Text

Design Basis Assurance Inspection (Teams) Inspection Report 05000382/2020012
	ML21033A873
Person / Time
Site:	Waterford
Issue date:	02/02/2021
From:	Vincent Gaddy; Region 4 Engineering Branch 1
To:	Ferrick J; Entergy Operations
	Clark D
References
	IR 2020012
	Download: ML21033A873 (25)
	v • d • e

February 2, 2021

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 - DESIGN BASIS ASSURANCE INSPECTION (TEAMS) INSPECTION REPORT 05000382/2020012

Dear Mr. Ferrick:

On January 8, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Waterford Steam Electric Station, Unit 3. On January 7, 2021, the NRC inspectors discussed the results of this inspection with Mr. Mathew Lewis, General Manager, Plant Operations and other members of your staff. The results of this inspection are documented in the enclosed report.

Three findings of very low safety significance (Green) are documented in this report. All of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations 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, Vincent G. Gaddy, Chief Engineering Branch 1 Division of Reactor Safety

Docket No. 05000382 License No. NPF-38

Enclosure:

As stated

Inspection Report

Docket Number:

05000382

License Number:

NPF-38

Report Number:

05000382/2020012

Enterprise Identifier: I-2020-012-0004

Licensee:

Entergy Operations, Inc.

Facility:

Waterford Steam Electric Station, Unit 3

Location:

Killona, LA.

Inspection Dates:

May 4, 2020 to December 31, 2020

Inspectors:

C. Baron, Mechanical Contractor

W. Cullum, Reactor Inspector

S. Gardner, Electrical Contractor

N. Hernandez, Operations Engineer

R. Kopriva, Senior Reactor Inspector

N. Okonkwo, Reactor Inspector

Approved By:

Vincent G. Gaddy, Chief

Engineering Branch 1

Division of Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (teams) 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 identify the most limiting conditions for the Component Cooling Water System during a Loss of Off-Site Power.

Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000382/2020012-01 Open/Closed

[H.14] -

Conservative Bias 71111.21M The inspectors identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion III,

"Design Control," for the failure of the licensee to identify the most limiting conditions for the Component Cooling Water (CCW) System during a Loss of Off-Site Power

Failure to Implement Comprehensive Testing of Portions of the Component Cooling Water System Surge Tank Isolation Circuits.

Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000382/2020012-02 Open/Closed None (NPP)71111.21M The inspectors identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion XI,

Test Control, for the failure of the licensee to implement periodic testing of portions of the control loops associated with the CCW surge tank isolation circuits.

Failure to Follow Procedures for Extending Preventative Maintenance Activities on Plant Installed Circuit Breakers Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000382/2020012-03 Open/Closed

[H.13] -

Consistent Process 71111.21M The inspectors identified a Green non-cited violation of Technical Specification 6.8.1.a with two examples of the licensee failing to adequately implement its preventive maintenance program for molded case and Magne-Blast circuit breakers. Specifically, the licensee failed to follow Procedure EN-DC-335, Preventive Maintenance (PM) Basis Templates, and ensure that preventative maintenance basis template deviations for molded case and Magne-Blast circuit breakers contained sufficient technical basis documentation and provided a clear and concise justification why preventative maintenance basis template deviations were appropriate.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors 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 Disease (COVID-19), regional inspectors were directed to begin telework. During this time regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. In some cases, portions of an IP were completed remotely and on-site. The inspection documented below was determined that the objectives and requirements stated in the IP could be completed remotely and onsite.

REACTOR SAFETY

===71111.21M - Design Bases Assurance Inspection (Teams)

The inspectors evaluated the following components and listed applicable attributes, permanent modifications, and operating experience:

Design Review - Risk-Significant/Low Design Margin Components (IP Section 02.02) (6 Samples)

From May 4, 2020, to December 31, 2020, the team inspected the following components and listed applicable attributes.

