IR 05000382/2020001
| ML20118C992 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 04/24/2020 |
| From: | John Dixon NRC/RGN-IV/DRP/RPB-D |
| To: | Vasquez S Entergy Operations |
| References | |
| IR2020001 | |
| Download: ML20118C992 (24) | |
Text
April 24, 2020
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - INTEGRATED INSPECTION REPORT 05000382/2020001 AND INDEPENDENT SPENT FUEL STORAGE INSPECTION 07200075/2020001
Dear Mr. Vazquez:
On March 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Waterford Steam Electric Station, Unit 3. On April 9, 2020, 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.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Waterford Steam Electric Station, Unit 3.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at Waterford Steam Electric Station, Unit 3. 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, John L. Dixon, Jr., Chief Reactor Projects Branch D Division of Reactor Projects
Docket Nos. 05000382 and 0720075 License No. NPF-38
Enclosure:
As stated
Inspection Report
Docket Number:
05000382 and 0720075
License Number:
Report Number:
05000382/2020001 and 0720075/2020001
Enterprise Identifier: I-2020-001-0002 and 1-2020-001-0091
Licensee:
Entergy Operations, Inc.
Facility:
Waterford Steam Electric Station, Unit 3
Location:
Killona, LA 70057
Inspection Dates:
January 1, 2020 to March 31, 2020
Inspectors:
R. Alexander, Senior Emergency Preparedness Inspector
S. Makor, Reactor Inspector
J. ODonnell, Senior Health Physicist
F. Ramirez Munoz, Senior Resident Inspector
C. Speer, Resident Inspector
L. Brookhart, Senior Spent Fuel Storage Inspector
E. Simpson, Health Physicist
Approved By:
John L. Dixon, Jr., Chief
Reactor Projects Branch D
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees 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 NRCs 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
Failure to Follow Work Instructions When Performing Maintenance on the Safety-Related Essential Chilled Water System Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000382/2020001-01 Open/Closed
[H.11] -
Challenge the Unknown 71152 The inspectors reviewed a self-revealed Green, non-cited violation of Technical Specification 6.8.1.a for the licensees failure to follow work instructions for replacing the damaged section of wiring for a temperature element in essential chilled water system loop A.
Specifically, maintenance technicians elected to remove and repair the temperature element conduit box, actions beyond the scope of the work order instructions, which created a breach in the system, a loss of level of the swing AB expansion tank, and a trip of the swing AB essential chiller. The actions resulted in having only one operable loop in the essential chilled water system and the unexpected entry into a 72-hour shutdown limiting condition of operation.
Additional Tracking Items
Type Issue Number Title Report Section Status NOV 05000382/2017009-01 Failure to Establish Appropriate Electrical-Related FLEX Strategies for Mitigating a Beyond-Design-Basis External Event 92702 Closed
PLANT STATUS
The unit 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/readingrm/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. From January 1 - March 19, 2020, 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.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week and during that time conducted plant status activities as described in IMC 2515, Appendix D; and observed risk-significant activities when warranted. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In the cases where it was determined the objectives and requirements could not be performed remotely, management elected to postpone and reschedule the inspection to a later date.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
External Flooding Sample (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated readiness to cope with external flooding for the following areas on March 15, 2020:
- Dry cooling towers
- Reactor auxiliary building
- Turbine building
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Auxiliary component cooling water train B following system maintenance on January 24, 2020
- (2) Temporary emergency diesel generators aligned to replace emergency diesel generator B on January 27, 2020
- (3) Emergency feedwater train B with train A out of service for maintenance on March 3, 2020
- (4) Essential chilled water train AB following re-alignment to replace essential chiller A on March 11, 2020
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Fire area RAB 33, shutdown cooling heat exchanger rooms A and B on February 10, 2020
- (2) Fire area RAB 34, safeguards valve gallery rooms A and B on February 10, 2020
- (3) Fire area RAB 8B, switchgear room B on February 26, 2020
- (4) Fire area RAB 32, auxiliary component cooling water room and pipe penetration area on January 26, 2020
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during a period of heightened activity for the turbine inlet valve stroke testing on January 30, 2020.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the simulator during an emergency preparedness drill on March 4, 2020.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:
- (1) Nitrogen gas system on February 3, 2020
- (2) Emergency feedwater system on February 7, 2020
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Planned auxiliary component cooling water train B maintenance on January 23, 2020
