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

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

4OA6 Meetings, Including Exit

Exit Meeting Summary

The inspectors debriefed Mr. Carl Rich, Director of Nuclear Safety Assurance, and other

members of the licensee's staff of the results of the licensed operator requalification

program inspection on July 25, 2013, and telephonically exited with Mr. Carl Rich and

other staff members on August 19, 2013. The licensee representatives acknowledged

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

examined during the inspection should be considered proprietary. No proprietary

information was identified.

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

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

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

the licensee whether any materials examined during the inspection should be

considered proprietary. No proprietary information was identified.

On October 1, 2013, the inspectors presented the inspection results to Ms. D. Jacobs,

Vice President, Operations, and other members of the licensee staff. The licensee

acknowledged the issues presented. The inspector asked the licensee whether any

materials examined during the inspection should be considered proprietary. No

proprietary information was identified.

- 40 - Enclosure 2

On November 19, 2013, a re-exit was held with Mr. John Jarrell, Regulatory Assurance

Manager, and other members of your staff. The purpose of this re-exit was to further

discuss the violations contained in the report.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (SL-IV) was identified by the

licensee and is a violation of NRC requirements which meets the criteria of the

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

Title 10 CFR, Part 55.9, Completeness and Accuracy of Information, requires that

information provided to the Commission by an applicant for a license or by a licensee

shall be complete and accurate in all material respects. Contrary to the above, on

September 13, 2012, an NRC Form 396, Certification of Medical Examination by Facility

Licensee, was submitted to the NRC for a licensed operator applicant with inaccurate

information. Specifically, a restriction for corrective lenses was omitted, even though the

applicants medical exam stated that the individual required corrective lenses. An

operating license was granted by the NRC to the individual without a corrective lens

restriction. The error was identified during the operators subsequent annual medical

examination in July 2013, after which the operator reported to licensing that an additional

restriction was being placed on his license though his vision had not changed. The

licensee confirmed that the operator had not performed any licensed duties and a

revised NRC Form 396 was submitted to Region IV on July 29, 2013. The licensee

documented the deficiency in Condition Report 2013-03181. The submission of

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

traditional enforcement process because it impacted the NRCs ability to perform its

regulatory function. The violation was determined to be Severity Level IV because it fits

the example of Enforcement Policy Section 6.4.d.1(d), Violation Examples: Licensed

Reactor Operators. This section states, SL IV violations involve, for example an

individual operator who met ANSI/ANS 3.4, Section 5, as certified on NRC Form 396,

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

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

having the undisclosed medical condition. In this case, the individual operator did

report the condition to the licensee, but the licensee failed to include that information in

its original license application to the NRC.

- 41 - Enclosure 2

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

D. Jacobs, Vice President, Operations

K. Cook, General Manager, Plant Operations

S. Adams, Senior Manager, Production

D. Boan, Supervisor, Radiation Protection

J. Briggs, Superintendent, Electrical Maintenance

K. Crissman, Senior Manager, Maintenance

D. Frey, Manager, Radiation Protection

R. Gilmore, Manager, Systems and Components

W. Hardin, Senior Licensing Specialist, Licensing

A. James, Manager, Security

B. Lanka, Director, Engineering

N. Lawless Manager, Chemistry

B. Lindsey, Senior Manager, Operations

M. Mason, Senior Licensing Specialist, Licensing

M. Mills, Manager, Nuclear Oversight

W. McKinney Manager, Performance Improvement

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

B. Pellegrin, Manager, Regulatory Assurance

G. Pierce, Manager, Training

R. Porter, Manager, Design & Program Engineering

D. Reider, Supervisor, Quality Assurance

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

J. Russo, Supervisor, Design Engineering

J. Signorelli, Supervisor, Simulator Support

R. Simpson, Superintendent, Licensed Operator Requalification

P. Stanton, Supervisor, Design Engineering

J. Williams, Senior Licensing Specialist

A1-1 Attachment

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000382-2013004-01 VIO Failure to Make a Report Required by 10 CFR 21.21

(Section 4OA5)

