October 30, 2018 Mr. John Dinelli Site Vice President Entergy Operations, Inc. 17265 River Road Killona, LA 70057-0751 SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3 – NRC INTEGRATED

INSPECTION REPORT 05000382/2018003 Dear Mr. Dinelli: On September 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford Steam Electric Station, Unit 3. On October 11, 2018, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report. The NRC inspectors did not identify any finding or violation of more than minor significance. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, “Public Inspections, Exemptions, Requests for Withholding.”

Sincerely, /RA/ Neil O’Keefe, Chief Branch D Division of Reactor Projects

Docket No. 50-382 License No. NPF-38 Enclosure: Inspection Report 05000382/2018003 w/ Attachments: 1. Documents Reviewed 2. NRC Request for Information

Enclosure

U.S. NUCLEAR REGULATORY COMMISSION Inspection Report

Docket Number(s): 05000382 License Number(s): NPF-38 Report Number(s): 05000382/2018003 Enterprise Identifier: 1-2018-003-0002 Licensee: Entergy Operations, Inc. Facility: Waterford Steam Electric Station, Unit 3 Location: Killona, Louisiana Inspection Dates: July 1, 2018 to September 30, 2018 Inspectors: F. Ramírez, Senior Resident Inspector

C. Speer, Resident Inspector J. Dixon, Senior Project Engineer

T. Farina, Senior Operations Engineer P. Elkmann, Senior Emergency Preparedness Inspector N. Greene, PhD, Senior Health Physicist I. Anchondo, Reactor Inspector, Engineering Branch 2 G. George, Senior Reactor Inspector, Engineering Branch 1 Approved By: Neil O’Keefe Branch Chief Division of Reactor Projects

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SUMMARY The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensee’s performance by conducting an integrated inspection at Waterford Steam Electric Station, Unit 3, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRC’s program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations No findings or violations of more than minor significance were identified during the inspection.

Additional Tracking Items

Type Issue number Title Report

Section Status

URI 05000382/2017008-04 Potential Failure to Obtain a License Amendment for Changes to Diesel Generator Surveillance Test Interval

71111.21M Closed

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PLANT STATUS The plant operated at or near rated thermal power for the entire inspection period. INSPECTION SCOPES Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, “Light-Water Reactor Inspection Program - Operations Phase.” The inspectors performed plant status activities described in IMC 2515 Appendix D, “Plant Status” and conducted routine reviews using IP 71152, “Problem Identification and Resolution.” The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards. REACTOR SAFETY 71111.01—Adverse Weather Protection

External Flooding (1 Sample) The inspectors evaluated readiness to cope with external flooding in the safety-related switchgear room A on August 1, 2018.

71111.04—Equipment Alignment

Partial Walkdown (4 Samples) The inspectors evaluated system configurations during partial walkdowns of the following systems/trains: (1) Shield building ventilation train A with train B out of service for maintenance on July 17,

2018

(2) Auxiliary feedwater system following an extended system outage on August 19, 2018

(3) Emergency feedwater train A with train B out of service for maintenance on August 21, 2018

(4) Emergency diesel generator A with emergency diesel generator B out of service for maintenance on September 11, 2018

Completed Walkdown (1 Sample) The inspectors evaluated system configurations during a complete walkdown of the reactor auxiliary building controlled ventilation area system on September 12, 2018.

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71111.05AQ—Fire Protection Annual/Quarterly

Quarterly Inspection (5 Samples) The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Fire area NS-TB-001, turbine building +15.00 east on July 18,2018 (2) Fire area NS-TB-003, turbine building mezzanine +40.00 east on August 19, 2018 (3) Fire area RAB 34-001, safeguards valve gallery rooms A and B on August 21, 2018 (4) Fire area NS-TB-004, turbine building +40.00 west on August 22, 2018 (5) Fire area RAB2-001, heating and ventilation mechanical room on September 11, 2018

Annual Inspection (1 Sample) The inspectors evaluated fire brigade performance during an unannounced fire drill in the +35 reactor auxiliary building electrical penetration B area on September 21, 2018.

71111.11—Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 Sample) The inspectors observed and evaluated requalification scenario in the simulator on July 23, 2018. Operator Performance (1 Sample) The inspectors observed and evaluated control room performance during control element assembly testing on August 3, 2018. Operator Exams (1 Sample) The inspector reviewed and evaluated requalification examination results on August 27, 2018.

71111.12Q—Maintenance Rule Implementation

Routine Maintenance Effectiveness (2 Samples) The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Dry cooling tower sump pump failures on July 24, 2018 (2) Controlled ventilation area system routine assessment of maintenance on August 8,

2018 71111.13—Maintenance Risk Assessments and Emergent Work Control (5 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

5

(1) Emergent work related to electrical bus 31AB on July 25, 2018

(2) Risk assessment associated with work in the transformer yard on August 13, 2018

(3) Planned yellow risk due to emergency feedwater system train B work window on August 21, 2018

(4) Planned yellow risk due to emergency diesel generator B work window on September 10, 2018

(5) Planned yellow risk due to emergency diesel generator A work window on September 27, 2018

71111.15—Operability Determinations and Functionality Assessments (4 Samples)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Operability determination for charging pump B due to relay calibration values found out

of tolerance on July 19, 2018

(2) Functionality assessment for motor generator set B due to high vibrations on July 31, 2018

(3) Operability determination for emergency diesel generator B due to low field voltage and current during testing on August 6, 2018

(4) Operability determination for emergency diesel generator B subgroup relays due to the failure of the safety injection actuation signal relay on August 21, 2018

71111.18—Plant Modifications (2 Samples)

The inspectors evaluated the following temporary modification: (1) Temporary replacement of failed pressurizer proportional heater bank 1 heaters 3 and

4 with heaters from backup bank 2 and 3 on August 1, 2018

(2) Ultimate heat sink margin restoration Phase 3 permanent modification on August 15, 2018

71111.19—Post Maintenance Testing (6 Samples)

The inspectors evaluated the following post maintenance tests: (1) Train A sequencer following relay replacement on August 6, 2018