- (2) Planned yellow risk due to emergency diesel generator B being out of service for maintenance on January 27, 2020
- (3) Planned static uninterruptible power supply re-alignment on March 2, 2020
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensees justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Operability assessment of low pressure safety injection train A when the low pressure safety injection pump A discharge flow control valve failed stroke time testing on February 6, 2020
- (2) Operability assessment of control element assembly calculators and core protection calculators following a control card failure on March 2, 2020
- (3) Operability assessment of the control room envelope when the train B control room outside air intake valve and air handling unit inlet isolation valves opened unexpectedly during maintenance on March 21, 2020
- (4) Operability assessment of emergency diesel generator B when an unexpected locked-in local annunciator horn was discovered on March 30, 2020
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Permanent modification to replace the pneumatic transducer for auxiliary component cooling water header train A component cooling water heat exchanger outlet temperature control valve on February 11, 2020
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:
- (1) Emergency feedwater pump A following maintenance on January 14, 2020
- (2) Chemical and volume control pump AB following maintenance on March 12, 2020
- (3) Component cooling water pump A following troubleshooting on March 26, 2020
- (4) Main steam isolation valve 1 upstream drip pot startup drain valve following maintenance on March 27, 2020
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Emergency feedwater header A to steam generator 1 backup flow control valve on March 9, 2020
- (2) Essential chilled water pump AB on March 11, 2020
Inservice Testing (IP Section 03.01) (2 Samples)
- (1) High pressure safety injection pump B on January 29, 2020
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The inspectors evaluated the Waterford Steam Electric Station, Unit 3 Emergency Plan, Revision 51, on March 22, 2020. The licensee implemented Revision 51 on January 30, 2020, and submitted the revised emergency plan to the NRC on February 6, 2020. This evaluation does not constitute NRC approval.
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) Site Emergency Preparedness Drill on March 4,
RADIATION SAFETY
71124.02 - Occupational ALARA Planning and Controls
Verification of Dose Estimates and Exposure Tracking Systems (IP Section 03.02) (1 Partial)
The inspectors evaluated dose estimates and exposure tracking.
(1)
(Partial)
WF3 RF21 and WF3 RF22 Post Outage ALARA Reports, each of which included an analysis of the top five dose jobs for each outage.
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.
External Dosimetry (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to external dosimetry that is used to assign occupational dose.
Internal Dosimetry (IP Section 03.03) (2 Samples)
The inspectors evaluated the following internal dose assessments for actual internal exposures:
- (1) Dose assessment for facial contamination event on refuel bridge during movement of In-core Instrumentation on January 14, 2019, CR-WF3-2019-00737
- (2) Dose assessment for facial contamination event during transfer cart repairs in the lower cavity on February 17, 2019, CR-WF3-2019-02942
Special Dosimetric Situations (IP Section 03.04) (1 Sample)
The inspectors evaluated the following special dosimetric situations:
- (1) Dose assessment for three declared pregnant workers.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)===
- (1) January 1, 2019, through December 31, 2019
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (1 Sample)
- (1) January 1, 2019, through December 31, 2019
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (1 Sample)
- (1) January 1, 2019, through December 31, 2019
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in maintenance rule functional failure evaluations that might be indicative of a more significant safety issue. The inspectors identified an observation related to a programmatic weakness and an associated minor violation that are documented in the Inspections Results section below.
Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) CR-WF3-2018-00998, impact of potential external toxic gas event on Waterford Steam Electric Station, Unit 3, FLEX Mitigation Strategies (Order EA-12-049) on January 23, 2020
- (2) CR-WF3-2019-08826, unauthorized maintenance on essential chiller A resulting in an unplanned 72-hour limiting condition for operation entry on February 17,
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
60855 - Operation of An ISFSI Operation of An ISFSI
- (1) The Waterford independent spent fuel storage installation (ISFSI) is located approximately 900 feet southwest of the reactor building within the plant protected area. The pad is roughly 120 feet wide and 154 feet long with the capacity to hold 72 HI-STORM 100S spent fuel storage casks configured in an 8 by 9 array. At the time of the routine inspection, the Waterford ISFSI pad contained a total of 26 HI-STORM 100S overpacks. The licensee was in the process of loading and processing canister 27. The licensee was loading canisters to the Holtec Certificate of Compliance No. 1014, Amendment 13, and HI-STORM 100 Updated Final Safety Analysis Report, Revision 18.
