IR 05000382/2020002
| ML20213C697 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/03/2020 |
| From: | John Dixon NRC/RGN-IV/DRP/RPB-D |
| To: | Vazquez S Entergy Operations |
| References | |
| IR 2020002 | |
| Download: ML20213C697 (16) | |
Text
August 3, 2020
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - INTEGRATED INSPECTION REPORT 05000382/2020002
Dear Mr. Vazquez:
On June 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Waterford Steam Electric Station, Unit 3. On July 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.
No NRC-identified or self-revealing findings were identified during this inspection.
A licensee-identified violation which was determined to be Severity Level IV is documented in this report. 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. 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 No. 05000382 License No. NPF-38
Enclosure:
As stated
Inspection Report
Docket Number:
05000382
License Number:
Report Number:
Enterprise Identifier: I-2020-002-0002
Licensee:
Entergy Operations, Inc.
Facility:
Waterford Steam Electric Station, Unit 3
Location:
Killona, LA 70057
Inspection Dates:
April 1, 2020 to June 30, 2020
Inspectors:
F. Ramirez Munoz, Senior Resident Inspector
C. Speer, Resident Inspector
P. Vossmar, Senior Project Engineer
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. A licensee-identified non-cited violation is documented in report section: 7115
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000382/2019-005-01 LER 2019-005-01 for Waterford Steam Electric Station, Unit 3 (Waterford 3),
Automatic Reactor Scram due to Steam Generator 1 High Level resulting from a Main Turbine Trip and Subsequent Reactor Power Cutback due to Failed Diode Modules with the Main Exciter 71153 Closed LER 05000382/2019-007-00 LER 2019-007-00 for Waterford Steam Electric Station, Unit 3 (Waterford 3),
Plant Shutdown Required by Technical Specifications Due to Charging Pump Suction Line Flaw 71153 Closed LER 05000382/2019-006-00 LER 2019-006-00 for Waterford Steam Electric Station, Unit 3 (Waterford 3),
Unplanned Loss of Both Trains of Broad Range Gas Monitors Results in a Condition that Could Have Prevented Fulfillment of a Safety Function 71153 Closed LER 05000382/2020-001-00 LER 2020-001-00 for Waterford Steam Electric Station, Unit 3 (Waterford 3),
Violation of Technical Specification 3.3.3.7.3.a (Broad Range Gas Detection) Due to Operators 71153 Closed and Maintenance Technicians Not Performing Procedure Step as Intended
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. 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 (COVID19), 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; observed risk-significant activities; and completed on site portions of IPs. 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 some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of hurricane season on May 13, 2020
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) High pressure safety injection train A while train B was out of service for planned maintenance on April 28, 2020
- (2) Emergency feedwater train A while train B was out of service for planned maintenance on May 11, 2020
- (3) Control room heating and ventilation train B while train A was out of service for planned maintenance on June 1, 2020
- (4) Essential chilled water train B while train A was out of service for surveillance testing on June 10, 2020
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of the control room heating and ventilation system on June 10, 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:
- (2) Fire area RAB 35, safety injection pump room B on May 29, 2020
- (3) Fire area RAB 15, emergency diesel generator B on June 26, 2020
- (4) Fire area RAB 16, emergency diesel generator A on June 26, 2020
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire drill in the gas storage tank yard on June 14, 2020.
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the following:
- (1) Flood zone 12, emergency diesel generator A room on June 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 reactivity manipulations and testing of safety-related equipment on June 23, 2020
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated simulator scenarios for operator requalification on June 17, 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 (SSCs) remain capable of performing their intended function:
- (1) Broad range toxic gas monitors on April 7, 2020
- (2) Reactor coolant system on May 5, 2020
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 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) Emergent work on auxiliary component cooling water header A component cooling water heat exchanger outlet temperature control valve following valve controller failure on April 14, 2020
- (2) Planned maintenance on the emergency breathing air system on April 21, 2020
- (3) Planned maintenance on high pressure safety injection system train B on April 28, 2020
- (4) Emergent work on auxiliary component cooling water due to the failure of wet cooling tower fan 5A on May 14, 2020
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Operability determination of essential chiller A due to an out of specification suction temperature reading on April 9, 2020
- (2) Operability determination of auxiliary component cooling water train A due to crediting manual operator actions to operate the component cooling water heat exchanger outlet temperature control valve on April 12, 2020
- (3) Operability determination of dry cooling tower fan 12B and emergency diesel generator B after use of torque wrench with unacceptable calibration on April 22, 2020
- (4) Functionality assessment of FLEX emergency diesel generators due to inappropriate output breaker settings on May 12, 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) Change of control boards for broad range toxic gas monitor B on April 13, 2020
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:
- (1) Auxiliary component cooling water pump A following scheduled maintenance on April 6, 2020