Opened and Closed

05000382-2013004-02 NCV Failure to Implement Fire Protection Program Procedure

Requirements When Securing from a Fire Watch

(Section 1R05)05000382-2013004-03 NCV Failure to Accomplish Activities Affecting Quality on a

Degraded Safety-Related Solenoid Valve In Accordance With

Procedure Requirements (Section 1R19)

Closed

05000382/2012-007-00 LER Inoperability of a Safety Related Valve Due to Backup Air

Accumulator Leakage

05000382/2009010-01 URI Failure to Evaluate Adverse Conditions for Reportability to the

NRC (Section 4OA5)

LIST OF DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

OP-901-521 Severe Weather and Flooding 309

ENS-EP-302 Severe Weather Response 11

Section 1R04: Equipment Alignment

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

OP-009-008 Safety Injection System 33

OP-002-004 Chilled Water System 311

OP-002-001 Auxiliary Component Cooling Water 305

A1-2

Section 1R05: Fire Protection

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

UNT-005-013 Fire Protection Program 12

FP-001-014 Duties of a Fire Watch 16

RAB 2-001 Prefire Strategy Elevation +46.00 RAB HVAC 12

Equipment Room

RAB 7-001 Prefire Strategy Elevation +35.00 RAB HVAC Relay 9

Room

RAB 39-001 Prefire Strategy Elevation -35.00 RAB General Area 11

FP-001-018 Pre Fire Strategies, Development and Revision 301

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

CONDITION REPORTS

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

Section 1R06: Flood Protection Measures

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

EN-DC-346 Cable Reliability Program 5

MNQ3-5 Flooding Analysis Outside Containment 4

W3F1-2007-0017 Response to Generic Letter 2007-01 0

W3F1-2009-0066 Clarification of Response to Generic Letter 2007-01 0

SEP-UIP-WF3 Underground Components Inspection Plan 1

WORK ORDERS

WO 227249

Section 1R07: Heat Sink Performance

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

EN-DC-316 Heat Exchanger Performance and Condition 3

A1-3

Section 1R07: Heat Sink Performance

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

Monitoring

PE-001-004 Heat Exchanger Performance 2

SEP-HX-WF3-001 Waterfords Generic Letter 89-13 Heat Exchanger 0

Test Basis

Section 1R11: Licensed Operator Requalification Program

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION/

DATE

EN-OP-115 Conduct of Operations 12

EN-TQ-114 Licensed Operator Requalification Training Program 8

Description

TM-OP-100 Operations Training Manual 24

ANSI/ANS-3.4- Medical Certification and Monitoring of Personnel April 29, 1983

1983 Requiring Operator Licenses for Nuclear Power Plants

ANSI/ANS-3.5- Nuclear Power Plant Simulators for Use in Operator September 4, 2009

2009 Training and Examination

ACAD 07-001 Guidelines for the Continuing Training of Licensed January 2007

Personnel

EN-TQ-217 Examination Security 2

OI-024-000 Maintaining Active SRO/RO Status 306

EN-NS-112 Medical Program 11

TM-OP-100 Operations Training Manual 24

MISCELLANEOUS DOCUMENTS

NUMBER TITLE DATE

WSIM-DIR-003- Steady State Test - 20%, 70%, 100% May 5, 2013

ANNUALTESTS

Att. 4.1

WSIM-DIR-003- Manual Reactor Trip May 5, 2013

ANNUALTESTS

Att. 4.2

A1-4

WSIM-DIR-003- Trip of any single RCP May 15, 2013

ANNUALTESTS

Att. 4.6

WWEX-LOR- 2011 LOR Biennial RO Exam Week 4 August 4, 2011

11044R

WWEX-LOR- 2011 LOR Biennial RO Exam Week 4 (Remedial) August 18, 2011

11046R

N/A 2013 LOR Cycle Written Exam Question Matrix July 23, 2013

WWEX-LOR- 2013 LOR Biennial RO Exam Week 2 July 18, 2013

13042R

TQF-201-IM06 Academic Review Board Recommendation November 14, 2011

N/A Simulator Differences List July 22, 2013

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

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

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

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

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

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

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

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

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

TQF-210-DD03 LOR Simulator Crew Performance Evaluation Report - July 25, 2013

Crews A and 3 (6)