(2) Charging pump A after seal pump/motor and gearbox replacement on August 9, 2018

(3) Auxiliary feedwater pump to motor coupling removal/reinstallation and pump outboard

bearing gasket replacement on August 14, 2018

6

(4) Reactor auxiliary building +46 HVAC air handling unit following planned maintenance on

September 5, 2018

(5) Auxiliary component cooling water pump B following emergent bearing oil replacement on September 18, 2018

(6) Emergency diesel generator A following planned relay replacement on September 27, 2018

71111.22—Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine (5 Samples)

(1) Emergency feedwater pump A operability run on July 10, 2018

(2) High pressure safety injection pump B operability run on July 25, 2018

(3) Reactor trip circuit breaker #5 test on August 1, 2018

(4) Core protection calculator A test on August 2, 2018

(5) Control room emergency filtration unit outside air intake upstream isolation valve test on August 14, 2018

71114.02—Alert and Notification System Testing (1 Sample)

The inspector evaluated the maintenance and testing of the alert and notification system on August 1, 2018.

71114.03—Emergency Response Organization Staffing and Augmentation System (1 Sample)

The inspector evaluated the readiness Emergency Preparedness Organization on August 2, 2018.

71114.04—Emergency Action Level and Emergency Plan Changes (2 Samples)

The inspector evaluated submitted changes to the Waterford 3 Steam Electric Station Emergency Plan, Revision 49, and Procedure EP-001-001, Recognition and Classification of Emergency Conditions,” Revision 33, between July 9 and 12, 2018. This evaluation does not constitute NRC approval.

71114.05—Maintenance of Emergency Preparedness (1 Sample)

The inspector evaluated the maintenance of the emergency preparedness program on August 6 and 7, 2018.

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71114.06—Drill Evaluation

Emergency Planning Drill (1 Sample) The inspectors evaluated an emergency planning drill on August 29, 2018.

RADIATION SAFETY

71124.02—Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls

Radiological Work Planning (1 Sample) The inspector evaluated the licensee’s radiological work planning by reviewing the following activities: (1) RWP 2016-0118, Loading of Dry Fuel Storage Cask #18, with Spent Fuel and Transport

including all DFS Support Activities to include Set Up/Demobilization, Revision 02

(2) RWP 2016-0119, Loading of Dry Fuel Storage Cask #19, with Spent Fuel and Transport including all DFS Support Activities to include Set Up/Demobilization, Revision 01

(3) RWP 2016-0123, Loading of Dry Fuel Storage Cask #23, with Spent Fuel and Transport including all DFS Support Activities to include Set Up/Demobilization, Revision 00

(4) RWP 2017-0515, RCP 1B Motor Replacement, Revision 00

(5) RWP 2017-0610, Erect/Dismantle Scaffolding in the Reactor Containment Building, Revision 00

(6) RWP 2017-0702, Reactor Disassembly Activities, Revision 00

(7) RWP 2017-0705, Reactor Reassembly Activities, Revision 00

(8) RWP 2018-0001, Radiation Protection to Perform Job Coverage, Routine Surveys, Inspections and Walkdowns, Revision 00

(9) RWP 2018-0006, Radwaste Processing/Shipping in all Radiologically Controlled Areas, Revision 00

Verification of Dose Estimates and Exposure Tracking Systems (1 Sample) The inspectors evaluated dose estimates and exposure tracking.

71124.04—Occupational Dose Assessment Source Term Characterization (1 Sample) The inspectors evaluated the licensee’s source term characterization.

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External Dosimetry (1 Sample) The inspectors evaluated the licensee’s external dosimetry program. Internal Dosimetry (1 Sample) The inspectors evaluated the licensee’s internal dosimetry program. Special Dosimetric Situations (1 Sample) The inspectors evaluated the licensee’s performance for special dosimetric situations.

OTHER ACTIVITIES – BASELINE 71151—Performance Indicator Verification (6 Samples)

The inspectors verified licensee performance indicators submittals listed below: (1) MS08: Heat Removal Systems (07/01/2017–06/30/2018)

(2) MS09: Residual Heat Removal Systems (07/01/2017–06/30/2018)

(3) MS10: Cooling Water Support Systems (07/01/2017–06/30/2018)

(4) EP01: Drill/Exercise Performance Sample (10/01/2017–06/30/2018)

(5) EP02: Emergency Response Organization Drill Participation Sample (10/01/2017–

06/30/2018)

(6) EP03: Alert And Notification System Reliability Sample (10/01/2017–06/30/2018)

71152—Problem Identification and Resolution

Annual Follow-up of Selected Issues (2 Samples) The inspectors reviewed the licensee’s implementation of its corrective action program related to the following issues: (1) Process analog control card failures that resulted in a Part 21 report to the NRC on

September 6, 2018

(2) Maintenance rule failure classification of the fast bus transfer failure during the Notification of Unusual Event in June 2017 on September 13, 2018

71153—Follow-up of Events and Notices of Enforcement Discretion

Licensee Event Reports (2 Samples)

The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:

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(1) Licensee Event Reports 05000382/2018-002-00 and 05000382/2018-002-01,

“Unplanned Loss of a Train of Control Room Outside Air Intake Radiation Monitors Results in a Condition Prohibited by Technical Specifications,” on August 16, 2018.

(2) Licensee Event Report 05000382/2017-002-01, “Automatic Reactor Scram due to the Failure of Fast Dead Bus Transfer Relays to Automatically Transfer Station Load to Off-Site Power on a Main Generator Trip,” on August 16, 2018.