- (2) High pressure safety injection system train B following relay replacements on April 20, 2020
- (3) Auxiliary component cooling water header A component cooling water heat exchanger outlet temperature control valve following transducer replacement on April 23, 2020
- (4) Reactor coolant loop 2 hot leg injection isolation valve following scheduled maintenance on May 5, 2020
- (5) Control room emergency filtration unit outside air intake downstream isolation valve following scheduled maintenance on May 27, 2020
- (6) Main feedwater isolation valve 1 following emergent maintenance on hydraulic accumulator on May 29, 2020
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Component cooling water system train A surveillance test on April 15, 2020
- (2) Shutdown heat exchanger A component cooling water outlet relief valve functional bench test on April 17, 2020
FLEX Testing (IP Section 03.02) (2 Samples)
- (1) N+1 FLEX core cooling pump rotational test on April 29, 2020
- (2) FLEX Core Cooling pump pressure boundary test on May 18,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===
- (1) April 2019 through March 2020
MS06: Emergency AC Power Systems (IP Section 02.05) (1 Sample)
- (1) April 2019 through March 2020
MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)
- (1) April 2019 through March 2020
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Control Element Drive Mechanism Control System Subgroup 10 Multiple Abnormal Coil Voltage Indications on April 24, 2020
71153 - Follow-up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000382/2019-005-01, Automatic Reactor SCRAM due to Steam Generator 1 High Level Resulting from a Main Turbine Trip and Subsequent Reactor Power Cutback due to Failed Diode Modules within the Main Exciter (ADAMS Accession No. ML20099C680). The inspectors reviewed the updated LER submittal. The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER; therefore, no performance deficiency was identified. The inspectors did not identify a violation of NRC requirements. The previous LER submittal was reviewed in Inspection Report 05000382/2019003.
- (2) LER 05000382/2019-007-00, Plant Shutdown Required by Technical Specifications Due to Charging Pump Suction Line Flaw (ADAMS Accession No. ML19269D869).
The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER; therefore, no performance deficiency was identified. The inspectors did not identify a violation of NRC requirements.
- (3) LER 05000382/2019-006-00, Unplanned Loss of Both Trains of Broad Range Gas Monitors Results in a Condition that Could have Prevented Fulfillment of a Safety Function (ADAMS Accession No. ML19235A260). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section 71153.
- (4) LER 05000382/2020-001-00, Violation of Technical Specification 3.3.3.7.3.a (Broad Range Gas Detection) Due to Operators and Maintenance Technicians Not Performing Procedure Step as Intended (ADAMS Accession No. ML20128J906).
The inspection conclusions associated with this LER are documented in this report under Inspection Results Section
INSPECTION RESULTS
Licensee-Identified Non-Cited Violation 71153 This violation of very low safety significance was identified by the licensee and has been entered into the licensees corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: 10 CFR 50.73(a)(2)(v)(D) requires, in part, that the holder of an operating license shall submit a licensee event report within 60 days of discovery of any condition which could prevent the fulfillment of a safety function.
Contrary to the above, the licensee failed to submit a licensee event report within 60 days of April 10, 2018, after discovering that both trains of broad range gas monitors were inoperable while the control room was not in isolate, a condition which could prevent the fulfillment of a safety function. Condition Report CR-WF3-2018-02009 documented the condition, but at the time the licensee inappropriately concluded the condition was not reportable. The licensee discovered this condition during reviews associated with LER 05000382/2019-006-00.
Significance/Severity: Severity Level IV. This violation was considered as traditional enforcement because the failure to notify the NRC had the potential for impacting the NRCs ability to perform its regulatory function. Consistent with the guidance in Section 6.9, paragraph d.9, of the NRC Enforcement Policy, the failure to report the condition which could prevent the fulfillment of a safety function was determined to be a Severity Level IV violation.
Corrective Action References: Condition Report CR-WF3-2019-06317
Minor Violation 71153 Minor Violation: During a review of LER 05000382/2020-001-00, Violation of Technical Specification 3.3.3.7.3.a Due to Operators and Maintenance Technicians Not Performing Procedure Step as Intended, the inspectors identified a minor violation of Technical Specification 3.3.3.7.3.a, Broad Range Gas Detection. Specifically, with broad range gas monitor (BRGM) B out of service for more than 7 days, on March 18, 2020, the licensee failed to maintain the control room ventilation system in the isolate mode of operation. During surveillance testing of chlorine monitor B with the control room isolated due to BRGM B inoperability, the licensee failed to perform procedure steps that would ensure the control room was maintained isolated during the test. As a result, the control room became unisolated for approximately 2 minutes.
Screening: The inspectors determined the performance deficiency was minor because it did not meet any of the Inspection Manual Chapter 0612 more-than-minor screening questions and did not significantly impact the Mitigating Systems Cornerstone in that there were no safety consequences. In particular, the redundant BRGM train maintained the ability to automatically isolate the control room, the technical specification noncompliance existed for 2 minutes, and the procedural error did not result in any unplanned equipment inoperability or unavailability. The licensee generated Condition Report CR-WF3-2020-01326 to address the operation prohibited by Technical Specifications.