W-OPS-LOR- Requal Training Attendance Records for 2012 July 22, 2013

2012-Cycles 1-6 Cycles 1-6

CONDITION REPORTS

CR-WF3-2013-03181 CR-WF3-2013-03441 CR-WF3-2013-00747 CR-WF3-2013-00961

CR-HQN-2013-00708 CR-WF3-2013-02266 CR-WF3-2013-03522

A1-5

Section 1R12: Maintenance Effectiveness

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

ECM97-006 Design Basis for CCW Makeup 1

CONDITION REPORTS

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

WORK ORDERS

WO 354081 WO 355051 WO 322052

Section 1R13: Maintenance Risk Assessment and Emergent Work Controls

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

EN-WM-104 On Line Risk Assessment 7

Integrated Risk Summary Form for Week of 7/29/13 0

8/4/13

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

9/8/13

OI-037-000 Operations Risk Assessment Guideline 304

CONDITION REPORTS

CR-WF3-2013-03574

Section 1R15: Operability Determinations and Functionality Assessments

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

EN-LI-108 Event Notification and Reporting 8

EN-OP-104 Operability Determinations 6

EC 46218 Provide Minimum Wall Thickness Data for Degraded 0

Piping Identified in CR-WF3-2012-3855

PS-S-004 Thermal Expansion Evaluation of Low Temperature 1

Piping Systems

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

A1-6

Section 1R15: Operability Determinations and Functionality Assessments

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

OP-100-014 Technical Specifications and Technical Requirement 313

Compliance

OI-037-000 Operations Risk Assessment Guideline 304

EN-CS-S-008- Pipe Wall Thinning Structural Evaluation 0

MULTI

CONDITION REPORTS

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

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

Section 1R18: Plant Modifications

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

EC 45995 Main Steam Isolation Valve B to Repair a Bonnet Vent 0

Plug

EC 46914 Main Feedwater Isolation Valve A Nitrogen 0

Accumulator B tubing replacement

Section 1R19: Post-Maintenance Testing

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

EC 38218 Operability Input for CR-WF3-2012-2870, ACC- 0

126A(B) Potential Leakage

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

Pump Analysis

EN-WM-107 Post Maintenance Testing 4

MI-005-211 Calibration of Control Valves and Accessories 8

MI-005-211 Calibration of Control Valves and Accessories 9

MN(Q)9-50 ACCW System Resistance 2

OP-002-001 Auxiliary Component Cooling Water 305

OP-903-006 Reactor Trip Circuit Breaker Test 10

A1-7

Section 1R18: Plant Modifications

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

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

Cooling Water Pump and Valve Operability Test

OP-903-065 Emergency Diesel Generator and Subgroup Relay 307

Operability Verification

OP-903-118 Primary Auxiliaries Quarterly IST Valve Tests 31

OP-903-119 Secondary Auxiliaries Quarterly IST Valve Test 18

STA-001-005 Leakage Testing of Air and Nitrogen Accumulators for 310

Safety Related Valves

TD-M120.0045 Masoneilan Instruction Manual 2034 for Electro- 0

Pneumatic Positioner Models 8012 & 8012-1-C &

8012-2-C & 8012-3-C

TD-M120.0055 Masoneilan Instruction Manual ES-5000 for Electro- 1

Pneumatic Positioner Models 8012 & 8012-2-C &

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

W3-DBD-14 Safety Related Air Operated Valves 301

CONDITION REPORTS

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

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

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

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

WORK ORDERS

WO 52486712 WO 360921

Section 1R22: Surveillance Testing

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

EC 18218 Change CVRIDPIS5220A & B Setpoints 0

EC 18219 Replace CVRIDPIS5220A, B CVRIDPIS5221A, 0

B Design Basis

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

A1-8

Section 1R22: Surveillance Testing

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

Cooling Water Pump and Valve Operability Test

OP-903-120 Containment and Miscellaneous Systems Quarterly 15

IST Valve Tests

W3-DBD-04 Design Basis Document: Component Cooling Water, 302

Auxiliary Component Cooling Water

SD-CCS Containment Cooling and Ventilation System 7

Description

OP-903-037 Containment Cooling Fan Operability Verification 6

OP-903-037 Safety Injection Pump Operability Verification 19

WORK ORDERS

WO 227323 WO 5251325

Section 1EP6: Drill Evaluation

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

EP Emergency Plan 44

EP-001-001 Recognition and Classification of Emergency 30

Conditions

2RS1 Radiological Hazard Assessment and Exposure Controls (71124.01)