The inspectors evaluated the licensees ISFSI cask loading from March 16 through 19, 2020. Specifically, the inspectors observed the following activities:
- Fuel assembly selection and placement into the dry fuel storage canister
- Processing of the spent nuclear fuel for storage, including forced helium dehydration, and helium backfill operations
- Heavy load lifts by the cask handling crane of the transfer cask and the spent fuel storage canister
- Stack-up operations for transferring the storage canister from the transfer cask to the HI-STORM overpack
- Walk-down of the ISFSI haul path
- Partial transport of the loaded HI-STORM overpack from the auxiliary building to the vertical cask transporter (VCT) for movement to the ISFSI pad The inspectors performed a walk-down of the ISFSI radioactive materials area and completed an independent radiation survey. The inspectors also performed a walk-down of the spent fuel floor and reactor auxiliary building. The inspectors observed the movement of the loaded HI-STORM cask on the low-profile-transporter as it was moved from the fuel building, transferred to the VCT, and part of its travel along the haul path to the ISFSI pad for final storage.
The inspectors evaluated the following:
- Spent fuel selection for the current dry cask loading campaign for Waterford (casks 26 and 27)
- Compliance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 72.104 for calendar years 2017, 2018, 2019, and 2020
- Fire hazards analyses and control of combustibles for ISFSI operations
- Selected radiological surveys of the ISFSI and dry fuel storage casks
- Selected ISFSI-related condition reports
- Quality assurance (QA) program implementation, including recent QA audits, surveillances, and quality control activities related to ISFSI operations
- Compliance to Technical Specifications for ISFSI operational surveillance activities and Updated Final Safety Analysis Report required annual maintenance activities
- Documentation of required annual maintenance and inspection activities for heavy lifting components, including special lifting devices, the sites cask handling crane, and the VCT
60857 - Review of 10 CFR 72.48 Evaluations Review of 10 CFR 72.48 Evaluations
- (1) The inspectors reviewed a list of 10 CFR 72.48 screenings performed by the licensee since November 2016. During this time period the licensee did not perform any 10 CFR 72.48 evaluations. The inspectors evaluated the following:
- Selected licensee 10 CFR 72.48 screenings for associated changes, tests, and experiments associated with ISFSI operations
- The process by which the licensee evaluates 10 CFR 72.48 screenings and evaluations performed by the Certificate of Compliance holder
- Changes made to the licensees 10 CFR 72.212 Report since November 2016 (moving from Revision 5 to Revision 8)
92702 - Follow-up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, Confirmatory Orders, And Alternative Dispute Resolution Confirmatory Orders
- (1) VIO 05000382/2017009-01, Failure to Establish Appropriate Electrical-Related FLEX Strategies for Mitigating a Beyond-Design-Basis External Event (EA-18-020), on January 23,
INSPECTION RESULTS
Failure to Follow Work Instructions When Performing Maintenance on the Safety-Related Essential Chilled Water System Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000382/2020001-01 Open/Closed
[H.11] -
Challenge the Unknown 71152 The inspectors reviewed a self-revealed Green, non-cited violation of Technical Specification 6.8.1.a for the licensees failure to follow work instructions for replacing the damaged section of wiring for a temperature element in essential services chilled water system loop A. Specifically, maintenance technicians elected to remove and repair the temperature element conduit box, actions beyond the scope of the work order (WO)instructions, which created a breach in the system, a loss of level of the swing AB expansion tank, and a trip of the swing AB essential chiller. These actions resulted in having only one operable loop in the essential chilled water system and the unexpected entry into a 72-hour shutdown limiting condition for operation.
Description:
On December 5, 2019, instrumentation and controls (I&C) technicians were performing maintenance on temperature element RFRITE3017A in essential chilled water system loop A. The purpose of the essential chilled water system is to provide air conditioning to the essential equipment rooms and main control room during normal operations and operation following a design basis accident. Work Order 536240 contained written instructions to repair a damaged wire associated with the temperature element.
During this maintenance window, essential chiller AB was being used in place of essential chiller A; therefore, two loops of the essential chilled water system were operable.
While performing the maintenance work, the instrumentation and controls technicians noticed that the conduit box that housed the temperature element was degraded. With the approval of the maintenance supervisor, the instrumentation and controls technicians decided to remove the degraded conduit box to replace it. They did not consider it a change in the scope of the work and felt confident based on previous work with similar applications of conduit boxes. However, WO 536240 did not contain instructions to remove the conduit box.
When the instrumentation and controls technicians removed the conduit box, it caused a breach of the essential chilled water system due to removal of the temperature element well that was attached to it. This system breach caused a loss of level in the essential chiller AB expansion tank. The control room operators noticed expansion tank AB rapidly dropping, which caused the trip of essential chiller AB and resulted in operations manually securing essential chiller pump AB. The loss of essential chiller AB resulted in an unexpected entry into TS 3.7.12, Essential Services Chilled Water System, which is a 72-hour shutdown limiting condition for operation.