Enforcement:
The licensee has taken action to restore compliance. This failure to comply with Technical Specification 3.3.3.7.3.a constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. This minor violation closes LER 05000382/2020-001-00.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On July 9, 2020, the inspectors presented the integrated inspection results to Mr. Sergio Vazquez, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
20-02548, 2020-02576
Procedures
EN-FAP-EP-010
Severe Weather Response
Recognition & Classification of Emergency Conditions
OP-901-521
Severe Weather and Flooding
334
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
2019-05291, 2019-05576, 2019-03940, 2019-05455,
2019-07668, 2019-08705, 2019-08987, 2020-01045,
20-01169, 2020-00208, 2020-00706, 2020-01109,
20-01170, 2020-01194
Procedures
OP-002-004
Chilled Water System
318
OP-003-014
Control Room Heating and Ventilation (HVC)
308
OP-009-003
Emergency Feedwater
309
OP-009-008
Safety Injection System
Work Orders
00539106
Procedures
Fire Brigade Drills
RAB 15-001
Waterford-3 S.E.S Prefire Strategy Elevation +21.00 RAB
(RCA) Emergency Diesel Generator 3B
RAB 16-001
Waterford-3 S.E.S Prefire Strategy Elevation +21.00 RAB
(RCA) Emergency Diesel Generator 3A
RAB 20-001
Waterford-3 S.E.S Prefire Strategy Elevation +21.00 RAB
(RCA) Component Cooling Water Pump AB
RAB 35-001
Waterford-3 S.E.S Prefire Strategy Elevation -35.00 RAB
(RCA) Safety Injection Pump Room B
Calculations
ECM15-004
Waterford 3 FLEX Internal Flooding Calculation
MNQ3-5
Flooding Analysis Outside Containment
PRA-W3-01-002
W3 Internal Flooding Analysis
71111.11Q Procedures
OP-002-005
Chemical and Volume Control
OP-903-11
Primary Auxiliaries Quarterly IST Valve Tests
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
20-01660, 2020-01647, 2020-01170, 2020-00706,
20-01109, 2020-00208, 2019-08987, 2019-07668
Calculations
Implement TS Amendment 218Control Room Habitability
Requirement
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
20-02188, 2020-02189
Miscellaneous
Amendment 149 to Facility Operating License No. NPF038
2/18/1999
Procedures
On Line Risk Assessment
OI-037-000
Operations Risk Assessment Guideline
315
Work Orders
2848173, 52850935
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
20-01373, 2020-01844, 2020-01629
Procedures
Operability Determination Process
Work Orders
267946, 52733875, 52796990, 52796989, 400265, 390398
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
20-00706
Miscellaneous
PE-WF3-
202297
Procurement Engineering Evaluation for DMA Data
Acquisition Board replacing the DSP Board
TD-T994.0025
Telosense Air Composition Monitor for Toxic Gas System &
Equipment Overview
TD-T994.0045
Service Procedures & Parts for the Telosense Air
Composition Monitor for Toxic Gas
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
20-01735, 2020-01750, 2020-01536, 2020-01541,
20-01543, 2016-03447, 2020-01546, 2017-00838,
20-2362
Procedures
ME-003-410
Motor-Operated Valve Thermal Overload Channel
Calibration
311
ME-007-008
Motor Operated Valves
OP-903-050
Component Cooling Water and Auxiliary Component Cooling
Water Pump and Valve Operability Test
OP-903-118
Primary Auxiliaries Quarterly IST Valve Tests
Work Orders
2842198, 52542199, 00535718, 52850935, 334111,
448459, 52872920, 544953
Calculations
FLEX Portable Pump Power, Train B
EC-M94-016
Component Cooling Water Safety Relief Valve Calculation
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
20-01942
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
CEP-IST-1
Inservice Testing Bases Document
316
SEP-WF3-IST-1
WF3 Inservice Testing Bases Document
TD-C710.0075
Crosby Valve & Gage Company Instruction Manual
Procedures
OP-903-118
Primary Auxiliaries Quarterly IST Valve Tests
Work Orders
2915654, 52874576, 00543696, 00386148
71151
Miscellaneous
NRC Performance Indicator (PI) Data - 2nd Quarter ROP
Data
07/15/2019
NRC Performance Indicator (PI) Data - 3rd Quarter ROP
Data
10/17/2019
NRC Performance Indicator (PI) Data - 4th Quarter 2019
ROP Data
01/16/2020
NRC Performance Indicator (PI) Data - QR (Quarterly
Report) ROP 1st Quarter 2020
04/20/2020
Procedures
Regulatory Performance Indicator Process
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
2019-05729
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
2019-04811, 2019-05729, 2019-05704, 2019-05755,
2019-05576, 2019-06317, 2016-03344, 2018-02009,
20-1326
Miscellaneous
CWTR3-19-87
Westinghouse Review of Waterford 3 Steam Generator
Narrow Range Water Level Response Following the Loss of
Main Turbine/Generator
2/31/2019