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

EN-RP-101 Access Control for Radiologically Controlled Areas 7

EN-RP-106-01 Radiological Survey Guidelines 0

EN-RP-108 Radiation Protection Postings 13

EN-RP-121 Radioactive Material Control 7

EN-RP-143 Source Control 9

A1-9

AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES

NUMBER TITLE DATE

QA-14115-2011- Quality Assurance Audit - Combined Radiation November 16, 2011

W3-1 Protection and Radwaste

CONDITION REPORTS

CR-WF3-2013-2256 CR-WF3-2013-3086 CR-WF3-2013-6848 CR-WF3-2012-06131

CR-WF3-2012-0622

RADIATION SURVEY RECORDS

NUMBER TITLE DATE

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

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

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

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

WF3-1210-0365 Reactor Coolant Pump 1A October 18, 2012

WF3-1210-0626 Reactor Cavity +21-foot October 23, 2012

WF3-1210-0560 Reactor Containment Building October 22, 2012

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

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

WF3-1211-1722 No. 1 Steam Generator Platform November 26, 2012

WF3-1211-1822 D Ring November 27, 2012

AIR SAMPLE RECORDS

NUMBER TITLE DATE

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

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

4022475 HP Lapel Sample - Upper Cavity October 20, 2012

4022484 HP Lapel Sample - Canal October 20, 2012

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

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

SEALED SOURCE INVENTORY AND LEAK TESTS

NUMBER DATE

310182 July 2, 2013

A1-10

2RS2 Occupational ALARA Planning and Controls (71124.02)

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

EN-RP-105 Radiological Work Permits 012

EN-RP-110 ALARA Program 011

EN-RP-110-03 Collective Radiation Exposure (CRE) Reduction 002

Guidelines

EN-RP-110-04 Radiation Protection Risk Assessment Process 002

EN-RP-110-05 ALARA Planning and Controls 002

EN-RP-110-06 Outage Dose Estimation and Tracking 001

RADIATION WORK PERMIT ALARA PACKAGES

NUMBER TITLE DATE

2012-0414 SI-109 A and B Refurbishing/Repair February 25, 2013

2012-0515 RCP 2B Motor Removal and Replacement. January 10, 2013

2012-0915 RSG Reactor Coolant System (RCS) Cutting and January 8, 2013

Welding.

2012-0916 RSG Pipe End Decontamination (PED) Activities and January 25, 2013

Support Activities

2012-0917 RSG Steam Generator Removal/Installation Activities February 18, 2013

and Support. Including Rigging Activities

2012-0924 RSG Support Structure / Restraints Modifications February 7, 2013

CONDITION REPORTS

CR-W3-2012-06441 CR-W3-2012-06446 CR-W3-2012-06502 CR-W3-2012-06515

CR-W3-2012-06543 CR-W3-2012-06593 CR-W3-2012-06660 CR-W3-2012-06770

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

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

CR-W3-2013-00344

A1-11

SURVEYS

WF3-1210-0855 WF3-1210-0859 WF3-1210-0932 WF3-1210-0880

WF3-1211-0112 WF3-1211-0194 WF3-1211-0572 WF3-1211-0948

WF3-1211-1122 WF3-1211-1113 WF3-1211-1116 WF3-1211-1175

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

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

WF3-1212-0812 WF3-1212-0912

MISCELLANEOUS DOCUMENTS

NUMBER TITLE DATE

CR-W3-2013- LT - Apparent Cause Evaluation Report Refuel 18 May 13, 2013

00250 Dose Goal Exceeded

Refuel 18 Outage ALARA Report

2RS5 Radiation Monitoring Instrumentation (71124.05)

