ML092240471
| ML092240471 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/12/2009 |
| From: | Clark J NRC/RGN-IV/DRP/RPB-E |
| To: | Kowalewski J Entergy Operations |
| References | |
| IR-09-003 | |
| Download: ML092240471 (43) | |
See also: IR 05000382/2009003
Text
UNITED STATES
NUC LE AR RE G UL AT O RY C O M M I S S I O N
R E GI ON I V
612 EAST LAMAR BLVD , SU I TE 400
AR LI N GTON , TEXAS 76011-4125
August 12, 2009
Joseph Kowalewski, Vice President, Operations
Entergy Operations, Inc.
Waterford Steam Electric Station, Unit 3
17265 River Road
Killona, LA 70057-3093
Subject: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED
INSPECTION REPORT 05000382/2009-003
Dear Mr. Kowalewski:
On July 7, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at
your Waterford Steam Electric Station, Unit 3. The enclosed integrated inspection report
documents the inspection findings, which were discussed on August 11, 2009, with you and
other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
This report documents three NRC identified findings of very low safety significance (Green). All
of these findings involved violations of NRC requirements. However, because of the very low
safety significance and because they are entered into your corrective action program, the NRC
is treating these findings as noncited violations, consistent with Section VI.A.1 of the NRC
Enforcement Policy. If you contest the violations or the significance of the noncited violations,
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, D.C. 20555-0001, with copies to the Regional Administrator, U.S. Nuclear
Regulatory Commission, Region IV, 612 E. Lamar Blvd, Suite 400, Arlington, Texas,
76011-4125; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission,
Washington, D.C. 20555-0001; and the NRC Resident Inspector at the Waterford Steam Electric
Station, Unit 3 facility. In addition, if you disagree with the characterization of any finding 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 Waterford Steam Electric Station, Unit 3. The information you provide will
be considered in accordance with Inspection Manual Chapter 0305.
Entergy Operations, Inc. -2-
In accordance with 10 CFR 2.390 of the NRC's Rules of Practice, a copy of this letter, and its
enclosure, will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records component of NRCs document system (ADAMS).
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the
Public Electronic Reading Room).
Sincerely,
/RA/
Jeffrey A. Clark, P.E.
Project Branch E
Division of Reactor Projects
Docket: 50-382
License: NPF-38
Enclosure:
NRC Inspection Report 05000382/2009003
w/Attachment: Supplemental Information
cc: w/Enclosure Site Vice President
Senior Vice President Waterford Steam Electric Station, Unit 3
Entergy Nuclear Operations Entergy Operations, Inc.
P. O. Box 31995 17265 River Road
Jackson, MS 39286-1995 Killona, LA 70057-0751
Director
Senior Vice President and Nuclear Safety Assurance
Chief Operating Officer Entergy Operations, Inc.
Entergy Operations, Inc. 17265 River Road
P. O. Box 31995 Killona, LA 70057-0751
Jackson, MS 39286-1995
General Manager, Plant Operations
Vice President, Operations Support Waterford 3 SES
Entergy Services, Inc. Entergy Operations, Inc.
P. O. Box 31995 17265 River Road
Jackson, MS 39286-1995 Killona, LA 70057-0751
Senior Manager, Nuclear Safety Manager, Licensing
and Licensing Entergy Operations, Inc.
Entergy Services, Inc. 17265 River Road
P. O. Box 31995 Killona, LA 70057-3093
Jackson, MS 39286-1995
Chairman
Louisiana Public Service Commission
P. O. Box 91154
Baton Rouge, LA 70821-9154
Entergy Operations, Inc. -3-
Parish President Council Chief, Technological Hazards
St. Charles Parish Branch
P. O. Box 302 FEMA Region VI
Hahnville, LA 70057 800 North Loop 288
Federal Regional Center
Director, Nuclear Safety & Licensing Denton, TX 76209
Entergy, Operations, Inc.
440 Hamilton Avenue Chairperson, Radiological Assistance
White Plains, NY 10601 Committee
Region VI
Louisiana Department of Environmental Federal Emergency Management Agency
Quality, Radiological Emergency Planning Department of Homeland Security
and Response Division 800 North Loop 288
P. O. Box 4312 Federal Regional Center
Baton Rouge, LA 70821-4312 Denton, TX 76201-3698
Entergy Operations, Inc. -4-
Electronic distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov)
Deputy Regional Administrator (Chuck.Casto@nrc.gov)
DRP Director (Dwight.Chamberlain@nrc.gov)
DRP Deputy Director (Anton.Vegel@nrc.gov)
DRS Director (Roy.Caniano@nrc.gov)
DRS Deputy Director (Troy.Pruett@nrc.gov)
Senior Resident Inspector (Ray.Azua@nrc.gov)
Resident Inspector (Dean.Overland@nrc.gov)
Branch Chief, DRP/E (Jeff.Clark@nrc.gov)
Senior Project Engineer, DRP/E (George.Replogle@nrc.gov)
WAT Site Secretary (Linda.Dufrene@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
Regional Counsel (Karla.Fuller@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov)
OEMail Resource
Regional State Liaison Officer (Bill.Maier@nrc.gov)
NSIR/DPR/EP (Steve.LaVie@nrc.gov)
Only inspection reports to the following:
OEDO RIV Coordinator (Leigh.Trocine@nrc.gov)
ROPreports
File located: R:\_REACTORS\_WAT\2009\WAT 2009003 RP-DHOAdams.doc ML092240471
SUNSI Rev Compl. :Yes No ADAMS :Yes No Reviewer Initials GDR
Publicly Avail : Yes No Sensitive Yes : No Sens. Type Initials GDR
RIV:SRI:DRP/E SPE/DRP/E C:DRS/EB1 C:DRS/EB2 C:DRs/OB
DHOverland GDReplogle TRFarnholtz NFOKeefe RELantz
/RA/-E /RA/ /RA/ /RA/ /RA/
8/4/09 8/5/09 8/5/09 8/5/09 8/5/09
C:DRS/PSB C:DRS/OSB2 C:DRP/E
MPShannon GEWerner JAClark
/RA/ /RA/ /RA/
8/ /09 8/8/09 8/11/09
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 05000382
License: NFP-38
Report: 05000382/2009003
Licensee: Entergy Operations, Inc.
Facility: Waterford Steam Electric Station, Unit 3
Location: Hwy. 18
Killona, LA
Dates: April 7 through July 7, 2009
Inspectors: D. Overland, Senior Resident Inspector
Paul J. Elkmann, Senior Emergency Preparedness Inspector
Gilbert L. Guerra, CHP, Emergency Preparedness Inspector
Approved By: Jeff Clark, Chief, Project Branch E
Division of Reactor Projects
-1- Enclosure
SUMMARY OF FINDINGS
IR 05000382/2009003; 4/7/09 - 7/7/09; Waterford Steam Electric Station, Unit 3; Problem
Identification and Resolution: Exercise Evaluation, Identification and Resolution of Problems
The report covered a 3-month period of inspection by resident inspectors and an announced
baseline inspection by regional based inspectors. Three Green noncited 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. 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 noncited violation of 10 CFR Part 50,
Appendix B, Criterion VXI (Corrective Actions), because the licensee failed to
identify the cause for a significant condition adverse to quality. The Train B 125
Vdc battery bank failed to pass a technical specification surveillance requirement
discharge test during a Spring 2008 outage. The root cause procedure required
that the licensee sequester the battery in a controlled area so that vital
information related to the failure could be obtained. However, the licensee
disposed of the battery instead. When questions arose concerning the specified
failure cause (impurities in the battery materials), the licensee was unable to
provide objective evidence to support the conclusion. Had the licensee obtained
objective evidence to support their conclusion that impurities caused the battery
failure, a 10 CFR Part 21 report may have been required. The licensee replaced
the battery and planned to replace similar batteries in the other two trains during
the next refueling outage. The licensee entered this finding in their corrective
action program as Condition Report CR-WF3-2009-2846.
