Text

IR 05000382-12-002, on 01/01/2012-03/31/2012, Waterford Steam Electric Station, Unit 3, Integrated Resident and Regional Report, Post Maintenance Testing and Surveillance Testing
	ML12122A381
Person / Time
Site:	Waterford
Issue date:	04/26/2012
From:	Allen D B; NRC/RGN-IV/DRP/RPB-E
To:	Jacobs D; Entergy Operations
References
	IR-12-002
	Download: ML12122A381 (34)
	v • d • e

April 26, 2012

Donna Jacobs, Site Vice President, Operations Entergy Operations, Inc. Waterford Steam Electric Station, Unit 3 17265 River Road Killona, LA 70057-0751 Subject: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED INSPECTION REPORT 05000382/2012002

Dear Ms. Jacobs:

On March 31, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford Steam Electric Station, Unit 3 facility. The enclosed inspection report documents the inspection results which were discussed on April 10, 2012, with you and other members of your staff.

The inspections examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

One NRC-identified and one self-revealing finding of very low safety significance (Green) were identified during this inspection. Both of these findings were determined to involve violations of NRC requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest these non-cited violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region IV, 1600 East Lamar Blvd., Arlington, Texas 76011-4511; the Director, Office of Enforcement, United States 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 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 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agencywide Document 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). To the extent possible, your response should not include any personal privacy or proprietary information so that it can be made available to the public without redaction.

Sincerely,/RA/ Donald B Allen Chief, Project Branch E Division of Reactor Projects Docket No.: 50-382 License No.: NPF-38

Enclosure:

NRC Inspection Report 05000382/2012002

w/Attachment:

Supplemental Information cc w/ encl: Electronic Distribution

SUMMARY OF FINDINGS

IR 05000382/2012002; 01/01/2012-03/31/2012; Waterford Steam Electric Station, Unit 3, Integrated Resident and Regional Report; Post Maintenance Testing and Surveillance Testing. The report covered a 3-month period of inspection by resident inspectors and an announced baseline inspection by a region-based inspector. Two Green non-cited violations of significance 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.

A Green self-revealing, non-cited violation of Waterford Steam Electric Station, Unit 3, Technical Specification 6.8.1.a occurred because the licensee did not establish procedures for performing preventive maintenance tasks on the dry cooling tower component cooling water inlet isolation valves CC-135A and CC-135B limit switches. Specifically, the licensee had not developed preventive maintenance tasks to lubricate or replace critical limit switches that provide a permissive for the operation of the dry cooling tower fans. As a result, on February 4, 2011, the limit switch on valve CC-135A failed to operate as designed and rendered an entire train of fans inoperable. The licensee entered this condition into their corrective action program as CR-WF3-2011-0679 for resolution. The immediate corrective action included the lubrication of the limit switch and the manual stroking of the valve to obtain free and smooth movement of the degraded equipment. The planned corrective actions included the development of a preventive maintenance task to lubricate and replace the limit switches on a scheduled frequency. The failure to establish procedures for performing preventive maintenance tasks on the dry cooling tower component cooling water inlet isolation valves CC-135A and CC-135B limit switches is a performance deficiency. The performance deficiency is more than minor because it is associated with the equipment performance attribute of the mitigating systems cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, since there was no preventive maintenance task for lubrication and replacement of the equipment, the limit switches can become stuck and render an entire train of dry cooling tower fans inoperable. The inspectors determined the significance of the finding using the NRC Inspection Manual 0609, Attachment 0609.04, "Phase 1 - Initial Screening and Characterization of Findings." The inspectors determined that the finding is of very low safety significance (Green) because it is not a design or qualification deficiency, did not represent a loss of a safety function of a system or a single train for greater than its technical specification completion time, and did not screen as potentially risk-significant due to an external initiating events. The inspectors also concluded that no cross-cutting aspect is applicable to this finding because the performance deficiency is not reflective of current performance (Section 1R19).

Green.