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

MI-005-906 Radiation Monitoring System Desk Guide 002

MI-003-387 Condenser Vacuum Pump Discharge Wide Range 12

Noble Gas Radiation Monitor Channel Calibration

(PRMIR0002)

MI-003-461 Boric Acid Condensate Discharge Liquid Effluent 12

Radiation Monitor Channel Calibration (PRMIR0627)

MI-003-371 Fuel Handling Building Ventilation System Emergency 306

Exhaust High Range Noble Gas Radiation Monitor

Channel Calibration (PRMIR3032)

MI-003-391 Component Cooling Water System A or B Liquid 306

Radiation Monitor Channel Calibration (PRMIR7050A

or B)

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

EN-CY-110 Chemistry Gamma Spectroscopy System Operation 2

CE-003-332 Use of the Beckman LS6500 2

EN-RP-301 Radiation Protection Instrument Control 5

A1-12

NUMBER TITLE REVISION

EN-RP-303-01 Automated Contamination Monitor Performance 0

Testing

AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES

NUMBER TITLE DATE

QS-2012-W3- Quality Assurance Surveillance Report May 15, 2012

008

QA-14/15-2011- Quality Assurance Audit November 10, 2011

W3-1

CONDITION REPORTS

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

2012-04918

RADIATION MONITORING SYSTEM CALIBRATION RECORDS

WO# NUMBER TITLE DATE

52321504 PRMIR7050A, Cal CCW System Rad Monitor per March 1, 2012

MI-003-391

52321537 PRMIR0002, Calibrate Electronics as per MI-003-387 August, 2012

52321563 PRMIR0627, Cal Boric Acid Cond Disch Liquid Mon July 2, 2012

MI-003-461

52324842 PRMIR0002, Calibrate Flow Portion per MI003-387 October 15, 2012

52335214 PRMIR3032, Calibrate Electronics as per MI-003-371 January 10, 2013

52358658 PRMIR3032, Calibrate Flow Portion per MI-003-371 June 3, 2013

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

CE-003-300 Preparation of Liquid Samples for Radiological Chemical 008

Analysis

A1-13

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

CE-003-509 Routine Filter Replacement and Grab Sampling on PIG 302

Monitors and WRGMS

CE-003-512 Liquid Radioactive Waste Release Permit (Manual) 001

CE-003-513 Gaseous Radioactive Waste Release Permit (Manual) 303

CE-003-514 Liquid Radioactive Waste Release Permit (Computer) 301

CE-003-515 Gaseous Radioactive Waste Release Permit (Computer) 303

CE-003-516 Calculation and Adjustment of Radiation Monitor 302

Setpoints

CE-003-700 General Grab Sampling Techniques 306

EN-CY-102 Laboratory Analytical Quality Control 004

EN-CY-108 Monitoring of Nonradioactive Systems 005

EN-CY-113 Response to Contaminated Spills/Leaks 007

MM-003-044 Shield Building Ventilation System Surveillance 301

MM-003-045 Control Room Air Conditioning 304

MM-003-046 Controlled Ventilation Area System Surveillance 301

UNT-005-014 Offsite Dose Calculation Manual 303

AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES

NUMBER TITLE DATE

22873 Audit of GEL Laboratories December 13, 2011

WLO-2013-00016 Pre-NRC Inspection Focused Assessment May 3, 2012

23428 Exelon Nuclear Audit of NUCON International, Inc. March 11, 2013

A1-14

CONDITION REPORTS

CR-WF3-2012-00910 CR-WF3-2012-01284 CR-WF3-2012-02107 CR-WF3-2012-02240

CR-WF3-2012-02491 CR-WF3-2012-03509 CR-WF3-2012-03956 CR-WF3-2012-04363

CR-WF3-2012-04571 CR-WF3-2012-04840 CR-WF3-2012-04995 CR-WF3-2012-05597

CR-WF3-2012-06182 CR-WF3-2012-06551 CR-WF3-2013-00282 CR-WF3-2013-00318

CR-WF3-2013-00677 CR-WF3-2013-02795 CR-WF3-2013-03087 CR-WF3-2013-04547

LO-WLO-2013-00016

10 CFR 50.75(g) CONDITION REPORTS

CR-WF3-2011-06065 CR-WF3-2012-02705

EFFLUENT RELEASE PERMITS

PERMIT NO TYPE RELEASE SYSTEM DATE

W3LB2012-147 Liquid Boric Acid Condensate Tank B (BWM) July 25, 2012

W3LC2012-202 Liquid Turbine Building Industrial Waste Tank September 26, 2012

(TBIWS)