The finding was more than minor because, if left uncorrected, it could lead to a
more significant safety concern. Specifically, since the cause of the battery
failure was not definitively found, the licensee may not have taken corrective
actions to prevent other battery failures. Using the Inspection Manual
Chapter 0609, Significance Determination Process, Phase 1 Screening
Worksheet, the finding was of very low risk significance because it did not
actually cause the loss of operability or functionality of another 125 Vdc battery at
the time of the inspection. This finding had a crosscutting aspect in the area of
Problem Identification and Resolution (Corrective Action Program Component)
because the licensee failed to thoroughly evaluate the need to keep the battery
prior to disposal P.1(c) (Section 4OA2).
- Green. The inspectors identified a noncited violation of 10 CFR Part 50,
Appendix B, Criterion XVI (Corrective Action), for the failure to promptly correct
-2- Enclosure
conditions adverse to quality. The licensee had documented several conditions
adverse to quality and then transferred the concerns to other condition reports.
Then, the licensee closed those condition reports without addressing the
concerns. Identified conditions included (1) the Train B 125 Vac discharge test
data indicated a loose battery connection but the battery was permitted to pass
the test anyway; (2) the root cause determination for the failed battery was
focused on the statements of one person and failed to address other information;
(3) the root cause determination failed to address conflicting information;
and (4) the root cause determination failed to properly address other potential
causes for the inoperable battery, such as tampering. Plant personnel had failed
to accurately translate the issues when transferring information from one
condition report to another. The licensee entered this finding into their corrective
action program as Condition Report CR-WF3-2009-1177.
The finding was more than minor because, if left uncorrected, it would become a
more significant safety concern. For example, the failure to include acceptance
criteria in the battery discharge test (intended to identify and correct loose battery
connections) could result in another inoperable 125 Vdc battery for an extended
period. The inspectors evaluated the finding using Inspection Manual
Chapter 609, Significance Determination Process, Phase 1 Screening Worksheet
and determined that the finding was of very low risk significance because it did
not result in another battery becoming inoperable or nonfunctional. This finding
had a crosscutting aspect in the area of Human Performance (Work Practices
Component) because plant personnel failed to effectively use human error
prevention techniques, such as self and peer checking, when transferring
concerns between condition reports H.4(a) (Section 4OA2).
Cornerstone: Emergency Preparedness
- Green. The inspectors identified a noncited violation of 10 CFR 50.47(b)(10) for
the licensees failure to develop and have in place guidelines for the choice of
protective actions during an emergency that were consistent with federal
guidance. Specifically, the licensees guidelines for extending existing protective
action recommendations into additional geographical areas of the emergency
planning zone under conditions of changing wind vectors were not consistent
with the guidance of EPA-400-R-92-001, AManual of Protective Action Guides
and Protective Actions for Nuclear Incidents.@ The licensees practices resulted
in unnecessary recommendations for protective actions in areas where valid
dose projections show federal protective action guides are not exceeded, and
may expose members of the public to unjustified risks. The licensee has entered
this issue into their corrective action system as Condition
Report CR-WF3-2009-03256.
This finding was more than minor because it was not similar to the examples of
Manual Chapter 0612, Appendix E, and affected the emergency preparedness
cornerstone objective because unnecessary protective actions may expose
members of the public to an unjustified risk. The finding was associated with the
-3- Enclosure
emergency response organization attributes of 50.47(b) planning standards and
training. This finding was of very low safety significance because it was not a
risk significant planning standard functional failure or degraded function because
licensee protective action recommendations would be issued in accordance with
federal guidance for all areas of the emergency planning zone where Protective
Action Guides are exceeded. This finding was evaluated as not having a
crosscutting aspect because the finding was not indicative of current licensee
performance (Section 1EP1).
B. Licensee-Identified Violations
None
-4- Enclosure
REPORT DETAILS
Summary of Plant Status
The plant began the inspection period on April 7, 2009, at 100 percent power and remained at
approximately 100 percent power for the rest of the inspection period.
1. REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and
1R01 Adverse Weather Protection (71111.01)
.1 Summer Readiness for Offsite and Alternate-ac Power
a. Inspection Scope
The inspectors performed a review of the licensees preparations for summer weather for
selected systems, including conditions that could lead to loss-of-offsite power and
conditions that could result from high temperatures. The inspectors reviewed the
licensees procedures affecting these areas and the communications protocols between
the transmission system operator and the plant to verify that the appropriate information
was being exchanged when issues arose that could affect the offsite power system.
Examples of aspects considered in the inspectors review included:
- The coordination between the transmission system operator and the plant during
off-normal or emergency events
- The explanations for the events
- The estimates of when the offsite power system would be returned to a normal
state
- The notifications from the transmission system operator to the plant when the
offsite power system was returned to normal
During the inspection, the inspectors focused on plant-specific design features and the
licensees procedures used to mitigate or respond to adverse weather conditions.
Additionally, the inspectors reviewed the 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 the licensee was 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:
-5- Enclosure
- Station startup transformers
- Uninterruptible power supplies
These activities constitute completion of one readiness for summer weather affect on
offsite and alternate ac power sample as defined in Inspection Procedure 71111.01-05.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignments (71111.04)
.1 Partial Walkdown
a. Inspection Scope
The inspectors a performed partial system walkdown of the following risk-significant
system:
- May 11, 2009, partial system walkdown of emergency diesel generator Train B
The inspectors selected this system based on its risk significance relative to the reactor
safety cornerstones at the time it was 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, 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 system incapable of performing their intended
functions. The inspectors also walked down accessible portions of the system 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 one partial system walkdown sample as defined
in Inspection Procedure 71111.04-05.
b. Findings
No findings of significance were identified.
-6- Enclosure
.2 Complete Walkdown
a. Inspection Scope
On June 3, 2009, the inspectors performed a complete system alignment inspection of
the containment spray system Train B to verify the functional capability of the system.
The inspectors selected this system because it was considered both safety-significant
and risk-significant in the licensees probabilistic risk assessment. The inspectors
walked down 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, operability of support systems, and to ensure that
ancillary equipment 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. Findings
No findings of significance were identified.
1R05 Fire Protection (71111.05)
.1 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:
- April 28, 2009, reactor auxiliary building fire Zones 33, 35, and 36
- May 11, 2009, reactor auxiliary building fire Zones 2, 15, 16, and 23
- May 27, 2009, reactor auxiliary building fire Zones 17, 18, and 19
- May 27, 2009, reactor auxiliary building fire Zones 20, and 21
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
-7- Enclosure
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. 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
No findings of significance were identified.
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 walked down the area
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.
- July 1, 2009, review of Operating Experience Smart Sample OpESS FY2007-02,
Flooding Vulnerabilities Due to Inadequate Design and Conduit / Hydrostatic
Seal Barrier Concerns, in the switchgear Train B room
These activities constitute completion of one flood protection measure inspection sample
as defined in Inspection Procedure 71111.06-05.
b. Findings
No findings of significance were identified.
-8- Enclosure
1R11 Licensed Operator Requalification Program (71111.11)
a. Inspection Scope
On May 28, 2009, the inspectors observed a crew of licensed operators in the plants
simulator to verify that operator performance was adequate, evaluators were identifying
and documenting crew performance problems, and training was being conducted in
accordance with licensee procedures. The inspectors evaluated the following areas:
- Licensed operator performance
- Crews clarity and formality of communications
- Crews ability to take timely actions in the conservative direction
- Crews prioritization, interpretation, and verification of annunciator alarms
- Crews correct use and implementation of abnormal and emergency procedures
- Control board manipulations
- Oversight and direction from supervisors
- Crews ability to identify and implement appropriate technical specification
actions and emergency plan actions and notifications
The inspectors compared the crews performance in these areas to pre-stablished
operator action expectations and successful critical task completion requirements.