The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, because the licensee did not identify and perform testing on a safety-related component to demonstrate that it would perform satisfactorily in service in accordance with requirements contained in applicable design documents. Specifically, the licensee did not identify and perform proper testing for the essential chiller hot gas bypass valves RFR-106A, B, and C. As a result, the licensee could not demonstrate that the safety-related valves would perform satisfactorily in service without performing a test and operability evaluation. The licensee entered this condition into the corrective action program as CR-WF3-2012-0632 and CR-WF3-2012-0659. The immediate corrective action included testing the hot gas bypass valves to demonstrate the proper performance of their safety function. The failure to identify and perform testing to demonstrate that a safety-related component would perform satisfactorily in service in accordance with requirements contained in applicable design documents is a performance deficiency. The performance deficiency is more than minor because it is associated with the equipment performance attribute of the mitigating systems cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the hot gas bypass valve closure is required to ensure the essential chiller can perform its safety function during all design basis accident conditions. The inspectors determined the significance of the finding using the NRC Inspection Manual 0609, Attachment 0609.04, "Phase 1 - Initial Screening and Characterization of Findings." The inspectors determined that the finding is of very low safety significance (Green) because it is not a design or qualification deficiency, did not represent a loss of a safety function of a system or a single train for greater than its technical specification completion time, and did not screen as potentially risk-significant due to any external initiating events. This finding has a cross-cutting aspect in the resources component of the human performance area in that the licensee did not ensure that complete, accurate, and up-to-date test procedures were available to demonstrate that equipment performance is adequate to assure nuclear safety H.2(c) (Section 1R22).

B. Licensee-Identified Violations

None

REPORT DETAILS

Summary of Plant Status The Waterford Steam Electric Station, Unit 3, began the inspection period at 100 percent power. On January 28, 2012, operators commenced a down power to approximately 55 percent to conduct repairs on the B steam generator feedwater pump. On January 30, 2012, operators increased power to 100 percent. The unit remained at 100 percent power for the rest of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Main article: IP 71111.01

.1 Readiness for Seasonal Extreme Weather Conditions

a. The inspectors performed a review of the adverse weather procedures for seasonal extreme low temperatures. The inspectors verified that weather-related equipment deficiencies identified during the previous year were corrected prior to the onset of seasonal extremes, and evaluated the implementation of the adverse weather preparation procedures and compensatory measures for the affected conditions before the onset of, and during, the adverse weather conditions. Inspection Scope During the inspection, the inspectors focused on plant-specific design features and the procedures used by plant personnel to mitigate or respond to adverse weather conditions. Additionally, the inspectors reviewed the updated final safety analysis report and performance requirements for systems selected for inspection and verified that operator actions were appropriate as specified by plant-specific procedures. Specific documents reviewed during this inspection are listed in the attachment. The inspectors also reviewed corrective action program items to verify that plant personnel were identifying adverse weather issues at an appropriate threshold and entering them into their corrective action program in accordance with station corrective action procedures. The inspectors' reviews focused specifically on the following plant systems: On February 12, 2012, the inspectors completed a review of the licensee's actions in preparation for cold weather conditions, and walked down the following systems and components: (1) component cooling water system; (2) dry cooling towers; (3) reactor auxiliary building fire protection system; and (4) main steam isolation valve actuators These activities constitute completion of one readiness for seasonal adverse weather sample as defined in Inspection Procedure 71111.01-05.

b. No findings were identified. Findings

.2 Readiness for Impending Adverse Weather Conditions

a. Since thunderstorms with potential tornados and high winds were forecast in the vicinity of the facility for March 21, 2012, the inspectors reviewed the plant personnel's overall preparations/protection for the expected weather conditions. On March 21, 2012, the inspectors walked down the wet and dry cooling systems because their safety-related functions could be affected, or required, as a result of high winds or tornado-generated missiles or the loss of offsite power. The inspectors evaluated the plant staff's preparations against the site's procedures and determined that the staff's actions were adequate. During the inspection, the inspectors focused on plant-specific design features and the licensee's procedures used to respond to specified adverse weather conditions. 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 updated 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 identified adverse weather issues at an appropriate threshold and dispositioned them through the corrective action program in accordance with station corrective action procedures. Specific documents reviewed during this inspection are listed in the attachment. Inspection Scope These activities constitute completion of one impending adverse weather condition sample as defined in Inspection Procedure 71111.01-05. b. No findings were identified. Findings

1R04 Equipment Alignment

Main article: IP 71111.04

.1 Partial Walkdown

a. The inspectors performed partial system walkdowns of the following risk-significant systems: Inspection Scope On January 13, 2012, essential chilled water train B while essential chiller A was out of service for emergent maintenance On February 29, 2012, train B of the electrical distribution switchgear during scheduled maintenance on the train A switchgear room ventilation On March 5, 2012, emergency diesel generator B while emergency diesel generator A was inoperable for scheduled maintenance On March 20, 2012, emergency feedwater train A while the turbine driven emergency feedwater pump was inoperable for scheduled maintenance The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones at the time they were inspected. 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, the updated 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 four partial system walkdown samples as defined in Inspection Procedure 71111.04-05. b. No findings were identified. Findings