OTHER ACTIVITIES – TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL INSPECTION RESULTS

Unresolved Item (Closed)

Potential Failure to Obtain a License Amendment for Changes to Diesel Generator Surveillance Test Interval URI 05000382/2017008-04

7111.21M

Description: U.S. Nuclear Regulatory Commission (NRC) Design Bases Assurance Inspection Report 05000382/2017008 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML17362A424), dated December 28, 2017, documents Unresolved Item 05000382/2017008-04, “Potential Failure to Obtain a License Amendment for Changes to Diesel Generator Surveillance Test Interval.” During that inspection, the team reviewed the licensee’s change to the surveillance test intervals for the train A and B emergency diesel generators, which was completed in accordance with the Waterford surveillance frequency control program. As a result, both emergency diesel generators went from being tested every 18 months to each emergency diesel generator being tested every 36 months. The team concluded that the license had failed to correctly evaluate the change in accordance with the surveillance frequency control program change process per NEI 04-10, “Risk Informed Method for Control of Surveillance Frequencies,” Revision 1. Specifically, the licensee had not correctly evaluated NEI 04-10, step 1, “Check for Prohibitive Commitments,” and step 2, “Can Commitments be Changed?” of the change process. During the inspection, the team determined that this change would have necessitated a 10 CFR 50.59 safety evaluation and subsequent license amendment because it would have resulted in more than a minimal increase in likelihood of a malfunction of a component important to safety as previously described in the final safety analysis report. At the conclusion of the inspection, the team decided to address this item pending the review of the licensee’s previously documented corrective actions associated with the potential issue. Since the conclusion of the inspection, the regulatory applicability of this unresolved item was addressed in NRC letter to Byron Generating Station, dated July 23, 2018, (ADAMS Accession Number ML 18204A144). The letter documents the withdrawal of a non-cited violation associated with 10 CFR 50.59 requirements applicable to changes in surveillance test intervals of emergency diesel generators. The review was conducted by an independent NRC panel and the outcome was documented, in part, as follow;

“In NEI 04-10 Step 2, a check is made to determine if the applicable regulatory commitments to the NRC can be changed. Evaluating changes to regulatory commitments is a separate activity based on a method acceptable to the NRC for managing and changing regulatory commitments (e.g., NEI 99-04). NEI 99-04 Section 3.1, “Definitions,” defines a regulatory commitment as an explicit statement to take a specific action agreed to, or volunteered by, a licensee and

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submitted in writing on the docket to the NRC. A regulatory commitment is an intentional undertaking by the licensee to (1) restore compliance with regulatory requirements, or (2) complete a specific action to address an NRC issue or concern (e.g., generic letter, bulletin, order, etc.)...Thus, there was no associated regulatory commitment to change under NEI 04-10 Step 2, and it was appropriate for the licensee to continue to step through the NDE 04-10 process to evaluate an EDG surveillance frequency change.”

Therefore, given the circumstances for the non-cited violation withdrawal and its applicability to this unresolved item, the NRC has concluded that there is no violation and no license amendment was required. This item is closed. Corrective Action Reference(s): N/A

EXIT MEETINGS AND DEBRIEFS On August 9, 2018, the inspector presented the emergency preparedness inspection results to Mr. J. Dinelli, Site Vice President, and other members of the licensee staff. The inspector verified that no proprietary information was retained or documented in this report. On August 27, 2018, the inspector presented the annual requalification inspection results to Mr. D. Constance, Operations Training Superintendent. The inspector verified no proprietary information was retained or documented for this inspection report. On September 13, 2018, the inspector presented the baseline radiation safety inspection results to Mr. S. Vazquez, General Manager of Plant Operations, and other members of the licensee staff. The inspector verified no proprietary information was retained or documented in this report. On October 11, 2018, the inspector presented the quarterly resident inspector inspection results to Mr. J. Dinelli, Site Vice President, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report.

Attachment 1

DOCUMENTS REVIEWED 71111.01 – Adverse Weather Protection Condition Reports

CR-WF3-2018-04408 Procedures Number Title

Revision

EN-LI-100 Process Applicability Determination 10 OP-901-521 Severe Weather and Flooding 326 Drawings Number Title

Date

G-580 Nuclear Plant Island Structure Flood Wall Penetrations, Sheet 1

July 10, 2018

G-580 Nuclear Plant Island Structure Flood Wall Penetrations, Sheet 2

April 3, 2011

G-580 Nuclear Plant Island Structure Flood Wall Penetrations, Sheet 3

April 25, 1991

71111.04 – Equipment Alignment Condition Reports CR-WF3-2017-01509 CR-WF3-2017-04445 CR-WF3-2018-04638 CR-WF3-2017-07561 CR-WF3-2017-07550 Work Orders 00475847 00476848 00433888 00397848 00427894 00468224 00467879 00435999 Procedures Number Title

Revision

OP-008-008 Shield Building Ventilation 10 OP-003-035 Auxiliary Feedwater 309 OP-009-003 Emergency Feedwater 309 OP-009-002 Emergency Diesel Generator 346 OP-002-010 Reactor Auxiliary Building HVAC and Containment

Purge 312

A1-2

71111.05 – Fire Protection Procedures Number Title

Revision

NS-TB-001 Waterford-3 S.E.S Pre-Fire Strategy Turbine Building +15.00 East

4

NS-TB-003 Waterford-3 S.E.S Pre-Fire Strategy Turbine Building +40.00 East

1

RAB 34-001 Waterford-3 S.E.S Pre-Fire Strategy Elev. -15.50 RAB (RCA) 8 NS-TB-004 Waterford-3 S.E.S Pre-Fire Strategy Turbine Building +40.00

West 1

RAB 2-001 Waterford-3 S.E.S Pre-Fire Strategy Elev. +46.00’ RAB (RCA) 13 EN-TQ-125 Fire Brigade Drills 6 RAB 6-001 Waterford-3 S.E.S Pre-Fire Strategy Elev. +35.00 RAB 9 Miscellaneous Documents Number Title

Date

Waterford 3 Fire Brigade Drill 2018 Completion Tracking Matrix

September 2018

Waterford 3 Fire Brigade Drill 2017 Completion Tracking Matrix

September 2018

Waterford 3 Fire Brigade Drill 2016 Completion Tracking Matrix

September 2018

71111.11 – Licensed Operator Requalification Condition Reports CR-WF3-2018-03123 CR-WF3-2018-03213 CR-WF3-2018-03085 CR-WF3-2017-06573 CR-WF3-2016-05408 CR-WF3-2016-07255 CR-WF3-2018-02492 CR-WF3-2017-00464 CR-WF3-2017-02044 CR-WF3-2017-01218 CR-WF3-2017-01623 CR-WF3-2017-03600