(1) Component Cooling Water Pump A, CC-MPMP -0001A

Design analyses of minimum required pump performance

Design analyses of maximum pump runout flow conditions

Procedures for periodic CCW pump testing

Results of recent comprehensive and quarterly pump tests

Calculations for CCW pump available net positive suction head

Design bases document and piping and instrumentation diagram for CCW system

Vendor manuals for the CCW pump

Corrective action documents to verify the monitoring of potential degradation

Control circuit design and testing for automatic CCW system makeup and isolation

(2) Auxiliary Component Cooling Water Pump A, ACC-MPMP-0001A

Design analyses of minimum required pump performance

Design analyses for ACCW system thermal performance

Procedures for periodic ACCW pump testing

Results of recent comprehensive and quarterly pump tests

Calculations for ACCW pump available net positive suction head

Design bases document and piping and instrumentation diagram for ACCW system

Vendor manuals for the ACCW pump

Corrective action documents to verify the monitoring of potential degradation

(3)125 VDC Bus 3A-DC-S:

Component maintenance history and corrective action program reports to verify the monitoring of potential degradation.

Load Study and Short Circuit Calculation to determine adequacy of design.

Procedures for circuit breaker inspection and testing to compare maintenance practices against industry and vendor guidance.

(4) CCW Control Loop/ Thermocouple, TE-CC7075A

Procedures for testing Loop channels and calibration of temperature components.

Uncertainty Calculation to determine adequacy of design.

Vendor documents for temperature sensor and signal processing.

Component maintenance history

(5) Dry Cooling Tower Fans "A".

Design Drawings for the Dry Cooling tower fans and fan motor

Fan Controls Schematic and wiring Diagrams for review of Fan Designs and Specifications

Fan Switchgear and Motor Control Center drawings for the fan motor controls and Protection and properly specified and controlled

Corrective Reports associated with fan and Motor to ensure fan failures are identified and resolved appropriately

Fan and fan motor preventive maintenance procedures and work orders to ensure Fan and fan motors are maintained to assure operability for their safety functions

Fan and fan motor Protective settings and control for the Fan and Motor to assure design and control setting criteria.

Calculation for the fan and motor sizing to assure design requirements are maintained

Engineering Changes and Modifications of fan and fan motor to assure design and design specification are maintained.

(6) Simulator Activities

Simulator Scenario 1:

The scenario was designed to place the crew in a moderate energy line break that impacted the RCS level. The simulation began in Mode 5 with both trains of shutdown cooling (SDC) in service. The scenario's first event was a SDC loop 2 suction isolation valve failing closed. Then a loss of component cooling water (CCW - inspection component) to the B train SDC heat exchanger occurred. The break was initiated in the A train of SDC, inside of containment.

The location of the break required the crew to take action within 20 minutes per OP-901-131, Shutdown Cooling Malfunction, to prevent draining the RCS below the top of the hot leg (time critical action number 33, SDC Moderate Energy Line Break).

Simulator Scenario 2:

The scenario was designed to place the crew in one of the licensee's top 50 cutsets and to validate two-time critical operator actions. The scenario began with the reactor in Mode 1. Component Cooling Water (inspection component) Pump B tripped due to an overcurrent condition, followed by the RCP Inlet Outside Isolation valve failing closed, and finally a loss of off-site power followed by the B Emergency Diesel Generator overspeed trip.

On the first event, the crew was required to diagnose the loss of the B CCW pump, enter OP-901-510, Component Cooling Water System Malfunctions, and align the AB CCW pump to replace the B CCW pump.

The second event required the crew to recognize the loss of CCW seal cooling to the RCPs, trip the reactor and secure all RCPs within 3 minutes (time critical action number 3, Loss of CCW to RCPs).

On event number three, due to the loss of off-site power (LOOP) and EDG B overspeed trip only CCW pump A was available requiring the crew to isolate one running train of CCW from the other train in accordance with Appendix 35 of OP-902-009, Single CCW Pump Operation within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (time critical action number 35).

In-Plant Job Performance Measures:

Four job performance measures (JPMs) were conducted to evaluate field procedures and operations department training effectiveness.

The first JPM evaluated the operator's response to a loss of refueling water storage pool (RWSP) volume via the RWSP purification system. This required the operator to isolate the RWSP from the RWSP purification piping (time critical action number 19).

The second JPM evaluated the operator's response to a condensate storage pool (CSP) lo-lo level. This required the operator to refill the CSP from the Waste Collection Tank Basin within 30 minutes (time critical action number 14).

The third JPM evaluated the operator's response to a LOOP with a failure of the only operable emergency diesel generator (station blackout). This required the operator to start and align the temporary emergency diesel generator (time critical action number 17).

The fourth JPM evaluated the operator's response to internal flooding caused by a medium energy line break. This required the operator to locate the source and secure or isolate the source of flooding (time critical action number 27).