.2 Complete Walkdown

a. On January 31, 2012, the inspectors performed a complete system alignment inspection of the auxiliary component cooling train B while auxiliary component cooling train A was inoperable for scheduled maintenance. The inspectors selected this system because it was considered both safety significant and risk significant in the licensee's probabilistic risk assessment. The inspectors inspected the system to review mechanical and electrical equipment line ups; electrical power availability; system pressure and temperature indications, as appropriate; component labeling; component lubrication; component and equipment cooling; hangers and supports; and operability of support systems. The inspectors also inspected the system to ensure that ancillary equipment Inspection Scope or debris did not interfere with equipment operation. The inspectors reviewed a sample of past and outstanding work orders to determine whether any deficiencies significantly affected the system function. In addition, the inspectors reviewed the corrective action program database to ensure that system equipment-alignment problems were being identified and appropriately resolved. Specific documents reviewed during this inspection are listed in the attachment. These activities constitute completion of one complete system walkdown sample as defined in Inspection Procedure 71111.04-05. b. No findings were identified. Findings

1R05 Fire Protection

Main article: IP 71111.05

.1 Quarterly Fire Inspection Tours

a. 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: Inspection Scope On March 5, 2012, reactor auxiliary building wing +46 foot elevation, fire area roof E, main steam isolation valve #2 area On March 7, 2012, reactor auxiliary building +35 foot elevation, fire area reactor auxiliary building 7, relay room On March 13, 2012, reactor auxiliary building +21 foot elevation, fire area reactor auxiliary building 15, emergency diesel generator B room On March 14, 2012, reactor auxiliary building +21 foot elevation, fire area reactor auxiliary building 8A, vital switchgear room A 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 that fire doors, dampers, and penetration seals appeared to be in satisfactory condition. 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. No findings were identified. Findings

.2 Annual Fire Protection Drill Observation

Main article: IP 71111.05A

a. On January 28, 2012, the inspectors observed the fire brigade activation as the result of an actual fire in turbine building +15 at steam generator feedwater pump B. The observation evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that the licensee staff identified deficiencies; openly discussed them in a self-critical manner at the drill debrief; and took appropriate corrective actions. Specific attributes evaluated were (1) proper wearing of turnout gear and self-contained breathing apparatus; (2) proper use and layout of fire hoses; (3) employment of appropriate fire fighting techniques; (4) sufficient firefighting equipment brought to the scene; (5) effectiveness of fire brigade leader communications, command, and control; (6) search for victims and propagation of the fire into other plant areas; (7) smoke removal operations; (8) utilization of preplanned strategies; (9) adherence to the preplanned drill scenario; and (10) drill objectives. Inspection Scope These activities constitute completion of one annual fire-protection inspection sample as defined in Inspection Procedure 71111.05-05. b. No findings were identified. Findings

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

Main article: IP 71111.11

.1 a. Quarterly Review of Licensed Operator Requalification Program On February 6, 2012, the inspectors observed a crew of licensed operators in the plant's simulator during requalification testing.

The inspectors assessed the following areas: Inspection Scope 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 These activities constitute completion of one quarterly licensed operator requalification program sample as defined in Inspection Procedure 71111.11. b. No findings were identified. Findings

.2 Quarterly Observation of Licensed Operator Performance

a. Inspection Scope

On January 28, 2012, the inspectors observed the performance of on-shift licensed operators in the plant's main control room. At the time of the observations, the plant was in a period of heightened activity due to a reduction in power to 55 percent to perform repairs on the B steam generator feedwater pump. The inspectors assessed the operators' adherence to plant procedures, expectations, and reactivity management policies.

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

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

Main article: IP 71111.12

a. The inspectors evaluated degraded performance issues involving the following risk significant systems: Inspection Scope On January 17, 2012, chilled water and refrigeration (essential chiller) relay failures On January 26, 2012, core protection calculators central processing unit board failures 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 Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or -(a)(2) Verifying appropriate performance criteria for structures, systems, and components classified as having an adequate demonstration of performance through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as requiring the establishment of appropriate and adequate goals and corrective actions for systems classified as not having adequate performance, as described in 10 CFR 50.65(a)(1)

The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were 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 quarterly maintenance effectiveness samples as defined in Inspection Procedure 71111.12-05. b. No findings were identified. Findings

1R13 Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

a. 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: Inspection Scope On January 19, 2012, scheduled maintenance activities on the essential chiller AB with the air handling unit for the switchgear ventilation being out of service On January 26, 2012, scheduled maintenance activities on the high pressure safety injection pump B with a tornado watch and the essential chiller AB being out of service On February 2, 2012, emergent maintenance activities on the containment cooling fan B with the component cooling water inlet isolation valve being out of service On February 12, 2012, emergent maintenance to repair feeder breaker on essential chiller B while essential chiller AB being unavailable On February 29, 2012, scheduled maintenance activities on the emergency diesel generator A On March 19, 2012, scheduled maintenance activities on the emergency diesel generator B lockout feature The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified 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 six maintenance risk assessments and emergent work control inspection samples as defined in Inspection Procedure 71111.13-05. b. No findings were identified. Findings