A1-3

Procedures Number Title

Revision

OP-100-010 Equipment Out of Service 316 OP-901-110 Pressurizer Level Control Malfunction 11 OP-901-220 Loss of Condenser Vacuum 303 OP-901-212 Rapid Plant Power Reduction 10 OP-902-000 Standard Post Trip Actions 16 OP-902-001 Reactor Trip Recovery 16 OP-902-008 Functional Recovery 27 OP-902-009 Standard Appendices 317 EP-001-001 Recognition & Classification of Emergency Conditions 33 OP-903-005 Control Element Assembly Operability Check 14 OP-903-094 ESFAS Subgroup Relay Test – Operating 31 Miscellaneous Documents Number Title

Revision or Date

WSXM-LOR-184EXM 2018 Cycle 4 Annual Simulator Exam – Week 3 E-214 Annual Requalification Results Summary August 20,

2018 71111.13 – Maintenance Risk Assessment and Emergent Work Review Condition Reports CR-WF3-2018-04154 CR-WF3-2018-04156 CR-WF3-2018-04180 CR-WF3-2018-05046 Work Orders 00432117 00427084 00432121 Procedures Number Title

Revision

EN-FAP-WM-107 Emergent Issues Process 1 EN-MA-125 Troubleshooting Control and Maintenance Activities 22 EN-WM-104 On Line Risk Management 17 OI-037-000 Operations’ Risk Assessment Guideline 313 EN-WM-104 On Line Risk Management 18 EN-OP-119 Protected Equipment Postings 9

A1-4

Miscellaneous Documents Number Title

Date

EN-OP-119 Att. 9.1 Protected Equipment Postings List for Emergency Diesel Generator A work window

September 23, 2018

EN-OP-119 Att. 9.1 Protected Equipment Postings List for Emergency Feedwater 228A and 224A

August 20, 2018

71111.15 – Operability Evaluations Condition Reports

CR-WF3-2018-04025 CR-WF3-2018-04021 CR-WF3-2018-04114 CR-WF3-2018-04709 Procedures Number Title

Revision

OP-008-008 Shield Building Ventilation 10 OP-903-068 Emergency Diesel Generator and Subgroup Relay

Operability Verification 321

71111.18 – Plant Modifications Condition Reports CR-WF3-2017-02774 CR-WF3-2018-04367 CR-WF3-2018-04296 CR-WF3-2018-04677 Procedures Number Title

Revision

EN-DC-136 Temporary Modifications 17 OP-001-001 Reactor Coolant System Fill and Vent 35 OP-903-097 Pressurizer Heater Capacity Verification 12 OP-901-502 Evacuation of Control Room and Subsequent Plant

Cooldown 35

A1-5

Drawings Number Title

Revision

5817-14492 UHS Air Deflector Structure Details Sheets 1 - 41 B424 Sheet 291 Pressurizer Proportional Heater Bank-1 18 B424 Sheet 286 Pressurizer Backup Heaters Bank 2 20 B424 Sheet 287 Pressurizer Backup Heaters Bank 3 18 B289 Sheet 23A1 480V Switchgear 3A32 Programmer Settings 8 B289 Sheet 23 Power Distribution and Motor Data 480V Switchgear 3A32

One Line Diagram 17

B289 Sheet 101 Power Distribution and Motor Data 480V Distribution Panels 6 B289 Sheet 158 Power Distribution and Motor Data 480V Switchgear Front

View 13

Miscellaneous Documents Number Title

Revision

EC-71594 Temporary Replace Failed Proportional Heater Bank 1 Heaters 3 (position F2) and 4 (position H2) with heaters from Backup Bank 2and 3 (positions E1 and C2)

0

EC-54532 Ultimate Heat Sink Margin Restoration – Phase 3 0 EC-52043 Ultimate Heat Sink Margin Restoration 0 71111.19 – Post-Maintenance Testing Condition Reports CR-WF3-2018-04419 CR-WF3-2018-07223 CR-WF3-2018-04415 CR-WF3-2018-01508 CR-WF3-2018-01004 CR-WF3-2018-00589 CR-WF3-2017-05397 CR-WF3-2018-04463 CR-WF3-2017-01483 CR-WF3-2017-05329 CR-WF3-2018-04444 CR-WF3-2017-04606 CR-WF3-2018-04632 CR-WF3-2018-05448 Work Orders 00496628 00434744 00364478 52735553 00450472 52756221 52713822 52746212 52745254 52735551 00477067 50551501 52805322 00496405

A1-6

Procedures Number Title

Revision

OP-903-068 Emergency Diesel Generator and Subgroup Relay Operability Verification

321

OP-009-002 Emergency Diesel Generator 346 OP-903-003 Charging Pump Operability Check 312 OP-904-007 Charging Pump Pulsation Dampener Pressure Check 016 OP-903-131 AFW High Discharge Pressure Trip Test 002 MM-006-161 AFW Pump Disassembly, Inspection and Reassembly 9 MM-006-162 Diesel Generator Cylinder Head Removal, Inspection and

Installation 7

EN-HU-106 Procedure and Work Instruction Use and Adherence 6 EN-MA-118 Foreign Material Exclusion 13 UNT-005-007 Plant Lubrication Procedure 304 OP-002-010 Reactor Auxiliary Building HVAC and Containment Purge 312 OP-903-050 Component Cooling Water and Auxiliary Component Cooling

Water Pump and Valve Operability Test

Drawings Number Title

Revision

G-168 Sheet 2 CVCS Flow Diagram 55 Miscellaneous Documents Number Title

Revision

WLP-OPS-CVC00 CVCS training document 27 WF3-ME-18-00001 Charging Pump Pulsation Dampener Vibration Evaluation 0 EC-75478 Evaluation of Charging Pump Pulsation Dampener Impact on