Design Review - Large Early Release Frequency (LERFs) (IP Section 02.02)===

Main article: IP 71111.21

(1) Low Pressure Safety Injection Pump A

Results of recently performed surveillance tests

Review of design requirements based on pump curves

Procedures for testing

Vendor manual requirements

Periodicity of maintenance tasks

Review of corrective action documentation

Modification Review - Permanent Mods (IP Section 02.03) (6 Samples)

(1) EC 46747 New EGF Fuel Oil Storage Tanks (FOST) - Reviewed functional design, tank capacity, protection from external events, design codes, inspections, capability to contain oil spills, provisions to fill tanks, and provisions to vent tanks.

(2) EC 52043 - Ultimate Heat Sink (UHS) Margin Restoration - Cooling Tower Recirculation Reduction

Due to the large volume of information associated with this modification, the review mostly focused on the cooling tower recirculation reduction and the Ultimate Heat Sink Calculation ECM 95-008.

(3) EC 54160 -- Wet Cooling Tower Fan Covers Fabrication and Placement - UHS Margin Restoration Project.

(4) EC 60655 - CED MEG at Underfrequency Replacement Relays

(5) EC 62411 - Emergency Diesel Generator Starting Air Circuit Reconfiguration.

(6) EC 46635 - Dry Cooling Tower "STS" Relay Wiring Modifications

Review of Operating Experience Issues (IP Section 02.06) (2 Samples)

(1) CR-PLP-2016-04256. AFI PRP.1 Radiation protection personnel, in a few instances, do not effectively monitor or communicate radiological hazards. This has resulted in an uncontrolled high radiation area, incorrect internal dose monitoring.

(2) CR-ANO-C-2014-01795 and CR-ANO-C-2014-00597. Green NCV for Failure to Follow Procedures Related to Review of Indications that Could Affect the Structural Integrity of the Unit 2 Reactor Building.

INSPECTION RESULTS

Failure to identify the most limiting conditions for the Component Cooling Water System during a Loss of Off-Site Power.

Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000382/2020012-01 Open/Closed

[H.14] -

Conservative Bias 71111.21M The inspectors identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion III, "Design Control," for the failure of the licensee to identify the most limiting conditions for the Component Cooling Water (CCW) System during a Loss of Off-Site Power

Description:

On May 22, 2020, the inspectors determined that the licensee failed to adequately evaluate the most limiting runout conditions for the component cooling water system. The inspectors reviewed Calculation MNQ9-2, Component Cooling Water System, Revision 2, as amended by engineering change EC-52043, which evaluated normal plant operation followed by a trip of one running component cooling water pump such that the one pump would supply both safety related trains and the non-essential header. The calculation did not consider the more limiting case of a LOOP with the failure of one component cooling water pump, which would cause additional flow demand due to both emergency diesel generators (EDGs) being in operation for some period of time.

In response to this issue, the licensee issued CR-WF3-2020-2178 and performed an operability determination, engineering change EC 86935, and concluded that there were no immediate safety concerns. Engineering change EC 86935 evaluated the capacity of the component cooling water pump motor to start and operate under runout conditions, determining bounding motor heat loads, and evaluating potential pump cavitation. In addition, engineering change EC 86935 evaluated the capability of the emergency diesel generators to operate with reduced component cooling water flow for some period of time. The engineering change concluded that the operator action to split the component cooling water trains or start the standby component cooling water pump (if available) is required to be completed within 58 minutes. The time critical operator action for this activity, TCA-35, require this action to be completed within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , however, validation demonstrated that it could be completed in 9 minutes. The licensee issued a standing order on May 19, 2020 to direct the operators to act within 30 minutes following a loss of off-site power with a failure of one component cooling water pump. The inspectors reviewed the operability determination and determined that the component cooling water and emergency diesel generator systems remained operable.

Corrective Actions: After discovery of the issue, the licensee performed an operability determination because there was no analysis available to ensure the operability of the component cooling water system and emergency diesel generators. The licensee also issued a standing order on May 19, 2020 to direct the operators to act within 30 minutes following a loss of off-site power with a failure of one component cooling water pump.