1R15 Operability Evaluations and Functionality Assessments

Main article: IP 71111.15

a. The inspectors reviewed the following assessments: Inspection Scope On January 23, 2012, operability evaluation for the emergency diesel generator B electronic speed control monitor On February 14, 2012, operability evaluation for essential chiller B and essential chiller AB On February 27, 2012, operability evaluation of air leak on emergency diesel generator B control air system On March 4, 2012, operability evaluation for dry cooling tower fans did not cycle to maintain temperature on component cooling train A On March 20, 2012, operability evaluation of emergency diesel generator B lockout protective feature when the turning gear engaged alarm failed to illuminate On March 22, 2012, operability evaluation of component cooling water system with a system leak through a lifted relief valve The inspectors selected these operability and functionality assessments based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that technical specification operability was properly justified and 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 updated final safety analysis report to the licensee personnel's evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. Additionally, the inspectors also reviewed a sampling of corrective action 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 six operability evaluations inspection samples as defined in Inspection Procedure 71111.15-05.

b. No findings were identified. Findings

R19 Post Maintenance Testing

Main article: IP 71111.19

a. The inspectors reviewed the following postmaintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability: Inspection Scope On January 14, 2012, corrective maintenance to replace a failed KB relay on essential chiller A On January 23, 2012, scheduled maintenance outage on the emergency diesel generator B On January 24, 2012, corrective maintenance to replace a solenoid on essential chiller AB On February 2, 2012, scheduled maintenance to replace limit switch on the component cooling water inlet isolation valve On March 4, 2012, corrective maintenance to replace process analog cards for the train A dry cooling tower fans On March 6, 2012, scheduled maintenance outage for emergency diesel generator A 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 Acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate The inspectors evaluated the activities against the technical specifications, the updated 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 postmaintenance 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 six postmaintenance testing inspection samples as defined in Inspection Procedure 71111.19-05.

b.

Introduction.

A Green self-revealing non-cited violation of Waterford Steam Electric Station, Unit 3, Technical Specification 6.8.1.a occurred because the licensee did not establish procedures for performing preventive maintenance tasks on the dry cooling tower (DCT) component cooling water inlet isolation valves CC-135A and CC-135B limit switches. Specifically, the licensee had not developed preventive maintenance tasks to lubricate or replace critical limit switches that provide a permissive for the operation of the DCT fans. Findings

Description.

On February 4, 2011, the train A DCT fans did not automatically start to maintain temperature as designed when component cooling water temperature exceeded 92 degrees Fahrenheit. The failure of the DCT fans to start was identified by an alarm in the main control room. An auxiliary component cooling water train A header low pressure alarm occurred when a temperature control valve opened to maintain component cooling water temperature below 95 degrees Fahrenheit. The ultimate heat sink at Waterford Unit 3 is composed of the component cooling water and auxiliary component cooling water systems. The inability of the DCT fans to auto start rendered train A of the ultimate heat sink inoperable. The licensee initiated a condition report to evaluate the cause of the problem. The licensee's investigation revealed that the failure of the DCT fans to auto start was due to a stuck limit switch on the train A DCT component cooling water inlet isolation valve CC-135A. The licensee determined that the arm on the limit switch became stuck while the valve was in the closed position. When the valve opened, the arm on the limit switch remained in the closed position. The inspectors noted from the review of the apparent cause evaluation that the limit switch must indicate that the valve is open to send the permissive signal required to start the DCT fans. The inspectors concluded that the limit switch became stuck because there was no preventive maintenance task to lubricate and check the functional operation of the component. The inspectors determined that there was no preventive maintenance task prescribed for the component because the limit switches were classified as non-critical components in the licensee's preventive maintenance program. The inspectors noted preventive maintenance basis procedure EN-DC-335 recommended that licensee personnel develop preventative maintenance tasks for those components classified as High or Low. The procedure also suggested that components classified as non-critical or run-to-failure generally would not have a preventive maintenance task assigned. The licensee originally classified the limit switches as high critical components, but changed the classification in 2006 during a preventive maintenance optimization project. Therefore, the licensee had not developed a preventive maintenance task for the limit switches when the licensee reclassified the component. The licensee entered this condition into their corrective action program as CR-WF3-2011-0679 for resolution. The immediate corrective action included the lubrication of the limit switch and the manual stroking of the valve to obtain free and smooth movement of the degraded equipment. The planned corrective actions include the development of a preventive maintenance task to lubricate and replace the limit switches on a scheduled frequency.

