IR 05000382/2020002

Integrated Inspection Report 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. Digitally signed by John L. Dixon Dixon Date: 2020.08.03 07:34:59 -05'00'

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: NPF-38 Report Number: 05000382/2020002 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 Enclosure

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 71153 Closed 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 LER 05000382/2019-007-00 LER 2019-007-00 for 71153 Closed Waterford Steam Electric Station, Unit 3 (Waterford 3),

Plant Shutdown Required by Technical Specifications Due to Charging Pump Suction Line Flaw LER 05000382/2019-006-00 LER 2019-006-00 for 71153 Closed 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 LER 05000382/2020-001-00 LER 2020-001-00 for 71153 Closed 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 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.

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:

(1) Fire area RAB 20, component cooling water pump AB on May 29, 2020

(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 Type Designation Description or Title Revision or

Procedure Date

71111.01 Corrective Action CR-WF3-YYYY- 2020-02548, 2020-02576

Documents NNNN

Procedures EN-FAP-EP-010 Severe Weather Response 7

EP-001-001 Recognition & Classification of Emergency Conditions 33

OP-901-521 Severe Weather and Flooding 334

71111.04 Corrective Action CR-WF3-YYYY- 2019-05291, 2019-05576, 2019-03940, 2019-05455,

Documents NNNN 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 44

Work Orders 00539106

71111.05 Procedures EN-TQ-125 Fire Brigade Drills 10

RAB 15-001 Waterford-3 S.E.S Prefire Strategy Elevation +21.00 RAB 8

(RCA) Emergency Diesel Generator 3B

RAB 16-001 Waterford-3 S.E.S Prefire Strategy Elevation +21.00 RAB 11

(RCA) Emergency Diesel Generator 3A

RAB 20-001 Waterford-3 S.E.S Prefire Strategy Elevation +21.00 RAB 8

(RCA) Component Cooling Water Pump AB

RAB 35-001 Waterford-3 S.E.S Prefire Strategy Elevation -35.00 RAB 9

(RCA) Safety Injection Pump Room B

71111.06 Calculations ECM15-004 Waterford 3 FLEX Internal Flooding Calculation 0

MNQ3-5 Flooding Analysis Outside Containment 6

PRA-W3-01-002 W3 Internal Flooding Analysis 3

71111.11Q Procedures OP-002-005 Chemical and Volume Control 65

OP-903-11 Primary Auxiliaries Quarterly IST Valve Tests 52

71111.12 Corrective Action CR-WF3-YYYY- 2020-01660, 2020-01647, 2020-01170, 2020-00706,

Documents NNNN 2020-01109, 2020-00208, 2019-08987, 2019-07668

71111.13 Calculations EC 15550 Implement TS Amendment 218Control Room Habitability 0

Requirement

Inspection Type Designation Description or Title Revision or

Procedure Date

Corrective Action CR-WF3-YYYY- 2020-02188, 2020-02189

Documents NNNN

Miscellaneous W3F1-99-0037 Amendment 149 to Facility Operating License No. NPF038 02/18/1999

Procedures EN-WM-104 On Line Risk Assessment 22

OI-037-000 Operations Risk Assessment Guideline 315

Work Orders 52848173, 52850935

71111.15 Corrective Action CR-WF3-YYYY- 2020-01373, 2020-01844, 2020-01629

Documents NNNN

Procedures EN-OP-104 Operability Determination Process 16

Work Orders 267946, 52733875, 52796990, 52796989, 400265, 390398

71111.18 Corrective Action CR-WF3-YYYY- 2020-00706

Documents NNNN

Miscellaneous PE-WF3- Procurement Engineering Evaluation for DMA Data 1

202297 Acquisition Board replacing the DSP Board

TD-T994.0025 Telosense Air Composition Monitor for Toxic Gas System & 0

Equipment Overview

TD-T994.0045 Service Procedures & Parts for the Telosense Air 1

Composition Monitor for Toxic Gas

71111.19 Corrective Action CR-WF3-YYYY- 2020-01735, 2020-01750, 2020-01536, 2020-01541,

Documents NNNN 2020-01543, 2016-03447, 2020-01546, 2017-00838,

20-2362

Procedures ME-003-410 Motor-Operated Valve Thermal Overload Channel 311

Calibration

ME-007-008 Motor Operated Valves 18

OP-903-050 Component Cooling Water and Auxiliary Component Cooling 42

Water Pump and Valve Operability Test

OP-903-118 Primary Auxiliaries Quarterly IST Valve Tests 51

Work Orders 52842198, 52542199, 00535718, 52850935, 334111,

448459, 52872920, 544953

71111.22 Calculations EC 49551 FLEX Portable Pump Power, Train B 0

EC-M94-016 Component Cooling Water Safety Relief Valve Calculation 1

Corrective Action CR-WF3-YYYY- 2020-01942

Documents NNNN

Inspection Type Designation Description or Title Revision or

Procedure Date

Miscellaneous CEP-IST-1 Inservice Testing Bases Document 316

SEP-WF3-IST-1 WF3 Inservice Testing Bases Document 7

TD-C710.0075 Crosby Valve & Gage Company Instruction Manual 1

Procedures OP-903-118 Primary Auxiliaries Quarterly IST Valve Tests 51

Work Orders 52915654, 52874576, 00543696, 00386148

71151 Miscellaneous W3F1-2019-0053 NRC Performance Indicator (PI) Data - 2nd Quarter ROP 07/15/2019

Data

W3F1-2019-0075 NRC Performance Indicator (PI) Data - 3rd Quarter ROP 10/17/2019

Data

W3F1-2020-0004 NRC Performance Indicator (PI) Data - 4th Quarter 2019 01/16/2020

ROP Data

W3F1-2020-0022 NRC Performance Indicator (PI) Data - QR (Quarterly 04/20/2020

Report) ROP 1st Quarter 2020

Procedures EN-LI-114 Regulatory Performance Indicator Process 17

71152 Corrective Action CR-WF3-YYYY- 2019-05729

Documents NNNN

71153 Corrective Action CR-WF3-YYYY- 2019-04811, 2019-05729, 2019-05704, 2019-05755,

Documents NNNN 2019-05576, 2019-06317, 2016-03344, 2018-02009,

20-1326

Miscellaneous CWTR3-19-87 Westinghouse Review of Waterford 3 Steam Generator 12/31/2019

Narrow Range Water Level Response Following the Loss of

Main Turbine/Generator

13