Corrective Actions: The licensees immediate corrective action was to repair the system breach by installing a new conduit box and realigning and restoring the level in the essential chiller AB expansion tank. Following the system restoration, essential chiller AB was placed back in service and the limiting condition for operation was exited within the allowed time frame.
Corrective Action References: Condition Report CR-WF3-2019-08826
Performance Assessment:
Performance Deficiency: The failure to follow work instructions as specified in WO 536240 was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the configuration control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, when the electricians performed unauthorized maintenance on the essential chilled water system, it resulted in a breach in the system, a loss of level in expansion tank AB, and a trip of essential chiller AB. The actions resulted in having only one operable loop in the essential chilled water system and the unexpected entry into a 72-hour shutdown limiting condition for operation.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined that the finding was of very low safety significance (Green) because
- (1) the finding was not a deficiency affecting the design or qualification of a mitigating system;
- (2) the degraded condition did not represent a loss of the PRA function of a single train technical specification system for greater than is technical specification allowed outage time;
- (3) the degraded condition did not represent a loss of the PRA function of one train of a multi-train technical specification system for greater than its technical specification allowed outage time;
- (4) the degraded condition did not represent a loss of the PRA function of two separate technical specification systems for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />;
- (5) the degraded condition did not represent a loss of a PRA system and/or function as defined in the PRIB or licensees PRA for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and
- (6) the degraded condition did not represent a loss of the PRA function of one or more non-technical specification trains of equipment designated as risk-significant in accordance with the licensees maintenance rule program for greater than 3 days.
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. Specifically, when the instrumentation and controls technicians and their supervisor encountered a condition that was not within the scope of the work instructions, they proceeded with the maintenance without evaluating the system consequences.
Enforcement:
Violation: Technical Specification 6.8.1.a, requires, in part, that procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2. Appendix A to Regulatory Guide 1.33, Section 9.a, requires, in part, that, maintenance that can affect the performance of safety-related equipment be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. The licensee established work instructions in WO 536240 to repair a damaged wire associated with a temperature element on the essential chilled water loop A.
Contrary to the above, on December 5, 2019, the licensee failed to implement the work instructions established in WO 536240 to repair a damaged wire associated with a temperature element on essential chilled water loop A, a safety-related system. Specifically, the instrumentation and controls technicians performed unauthorized maintenance that was not directed by the WO by also removing an adjacent degraded conduit box which pulled the associated temperature element well. This added work resulted in a breach in the system, a loss of level of expansion tank AB, a trip of essential chiller AB, and an unexpected entry into a 72-hour shutdown limiting condition for operation.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Minor Violation 71152 Minor Violation: The inspectors identified a minor violation of 10 CFR 50.65(b)(1) for the licensees failure to include the closed function of the emergency feedwater header B to steam generator 2 flow control valve, EFW-224B, in the scope of the maintenance rule program.
Screening: The inspectors determined the violation to be minor because it did not impact the Mitigating Systems cornerstone, consistent with Inspection Manual Chapter 0612, Appendix E, Example 8.c. The licensee generated condition report CR-WF3-2020-01183 to address the failure to include the closed function of EFW-224B in the scope of the maintenance rule program.
Enforcement:
The licensee has taken action to restore compliance. This failure to comply with 10 CFR 50.65(b)(1) constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
Observation: Semi-Annual Trend Review: Maintenance Rule Adverse Trend 71152 The inspectors identified an adverse trend involving the licensees implementation of their maintenance rule program. Specifically, the inspectors noted multiple instances where adverse conditions for structures, systems, and components scoped into the maintenance rule were not consistently evaluated against all applicable functional failure criteria.
- CR-WF3-2019-03069 documented three instances where failed local leak rate testing of containment isolation valves was not evaluated against the containment building maintenance rule functions. For each of these failures, the valves were evaluated against the maintenance rule functional failure criteria for the system they were explicitly assigned to (i.e., SI-405B was evaluated against the safety injection system criteria), but they were not evaluated against the applicable containment building system criteria despite being containment isolation valves. When challenged by the inspectors, the licensee re-evaluated the three instances and determined that they represented functional failures of the containment building system criterion for failing to satisfactorily pass local leak rate testing. This deficiency was previously communicated to the licensee and documented in NRC Inspection Report 05000382/2019001 as a semiannual trend review for weaknesses in the licensees maintenance rule program.