Corrective Action References: CR-WF3-2020-2178

Performance Assessment:

Performance Deficiency: The inspectors determined that the failure to identify and analyze the most limiting conditions for the component cooling water system during a loss of off-site power was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Design 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, similar to example 3.a in Manual Chapter 0612, Appendix E, "Example of Minor Issues," regardless of the final operability or functionality, the calculation errors were significant such that there was reasonable doubt with respect to the runout condition of a CCW pump resulting from a loss of off-site power and a single component failure to affect the assurance of availability and reliability. For example, to ensure qualification, the licensee had to revise the calculation or had to revise or rework the modification to correctly resolve the postulated event concerns. In addition, the event substantially reduced the time required to establish additional cooling to the diesel generators.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, Mitigating Systems Screening Questions, of Inspection Manual Chapter (IMC) 0609, issued January 1, 2021, the inspectors determined this finding is not a deficiency affecting the design or qualification of a mitigating structure, system, or component; the finding does not represent a loss of function of a Technical Specification train, system, or two separate Technical Specification systems for greater than their Technical Specification allowed outage time; the finding does not represent a loss of system and/or function for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; and the finding does not represent an actual loss of function of one or more non-Technical Specification trains of equipment designated as risk-significant in accordance with the licensees maintenance rule program. Therefore, the inspectors determined the finding was of very low safety significance (Green).

Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision making-practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop. Specifically, individuals failed to identify and analyze the most limiting conditions for the component cooling water system during a loss of off-site power [H.14]

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion III, "Design Control," states, "Measures shall be established to assure that applicable regulatory requirements and the design basis, for those structures, systems, and components to which this appendix applies, are correctly translated into specifications, drawings, procedures, and instructions." Contrary to the above, since February 15, 2018 the licensee failed to assure that applicable regulatory requirements and the design basis for the component cooling water system was correctly translated into procedures. Specifically, the licensee failed to identify and analyze the most limiting conditions for the component cooling water system during a loss of off-site power. As a result, the time required to establish additional cooling to the diesel generators by splitting the component cooling water trains or starting the standby component cooling water pump (if available) was substantially reduced.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Implement Comprehensive Testing of Portions of the Component Cooling Water System Surge Tank Isolation Circuits.

Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000382/2020012-02 Open/Closed

None (NPP)71111.21M The inspectors identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion XI, Test Control, for the failure of the licensee to implement periodic testing of portions of the control loops associated with the component cooling water (CCW) surge tank isolation circuits.

Description:

On May 20, 2020, the inspectors determined that the licensee failed to implement periodic testing of portions of the control loops associated with the component cooling water surge tank isolation circuits. During a review of the component cooling water system design, the inspectors noted that the component cooling water system design included provisions to automatically split the two safety related headers and to isolate the non-safety related portions of the system upon reduced level in the component cooling water surge tank. This design feature was required to preserve the component cooling water inventory of at least one safety related train to support safe shutdown in the event of leakage from the component cooling water system. The design included level switches on the surge tank and associated relays to close the component cooling water system isolation valves. The inspectors determined that the A train component cooling water surge tank level switch was being periodically tested, but the associated LSX relay (CC EREL701) was not being periodically verified. The redundant B train LSX relay (CC EREL702) was also found not being periodically verified.

The inspectors noted that Final Safety Analysis Report (FSAR) section 7.1.1.3 stated that Engineered Safety Features (ESF) support systems, including the component cooling water system, were designed to the same criteria as those for the safety related systems that they support. FSAR section 7.1.2.5 addressed conformance with IEEE Standard 338-1971 and stated that engineered safety features systems are periodically tested in accordance with the criteria described in the standard. In addition, NRC Information Notice 95-15, Inadequate Logic Testing of Safety-Related Circuits, addressed overlap testing of safety related circuits to ensure that no part of the logic is overlooked.

In response to this issue, the licensee issued CR-WF3-2020-02316 and performed an operability determination, engineering change EC-87009, and concluded that there were no immediate safety concerns. Engineering change EC 87009 evaluated the safety function of this control circuit and the potential failure modes associated with the relays and determined that the components were non-conforming but had a reasonable expectation of operability. The inspectors reviewed the operability determination and determined that the component cooling water system remained operable.

Corrective Actions: After discovery of the issue, the licensee performed an operability determination to address the failure to implement periodic testing of portions of the control loops associated with the component cooling water surge tank isolation circuits.