Operability 0

PE Eval 153315 Head, Cylinder, Emergency Diesel Generator 0 71111.22 – Surveillance Testing Condition Reports CR-WF3-2018-04236 CR-WF3-2018-04214 CR-WF3-2018-04202 CR-WF3-2018-04314 CR-WF3-2018-04365 Work Orders 52645246 52819598

A1-7

Procedures Number Title

Revision

OP-903-030 Safety Injection Pump Operability Verification 36 MI-005-214 Calibration of Flow Instruments 6 OP-903-006 Reactor Trip Circuit Breaker Test 13 MI-003-126 Core Protection Calculator Functional Test 20 OP-903-100 MOV Overload Bypass Test 310 OP-903-046 Emergency Feed Pump Operability Check 322 Drawings Number Title

Revision

B-424 Sheet 1153 Control Room Emergency Filtration Unit North Intake 20 Miscellaneous Documents Number Title

Revision

SEP-WF3-IST-2 WF3 IST Plan 7 71114.02 – Alert and Notification System Testing Condition Reports

2017-03818 2017-06905 Work Orders

52710344 52735556 52735558 Procedures Number Title

Revision or Date

Updated Alert and Notification System Design Report, December 2014

8

FEMA REP-10 Design Report Addendum July 14, 2015

EPP-422 Siren and Helicopter Warning System Maintenance, 11 EPP-424 Siren Testing and Siren System Administrative Controls, 19

A1-8

71114.03 – Emergency Response Organization Staffing and Augmentation Systems Condition Reports

2016-04434 2016-04435 2016-04436 2016-04437 2016-04438 2016-06548 2016-06547 2016-06549 2016-06949 2017-01152 2017-01154 2017-05394 2017-05396 2017-07826 2017-09090 Procedures Number Title

Revision

EN-EP-310 Emergency Response Organization Notification System 5 EN-EP-801 Emergency Response Organization 15 EP-002-015 Emergency Responder Activation 303 EPP-462 Evaluation of Pager Tests 4 71117.04 – Emergency Action Level and Emergency Plan Changes Procedures Number Title

Revision

EN-EP-305 Emergency Planning 10CFR50.54(q) Review Program 6 Miscellaneous Documents Number Title

Revision

10CFR50.54(q)(3) Screening Evaluation for EP-002-100 45 10CFR50.54(q)(3) Screening Evaluation for EN-EP-801 14 10CFR50.54(q)(3) Screening Evaluation for Emergency Plan 47 10CFR50.54(q)(3) Screening Evaluation for Emergency Plan 48 10CFR50.54(q)(3) Screening Evaluation for On-Shift Staffing

Analysis 1

10CFR50.54(q)(3) Screening for Emergency Plan 49 10CFR50.54(q)(3) Screening Evaluation for EP-001-001 33 71114.05 – Maintenance of Emergency Preparedness Condition Reports

2016-04573 2016-04891 2016-05315 2016-05563 2016-05572 2016-06017 2016-06404 2016-07104 2016-07597 2017-00008 2017-01627 2017-01826 2017-02502 2017-03304 2017-04233 2017-05494 2017-05535 2017-05662 2017-05875 2017-06905 2017-06978 2017-07707 2017-08244 2017-08367

A1-9

2017-08388 2017-09328 2017-09512 2017-09772 2017-09804 2017-09833 2018-00047 2018-00104 2018-00539 2018-00980 2018-01009 2018-02867 2018-02988 2018-03489 2018-04476 2018-04479 LO-HQNLO-2016-00050 LO-HQNLO-2016-00056 CRHQN-2018-01704 Work Orders

00422707 00422708 00448915 00450676 00451436 00451985 00461103 00476211 00488788 00489973 00492462 00495965 52580909 52702861 52707267 52772677 52728394 Procedures Number Title

Revision

EN-EP-306 Drills and Exercises 9 EN-EP-308 Emergency Planning Critiques 5 EN-EP-801 Emergency Response Organization 15 EN-LI-102 Corrective Action Program 32, 33 EN-LI-104 Self-Assessment and Benchmark Process 13 EN-QV-109 Audit Process 34 EP-001-010 Unusual Event 303 EP-002-015 Emergency Responder Activation 301 EP-003-020 Emergency Preparedness Drills and Exercises, 304 EP-003-030 Emergency Program Review, Updating, and Modification, 303 EP-003-040 Emergency Equipment Inventory, 308 EP-003-070 Emergency Communications Systems Routine Testing, 304 EPP-401 Review, Publication and Distribution of Public Information

Materials, 2

EPP-428 Emergency Facilities and Equipment Readiness, 306

A1-10

Miscellaneous Documents Number Title

Revision or Date

Waterford3 Emergency Plan 47, 48, 49 LO-WLO-2017-0048 2017 Pre NRC Evaluation Exercise Assessment October 16,

2017 LO-WLO-2017-00077 Pre NRC Program Inspection Assessment QA-7-2017-W3-1 Emergency Preparedness Audit May 26, 2017 QA-7-2018-W3-1 Emergency Preparedness Audit May 10, 2018 Monthly Communications Drill September 13,

2016 Monthly Communications Drill January 31,

2017 Monthly Communications Drill November 21,

2017 Monthly Communications Drill April 3, 2018 Inspection of Emergency Diesel Generator September 12,

2016 Inspection of Emergency Diesel Generator July 6, 2017 Inspection of Emergency Diesel Generator May 3, 2018 Emergency Communications Test Sheet August 30, 2016 Emergency Communications Test Sheet December 20,

2016 Emergency Communications Test Sheet April 30, 2017 Emergency Communications Test Sheet November 6,

2017 Emergency Communications Test Sheet December 13,

2017 Emergency Communications Test Sheet February 20,

2018 Readiness Condition – Control Room December 12,

2016 Readiness Condition – Control Room November 1,

2017 Readiness Condition – Control Room April 3, 2018 Readiness Condition – Technical Support Center July 6, 2017 Readiness Condition – Technical Support Center December 4,