- CR-WF3-2019-07024 documented the failure of the auxiliary component cooling water header train A component cooling water heat exchanger outlet temperature control valve, ACC-126A, such that the associated nitrogen accumulator would not be able to supply adequate nitrogen on the loss of instrument air to meet the required 10-hour mission time to operate automatically. This failure was evaluated against the auxiliary component cooling water maintenance rule functions, but it was not evaluated against the nitrogen gas system maintenance rule criteria. When challenged by the inspectors, the licensee re-evaluated the condition and determined that it represented a functional failure of the nitrogen gas system criterion to provide enough nitrogen gas to the valve to perform for the required 10-hour mission time.
This condition is associated with a finding documented in NRC Inspection Report 05000382/2019004.
- CR-WF3-2019-02901 documented a failure of the emergency feedwater header B to steam generator 2 flow control valve, EFW-224B, in which the associated controller would not close the valve due to an air leak. The failure was evaluated against the emergency feedwater system maintenance rule criteria, but the inspectors noted that only the open functions were captured in the scope of the maintenance rule. The actual failure of the valve involved a failure to close, which is a required safety function for the valve evaluated in the licensees Updated Final Safety Analysis Report to combat a ruptured steam generator. When challenged by the inspectors, the licensee determined that the closed function of the valve was inappropriately not scoped into the maintenance rule program. In addition to the failure to properly scope EFW-224B into the maintenance rule program, the inspectors noted that the air leak on EFW-224B was not evaluated against the nitrogen gas maintenance rule functions.
When challenged by the inspectors, the licensee determined that a functional failure evaluation should have been performed but that the condition ultimately was not a maintenance rule functional failure. This issue was documented as a minor violation in the Inspection Results section of this report.
The inspectors concluded that the repeated failure to consistently consider all applicable functions when performing maintenance rule functional failure evaluations represents a weakness in the licensees maintenance rule program. However, the inspectors did not find that accounting for these functional failures would result in systems being reclassified from maintenance rule (a)(2) to (a)(1) status.
The licensee captured the inspectors observation in condition reports CR-WF3-2020-01190 and CR-WF3-2019-08187. The licensees immediate corrective action was to perform functional failure evaluations for the identified condition reports. The licensee is planning action to assess the extent of condition for potentially missed functional failure evaluations and to address the weakness in their maintenance rule program. Included in the planned actions is the development of an enhanced maintenance rule database that would explicitly tie each plant component scoped into the maintenance rule to all the applicable system functions and functional failure criteria.
Assessment 92702 Background On July 20, 2018, the U.S. Nuclear Regulatory Commission (NRC) issued a Notice of Violation (NOV) to Entergy Operations, Inc. (Entergy), Waterford Steam Electric Station, Unit 3 (Inspection Report 05000382/2017009 (Agencywide Documents Access and Management System Accession (ADAMS) No. ML18201A492). The Green finding and NOV (EA-18-020)were associated with the failure to establish appropriate design and procedures associated with providing electrical power using the N+1 FLEX diesel generator to support transition phase (Phase 2) strategies. These strategies, required by Post-Fukushima Lessons Learned Order EA-12-049, are intended to maintain or restore the core cooling and spent fuel pool cooling capabilities in mitigating a beyond-design-basis external event.
Entergy (the licensee) provided their initial response to the NOV on August 8, 2018 (ADAMS Accession No. ML18221A639), and provided supplements on September 12, 2018 (ADAMS Accession No. ML18255A321) and May 17, 2019 (ADAMS Accession No. ML19137A341).
Inspection and Assessment The inspectors reviewed the licensees responses to the NOV to confirm the stated corrective actions would be timely and appropriate to address the nature of the violation. Further, the inspectors reviewed the cause evaluation completed by the licensee to address the Green finding and NOV, and determined that the licensee:
- (1) appropriately evaluated the problem, at a level commensurate with the significance of the problem (Level B Adverse Cause Analysis), using a systematic methodology in accordance with licensee procedures;
- (2) appropriately considered the extent of condition;
- (3) appropriately identified the direct cause and causal factors; and
- (4) appropriately established and prioritized corrective action plans to address the direct cause, causal factors, and extent of condition.