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of one quarterly licensed-operator requalification
program sample as defined in Inspection Procedure 71111.11.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness (71111.12Q)
a. Inspection Scope
The inspectors evaluated degraded performance issues involving the following risk
significant systems:
- June 2, 2009, emergency lighting system
- June 29, 2009, review of Operating Experience Smart
Sample OpESS FY2008-01, Negative trend and Recurring Events Involving
-9- Enclosure
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
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. Findings
No findings of significance 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:
- 10 - Enclosure
- April 17, 2009, replacement and calibration of power Supply 37-H for PPS
Channel B
- April 21, 2009, planned maintenance outage of Train B emergency core cooling
systems
- May 6, 2009, scheduled maintenance outage of high pressure safety injection
Train A
- June 17, 2009, corrective maintenance to replace station Battery 3AB-S Cell 31
due to low individual cell voltage
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 four maintenance risk assessments and
emergent work control inspection samples as defined in Inspection
Procedure 71111.13-05.
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations (71111.15)
a. Inspection Scope
The inspectors reviewed the following issues:
- May 12, 2009, voiding discovered at low pressure safety injection Pump A
discharge to reactor coolant Loop 2B vent
- May 13, 2009, multiple trips of control room emergency filtration unit Train A
- May 13, 2009, failure of emergency diesel generator Train A to achieve 110
percent design basis load during scheduled surveillance run
- 11 - Enclosure
The inspectors selected these potential operability issues 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 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. The inspectors determined, where appropriate,
compliance with bounding limitations associated with the evaluations. 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 three operability evaluations inspection
sample(s) as defined in Inspection Procedure 71111.15-05
b. Findings
No findings of significance were identified.
1R19 Postmaintenance Testing (71111.19)
a. Inspection Scope
The inspectors reviewed the following postmaintenance activities to verify that
procedures and test activities were adequate to ensure system operability and functional
capability:
- April 20, 2009, replacement and calibration of power Supply 37-H for PPS
Channel B
- April 22, 2009, replacement of diesel generator sequencer
Relay EG EREL2392-N following Part 21 recall
- May 7, 2009, breaker and motor maintenance and relay replacement on high
pressure safety injection Pump A
- May 13, 2009, leak test and adjustment for control room outside air intake
Valve HVC-102 following multiple trips of control room emergency filtration unit
Train A
- May 15, 2009, replacement of a motor-operated potentiometer and adjustment of
the mechanical governor following a failed emergency diesel generator Train A
surveillance run
- 12 - Enclosure
- June 5, 2009, motor maintenance and oil leak repair for containment spray
Pump A
- June 12, 2009, corrective maintenance to replace pump plungers and packing to
correct leaking seals on charging Pump AB in an attempt to reduce reactor
coolant system leakage
- June 16, 2009, corrective maintenance to replace pump plungers and packing to
correct leaking seals on charging Pump B in an attempt to reduce reactor coolant
system leakage
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 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 eight postmaintenance testing inspection
samples as defined in Inspection Procedure 71111.19-05.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing (71111.22)
a. Inspection Scope
The inspectors reviewed the Final Safety Analysis Report, procedure requirements, and
technical specifications to ensure that the five 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
- 13 - Enclosure
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.
- April 23, 2009, low pressure safety injection Pump B operability check
- April 27, 2009, component cooling water in-service valve testing
- May 8, 2009, emergency feedwater Pump A operability check
- May 26, 2009, emergency diesel generator Train A
- June 15, 2009, reactor coolant system leakage detection
- 14 - Enclosure
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of five surveillance testing inspection sample(s) as
defined in Inspection Procedure 71111.22-05.
b. Findings
No findings of significance were identified.
Cornerstone: Emergency Preparedness
1EP1 Exercise Evaluation (71114.01)
a. Inspection Scope
The inspectors reviewed the objectives and scenario for the 2009 biennial emergency
plan exercise to determine if the exercise would acceptably test major elements of the
emergency plan. The scenario simulated a tornado touchdown on site that damaged the
turbine building, a failure of a liquid radiological waste tank, a main generator trip leading
to damage in the station switchyard causing a loss of offsite power, failures of both
emergency diesel generators leading to station blackout conditions, a large reactor
coolant system break inside containment, fission product barrier failures, core damage
from fuel overheating, a filtered and monitored radiological release to the environment
via a containment penetration failure and annulus ventilation, and a change in the
direction of the radiological release to demonstrate the licensee emergency response
organizations capability to implement their emergency plan.
The inspectors evaluated exercise performance by focusing on the risk-significant
activities of event classification, offsite notification, recognition of offsite dose
consequences, and development of protective action recommendations, in the control
room simulator and the following dedicated emergency response facilities:
- Operations Support Center
- Emergency Operations Facility
The inspectors also assessed recognition of, and response to, abnormal and emergency
plant conditions, the transfer of decision making authority and emergency function
responsibilities between facilities, onsite and offsite communications, protection of
emergency workers, emergency repair evaluation and capability, and the overall
implementation of the emergency plan to protect public health and safety and the
environment. The inspectors reviewed the current revision of the facility emergency
plan, emergency plan implementing procedures associated with operation of the
licensees emergency response facilities, procedures for the performance of associated
emergency functions, and other documents as listed in the attachment to this report.
- 15 - Enclosure
The inspectors compared the observed exercise performance with the requirements in
the facility emergency plan, 10 CFR 50.47(b), 10 CFR Part 50, Appendix E, and with the
guidance in the emergency plan implementing procedures and other federal guidance.
The inspectors attended the postexercise critiques in each emergency response facility
to evaluate the initial licensee self-assessment of exercise performance. The inspectors
also attended a subsequent formal presentation of critique items to plant management.
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of one sample as defined in Inspection
Procedure 71114.01-05.
b. Findings
Introduction. The inspectors identified a noncited violation of 10 CFR 50.47(b)(10) for
the licensees failure to develop and have in place guidelines for the choice of protective
actions during an emergency that were consistent with federal guidance. Specifically,
the licensees guidelines for extending existing protective action recommendations into
additional geographical areas of the emergency planning zone under conditions of
changing wind vectors were not consistent with the guidance of EPA-400-R-92-001,
AManual of Protective Action Guides and Protective Actions for Nuclear Incidents.@
Description. The inspectors identified that Procedure EP-2-052, AProtective Action
Guidelines,@ Revision 20, allows the licensee to generate evacuation protective action
recommendations for members of the general public in areas of the emergency planning
zone where radiological protective action guides are not exceeded. Specifically,
inspectors determined that, with an existing initial protective action recommendation
based on plant conditions, the licensee's practice when changes occur in the wind
direction vector were to recommend to offsite authorities in any circumstance additional
protective actions to the same downwind distance for every geographical area traversed
by the wind as previously recommended. The recommendations would be done without
considering in the decision process whether EPA protective action guides were
exceeded in the newly-affected areas. The licensees practices result in unnecessary
recommendations for protective actions in areas where valid dose projections show
federal protective action guides are not exceeded, and may expose members of the
public to unjustified risks.
The inspectors determined the licensee has adopted a prompt protective action scheme
based on EPA-400-R-92-001, AManual of Protective Action Guides and Protective
Actions for Nuclear Incidents,@ as described by:
- Waterford 3 Steam Electric Station Emergency Plan, Revision 37,
Section 6.6.1.2, Offsite Protective Action Recommendations, states, in part, the
set of guidelines, based on dose projections, is consistent with both EPA
protective action guidelines and with the protective action guidelines of the State
of Louisiana Peacetime Radiological Response Plan, that guidelines will be used
to minimize risks for an accident and that, when total effective dose equivalent
- 16 - Enclosure
projected dose is less than 1 rem or to the projected committed dose equivalent
thyroid is less than 5 rem, no immediate actions are necessary.
- Procedure EP-2-052, AProtective Action Guidelines,@ Revision 20, states in
Section 1.0 the purpose is to provide guidance for protective action
decisionmaking with respect to the EPA Protective Action Guidelines, and in
Section 5.2.1.3, that if dose projection information is available, then use
Attachment 7.2 or equivalent computerized methods which assess the projected
radiation dose to modify the initial General Emergency protective actions as
necessary.