Analysis.

The failure to establish procedures for performing preventive maintenance tasks on the DCT component cooling water inlet isolation valves CC-135A and CC-135B limit switches is a performance deficiency. The inspectors determined that it was reasonable for the licensee to be able to foresee and prevent occurrence of this deficiency. The performance deficiency is more than minor because it is associated with the equipment performance attribute of the mitigating systems cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, since there was no preventive maintenance task for lubrication and replacement of the component, the limit switches can become stuck and render an entire train of DCT fans inoperable. The inspectors determined the significance using the NRC Inspection Manual 0609, Attachment 0609.04, "Phase 1 - Initial Screening and Characterization of Findings." The inspectors determined that the finding is of very low safety significance (Green) because it is not a design or qualification deficiency, did not represent a loss of a safety function of a system or a single train for greater than its technical specification completion time, and did not screen as potentially risk-significant due to an external initiating events. The inspectors also concluded that no cross-cutting aspect is applicable to this finding because the performance deficiency is not reflective of current performance since reclassification of the component occurred in 2006.

Enforcement.

Waterford Steam Electric Station, Unit 3, Technical Specification 6.8.1.a requires, in part, that procedures shall be established and implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Appendix A, Section 9b states, in part, that preventive maintenance schedules should be developed to specify lubrication schedules, inspections of equipment, and inspection or replacement of parts that have a specific lifetime. Contrary to the above, from 2006 to the present, the licensee had not developed preventive maintenance tasks to specify lubrication and replacement schedules of critical limit switches that provide a permissive for the operation of the DCT fans. As a result, on February 4, 2011, the limit switch on valve CC-135A failed to operate as designed and rendered an entire train of DCT fans inoperable. The immediate corrective action included the lubrication of the limit switch and the manual stroking of the valve to obtain free and smooth movement of the degraded equipment to restore compliance. The licensee entered this condition into their corrective action program as CR-WF3-2011-0679 for resolution. Because this violation of Technical Specification 6.8.1.a is of very low safety significance and was entered into the licensee's corrective action program, this violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy: NCV 05000382/2012002-01, "Failure to Develop Preventive Maintenance Tasks for Critical Limit Switches on Component Cooling Water Inlet Isolation Valves."

R22 Surveillance Testing

Main article: IP 71111.22

a. Inspection Scope

The inspectors reviewed the updated final safety analysts 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 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. Specific documents reviewed during this inspection are listed in the attachment.

On January 26, 2012, essential chiller AB On February 2, 2012, auxiliary component cooling water pump A (an inservice test) On February 9, 2012, fire protection system pump operability test On February 13, 2012, reactor coolant system water inventory balance (a leak detection surveillance) On March 7, 2012, component cooling water pump A (an inservice test) On March 19, 2012, emergency diesel generator B These activities constitute completion of six surveillance testing inspection samples as defined in Inspection Procedure 71111.22-05. b.

Introduction.

The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI because the licensee did not identify and perform testing on a safety-related component to demonstrate that it would perform satisfactorily in service in accordance with requirements contained in applicable design documents. Specifically, the licensee did not identify and perform proper testing for the essential chiller hot gas bypass valves RFR-106A, B, and C. Findings

Description.

On January 18, 2012, the AB essential chiller hot gas bypass valve (HGBV) RFR-106C did not open as designed when the ambient temperature fell below a predetermined set-point on a temperature switch. The licensee noted that the AB essential chiller secured and automatically started five times on load recycle. The initial troubleshooting assessment determined that the most likely cause was the malfunction of the HGBV since it did not open to artificially load the chiller at low load conditions by introducing a portion of the hot gas from the compressor directly to the cooler. This helps prevent surging of the chiller at low load conditions. The licensee initiated a condition report and a work request to resolve the problem.