The inspectors conducted an onsite inspection of the completed corrective actions the week of January 21, 2020, by way of procedure walk-throughs, reviewing engineering changes and related documentation, and conducting physical walkdowns of new equipment and modifications made to the plant. Specifically, the inspectors reviewed:
- (1) the design change to allow for the staging and operation of the N+1 FLEX diesel generator from within the Nuclear Plant Island Structure (on the Q-Deck);
- (2) revisions to the licensees Technical Requirements Manual relative to the functionality and allowed outage time criteria for the N and N+1 FLEX diesel generators;
- (3) revisions to the FLEX Support Guidelines, Abnormal Procedure for Severe Weather and Flooding, and other work orders necessary to stage and operate the N+1 FLEX diesel generator on the Q-Deck; and
- (4) additional enhancements to licensee organizational and programmatic review processes identified which may have precluded the problem from occurring during the initial design of the FLEX strategies.
The inspectors concluded that the corrective actions were completed in a timely manner, commensurate with the safety significance of the problem, and were appropriate to establish the strategy to utilize the N+1 FLEX diesel generator in response to an extended loss of all AC power for all of the beyond-design-bases external events applicable to Waterford Steam Electric Station, Unit 3. No issues of more than minor safety significance were identified.
Therefore, the inspectors determined that the causes, corrective actions taken to address recurrence, and full compliance NRC Order EA-12-049 has been achieved, such that the violation (VIO 05000382/2017009-01) is adequately addressed and may be closed.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On January 23, 2020, the inspectors presented the N+1 FLEX diesel generator-related NOV follow-up inspection results to M. Lewis, Plant Manager and other members of the licensee staff.
- On February 18, 2020, the inspectors presented the Radiation Safety Exit Meeting inspection results to Mr. S. Vazquez, Site Vice President, and other members of the licensee staff.
- On March 19, 2020, the inspectors presented the Independent Spent Fuel Storage Installation inspection results to Mr. S. Vazquez, Site Vice President, and other members of the licensee staff.
- On March 31, 2020, the inspectors presented the EP exit briefing for Emergency Plan revision in-office inspection results to Mr. J. Overly, Manager, Emergency Preparedness and other members of the licensee staff.
- On April 9, 2020, the inspectors presented the integrated inspection results to Mr. S. Vazquez, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
OP-002-001
Auxiliary Component Cooling Water
315
Procedures
OP-002-004
Chilled Water System
318
Procedures
OP-009-003
Emergency Feedwater
309
Procedures
OP-901-521
Severe Weather and Flooding
334
Procedures
OP-TEM-008
Emergency Diesel Generator A(B) Backup Temporary
Diesel Generator(s)
Procedures
RAB 33-001
Shutdown Cooling Heat Exchanger A and B
Procedures
RAB 34-001
Safeguards Valve Gallery Rooms A and B
Procedures
RAB 8B, E, F-001
Switchgear Room B
71111.11Q Procedures
OP-903-007
Turbine Inlet Valve Cycling Test
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
2019-02889, 2019-00941, 2019-02901, 2019-04868,
2019-06698, 2019-06162, 2019-07024, 2019-08184,
2019-02123, 2019-02067, 2019-02066, 2019-01955,
2019-01955, 2019-02066, 2018-03165, 2018-03164,
20-01225, 2020-01190, 2020-01183, 2020-01178,
20-01175
Drawings
G-166 Sheet 2
Flow Diagram N2, H2, CO2 Systems
Procedures
Procedures
Maintenance Rule Scope and Basis
Procedures
Maintenance Rule Monitoring
Calculations
Vital and Measurement SUPS Upgrade Project
Calculations
Update SUPS EC-43927 with NFPA-805 Requirements
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
20-00756, 2020-01079, 2020-01091, 2020-01092
Miscellaneous
Tagout 2020-0014 EDG B Outage - List of Protected
Equipment
January 27,
20
Procedures
On Line Risk Assessment