W3LB2013-066 Liquid Waste Condensate Tank B (LWM) April 2, 2013

W3GC2012-079 Gaseous Plant Stack June 27, 2012

EFFLUENT RELEASE PERMITS

PERMIT NO TYPE RELEASE SYSTEM DATE

W3GB2013-050 Gaseous Containment May 9, 2013

W3GC2013-057 Gaseous Fuel Handling Building May 13, 2013

IN-PLACE FILTER TESTING RECORDS

WORK ORDER SYSTEM TRAIN TEST DATE

52434436 Shield Building Ventilation B Charcoal absorber December 19, 2012

52321632 Shield Building Ventilation A HEPA Filter February 10, 2012

52351427 Control Room Emergency B Charcoal absorber March 29, 2013

Filtration Unit

52331428 Control Room Emergency B HEPA Filter March 27, 2013

Filtration Unit

A1-15

52376581 Controlled Ventilation Area B HEPA Filter June 25, 2013

52376581 Controlled Ventilation Area B Charcoal absorber June 29, 2013

MISCELLANEOUS DOCUMENTS

NUMBER TITLE DATE

2011 Annual Radiological Effluent Release Report April 30, 2012

2012 Annual Radiological Effluent Release Report April 30, 2013

Intra-Laboratory Comparison Results 2011

EC-10953 Engineering Change for Modified Release Path to May 11, 2009

Circulating Water System

EC-28466 Engineering Change for Circulating Water System Piping In Progress

Rerouting

2RS7 Radiological Environmental Monitoring Program (71124.07)

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

CE-003-522 Meteorological Data Collection and Processing 4

CE-003-523 Meteorological Monitoring Program 1

CE-003-525 REMP Evaluations and Reports 301

CE-003-526 Collection and Preparation of REMP Liquid Samples 302

CE-003-527 Collection of Milk Samples 1

CE-003-528 Collection of Sediment Samples 1

CE-003-529 Collection of Vegetation Samples 1

CE-003-530 Collection and Preparation of Fish Sample 1

CE-003-531 Collection and Preparation of REMP Air Samples 1

CE-003-532 Preparation and Distribution of REMP Thermoluminescent 301

Dosimeters

CE-003-533 REMP Shipping 1

CE-003-534 Land Use Census 2

A1-16

ESP-8-069 Radiological Environmental Analytical Services 00

UNT-005-014 Offsite Dose Calculation Manual 303

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

EN-QV-108 QA Surveillance Process 9

EN-QV-109 Audit Process 24

Quality Assurance Program Manual 24

AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES

NUMBER TITLE REVISION

EN-LI-104 Pre-NRC Inspection Focused Assessment - 9

Effluents and Environmental

CONDITION REPORTS

CR-WF3-2012-1360 CR-WF3-2012-2737 CR-WF3-2012-2942 CR-WF3-2012-4067

CR-WF3-2012-4281 CR-WF3-2012-4296 CR-WF3-2012-4385 CR-WF3-2012-4408

CR-WF3-2012-7354 CR-WF3-2012-7487 CR-WF3-2013-1967 CR-WF3-2013-2941

CALIBRATION AND MAINTENANCE RECORDS

NUMBER TITLE DATE

WO-WF3-52410699 Primary Met Tower Calibration Package October 2012

WO-WF3-52447365 Primary Met Tower Calibration Package May 2013

WO-WF3-52431357 Secondary Met Tower Calibration Package February 2012

WO-WF3-52469672 Secondary Met Tower Calibration Package August 2013

MISCELLANEOUS DOCUMENTS

TITLE DATE

Annual Radiological Environmental Operating Report 2011

Annual Radiological Environmental Operating Report 2012

Annual Radioactive Effluent Release Report 2011

Annual Radioactive Effluent Release Report 2012

Annual Meteorological Monitoring Program Report 2011

Annual Meteorological Monitoring Program Report 2012

A1-17

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation (71124.08)