The inspectors reviewed the condition report and associated work orders related to this issue. During the review, the inspectors noted that the licensee used three methods to test the HGBVs depending on plant conditions per Attachment 11.12 of Operating Procedure OP-002-004, "Chilled Water System." The licensee developed these three methods from a work order task prior to the methods being translated to the procedure in October 2011. However, the inspectors identified that two of the three methods in the procedure and none of the methods specified in the work order task tested the safety-related circuitry associated with the valve. The HGBV circuitry has a safety-related solenoid valve to close the valve when chilled water temperature increases to a predetermined set-point on a temperature switch. The HGBV safety position is to close so that there is full capacity of the chillers to remove heat from the chilled water system during design basis accident conditions. The inspectors determined that each HGBV must be verified operable or be in its safety-related closed position so that the associated chiller can perform its safety function. The inspectors reviewed the previous surveillances and work order tasks for the essential chiller HGBVs and determined that the safety-related circuitry to close the HGBV had not been previously demonstrated. The inspectors concluded that the licensee had not identified and performed proper testing for the essential chillers HGBVs. The licensee entered this condition into the corrective action program as CR-WF3-2012-0632 and CR-WF3-2012-0659. The immediate corrective action included testing the HGBVs RFR-106A and 106B to demonstrate the proper performance of their safety function. The essential chiller HGBV RFR-106C associated with AB essential chiller remained inoperable until the licensee performed corrective maintenance on the valve. The licensee also conducted an operability determination that documented and evaluated the non-conformance and degraded condition.

Analysis.

The failure to identify and perform testing to demonstrate that a safety-related component would perform satisfactorily in service in accordance with requirements contained in applicable design documents is a performance deficiency. The inspectors determined that it was reasonable for the licensee to be able to foresee and prevent occurrence of this deficiency. The performance deficiency is more than minor because it is associated with the equipment performance attribute of the mitigating systems cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, HGBV closure is required to ensure the essential chiller can perform its safety function during all design basis accident conditions. The inspectors determined the significance using the NRC Inspection Manual 0609, Attachment 0609.04, "Phase 1 - Initial Screening and Characterization of Findings." The inspectors determined that the finding is of very low safety significance (Green) because it is not a design or qualification deficiency, did not represent a loss of a safety function of a system or a single train for greater than its technical specification completion time, and did not screen as potentially risk-significant due to any external initiating events. This finding has a cross-cutting aspect in the resources component of the human performance area in that the licensee failed to ensure that complete, accurate, and up-to-date test procedures were available to demonstrate that equipment performance is adequate to assure nuclear safety H.2(c).

Enforcement.

Title 10 of CFR Part 50, Appendix B, Criterion XI, "Test Control," requires, in part, that a test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Contrary to the above, as of February 2, 2012, the licensee had not identified and performed testing to demonstrate that a safety-related component would perform satisfactorily in service in accordance with requirements contained in applicable design documents. Specifically, the licensee had not identified and performed proper testing for the essential chiller HGBVs RFR-106A, B, and C. As a result, the licensee could not demonstrate that the HGBV would close under design basis accident conditions without performing a test and operability evaluation. The licensee performed an operability determination that documented and evaluated this non-conformance and degraded condition. The licensee entered this condition into their corrective action program as CR-WF3-2012-0632 and CR-WF3-2012-0659. The immediate corrective action included testing the HGBVs to demonstrate the proper performance of their safety function. Because this violation of Appendix B, Criterion XI is of very low safety significance and was entered into the licensee's corrective action program, this violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy: NCV 05000382/2012002-02, "Failure to Identify and Perform Testing to Demonstrate Performance of Safety-Related Valves". Cornerstone: Emergency Preparedness 1EP4 Emergency Action Level and Emergency Plan Changes (IP71114.04)

a. Inspection Scope

The headquarters staff from the office of Nuclear Security and Incident Response (NSIR) performed an in-office review of the latest revisions of various Emergency Plan Implementing Procedures (EPIPs) located under ADAMS accession number ML12053A014 as listed in the attachment.

The licensee transmitted the EPIP revisions to the NRC pursuant to the requirements of 10 CFR50, Appendix E, Section V, "Implementing Procedures." The NRC review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection. The specific documents reviewed during this inspection are listed in the Attachment.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

Main article: IP 71114.06

.1 Emergency Preparedness Drill Observation

a. The inspectors evaluated the conduct of a routine licensee emergency drill on February 15, 2012, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator, technical support center, and emergency offsite facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensee drill critique to compare any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the corrective action program. As part of the inspection, the inspectors reviewed the drill package and other documents listed in the attachment. Inspection Scope These activities constitute completion of one sample as defined in Inspection Procedure 71114.06-05.

b. No findings were identified. Findings

.2 Training Observations

a. The inspectors observed a simulator training evolution for licensed operators on February 6, 2012, which required emergency plan implementation by a licensee operations crew. This evolution was planned to be evaluated and included in performance indicator 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.