The inspectors reviewed the licensees Emergency Plan and emergency plan
implementing procedure for making protective action recommendations to offsite
authorities, and discussed with licensee emergency preparedness staff the licensees
expectations and practices for making protective action recommendations under
conditions of changing wind direction and radiological severity. The inspectors were
informed by the licensees emergency preparedness management that their practice
with regard to changing wind direction was to always recommend extending existing
protective actions to adjacent geographical areas affected by the new wind vector(s) to
the same downwind distance as in previously-affected areas. The licensee would make
this automatic extension of existing protective action recommendations without
considering dose projection results, even when valid dose projections were available
that showed protective action guides were not exceeded along the new wind vector(s).
The inspectors concluded that the licensees practice of always recommending to offsite
authorities the extension of protective actions to the same downwind distance as existing
recommendations was not in accordance with the guidance of EPA-400-R-92-001,
because the licensee did not modify initial General Emergency protective actions based
on EPA protective action guides when valid dose projection information was available.
The inspectors determined that the licensee performed periodic dose assessments to
assess the impact of a radiological release on the emergency planning zone as
meteorological and radiological conditions change. The inspectors determined the
licensee's practices under conditions of changing wind direction and release severity
would always result in appropriate protective action recommendations to offsite
authorities for geographical areas in the emergency planning zone where radiological
risk to the public exists (that is, where protective action guides are exceeded), but also
could result in recommendations to evacuate geographical areas where radiological risk
is determined not to exist (that is, where protective guides are not exceeded).
Analysis. Licensee practices resulting in recommending to offsite authorities protective
actions for the public in geographical areas of the emergency planning zone where valid
dose assessment has not identified that protective action guides are projected to be
exceeded was a performance deficiency, and it was within the licensees ability to
foresee and correct, and could have been prevented. The finding was more than minor
because it was not similar to the examples of Manual Chapter 0612, Appendix E, and
has the potential to impact public safety because unnecessary protective actions may
expose members of the public to an unjustified risk. The finding was associated with the
- 17 - Enclosure
emergency response organization attributes of 50.47(b) planning standards and training.
The finding affects the emergency preparedness cornerstone objective because
recommendations to offsite authorities to take protective actions in areas where
protective action guides were not exceeded affects the offsite authoritys ability to protect
the health and safety of the public, and may have resulted in unnecessary risk to the
public. This finding was evaluated using the emergency preparedness significance
determination process and was determined to have very low safety significance (Green)
because it was a failure to comply with NRC requirements, was associated with
emergency preparedness planning standard 50.47(b)(10), was associated with a risk
significant planning standard as defined in Manual Chapter 0609, Appendix B,
Section 2.0, and was not a risk significant planning standard functional failure or a risk
significant planning standard degraded function because appropriate protective action
recommendations would be issued for all geographical areas of the plume phase
emergency planning zone where protective action guides are exceeded. The finding
was evaluated as not having a crosscutting aspect.
Enforcement. Title 10 of the Code of Federal Regulations, 50.47(b)(10) states, in part,
that guidelines for the licensees choice of protective actions during an emergency,
consistent with federal guidance, are developed and in place.Section IV(B) of Part 50,
Appendix E, requires, in part, that a licensee describe the basis for determining when
and what type of protective measures should be considered outside the site boundary.
Federal guidance for the choice of protective actions during an emergency is described
in EPA-400-R-92-001. Section 1.4 of EPA-400-R-92-001 states that protective action
guides are the approximate levels at which protective measures are justified.
Section 2.3.1 of EPA-400-R-92-001 states that evacuation is seldom justified at
projected radiation doses less than one rem of total effective dose equivalent.
Contrary to the above, the licensee did not develop and have in place guidelines for the
choice of protective actions during an emergency that were consistent with federal
guidance. The licensees guidelines for extending initial General Emergency protective
action recommendations under conditions of changing wind direction vectors were not
consistent with EPA-400-R-92-001 guidance. Specifically, the licensees process of
automatically extending existing offsite protective action recommendations without
evaluating dose assessment information did not provide justification for recommending
protective actions in geographical areas where valid dose projections show federal
protective action guides are not exceeded. Because this failure was of very low safety
significance and has been entered into the licensee=s corrective action system
(Condition Report CR-WF3-2009-03256), this violation is being treated as a noncited
violation, consistent with Section VI.A of the NRC Enforcement Policy:
NCV 05000382/2009003-1, Licensee Practices Result in Protective Action
Recommendations for Areas Where Protective Action Guides Are Not Exceeded.
- 18 - Enclosure
Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes (71114.04)
a. Inspection Scope
The inspector performed an in-office review of Revision 37 to the Waterford 3 Steam
Electric Station Emergency Plan submitted May 12, 2009. This revision added security
threats to the bases of the four emergency classifications, revised the [offsite]
Notification Message Form to characterize radiological releases as being below or above
federally-approved operating limits, added detail about the functions of the Reactor
Auxiliary Building instrumentation laboratory, increased the number of available voice
communications channels from 5 to 23, increased the number of offsite emergency
warning sirens from 72 to 73, revised definitions used in the emergency plan, updated
station position titles and service vendors, and made minor editorial changes.
This revision was compared to its previous revision, to the criteria of NUREG-0654,
Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and
Preparedness in Support of Nuclear Power Plants, Revision 1, and to the standards in
10 CFR 50.47(b), to determine if the revision adequately implemented the requirements
of 10 CFR 50.54(q). This review was not documented in a safety evaluation report and
did not constitute approval of the licensees changes; therefore, this revision is subject to
future inspection.
These activities constitute completion of one sample as defined in Inspection
Procedure 71114.04-05.
b. Findings
No findings of significance were identified.
4. OTHER ACTIVITIES
4OA1 Performance Indicator Verification (71151)
.1 Data Submission Issue
a. Inspection Scope
The inspectors performed a review of the data submitted by the licensee for the first
quarter 2009 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.
- 19 - Enclosure
b. Findings
No findings of significance were identified.
.2 Safety System Functional Failures
a. Inspection Scope
The inspectors sampled licensee submittals for the safety system functional failures
performance indicator for the period from the first quarter 2008 through the first
quarter 2009. To determine the accuracy of the performance indicator data reported
during those periods, performance indicator definitions and guidance contained in NEI
Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5,
and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73, definitions
and guidance were used. 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
March 2008 through March 2009 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 of significance were identified.
.3 Mitigating Systems Performance Index - Emergency ac Power System
a. Inspection Scope
The inspectors sampled licensee submittals for the mitigating systems performance
index - emergency ac power system performance indicator for the period from the first
quarter 2008 through the first quarter 2009. To determine the accuracy of the
performance indicator data reported during those periods, performance indicator
definitions and guidance contained in NEI Document 99-02, Regulatory Assessment
Performance Indicator Guideline, Revision 5, was used. The inspectors reviewed the
licensees operator narrative logs, mitigating systems performance index derivation
reports, issue reports, event reports, and NRC integrated inspection reports for the
period of March 2008 through March 2009 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
- 20 - Enclosure
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 of significance were identified.
.4 Mitigating Systems Performance Index - High Pressure Injection Systems
a. Inspection Scope
The inspectors sampled licensee submittals for the mitigating systems performance
index - high pressure injection systems performance indicator for the period from the first
quarter 2008 through the first quarter 2009. To determine the accuracy of the
performance indicator data reported during those periods, performance indicator
definitions and guidance contained in NEI Document 99-02, Regulatory Assessment
Performance Indicator Guideline, Revision 5, was used. 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
March 2008 through March 2009 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 safety system functional failures sample as
defined in Inspection Procedure 71151-05.
b. Findings
No findings of significance were identified.