Procedures
OI-037-000
Operations Risk Assessment Guideline
314
Procedures
OP-006-005
Inverters and Distribution
339
Procedures
OP-006-005
Inverters and Distribution
340
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
2783599
Calculations
ECM11-003
W3 Decay Heat Removal with Reduced Flow Through the
Shutdown Cooling Heat Exchanger
Calculations
ECM97-069
Design Basis Review for Safety Injection System Valves SI-
29A and SI-129B
Calculations
MNQ6-48
Safety Injection System Split Flow Calculation
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
20-00618, 2018-00628, 2020-00998, 2020-01019
20-01020, 2020-01021, 2020-01042, 2019-06693
20-01391. 2020-01326, 2020-01487, 2020-01495
Procedures
Operability Determination Process
Procedures
MI-003-500
Chlorine Detection system channel functional Test and
Calibration HVCIA5400 A or B
Miscellaneous
Parent EC - Replace/Relocate the Masoneilan 8005N I/P
Transducers with Conoflow GT25CD1826 I/P Transducers
Miscellaneous
Child EC (ACC-126A) - Replace/Relocate the Masoneilan
8005N I/P Transducer with Conoflow GT25CD1826 I/P
Transducer
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
20-01383
Procedures
Conduct of Maintenance
Procedures
Post-Maintenance Testing
Work Orders
541434
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
20-01251, 2020-01256
Miscellaneous
OP-903-063
Chilled Water Pump Operability Verification
311
Procedures
OP-903-030
Safety Injection Pump Operability Verification
Procedures
OP-903-046
Emergency Feedwater Pump Operability Check
23
Procedures
OP-903-121
Safety Systems Quarterly IST Valve Tests
Miscellaneous
CFR 50.54(Q)(3) Screening and Evaluation for Waterford
Emergency Plan Revision 51
2/11/2019
Self-Assessments
WF3 RF21 Post Outage ALARA Report
05/31/2018
Self-Assessments
WF3 RF22 Post Outage ALARA Report
01/14/2020
Corrective Action
Documents
CR-HQN-
2019-2210, 2019-2840, 2020-0037
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
2018-4963, 2018-5061, 2018-5216, 2018-6182,
2019-0054, 2019-1022, 2019-4407, 2019-6179,
2019-7004, 2019-7240, 2019-7522, 2019-7683,
20-0134
Miscellaneous
Dosimeter of Legal Record Expectations
2/10/2020
Miscellaneous
2019
NVLAP Accreditation for 100518-0
2/17/2018
Miscellaneous
20
NVLAP Accreditation for 100518-0
01/01/2020
Miscellaneous
DLR# 190021
DLR/SRD Discrepancy Investigation (CR-WF3-2019-5555)
06/06/2019
Miscellaneous
DLR# 191638
DLR/SRD Discrepancy Investigation (CR-WF3-2019-5555)
06/06/2019
Miscellaneous
DLR# 194028
DLR/SRD Discrepancy Investigation (CR-WF3-2019-5555)
06/06/2019
Miscellaneous
DLR# 194175
DLR/SRD Discrepancy Investigation (CR-WF3-2019-5555)
06/06/2019
Miscellaneous
DLR# 194199
DLR/SRD Discrepancy Investigation (CR-WF3-2019-5555)
06/06/2019
Miscellaneous
Neutron Dose Tracking Form (3 workers)
03/31/2018
Miscellaneous
Neutron Dose Tracking Form (2 workers)
03/31/2018
Miscellaneous
Neutron Dose Tracking Form (4 workers)
04/18/2018
Miscellaneous
Neutron Dose Tracking Form (2 workers)
04/18/2018
Miscellaneous
Neutron Dose Tracking Form (3 workers)
05/02/2018
Miscellaneous
EN-RPT-19-003
Standardization of a Bias Between DLRs and SRDs in the
Entergy Fleet
Update Based on 2018 Results
10/31/2019
Miscellaneous
LWM 2019
Part 61 Waste Stream Analysis for LWM and DAW
01/01/2019
Miscellaneous
NAIPKLCT.NLB
Nal Peak Locate Library
2/11/2020
Miscellaneous
STDNPPNA.NLB
Basic NaI NPP Library
2/11/2020
Miscellaneous
WF3-RPT-16-001
Waterford 3 Containment Neutron Study
06/07/2016
Miscellaneous
WF3-RPT-16-002
Waterford 3 Dry Fuel Storage Neutron Study
06/07/2016
Miscellaneous
WF3-RPT-85-001
Neutron Dose and Energy Spectral Measurements Inside
Reactor Containment at Waterford 3 SES
05/01/1985
Procedures
Air Sampling
Procedures
Radiological Diving
Procedures
Conduct of Radiation Protection
Procedures
Dosimetry Administration
Procedures
Dose Assessment
Procedures
Special Monitoring Requirements
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Prenatal Monitoring
Procedures
Whole Body Counting / In-Vitro Bioassay
Procedures
Electronic Alarming Dosimeters
Self-Assessments LO-WLO-2019-