2017 Readiness Condition – Technical Support Center June 19, 2018

A1-11

Readiness Condition – Operational Support Center July 6, 2017 Readiness Condition – Operational Support Center April 3, 2018 Readiness Condition – Emergency Operations

Facility September 29, 2016

Readiness Condition – Emergency Operations Facility (March)

July 6, 2017

Readiness Condition – Emergency Operations Facility (June)

July 6, 2017

Readiness Condition – Emergency Operations Facility

April 3, 2018

Readiness Condition – Emergency Operations Facility

June 19, 2018

Readiness Condition – Joint Information Center December 4, 2017

Readiness Condition – Joint Information Center April 3, 2018 Assembly Area Supervisors Kit Inventory July 6, 2017 Assembly Area Supervisors Kit Inventory June 19, 2018 After-Action Report for the Notification of Unusual

Event declared on July 17, 2017

Evaluation Report for the Medical Drill Conducted February 12, 2016

February 18, 2016

W3D3-2016-0003 Evaluation Report for the Exercise Conducted April 6, 2016

May 3, 2016

Evaluation Report for the Health Physics Drill Conducted June 22, 2016

July 13, 2016

W3D3-2016-0006 Evaluation Report for the Exercise Conducted June 15, 2016

July 15, 2016

W3E3-2016-0008 Evaluation Report for the Exercise Conducted August 31, 2016

September 27, 2016

W3D3-2016-0009 Evaluation Report for the Drill Conducted October 7, 2016

October 7, 2016

W3D3-2016-0008 Evaluation Report for the Drill Exercise Conducted December 7, 2016

Evaluation Report for the Medical Drill Conducted January 23, 2017

February 22, 2017

W3D3-2017-0004 Evaluation Report for the Control Room Breathing Air Drill Conducted March 24, 2017

March 24, 2017

Evaluation Report for the Exercise Conducted June 28, 2017

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W3D3-2017-0007 Evaluation Report for the Control Room Breathing Air Drill Conducted September 15, 2017

September 19, 2017

2017-05 Evaluation Report for the Drill Exercise Conducted July 12, 2017, Revision 1

October 19, 2017

Evaluation Report for the Exercise Conducted October 26, 2017

2017-017 Evaluation Report for the Focused Drill for Site Accountability

November 29, 2017

Evaluation Report for the Exercise Conducted December 13, 2017

Evaluation Report for the Exercise Conducted February 21, 2018

Evaluation Report for the Control Room Breathing Air Drill Conducted June 15, 2018

June 15, 2018

Evaluation Report for the Exercise Conducted June 20, 2018

July 18, 2018

WF3-IC-17-00002 Engineering Report: Plant Paging System Reliability Study

71114.06 – Drill Evaluation Miscellaneous Documents Number Title

Date

Red Team Site Drill Scenario Description August 29, 2018

Notification Forms for Red Team Site Drill August 29, 2018

71124.02 – Occupational ALARA Planning and Controls Condition Reports

WF3-2017-03249 WF3-2017-03344 WF3-2017-03771 WF3-2017-03778 WF3-2018-00831 Procedures Number

Title

Revision

EN-RP-100 Radiation Worker Expectations 12

EN-RP-105 Radiological Work Permits 18

EN-RP-109 Hot Spot Program 05

EN-RP-110 ALARA Program 14

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Procedures Number

Title

Revision

EN-RP-110-03 Collective Radiation Exposure (CRE) Reduction Guidelines

04

EN-RP-110-04 Radiation Protection Risk Assessment Process 07

EN-RP-152 Conduct of Radiation Protection 04 Audits and Self-Assessments

Number Title Date

LO-WLO-2017-00069 Self-Assessment: Occupational ALARA Planning and Controls July 24, 2018

Radiation Work Permits

Number Title Revision

2016-0118 Loading of Dry Fuel Storage Cask #18 with Spent Fuel and Transport including all DFS Support Activities to include Set Up/Demob

02

2016-0119 Loading of Dry Fuel Storage Cask #19 with Spent Fuel and Transport including all DFS Support Activities to include Set Up/Demob

01

2016-0123 Loading of Dry Fuel Storage Cask #23 with Spent Fuel and Transport including all DFS Support Activities to include Set Up/Demob

00

2017-0515 RCP 1B Motor Replacement 00

2017-0610 Erect/Dismantle Scaffolding in the Reactor Containment Building

00

2017-0702 Reactor Disassembly Activities 00

2017-0705 Reactor Reassembly Activities 00

2018-0001 Radiation Protection to Perform Job Coverage, Routine Surveys, Inspections and Walkdowns

00

2018-0006 Radwaste Processing/Shipping in all Radiologically Controlled Areas

00

ALARA Planning, In-Progress Reviews, and Post-Job Reviews

Number Title Revision

EN-RP-105, Att.9.5 Refuel 20 Outage ALARA Report 01

EN-RP-105, Att.9.5 Refuel 21 Outage ALARA Report 00

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Miscellaneous Documents Number

Title

Revision or Date

EC 0000042470 Evaluate TSR 2008-24, 2010-01, 2011-30, 2012-24, 2012-33, 2012-36, 2011-79 as Long-Term Shielding

February 20, 2013

2017 Annual Radiation Protection Program Report 06

Waterford-3 Abbreviated 5-Year Exposure Reduction Plan 2018-2022

December 4, 2017

71124.04 – Occupational Dose Assessment Condition Reports

HQN-2016-1136 WF3-2016-07300 WF3-2017-01829 WF3-2017-02024 WF3-2017-06719

WF3-2017-06758 WF3-2017-07702 WF3-2018-01726 WF3-2017-03148

Audits and Self-Assessments

Number Title Date

LO-WLO-2016-00037 Self-Assessment: Bioassay Program January 16, 2017

LO-WLO-2017-00069 Self-Assessment: Occupational Dose Assessment July 23, 2018 Calibration Records