.5 Drill/Exercise Performance (EP01)
a. Inspection Scope
The inspectors sampled licensee submittals for the Drill and Exercise Performance,
performance indicator for the period from July 2008 through March 2009. To determine
the accuracy of the performance indicator data reported during those periods,
performance indicator definitions and guidance contained in Nuclear Energy Institute
Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5,
was used. The inspectors reviewed the licensees records associated with the
- 21 - Enclosure
performance indicator to verify that the licensee accurately reported the indicator in
accordance with relevant procedures and the Nuclear Energy Institute guidance.
Specifically, the inspectors reviewed licensee records and processes including
procedural guidance on assessing opportunities for the performance indicator;
assessments of performance indicator opportunities during predesignated control room
simulator training sessions, performance during the 2007 biennial exercise, and
performance during other drills. Specific documents reviewed are described in the
attachment to this report.
These activities constitute completion of the drill/exercise performance sample as
defined in Inspection Procedure 71151-05.
b. Findings
No findings of significance were identified.
.6 Emergency Response Organization Drill Participation (EP02)
a. Inspection Scope
The inspectors sampled licensee submittals for the Emergency Response Organization
Drill Participation performance indicator for the period from July 2008 through March
2009. To determine the accuracy of the performance indicator data reported during
those periods, performance indicator definitions and guidance contained in Nuclear
Energy Institute Document 99-02, Regulatory Assessment Performance Indicator
Guideline, Revision 5, was used. The inspectors reviewed the licensees records
associated with the performance indicator to verify that the licensee accurately reported
the indicator in accordance with relevant procedures and the Nuclear Energy Institute
guidance. Specifically, the inspectors reviewed licensee records and processes
including procedural guidance on assessing opportunities for the performance indicator,
rosters of personnel assigned to key emergency response organization positions, twelve
selected emergency responder training records, and a sample of eight exercise
participation records. Specific documents reviewed are described in the attachment to
this report.
These activities constitute completion of the emergency response organization drill
participation sample as defined in Inspection Procedure 71151-05.
b. Findings
No findings of significance were identified.
- 22 - Enclosure
.7 Alert and Notification System (EP03)
a. Inspection Scope
The inspectors sampled licensee submittals for the Alert and Notification System
performance indicator for the period from July 2008 through March 2009. To determine
the accuracy of the performance indicator data reported during those periods,
performance indicator definitions and guidance contained in Nuclear Energy Institute
Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 5,
was used. The inspectors reviewed the licensees records associated with the
performance indicator to verify that the licensee accurately reported the indicator in
accordance with relevant procedures and the Nuclear Energy Institute guidance.
Specifically, the inspectors reviewed licensee records and processes including
procedural guidance on assessing opportunities for the performance indicator and the
results of bimonthly alert notification system operability tests. Specific documents
reviewed are described in the attachment to this report.
These activities constitute completion of the alert and notification system sample as
defined in Inspection Procedure 71151-05.
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems (71152)
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency
Preparedness, Public Radiation Safety, Occupational Radiation Safety, and
.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
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. Minor issues entered into the licensees corrective action
program because of the inspectors observations are included in the attached list of
documents reviewed.
- 23 - Enclosure
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. Findings
No findings of significance 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 of significance were identified.
.3 Semi-Annual Trend Review
a. Inspection Scope
The inspectors performed a review of the licensees corrective action program and
associated documents to identify trends that could indicate the existence of a more
significant safety issue. The inspectors focused their review on repetitive equipment
issues, but also considered the results of daily corrective action item screening
discussed in Section 4OA2.2, above, licensee trending efforts, and licensee human
performance results. The inspectors nominally considered the period from October 2008
through June 2009, although some examples expanded beyond those dates where the
scope of the trend warranted.
The inspectors also included issues documented outside the normal corrective action
program in major equipment problem lists, repetitive and/or rework maintenance lists,
departmental problem/challenges lists, system health reports, quality assurance
audit/surveillance reports, self-assessment reports, and maintenance rule assessments.
The inspectors compared and contrasted their results with the results contained in the
licensees corrective action program trending reports. Corrective actions associated with
a sample of the issues identified in the licensees trending reports were reviewed for
adequacy.
These activities constitute completion of one single semi-annual trend inspection sample
as defined in Inspection Procedure 71152-05.
- 24 - Enclosure
b. Findings
Introduction. The inspectors identified a noncited violation of 10 CFR Part 50,
Appendix B, Criterion XVI (Corrective Action), for the failure to promptly correct
conditions adverse to quality. The licensee had documented several conditions adverse
to quality and then transferred the concerns to other condition reports. Then, the
licensee closed those condition reports without addressing the concerns. Identified
conditions included (1) the Train B 125 Vac discharge test data indicated a loose battery
connection but the battery was permitted to pass the test anyway; (2) the root cause
determination for the failed battery was focused on the statements of one person and
failed to address other information; (3) the root cause determination failed to address
conflicting information; and (4) the root cause determination failed to properly address
other potential causes for the inoperable battery, such as tampering.
Description. On December 17, 2008, the NRC described to the licensee several
concerns with a root cause analysis for a significant condition adverse to quality (Train B
125 Vdc battery failure identified on September 2, 2008). Specifically, the inspectors
identified that (1) the root cause determination for the failed battery was focused on the
statements of one person and failed to address other information; (2) the root cause
determination failed to address conflicting information from different individuals;
and (3) the root cause determination failed to properly address other potential causes for
the inoperable battery, such as tampering. These concerns were entered into the
corrective action process as Condition Report CR-WF3-2008-5852. This condition
report was closed out to Condition Report CR-WF3-2009-4179, Corrective Action CA-54,
which was intended to correct the conditions. However, this condition report was
subsequently closed without addressing the concerns.
On January 6, 2009, the licensee identified that the Train B 125 Vac discharge test data
(May 27, 2008) indicated a loose battery connection but the battery was permitted to
pass the test anyway. Several months later, the licensee found that the loose
connection had rendered the battery inoperable. That condition was documented in
Condition Report CR-WF3-2009-0069. This condition report was subsequently closed
out to Condition Report CR-WF3-2009-4179, Corrective Action CA-55, which was
intended to address the condition. However, the corrective action was closed without
addressing the concern.
NOTE: Additional NRC followup to the failed station battery will be documented
in NRC Inspection Report 05000382/2009008.
On February 9, 2009, the inspectors identified that the licensee had closed Condition
Report CR-WF3-2008-4179 but had not corrected the conditions that were transferred to
the document from Condition Reports CR-WF3-2008-5852 and CR-WF3-2009-0069.
The licensee entered this new finding into their corrective action process as Condition
Report CR-WF3-2009-0697.
- 25 - Enclosure
To determine the extent of condition, the licensee reviewed the corrective actions for
Condition Report CR-WF3-2008-4179 and determined that an additional seven
corrective actions had been closed out without fully being answered. These additional
examples were entered into the licensees corrective action program as Condition
Report CR-WF3-2009-1177. The licensee characterized the problem as a significant
condition adverse to quality. Subsequently, the licensees extent of condition review
identified an additional 30 examples where corrective actions were inappropriately
closed without correcting the identified conditions in the past 14 months.
Analysis. The failure to correct conditions adverse to quality was a performance
deficiency. The finding was more than minor because, if left uncorrected, it would
become a more significant safety concern. For example, the failure to include
acceptance criteria in the battery discharge test (intended to identify and correct loose
battery connections) could result in another inoperable 125 Vdc battery for an extended
period. The inspectors evaluated the finding using Inspection Manual Chapter 0609,
Significance Determination Process, Phase 1 Screening Worksheet and determined that
the finding was of very low risk significance because it did not result in another battery
becoming inoperable or nonfunctional. This finding had a crosscutting aspect in the area
of Human Performance (Work Practices Component) because plant personnel failed to
effectively use human error prevention techniques, such as self and peer checking,
when transferring concerns between condition reports H.4(a).