00041
Self-Assessment: Occupational Dose Assessment
10/07/2019
Self-Assessments QA-14/15-2019-
W3-1
Quality Assurance Audit Report:
Radiation Protection and Radwaste
10/28/2019
71151
Miscellaneous
NRC Performance Indicator (PI) Data - 1st Quarter ROP
Data
04/11/2019
71151
Miscellaneous
NRC Performance Indicator (PI) Data - 3rd Quarter ROP
Data
10/17/2019
71151
Miscellaneous
NRC Performance Indicator (PI) Data - 4th Quarter ROP
2019 Data
01/16/2020
71151
Procedures
NRC Performance Indicator (PI) Data - 2nd Quarter ROP
Data
07/15/2019
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
20-01183, 2020-01190, 2020-01175, 2020-01178,
20-01225, 2019-02901, 2019-02821, 2019-08187
2019-07204, 2019-03069, 2020-00472, 2019-08184,
2019-08185, 2019-02066, 2019-02067, 2019-03144,
2019-03957
Miscellaneous
White Paper: Impacts of External Toxic Gas Event on
Waterford 3 FLEX Mitigating Strategies
01/21/2020
Procedures
Procedures
Maintenance Rule Monitoring
Procedures
Maintenance Rule (A)(1) Process
Procedures
FIG-001
Extended Loss of AC Power
Procedures
STA-001-005
Leakage Testing of Air and Nitrogen Accumulators for
Safety Related Valves
21
2702
Calculations
ECC19-013
FLEX N+1 Diesel Generator Seismic Restraint
000
2702
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
2018-04443
2702
Corrective Action
Documents
CR-WF3-2018-
04443
Adverse Condition Analysis: Failure to implement
appropriate strategy for N+1 FLEX diesel generator
08/07/2018
2702
Corrective Action
CR-WF3-YYYY-
20-00331
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Resulting from
Inspection
NNNN
2702
Drawings
SK-EC80346-CS-
001
10/11/2019
2702
Engineering
Evaluations
FLEX N+1 Diesel Strategy Revision (including P2E
Attachments)
000
2702
Engineering
Evaluations
WF3-ME-15-
00003
Wind-Generated Missile Evaluation of Exposed Piping for
2702
Engineering
Evaluations
WF3-SA-14-
00002
Waterford 3 FLEX Strategy Development
2702
Fire Plans
CT1-001
Pre-Fire Strategy: Dry Cooling Tower A
007
2702
Fire Plans
CT3-001
Pre-Fire Strategy: Wet Cooling Tower A
009
2702
Miscellaneous
EOS Checklists
19-0231, 19-0373, 19-0523 (TRM action statement entries
for N or N+1 FLEX DG non-functional)
05/14/2019,
07/30/2019,
10/12/2019
2702
Procedures
EN-FAP-LI-015
Response to New Regulatory Requirements
2702
Procedures
Technical Task Risk & Rigor
2702
Procedures
FIG-001
Extended Loss of AC Power
007
2702
Procedures
FSG-005
Initial Assessment and FLEX Equipment Staging
011
2702
Procedures
OP-901-521
Off Normal Procedure: Severe Weather and Flooding
333
2702
Procedures
OP-902-005
Emergency Operating Procedure: Station Blackout
Recovery Procedure
2702
Procedures
UNT-007-060
Control of Loose Items
306
2702
Work Orders
00532845
Stage FLEXMDSG0002 and Support Equip to RAB+21 Q-
Deck
60855
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
2016-02536, 2016-05342, 2016-05409, 2019-06119
Miscellaneous
CFR 72.212 Evaluation Report for the Waterford Unit 3
CFR 72.212 Evaluation Report for the Waterford Unit 3
CFR 72.212 Evaluation Report for the Waterford Unit 3
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
DFS-003-002
Transport of Loaded and Unloaded HI-STORM
DFS-003-003
MPC Preparation for Loading
DFS-003-004
Handling and Loading of MPC
DFS-003-005
MPC Backfill and Sealing Operation
DFS-003-006
Stack-Up and Transfer of Loaded MPC
DFS-003-008
Heavy Haul Path Preparation for Cask
DFS-007-003
Radiation Monitoring Requirements for Loading and Storage
HI-STORM
EN-FAP-OU-108
Fuel Handling Process
Corrective Action Program
RF-005-001
Fuel Movement
23
RF-005-004
Transfer of Spent Fuel Assemblies to the Multi-Purpose
Canister
Radiation
Surveys
ISFSI Pad Survey Map
03/02/2020
Self-Assessments O2C-W3-2016-
0533
O2C Report
2/02/2016
QA-20-2018-W3-
Quality Assurance Audit Report
08/15/2017
60857
Engineering
Changes
Revised Seismic Stack-up Analysis
10/31/2016
Procedures
Process Applicability Determination
8.1
Process Applicability Determination Form
09/26/2018
8.1
Process Applicability Determination Form
2/10/2020
CFR 50.59 Evaluations
CFR 72.48 Evaluations
14