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

b. No findings were identified. Findings

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical Protection

4OA1 Performance Indicator Verification

Main article: IP 71151

.1 Data Submission Issue

a. The inspectors performed a review of the performance indicator data submitted by the licensee for the fourth Quarter 2011 performance indicators for any obvious inconsistencies prior to its public release in accordance with Inspection Manual Chapter 0608, "Performance Indicator Program." Inspection Scope This review was performed as part of the inspectors' normal plant status activities and, as such, did not constitute a separate inspection sample.

b. No findings were identified. Findings

.2 Unplanned Scrams per 7000 Critical Hours (IE01)

a. The inspectors sampled licensee submittals for the unplanned scrams per 7000 critical hours performance indicator for the period from the fourth quarter 2010 through the fourth quarter 2011. 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, event reports, and NRC integrated inspection reports for the period of January 2011 through January 2012 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. Inspection Scope These activities constitute completion of one unplanned scrams per 7000 critical hours sample as defined in Inspection Procedure 71151-05. b. No findings were identified. Findings

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

a. The inspectors sampled licensee submittals for the unplanned power changes per 7000 critical hours performance indicator for the period from the fourth quarter 2010 through the fourth quarter 2011. 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, maintenance rule records, event reports, and NRC integrated inspection reports for the period of January 2011 through January 2012 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. Inspection Scope These activities constitute completion of one unplanned transients per 7000 critical hours sample as defined in Inspection Procedure 71151-05.

b. No findings were identified. Findings

.4 Unplanned Scrams with Complications (IE04)

a. The inspectors sampled licensee submittals for the unplanned scrams with complications performance indicator for the period from the fourth quarter 2010 through the fourth quarter 2011. 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, event reports, and NRC integrated inspection reports for the period of January 2011 through January 2012 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. Inspection Scope These activities constitute completion of one unplanned scrams with complications sample as defined in Inspection Procedure 71151-05. b. No findings were identified. Findings

4OA2 Problem Identification and Resolution

Main article: IP 71152

.1 Routine Review of Identification and Resolution of Problems

a. As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensee's corrective action program at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. The inspectors reviewed attributes that included the complete and accurate identification of the problem; the timely correction, commensurate with the safety significance; the evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews; and the classification, prioritization, focus, and timeliness of corrective actions. Minor issues entered into the licensee's corrective action program because of the inspectors' observations are included in the attached list of documents reviewed. Inspection Scope 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. b. No findings were identified. Findings

.2 Daily Corrective Action Program Reviews

a. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensee's corrective action program. The inspectors accomplished this through review of the station's daily corrective action documents. Inspection Scope 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. No findings were identified. Findings

.3 Selected Issue Follow-up Inspection

a. On January 18, 2012, during a review of items entered in the licensee's corrective action program, the inspectors recognized a corrective action item documenting actions associated with the failure of essential chiller AB relief valve, RFR-107 C. The inspectors reviewed the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of the resolution. The inspectors assessed whether the evaluation identified likely causes for the issues and identified appropriate corrective actions to address the identified causes. The inspectors also conducted a review of the corrective actions to verify that appropriate measures were in place to prevent reoccurrence of the issue. In addition, the inspectors assessed whether the licensee's evaluation considered extent of condition, generic implications, common cause, and previous occurrences. The inspectors reviewed the potential impact on nuclear safety and risk to verify that the licensee had taken corrective actions commensurate with the significance of the issue. The inspectors evaluated these actions against the requirements of the licensee's corrective action program and performance attributes contained in IP 71152, Section 03.06. Inspection Scope These activities constitute completion of one in-depth problem identification and resolution sample as defined in Inspection Procedure 71152-05.

b. The inspectors reviewed the failure of essential chiller AB relief valve, RFR-107 C and determined that the vendor specification for the relief valve recommended replacement after five years. However, the existing licensee preventive maintenance task replaced the valves after eight or 10 years (depending on the chiller). Since the relief valve failed after four years, the longer maintenance periodicity did not contribute to the event. The licensee plans to revise the preventive maintenance task to provide a shorter frequency. Findings and Observations

.4 In-depth Review of Operator Workarounds

a. On March 16, 2012, during a review of items entered in the licensee's corrective action program, the inspectors reviewed operator workarounds and burdens. The inspectors considered the following during the review of the licensee's actions: (1) complete and accurate identification of problems in a timely manner; (2) evaluation and disposition of operability/reportability issues; (3) consideration of extent of condition, generic implications, common cause, and previous occurrences; (4) classification and prioritization of the resolution of the problem; (5) identification of root and contributing causes of the problem; (6) identification of corrective actions; and (7) completion of corrective actions in a timely manner. Inspection Scope These activities constitute completion of one in-depth problem identification and resolution sample as defined in Inspection Procedure 71152-05 b. No findings were identified. Findings

4OA3 Follow-up of Events and Notices of Enforcement Discretion

Main article: IP 71153

.1 (Closed) Licensee Event Report (LER) 05000382/2011-004-00, Vendor Notification of Non-Conforming Part Renders Both Trains of QSPDS Inoperable

On July 27, 2011, the licensee received a Westinghouse Nuclear Safety Advisory Letter that the power supply harness for the qualified safety parameter display system (QSPDS) may be undersized and potentially unable to perform its function during all environmental conditions. The licensee installed this harness in both QSPDS channels, but no failures had occurred since installation. The inspectors reviewed this condition and the licensee's corrective actions to address the potentially undersized harnesses. No findings or violations of NRC requirements were identified. This licensee event report is closed.