Enforcement. In accordance with 10 CFR Part 50, Appendix B, Criterion XVI,
Corrective Action, requires, in part, that measures be established to assure that
conditions adverse to quality are promptly identified and corrected. On December 17,
2008, and on January 6, 2009, four conditions adverse to quality were identified by the
inspectors and the licensee, as noted in the body of this report. Contrary to the above,
the licensee failed to correct the conditions adverse to quality, in that the concerns were
transferred to another condition report and then closed without action. Because this
violation was of very low safety significance and was entered in the corrective action
program as Condition Report CR-WF3-2009-0697, this violation is being treated as a
noncited violation, consistent with Section VI.A of the NRC Enforcement Policy:
NCV 05000382/2009002-02, Failure to Correct Several Conditions Adverse to Quality.
.4 Selected Issue Follow-up Inspection
a. Inspection Scope
During a review of items entered in the licensees corrective action program, the
inspectors reviewed operator workarounds and burdens and conducted a review of
conditions surrounding the premature failure of the Train B 125 Vdc station battery. 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
- 26 - Enclosure
causes of the problem; (6) identification of corrective actions; and (7) completion of
corrective actions in a timely manner.
These activities constitute completion of two in-depth problem identification and
resolution samples as defined in Inspection Procedure 71152-05.
b. Findings
Introduction. The inspectors identified a green noncited violation of 10 CFR Part 50,
Appendix B, Criterion XVI (Corrective Actions), because the licensee failed to identify the
cause for a significant condition adverse to quality. The Train B 125 Vdc battery bank
failed to pass a technical specification surveillance required discharge test during a
Spring 2008 outage. The root cause procedure required that the licensee sequester the
battery in a controlled area so that vital information related to the failure could be
obtained. However, the licensee disposed of the battery instead. When questions arose
concerning the specified failure cause (impurities in the battery materials), the licensee
was unable to provide objective evidence to support the conclusion. Had the licensee
obtained objective evidence to support their conclusion that impurities caused the
battery failure, a 10 CFR Part 21 report may have been required. The licensee replaced
the battery and planned to replace similar batteries in the other two trains during the next
refueling outage.
Description. On May 16, 2008, during a refueling outage, the licensee conducted a
technical specification required performance test of the safety-related Train B, 125 Vdc
station battery. The licensee determined that the battery capacity was 86.25 percent
from this test. This was an unexpected result, as the licensee had predicted a capacity
near 100 percent.
The licensee consulted with the battery vendor (C&D). The vendor advised the licensee
that the licensees testing method may be inappropriate and suggested changes. The
licensee performed a second test of the battery on May 22 and noted that the capacity
was 71.6 percent. Technical Specification Surveillance Requirement 4.8.2.1.d required
that the battery capacity be verified to be at least 80 percent of the manufacturers rating
every 60 months, when subjected to a discharge test. The failure to pass the technical
specification surveillance requirement rendered the battery inoperable. The battery had
a vendor specified 20- year service life but had only lasted a little more than 15 years.
The licensee promptly procured a new battery and replaced the failed Train B battery.
The only extent of condition review that the licensee performed was to verify that the
other station batteries were from different manufacturing lots. At the time of the
surveillance failure, the plant was in an outage and was relying on the other station
batteries to meet the requirements for the technical specification required minimum
equipment.
In response to the battery failure, the licensee performed a root cause analysis, as
documented in Condition Report WF3-2008-02431, dated August 12, 2008. The
licensee considered the battery failure a significant condition adverse to quality. The
licensee concluded that the battery had most likely failed the test because of impurities
- 27 - Enclosure
introduced during manufacturing. The licensee reached this conclusion based on the
elimination of other potential causes that they had considered. The inspectors
determined that the licensee did not obtain vendor assistance or input. The licensee did
not perform testing to verify that impurities were actually present in the battery. Then,
the licensee disposed of the battery. No cells from the defective battery train were
returned to the vendor for analysis.
On July 30, 2009, licensee senior management decided to reassess the root cause
because they no longer believed that it involved a manufacturing defect. The inspectors
identified that the licensee had failed to meet the requirements of 10 CFR Part 50,
Appendix B, Criterion XVI (Corrective Actions), for the battery failure. This requirement
specifies, in part, that the cause of significant conditions adverse to quality be
determined and corrective actions taken to preclude repetition. In this instance, since
the licensee disposed of the battery prior to performing a thorough analysis of the failed
components, the licensee could not adequately determine the cause.
The inspectors also noted that the licensee had failed to follow their root cause
procedure concerning analysis of failed components. Corporate Procedure EN-LI-118,
Root Cause Analysis Process, Revision 7, discusses actions to be performed during
the course of performing a root cause analysis. Section 5, step [3](a)(3) required the
licensee to initiate physical evidence collection and move items to a controlled area to
prevent tampering or loss. For the failed battery, the licensee did not complete these
actions.
Additionally, had the licensee conclusively determined that battery failure was caused by
impurities introduced during the manufacturing process, a 10 CFR Part 21, Reporting of
Defects and Noncompliance, may have been required. This regulation requires
licensees and vendors to notify the NRC of defects in safety-related components that
could involve a substatial safety hazard. If the failure did involve a defect, the inspectors
believed that a subsafety hazard would exist due to the rapid degradation that occurred
within a single surveillane interval making the failure undetectable. The NRC would then
notify licensees that could be affected by the condition so that they could take
appropriate corrective measures. In this instance, however, since the cause of the
failure was not actually known, the NRC could not evaluate the condition or further
consider a generic communication.
Analysis. The failure to identify the cause for a significant condition adverse to quality
was a performance deficiency. The finding was more than minor because, if left
uncorrected, it could lead to a more significant safety concern. Specifically, since the
cause of the battery failure was not definitively found, the licensee may not have taken
corrective actions to prevent other battery failures. Using the Inspection Manual
Chapter 0609, Significance Determination Process, Phase 1 Screening Worksheet, the
finding was of very low risk significance because it did not actually cause the loss of
operability or functionality of another 125 Vdc battery at the time of the inspection. This
finding had a crosscutting aspect in the area of Problem Identification and Resolution
(Corrective Action Program Component) because the licensee failed to thoroughly
evaluate the need to keep the battery prior to disposal P.1(c).
- 28 - Enclosure
Enforcement. Title 10 CFR Part 50, Appendix B, Criterion XVI (Corrective Actions),
requires, in part, that Measures shall be established to assure that conditions adverse
to quality . . . are promptly identified and corrected. In the case of significant conditions
adverse to quality, the measures shall assure that the cause of the condition is
determined and corrective action taken to preclude repetition. Contrary to the above, as
of July 7, 2009, the licensee had identified a significant condition adverse to quality
(125 Vdc battery train failure on May 22, 2008) but had not determined the cause of the
condition and therefore could not specify actions to preclude repetition. Because this
violation was of very low safety significance and was entered in the corrective action
program as Condition Report CR-WF3-2009-2846, this violation is being treated as a
noncited violation, consistent with Section VI.A of the NRC Enforcement Policy:
NCV 05000382/2009003-03, Failure to Determine the Cause of a 125 Vdc Battery
Failure.
4OA5 Other Activities
.1 Quarterly Resident Inspector Observations of Security Personnel and Activities
a. Inspection Scope
During the inspection period, the inspectors performed observations of security force
personnel and activities to ensure that the activities were consistent with Waterford
Steam Electric Station security procedures and regulatory requirements relating to
nuclear plant security. These observations took place during both normal and off-normal
plant working hours.
These quarterly resident inspector observations of security force personnel and activities
did not constitute any additional inspection samples. Rather, they were considered an
integral part of the inspectors normal plant status review and inspection activities.
b. Findings
No findings of significance were identified.
4OA6 Meetings
Exit Meeting Summary
On May 27, 2009, the inspector conducted a telephonic exit meeting to present the results of
the in-office inspection of changes to the licensees emergency plan to Mr. J. Lewis, Manager,
Emergency Preparedness, and other members of the licensees staff. The licensee
acknowledged the issues presented.