Corrective Action References: CR-WF3-2020-02316

Performance Assessment:

Performance Deficiency: The inspectors determined that the failure to implement periodic testing of portions of the control loops associated with the component cooling water (CCW)surge tank isolation circuits was a performance deficiency

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance 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, the licensee failed to implement periodic testing of portions of the control loops associated with the component cooling water surge tank isolation circuits particularly the LSX relay (CC EREL701), associated with the component cooling water surge tank level switch. The failure to periodically test LSX relay (CC EREL701)associated with both the A and B train component cooling water surge tank level switches, did not ensure the availability and reliability of the component cooling water systems to respond to initiating events so as to prevent undesirable consequences.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, Mitigating Systems Screening Questions, of Inspection Manual Chapter (IMC) 0609, issued January 1, 2021, the inspectors determined this finding is not a deficiency affecting the design or qualification of a mitigating structure, system, or component; the finding does not represent a loss of function of a Technical Specification train, system, or two separate Technical Specification systems for greater than their Technical Specification allowed outage time; the finding does not represent a loss of system and/or function for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; and the finding does not represent an actual loss of function of one or more non-Technical Specification trains of equipment designated as risk-significant in accordance with the licensees maintenance rule program. Therefore, the inspectors determined the finding was of very low safety significance (Green).

Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion XI, Test Control, states, in part, A test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Contrary to the above, from initial operation of the plant until May 20, 2020, the licensee failed to assure that all testing required to demonstrate that the structures, systems, and components would perform satisfactorily were identified and performed. The licensee failed to implement periodic testing of portions of the control loops associated with the component cooling water surge tank isolation circuits. Specifically, the LSX relay (CC EREL701), associated with the component cooling water surge tank level switch, was not being periodically tested. The redundant B train LSX relay (CC EREL702) was also found not being periodically verified.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Follow Procedures for Extending Preventative Maintenance Activities on Plant Installed Circuit Breakers Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000382/2020012-03 Open/Closed

[H.13] -

Consistent Process 71111.21M The inspectors identified a Green non-cited violation of Technical Specification 6.8.1.a with two examples of the licensee failing to adequately implement its preventive maintenance program for molded case and Magne-Blast circuit breakers. Specifically, the licensee failed to follow Procedure EN-DC-335, PM Basis Templates, and ensure that preventative maintenance basis template deviations for 480 VAC molded case and 4160 VAC Magne-Blast circuit breakers contained sufficient technical basis documentation and provided a clear and concise justification why preventative maintenance basis template deviations were appropriate.

Description:

Example 1:

On May 22, 2020, during the Design Basis Assurance Inspection (Teams) the inspectors identified a concern related to the licensees functional test program for safety related, Class 1E molded case circuit breakers (MCCB). The Waterford Updated Final Safety Analysis Report, Subsection 8.3.2.2., states, The 125 V dc electric system is designed to meet the requirements of IEEE-279-1971, IEEE-308-1971, General Design Criteria 17 and 18, and Regulatory Guides 1.6 and 1.32. The team determined that the Regulatory Guide 1.32 and IEEE 308-1974, Standard Criteria for Class 1E Power Systems at Nuclear Generating Station, specified that Class 1E molded case circuit breakers be periodically tested to determine the on-going acceptability as a protective device and verify their ability to perform their safety function. To determine this, the inspectors noted that IEEE 308-1971, Section 5.3 Direct-Current Systems, subsection 5.3.2, Distribution System, Paragraph 4, Surveillance, stated, the distribution system shall be monitored to the extent that is shown to be ready to perform its intended function. Section 6, Surveillance Requirements, Subsection 6.3, Periodic Equipment Tests, stated, in part, tests shall be performed at scheduled intervals to:

(1) Detect the deterioration of the system toward unacceptable condition.

(2) Demonstrate that standby power equipment and other components that are not exercised during normal operation of the station are operable.

During the review of the licensees testing program for Class 1E molded-case circuit breakers, the inspectors determined that the licensees program did not ensure the reliability of the installed breakers because the program did not adhere to the Entergy Fleet Preventative Maintenance (PM) Basis for Molded Case Breakers preventative maintenance interval, PM Basis Template EN - Breaker - Molded Case Circuit requires that Molded Circuit Breaker. Licensee procedure EN-DC-335, PM Basis Template, identifies the current Entergy Fleet preventative maintenance interval for MCCBs as 10 years, which is required to be reviewed annually to ensure consistency with industry standards and best preventative maintenance practices. However, EN-DC-335, Section 5.2.6.1 Template Deviations, states, Fleet and Site Specific Preventative Maintenance Basis Templates can deviate from established EPRI or industry standard preventive maintenance recommendations provided the technical bases for the differences are documented within the preventative maintenance template and all requirements of the applicable Review, Approval, and Revision section of the procedure were satisfied. Further, subsection 5.2.6.4 states PM Basis Template deviations must contain sufficient technical basis documentation, providing a clear and concise justification why the PM Basis Template deviation is appropriate".