Number Title Date

017027353 Canberra GEM-5 Calibration Data Sheet April 25, 2018

Procedures Number

Title

Revision

EN-RP-131 Air Sampling 16

EN-RP-201 Dosimetry Administration 05

EN-RP-204 Special Monitoring Requirements 11

EN-RP-205 Prenatal Monitoring 03

EN-RP-208 Whole Body Counting/In-Vitro Bioassay 07

EN-RP-312 Operation and Calibration of the Canberra GEM-5 01

EN-RP-314 Passive Monitor Sensitivity Testing 00

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Miscellaneous Documents Number

Title

Date

2017-2018 Entergy Waterford-3 Radiation Protection Department Respiratory Improvement Plan September 4, 2018

Review of Neutron Dose Estimates 2016 July 25, 2017

Field Trials with the Use of the REM-500 at Waterford-3 July 28, 2017

Review of the Capabilities of the Passive Monitoring Program to Detect Intakes at Waterford-3 October 4, 2017

71151 – Performance Indicator Verification Condition Reports

2017-07707 2017-08036 2017-08367 2017-08790 2017-09261 2017-09507 2017-09512 2017-09637 2018-00678 2018-02077 2018-02656 2018-02870 Procedures Number Title

Revision

EP-001-001 Recognition and Classification of Emergencies 32, 33 EP-002-010 Notifications and Communications 313, 314, 315 EP-002-052 Protective Action Guidelines 25 EPP-424 Siren Testing and Siren System Administrative Controls, 19 71152 – Identification and Resolution of Problems Condition Reports

CR-WF3-2018-01054 CR-WF3-2018-01849 CR-WF3-2017-07486 CR-WF3-2018-01981 CR-WF3-2017-09887 CR-WF3-2018-01049 CR-WF3-2018-01978 CR-WF3-2018-01994 CR-WF3-2018-06078 CR-WF3-2018-05252 Procedures Number Title

Revision

EN-LI-108 Att. 9.1 10 CFR 21 Discovery Determination & Reportability Evaluation Sheet for CR-WF3-2018-1994

9

EN-DC-205 Maintenance Rule Monitoring 6

A1-16

Drawings Number Title

Revision

B425 T7075B1 Control Loop Diagram CC-Dry Cooling tower B Fan Cooling

4

B425 T7070BD Control Loop Diagram CC-Dry Cooling tower B Outlet Temp

4

B425 T5009A Control Loop Diagram HVR-CCW Pump Heat Exchanger A Room Temp

5

71153 – Event Followup Miscellaneous Documents Number Title

Date

W3F1-2017-0076 NRC Performance Indicator (PI) Data – 3rd Quarter 2017 ROP Data

October 6, 2017

W3F1-2018-0004 NRC Performance Indicator (PI) Data – 4th Quarter 2017 ROP Data

January 9, 2018

W3F1-2018-0024 NRC Performance Indicator (PI) Data – 1st Quarter 2018 ROP Data

April 12, 2018

W3F1-2018-0042 NRC Performance Indicator (PI) Data – 2nd Quarter 2018 ROP Data

July 13, 2018

Attachment 2

The following items are requested for the Occupational Radiation Safety Inspection

at Waterford-3

Dates of Inspection: 09/10/2018 to 09/14/2018

Integrated Report 2018003 Inspection areas are listed in the attachments below. Please provide the requested information on or before Monday, August 13, 2018. Please submit this information using the same lettering system as below. For example, all contacts and phone numbers for Inspection Procedure 71124.02 should be in a file/folder titled “2-A,” applicable organization charts in file/folder “2-B,” etc. If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at least 30 days later than the onsite inspection dates, so the inspector will have access to the information while writing the report. In addition to the corrective action document lists provided for each inspection procedure listed below, please provide updated lists of corrective action documents at the entrance meeting. The dates for these lists should range from the end dates of the original lists to the day of the entrance meeting. If more than one inspection procedure is to be conducted and the information requests appear to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which file the information can be found. If you have any questions or comments, please contact Natasha Greene at 817-200-1154 or via e-mail at Natasha.Greene@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget, control number 3150-0011.

A2-2

2. Occupational ALARA Planning and Controls (71124.02)

Date of Last Inspection: April 24, 2017

A. List of contacts and telephone numbers for ALARA program personnel. Please include

area code and prefix. If work cell numbers are appropriate, then please include them as well.

B. Applicable organization charts including position or job titles. Please include as appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C), Engineering, and Emergency Protection. (Recent pictures are appreciated.)

C. Copies of audits, self-assessments, LARs, and LERs, written since the date of last inspection, focusing on ALARA

D. Procedure index for ALARA Program procedures and other related disciplines. E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures may be requested by number after the inspector reviews the procedure indexes. 1. ALARA Program 2. ALARA Planning 3. ALARA Reviews 4. ALARA Committee 5. Radiation Work Permit Preparation

F. Please provide a list of NRC Regulatory Guides and NUREGs that you are currently committed to relative to this program. Please include the revision and/or date for the commitment and where this may be located in your current licensing basis documents.

G. Please provide a summary list of corrective action documents (including corporate and sub-tiered systems) written since the date of last inspection, related to the ALARA program, including exceeding RWP Dose Estimates.

NOTE: These lists should include a description of the condition that provides sufficient detail that the inspector can ascertain the regulatory impact, the significance level assigned to the condition, the status of the action (e.g., open, working, closed, etc.) and the search criteria used. Please provide in document formats which are “sortable” and “searchable” so that inspector can quickly and efficiently determine appropriate sampling and perform word searches, as needed. (Excel spreadsheets are the preferred format.) If codes are used, please provide a legend for each column where a code is used.

H. List of work activities (RWPs) greater than 1 rem, since date of last inspection, including the original dose estimates and actual doses accrued. (Excel format preferred). Please provide all revisions/changes, as well as any related RWPs that support the work activity.

Provide any post evaluations, lessons learned, and/or corrective action documents generated as a result of this work activity. If available, provide any justifications/reasons for actual dose exceedances of the initial dose estimate.

I. List of active work activities (RWPs) that will be in use while we are onsite, including the dose and dose rate settings, and if available, the planned dose.