On June 26, 2009, the inspectors presented the results of the inspection of the onsite
emergency preparedness exercise to Mr. J. Kowalewski, Site Vice President, and other
members of the licensees staff. The licensee acknowledged the issues presented. The
inspectors asked the licensee whether any materials examined during the inspection should be
- 29 - Enclosure
considered proprietary or sensitive. All identified proprietary or sensitive information examined
during the inspection had been returned to the licensee.
On June 30 and July 1, 2009, the inspectors discussed the technical and regulatory aspects of
the identified emergency preparedness noncited violation with Mr. J. Lewis, Manager,
On July 20, 2009, the inspectors presented the inspection results to Mr. Joe Kowalewski, Site
Vice-President, and other members of the licensee staff. A followup telephonic exit was
conducted on August 10 with Mr. Joe Kowalewski 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.
- 30 - Enclosure
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
M. Adams, Supervisor, System Engineering
S. Anders, Manager, Plant Security
B. Briner, Technical Specialist IV, Componet Engineering
K. Christian, Director, Nuclear Safety Assurance
K. Cook, Manager, Operations
C. Fugate, Assistant Manager, Operations
M. Haydel, Supervisor, Programs and Components
J. Kowalewski, Vice President of Operations
J. Lewis, Manager, Emergency Preparedness
B. Lindsey, Manager, Maintenance
M. Mason, Senior Licensing Specialist, Licensing
W. McKinney, Manager, Corrective Action and Assessments
R. Murillo, Manager, Licensing
K. Nicholas, Director, Engineering
R. Putnam, Manager, Programs and Components
J. Williams, Senior Licensing Specialist, Licensing
LIST OF ITEMS OPENED AND CLOSED
Opened and Closed
05000382/2009003-01 NCV Licensee Practices Result in Protective Action
Recommendations for Areas Where Protective Action
Guides are Not Exceeded.(Section 1EP1)05000382/2009003-02 NCV Failure to Correct Several Conditions Adverse to Quality
(Section 4OA2)05000382/2009003-03 NCV Failure to Determine the Cause of a 125 Vdc Battery
Failure (Section 4OA2)
LIST OF DOCUMENTS REVIEWED
Section 1R01: Adverse Weather Protection
CONDITION REPORTS
CR-WF3-2009-2229 CR-WF3-2009-2305 CR-WF3-2009-2306 CR-WF3-2009-2961
CR-WF3-2009-2413 CR-WF3-2009-2767 CR-WF3-2009-2307 CR-WF3-2009-2118
CR-WF3-2009-2414 CR-WF3-2009-2938 CR-WF3-2009-2326 CR-WF3-2009-0687
CR-WF3-2009-2415 CR-WF3-2009-2651 CR-WF3-2009-2343 CR-WF3-2009-0155
A-1 Attachment
WORK ORDERS
51798176 51701184 194505 51088942
51697577 51680597 167665
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
ENS-PL-159 Summer Reliability
OP-009-002 Emergency Diesel Generator 310
OP-006-001 Plant Distribution 305
OP-006-008 Transformer Operation 301
OP-006-009 Electrical Bus Outages 4
OP-006-005 Inverters and Distribution 302
OP-902-003 Loss of Offsite Power 6
Section 1R04: Equipment Alignment
WORK ORDERS
52021780 34838
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
OP-009-002 Emergency Diesel Generator 308
OP-903-121 Safety Systems Quarterly IST Valve Tests 9
OP-009-001 Containment Spray 301
1R05: Fire Protection
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
UNT-005-013 Fire Protection Program 10
OP-009-004 Fire Protecton 305
MM-004-424 Building fire Hose Station Inspection and Hose 10
Replacement
MM-007-010 Fire Extinguisher Inspection and Extinguisher 302
Replacement
FP-001-014 Duties of a Fire Watch 14
A-2 Attachment
FP-001-015 Fire Protection Impairments 302
DBD-018 Appendix R/fire Protection
Section 1R06: Flood Protection Measures
NUMBER TITLE REVISION
OP-901-521 Severe Weather and Flooding 4
OP-902-008 Functional Recovery Procedure 15
FSAR Section 3.6A.6 Flooding Analysis 14-A
FSAR Section 3.6A.6.4.1 Reactor Auxiliary Building - High Energy Pipe 14-A
Breaik
DWG - G173 Sheet 2 Sump Pump System - Reactor Auxiliary Bldg. 5
FSAR Figure 9.3-5 Reactor Auxiliary Building Drainage Sys. 4
Section 1R11: Licensed Operator Requalification Program
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
E-68 Simulator Scenario 3
OP-901-202 Steam Generator Tube Leakage or High Activity 9
OP-901-212 Rapid Plant Power Reduction 3
OP-902-000 Standard Post Trip Actions 10
OP-902-008 Safety Function Recovery Procedure 15
Section 1R12: Maintenance Effectiveness
CONDITION REPORTS
CR-WF3-2009-2662 CR-WF3-2009-2384 CR-WF3-2009-2356 CR-WF3-2009-2355
CR-WF3-2009-2245 CR-WF3-2009-2223 CR-WF3-2009-2092 CR-WF3-2009-1356
CR-WF3-2009-1284 CR-WF3-2009-0205 CR-WF3-2009-0017 CR-WF3-2009-0016
CR-WF3-2008-5905 CR-WF3-2008-5669 CR-WF3-2008-4215 CR-WF3-2008-3210
CR-WF3-2008-3106 CR-WF3-2008-2957 CR-WF3-2008-2833 CR-WF3-2008-2756
CR-WF3-2008-2467 CR-WF3-2008-1315 CR-WF3-2008-0676 CR-WF3-2008-0613
CR-WF3-2007-0762 CR-WF3-2008-0037 CR-WF3-2008-5786 CR-WF3-2009-2321
CR-WF3-2007-0935 CR-WF3-2008-2352 CR-WF3-2009-0785 CR-WF3-2009-2337
CR-WF3-2007-1666 CR-WF3-2008-5115 CR-WF3-2009-1972 CR-WF3-2009-2343
CR-WF3-2007-2469 CR-WF3-2008-5258 CR-WF3-2009-2306 CR-WF3-2009-2861
CR-WF3-2007-4448 CR-WF3-2007-4280 CR-WF3-2007-4281 CR-WF3-2007-2610
A-3 Attachment
WORK ORDERS
117089 155100 172152 51562560
94701 94702 113371 132935
00085241 00140811 95498 51097820
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
DC-121 Maintenance Rule 1
NUMARC 93-01 Industry Guideline for Monitoring the Effectiveness 3
of Maintenance at Nuclear Power Plants
Section 1R13: Maintenance Risk Assessment and Emergency Work Controls
CONDITION REPORTS
CR-WF3-2009-1706 CR-WF3-2009-1718 CR-WF3-2009-3023 CR-WF3-2009-2807
WORK ORDERS
00190937 186497 160282 51657973
186508 185547 185560 184949
173008 136785 116977 197599
197692
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
EN-WEM-101 On-Line Work Management Process 1
OI-037-000 Operations Risk Assessment Guideline 2
OP-006-003 125 Vdc Electric Distribution 301
ME-007-002 Molded Case Circuit Breakers 15
ME-007-008 Motor-Operated Valves 16
ME-007-045 Motor-Operated Valve Motor Power Monitor 2
UNT-001-015 Equipment QAualification Program 7
ME-004-809 Low/Medium voltage Power & Control 302
Cable/Conductor Terminations and splices
ME-007-047 VOTES Testing of Motor-Operated Valves 5
OP-009-008 Safety Injection System 25
OP-009-001 Containment spray 301
MI-005-464 Plant Protection System Power Supply Calibration 303
OP-009-007 Plant Protection System 9
ME-007-005 Time Delay Relay Setting Check Adjustment 13
A-4 Attachment
ME-004-330 4KV Induction Motor Maintenance 300