.2 (Closed) LER 05000382/2011-005-00, Loss of Essential Chiller B Caused Less Than 100 Percent Emergency Feedwater Supply Capability

On October 20, 2011, the essential chilled water loop B was declared inoperable due to a Freon relief valve failure. This resulted in the emergency feedwater train B also being inoperable. At the time, the emergency feedwater pump AB was also inoperable for scheduled maintenance. The end result was less than 100 percent emergency feedwater capability. The licensee entered the violation into their corrective action program and took action to replace the relief valves every three years. No findings or more than minor violations of NRC requirements were identified. This licensee event report is closed.

4OA6 Meetings, Including Exit Exit Meeting Summary On April 10, 2012, the inspectors presented the inspection results to Ms. Donna Jacobs, Site Vice President, 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 were identified.

A-1 Attachment

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Entergy Personnel

D. Jacobs, Site Vice President, Operations

K. Cook, General Manager, Plant Operations

K. Nichols, Director, Engineering

D. Hamilton, Director, Nuclear Safety Assurance

B. Lanka, Manager, System Engineering

W. McKinney, Manager, Corrective Action Program and Assessments

W. Steeleman, Manager, Licensing

R. Gilmore, Manager, Programs and Components

C. Fugate, Manager, Operations

J. Hornsby, Manager, Chemistry

R. Porter, Manager, Design Engineering

B. Lindsey, Manager, Maintenance

G. Fey, Manager, Emergency Planning

J. Gumnick, Manager, Radiation Protection

J. Rachal, Supervisor, System Engineering

R. O'Quinn, Senior Engineer, Programs and Components

D. Viener, Supervisor, Programs and Components

J. Pollack, Senior Licensing Specialist, Licensing

W. Hardin, Senior Licensing Specialist, Licensing

NRC Personnel

M. Davis, Senior Resident Inspector

D. Overland, Resident Inspector

R. Azua, Senior Project Engineer

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000382/2012002-01 NCV Failure to Develop Preventive Maintenance Tasks for Critical Limit Switches on Component Cooling Water Inlet Isolation Valves (Section 1R19)

05000382/2012002-02 NCV Failure to Identify and Perform Testing to Demonstrate Performance of Safety-Related Valves (Section 1R22)

Closed

05000382/LER-2011-004-00 LER Vendor Notification of Non-Conforming Part Renders Both Trains of QSPDS Inoperable

05000382/LER-2011-005-00 LER Loss of Essential Chiller B Caused Less Than 100% Emergency Feedwater Supply Capability LISTS OF

DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

Procedures/Documents Number Title Revision

OP-002-007 Freeze Protection and Temperature Maintenance 16

OP-901-521 Severe Weather and Flooding 304

Section 1R04: Equipment Alignment

Procedures/Documents Number Title Revision

OP-002-001 Auxiliary Component Cooling Water 302

OP-002-003 Component Cooling Water 309

OP-009-003 Emergency Feedwater 303

OP-002-004 Chilled Water System 307

OP-009-002 Emergency Diesel Generator 317

OP-006-001 Plant Distribution Systems 307

SD-CHW Essential Chilled Water 6 DWG G-853 HVAC Chilled Water Flow

Condition Reports

CR-WF3-2011-6573

CR-WF3-2011-6653

CR-WF3-2012-0022 CR-WF3-2012-0024

Section 1R05: Fire Protection

Procedures/Documents Number Title Revision

UNT-005-013 Fire Protection Program 11

OP-009-004

Fire Protection

307

MM-007-010

Fire Extinguisher Inspection and Replacement

304

EN-DC-161 Control of Combustibles

6

FP-001-014

Duties of a Fire Watch

16

FP-001-015

Fire Protection System Impairments

303

OP-903-060 Fire Hose Station Inspection 8

NS-TB-002 Pre-Fire Strategies for +15 TG West 1 G-1369 Fire Protection Reactor Building and Wing Area Plan Elevation +46 0 G-1375 Fire Protection Reactor Auxiliary Building Plan Elevation +35 1 G-1359 Fire Protection Reactor Auxiliary Building Plan Elevation +21 2