A2-3

J. Site dose totals for the past 3 years (based on dose of record). Also provide the current year-to-date (YTD) collective radiation exposure (CRE). In addition, please provide another document that separates the online and outage doses for the past 3 years.

K. Most recent assessment of your isotopic mix, including the hard-to-detect radionuclides and alpha hazards. Include a list of new and historical exposure issues (radiological source term or high exposure areas/activities).

L. If available, provide a copy of the ALARA outage report or evaluation for the two most recently completed outages for each unit

M. Please provide the methods/reports that are in your process to meet the requirements of 10 CFR 20.1101(c) for periodic review of your RP program.

N. Current exposure trends (BRAC dose rates and/or source term information)

A2-4

4. Occupational Dose Assessment (Inspection Procedure 71124.04) Date of Last Inspection: September 12, 2016

A. List of contacts and telephone numbers for the Dose Assessment personnel. Please

include area code and prefix. If work cell numbers are appropriate, then please include them as well.

B. Applicable organization charts including position or job titles. Please include as

appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C), Engineering, and Emergency Protection. (Recent pictures are appreciated.)

C. Copies of audits, self-assessments, vendor or NUPIC audits of contractor support, and

LERs written since date of last inspection, related to Occupational Dose Assessment D. Procedure indexes for Occupational Dose Assessment procedures and other related

disciplines. E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures will be requested by number after the inspector reviews the procedure indexes. 1. Radiation Protection Program 2. Radiation Protection Conduct of Operations 3. Personnel Dosimetry Program 4. Electronic Dosimeters 5. Air Sample Analysis 6. Performance of High or Special Exposure Work 7. Declared Pregnant Worker 8. Bioassay Program (Internal Dose Assessment)

F. Please provide a list of NRC Regulatory Guides and NUREGs that you are currently committed to relative to this program. Please include the revision and/or date for the commitment and where this may be located in your current licensing basis documents.

G. Please provide a summary list of corrective action documents (including corporate and sub-tiered systems) written since date of last inspection, associated with: 1. National Voluntary Laboratory Accreditation Program (NVLAP) 2. Dosimetry (TLD/OSL, etc.) problems 3. Electronic alarming dosimeters 4. Bioassays or internally deposited radionuclides or internal dose 5. Neutron dose

NOTE: These lists should include a description of the condition that provides sufficient detail that the inspector can ascertain the regulatory impact, the significance level assigned to the condition, the status of the action (e.g., open, working, closed, etc.) and the search criteria used. Please provide in document formats which are “sortable” and “searchable” so that inspector can quickly and efficiently determine appropriate sampling and perform word searches, as needed. (Excel spreadsheets are the preferred format) If codes are used, please provide a legend for each column where a code is used.

A2-5

H. List of positive whole body counts (excluding K-40) since date of last inspection, include date(s), reason(s), activity assessed, and doses calculated and assigned. Names and personal information can be redacted, if desired

I. Part 61 analyses or other analyses of plant isotopic mixture (alpha, beta, gamma, and neutron) for appropriate instrumentation calibration sources and dosimetry selection and hard-to-detect plant nuclide scaling factors for intakes/uptakes.

J. The most recent National Voluntary Laboratory Accreditation Program (NVLAP) accreditation report or, if dosimetry is provided by a vendor, the vendor’s most recent results and which dosimeter(s) is (are) use at the site and for what purpose(s) (DLR, neutron, environmental, etc.).

K. Please provide the latest assessment of your radiological source term as it relates to the

internal/external exposure of workers. L. If available, please provide your latest source term reduction strategy. M. Have available for on-site review the LLDs or MDAs for each onsite WBC or other

internal dose assessment instrumentation. N. If available, please provide the latest neutron source term characterization.

Describe why the neutron dosimetry used is appropriate for these locations. O. A list of airborne radioactivity areas (and associate RWPs) where DAC-hr monitoring

was used with air sampling to track and assign dose (BZ lapel air samples, etc.). P. Please have available for on-site review, a list of workers that declared a pregnancy

since the last inspection. Declared Pregnant Worker monitoring of worker and fetus. Please provide the most recent NRC Form 5 for these individuals. No more than three are requested. Please redact any sensitive information.

Q. A list of EDEX or multi-badge dosimetry uses since the last inspection, include the

associated RWP and dose accrued.

WATERFORD STEAM ELECTRIC STATION, UNIT 3 – NRC INTEGRATED INSPECTION REPORT 05000382/2018003 – October 30, 2018 DISTRIBUTION KKennedy, RA SMorris, DRA AVegel, DRP MHay, DRP MShaffer, DRS RLantz, DRS DCylkowski, RC NOKeefe, DRP JDixon, DRP RBywater, DRP FRamirez, DRP LNewman, DRP LReyna, DRP CCook, RIV/OEDO VDricks, ORA JWeil, OCA APulvirenti, NRR AMoreno, RIV/CAO BMaier, RSLO GMiller, IPAT PJayroe, IPAT MHerrera, DRMA JVera, DRP LReyna, DRP R4Enforcement ROP Reports ROPreports.Resource@nrc.gov

DOCUMENT NAME: R:\_REACTORS\_WAT\2018\WAT2018003-IR-FR ML18304A163.docx ADAMS ACCESSION NUMBER: ML18304A163 ■ SUNSI Review ADAMS: Non-Publicly Available ■ Non-Sensitive Keyword:

By: NFO ■ Yes No ■ Publicly Available Sensitive NRC-002 OFFICE SRI:DRP/D RI:DRP/D Tl:DRS/IPAT BC:DRS/EB1 Bc:DRS/EB2 BC:DRS/PSB2 NAME FRamirez CSpeer GMiller TFarnholtz GWerner HGepford SIGNATURE FCR CAS GBM TRF GEW hjg DATE 10/16/2018 10/17/18 10/25/18 10/25/2018 10/24/2018 10/25/18 OFFICE BC:DRS/OB BC:DRP/D NAME VGaddy NO’Keefe SIGNATURE TJF for NFO DATE 10/25/2018 10/29/2018

OFFICIAL RECORD COPY