ME-004-211 Station Battery (Quarterly) 7
ME-002-210 Station Battery Bank & Charger (Quarterly) 14
Section 1R15: Operability Evaluations
CONDITION REPORTS
CR-WF3-2009-2189 CR-WF3-2008-5867 CR-WF3-2008-5618 CR-WF3-2009-2253
CR-WF3-2009-2212 CR-WF3-2009-2226 CR-WF3-2009-2229 CR-WF3-2009-2253
WORK ORDERS
51646383 194110 164712 51701184
51695212 52033543 194505
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
OP-903-026 Emergency Core Cooling System Valve Lineup 17
Verification
OP-009-008 Safety Injection 25
MM-007-038 Valves HVC-101 and HVC-102 Leak Test 300
OP-009-002 Emergency Diesel Generator 308
OP-903-068 Emergency Diesel Generator Operability and 302
Subgroup Relay Operability Verification
OP-903-15 Train A Integrated Emergency Diesel Generator / 10
Engineering Safety Features Test
Section 1R19: Postmaintenance Testing
CONDITION REPORTS
CR-WF3-2009-1706 CR-WF3-2009-1718 CR-WF3-2008-5786 CR-WF3-2008-4765
CR-WF3-2008-4304 CR-WF3-2008-4304 CR-WF3-2008-4765 CR-WF3-2009-2253
CR-WF3-2009-2212 CR-WF3-2009-2226 CR-WF3-2009-2229 CR-WF3-2009-225
WORK ORDERS
00190937 180143 46961 168290
173009 516557973 186508 185547
185560 184946 173008 52022649
52030855 52022009 51646383 194110
164712 51701184 51695212 52033543
34838 170228 52033835 52036094
194505 52034706 52031652 191225
197180
A-5 Attachment
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
MI-005-464 Plant Protection System Power Supply Calibration 303
OP-009-007 Plant Protection System 9
MI-013-522 PPS Ground Detection Test 5
MI-005-293 Retest Procedure for Power Supplies 2
OP-903-107 Plant Protection System Channel A&B&C&D 303
Functional Test
ME-007-005 Time Delay Relay Setting Check Adjustment 13
OP-009-008 Safety Injection System 25
OP-903-030 Safety Injection Pump Operability Verification 15
OP-009-008 Safety Injection System 25
ME-007-002 Molded Case Circuit Breakers 15
ME-007-005 Time Delay Relay Setting Check Adjustment 13
ME-007-008 Motor Operated Valves 16
ME-007-045 Motor-Operated Valve Motor Power Monitor 2
ME-004-809 Low/Medium Voltage Power & Control 302
Cable/Conductor Terminations and Splices
ME-007-057 MCE/EMAX Data Acquisition 4
ME-004-330 4KV Induction Motor Maintenance 300
MM-007-038 Valves HVC-101 and HVC-102 Leak Test 300
OP-009-002 Emergency Diesel Generator 308
OP-903-068 Emergency Diesel Generator Operability and 302
Subgroup Relay Operability Verification
OP-903-115 Train A Integrated Emergency Diesel Generator / 10
Engineering Safety Features Test
OP-100-002 Leak Reduction 300
OP-903-003 Charging Pump Operability Check 301
OP-002-005 Chemical and Volume Control 28
OP-903-035 Containment Spray Pump Operability Check 13
OP-009-001 Containment Spray 301
MM-006-021 Charging Pump Maintenance 9
A-6 Attachment
Section 1R22: Surveillance Testing
WORK ORDERS
52033543 51794147 51797247 51695212
51795535 52034706 52031652
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION
OP-903-030 Safety Injection Pump Operability Verification 15
OP-009-008 Safety Injection System 25
OP-903-118 Primary Auxiliaries Quarterly IST Valve Test 16
OP-002-003 Component Cooling Water System 305
OP-009-003 Emergency Feedwater 301
OP-903-046 Emergency Feed Pump Operability Check 304
OP-002-005 Chemical and Volume Control 28
OP-100-002 Leak Reduction 300
OP-009-002 Emergency Diesel Generator 308
OP-903-068 Emergency Diesel Generator Operability and 302
Subgroup Relay Operability Verification
OP-903-115 Train A Integrated Emergency Diesel Generator / 10
Engineering Safety Features Test,
Section 1EP1: Exercise Evaluation
PROCEDURES/DOCUMENTS
NUMBER TITLE REVISION / DATE
EP-1-001 Recognition and Classification of Emergencies 22
EP-1-020 Actions for Alert 301
EP-1-030 Actions for Site Emergency 25-2
EP-1-040 Actions for General Emergency 26-2
EP-2-010 Notifications and Communications 303
EP-2-015 Emergency Responder Activation 8-1
EP-2-030 Emergency Radiation Exposure Guidelines and 9
Controls
EP-2-031 In-Plant Radiation Control during Emergencies 7-2
EP-2-033 KI Administration 301
EP-2-034 Onsite Surveys during Emergencies 5-1
EP-2-050 Offsite Dose Assessment 303
A-7 Attachment
NUMBER TITLE REVISION / DATE
EP-2-052 Protective Action Guidelines 20
EP-2-071 Site Protective Measures 18-2
EP-2-100 TSC Activation, Operation, and Deactivation 33
EP-2-101 OSC Activation, Operation, and Deactivation 302
EP-2-102 EOF Activation, Operation, and Deactivation 301
EP-2-130 Emergency Team Assignments 22
2007-03 2007 Green Team Site Drill February 18, 2008
2007-04 2007 Green Team Biennial Exercise March 10, 2008
2008-01 2008 Red Team Site Drill August 3, 2008
2008-03 2008 Blue Team Site Drill January 8, 2009
2008-04 2008 Orange Team Site Drill March 29, 2009
2009-01 2009 Green Team Site Drill June 19, 2009
2009-02 2009 Blue Team Site Drill June 21, 2009
WLP-EP-EDIR Emergency Preparedness Lesson Plan: Emergency 7
Director
WLP-EP-EC Emergency Preparedness Lesson Plan: Emergency 6
Coordinator
WLP-EP-RPC Emergency Preparedness Lesson Plan: Radiation 3
Protection Coordinator
WLP-OPS-EP02 Operations Lesson Plan: Emergency Plan Training for 8
Control Room Personnel, Training Personnel, and
Operations Coordinators
CORRECTIVE ACTION DOCUMENTS
2009-01101 2009-01184
Section 4OA1: Performance Indicator Verification
NUMBER TITLE REVISION
NEI 99-02 Regulatory Assessment Performance Indicator 5
Guideline
PROCEDURES
NUMBER TITLE REVISION
EP-1-001 Recognition and Classification of Emergencies 22
EP-2-010 Notifications and Communications 303
EP-2-052 Protective Action Guidelines 20
A-8 Attachment
EP-3-070 Emergency Communications Systems Routine 301
Testing
EN-EP-201 Emergency Planning Performance Indicators 8
EN-LI-114 Perofrmance Indicator Process 4
EPP-422 Siren and Helicopter Warning System Maintenance 4
EPP-424 Siren Testing and Siren Administrative Controls 12
MISCELLANEOUS DOCUMENTS
TITLE REVISION
Water3 Steam Electric Station Emergency Plan 37
Section 4OA2: Identification and Resolution of Problems
PROCEDURES
NUMBER TITLE REVISION
OI-002-000 Annunciator, Control Room Instrumentation and 301
Workaround Status Control
OI-034-000 Work Management Center 18
EN-LI-102 Corrective Action Process 11
ME-003-240 Battery Performance Test 13
EN-LI-118 Root Cause Analysis Process 7
CONDITION REPORTS
CR-WF3-2009-0069 CR-WF3-2009-1177 CR-WF3-2009-0697 CR-WF3-2008-4179
CR-WF3-2008-2431 CR-WF3-2008-2515 CR-WF3-2008-5852 CR-WF3-2009-2846
WORK ORDERS
155714 169263 168928 157646
156715 148345 152819
A-9 Attachment