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

EN-RP-121 Radioactive Material Control 7

EN-RW-102 Radioactive Shipping Procedure 10

EN-RW-104 Scaling Factors 3

RW-002-200 Collection & Packaging of Solid Radwaste 303

RW-002-210 Radioactive Waste Solidification & Dewatering 301

RW-002-240 Package and Handling Radwaste DAW 300

RW-002-300 Blowdown Demineralizer Resin Transfer 300

AUDITS, SELF-ASSESSMENTS, AND SURVEILLANCES

NUMBER TITLE DATE

NUPIC Audit No. Energy Solutions Mega Audit November 23, 2012

2012-011

EN-LI-104 Pre-Assessment Radioactive Solid Waste Processing April 24, 2012

and Radioactive Material Handling, Storage, and

Transportation

QA-14/15- Quality Assurance Audit Report: Radiation October 11, 2011

20011-GGNS-1 Protection/Radwaste

CONDITION REPORTS

CR-WF3-2011-07711 CR-WF3-2012-03042 CR-WF3-2012-07168 CR-WF3-2013-00508

CR-WF3-2013-01253 CR-WF3-2013-01682 CR-WF3-2013-02905 CR-WF3-2013-03335

CR-WF3-2013-03952 CR-WF3-2013-04553 CR-WF3-2013-04556 CR-WF3-2013-04557

CR-HQN-2013-00858 CR-HQN-2013-00859

RADIOACTIVE MATERIAL AND WASTE SHIPMENTS

NUMBER TITLE DATE

11-1010 Bead Resin and Dry Active Waste, Oak Ridge, TN June 23, 2011

11-1011 LWM Resin, Oak Ridge, TN August 22, 2011

11-1011 Dewatered Resin, Studsvik Erwin, TN September 21, 2011

11-3024 Lead Blankets, 3-Mile Island, Harrisburg, PA February 25, 2011

12-1008 Dry Active Waste, Energy Solutions, Oak Ridge, TN June 21,2012

12-1009 SGBD Resin, Energy Solutions, Oak Ridge, TN October 24, 2012

12-3049 Empty Fuel Cask, Energy Solutions, Oak Ridge, TN August 9, 2012

A1-18

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION / DATE

FSAR Chapter WSES Updated Final Safety Analysis Report 12

11

FSAR Chapter WSES Updated Final Safety Analysis Report 12

12

2012 Annual Radiological Effluent Release Report April 30, 2012

2011 Annual Radiological Effluent Release Report April 30, 2013

Section 4OA1: Performance Indicator Verification

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

EN-LI-104 Performance Indicator Process 6

EN-FAP-OM-005 Nuclear Performance Indicator Process 0

ECH-NE-09- Waterford 3 Mitigating System Performance Index Basis 2

00036 Document

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION

NEI 99-02 Regulatory Assessment Performance Indicator Guideline 6

Section 4OA2: Identification and Resolution of Problems

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

EN-LI-102 Corrective Action Process 20

EN-LI-119 Apparent Cause Evaluation (ACE) Process 16

Section 4OA3: Event Follow-Up

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

LER Inoperability Of A Safety Related Valve Due To Backup 0

05000382/2012- Air Accumulator Leakage

007-00

A1-19

Section 4OA5: Other Activities

PROCEDURES/DOCUMENTS

NUMBER TITLE REVISION

EN-CY-109 Sampling and Analysis of Groundwater Monitoring Wells 2

EN-CY-111 Radiological Ground Water Monitoring Program 2

CONDITION REPORTS

CR-HQN-2012-00676 CR-HQN-2012-00673 CR-HQN-2013-00861

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION/

DATE

LO-WTHQN- Focused Self-Assessment Report - NEI 07-07 November 30, 2011

2011-123 Compliance - Waterford-3

NEI Ground Water Protection Initiative NEI Peer December 9, 2009

Assessment Report

Ground Water Monitoring Plan - Entergy Nuclear 2

Waterford-3 Station

A1-20

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