The inspectors determined that Waterford had extended their preventative maintenance interval to 20 years for Westinghouse HKD3225 molded case circuit breakers, 17 or 15 years for the remaining Westinghouse HFD molded case circuit breakers. The extensions did not provide sufficient preventative maintenance surveillances to identify deterioration and ensure that overcurrent faults would be cleared at the lowest level of distribution. These extensions were implemented without documented technical justification. Evidence was provided that a justification may have been completed in 2008, but no justification supporting current preventative maintenance practices was documented within the preventative maintenance template as required by procedure EN-DC-335, Section 5.2.6[1]. Additionally, this schedule is not being rigorously adhered to. Currently 10 of 19 breakers in the 3A panel are beyond their 15-year test interval. Consequently, the licensee's molded case circuit breaker test program is ineffective in monitoring deterioration.

Example 2:

During the Problem Identification and Resolution Inspection, the inspectors noted that on July 14, 2020, during the performance of OP-903-094, Engineered Safety Feature Actuation Signal Subgroup Relay Test - Operating, the train A essential feedwater (EFW) pump failed to start when the Magne-Blast breaker failed to close. Subsequently, on October 14, 2020, during performance of OP-903-029, Safety Injection Actuation Signal Test, the train B high pressure safety injection (HPSI) pump failed to start when the Magne-Blast breaker failed to close. The high pressure safety injection breaker was removed from its cubicle on October 18, 2020, for further inspection and overhaul under Work Order 552454. The inspectors reviewed Work Order 552454, Condition Report (CR)-WF3-2020-06110, and CR-WF3-2020-5982, which documented the high pressure safety injection breaker worn parts that were identified and removed during the breaker overhaul.

The inspectors noted that during the performance of Work Order 552454-11 the licensee identified several parts that showed signs of wear; the licensee wrote CR-WF3-2020-06110 to document these conditions. The licensee subsequently removed and replaced the following components: the auxiliary switch; arching contact braids; the inner and outer latch pawl; the close latch bearing; the stationary contact; the closing latch return spring; the closing spring assembly; the charging motor; the closing spring; and the strike plate weld. Additionally, the inspector noted that the HPSI breaker had not been overhauled since 2001.

The inspectors noted that Procedure EN-DC-335, PM Basis Templates, which is applicable to all Entergy stations, defines the requirements for the development, approval, and revision of preventative maintenance basis templates for critical equipment types at Entergy Nuclear sites. The inspectors noted that the failed high pressure safety injection breaker had exceeded or deviated from the licensee PM Bases Template, Entergy Nuclear - Switchgear

- Medium Voltage - 1kV to 7 kV, overhaul frequency of 12 years without sufficient technical basis documentation or a clear and concise justification of why the Preventative Maintenance Basis Template deviation was appropriate. Specifically, Procedure EN-DC-335, Revision 8, Step 5.2.6[4], requires, in part, that preventative maintenance basis template deviations must contain sufficient technical basis documentation and provide a clear and concise justification why the preventative maintenance basis template deviation is appropriate. Although the licensee had issued Report ER W3 1998 1015, Magne-Blast Circuit Breaker Overhaul Recommendations, on August 25, 1998, the licensee failed to reconcile, revise, and evaluate it for the Preventative Maintenance Optimization System deviation during periodic reviews, which are required annually.

The inspectors identified nine additional breakers that exceeded the 12-year overhaul frequency without appropriate justification. These breakers include the following: switchgear 3A bus tie to switchgear 3AB (4KVEBKR3A-1); switchgear bus 3A tie to 2A (4KVEBKR3B-11); train A containment spray pump (CS EBKR3A-6); train A and B safety injection pump (SI EBKR3A-5 and SI EBKR3B-4, respectively); train A HPSI (SI EBKR3A-5); train B component cooling water pump B (CC EBKR3B-8); and train A and AB essential chiller (RFREBKR3A-9 and RFREBKR3AB-5, respectively).

Corrective Actions: In response to this issue, the licensee determined that the molded case circuit breakers and Magne-Blast circuit breakers will remain operable while implementing corrective actions to ensure appropriate testing intervals are technically justified to meet IEEE 308-1971.

Corrective Action References: Condition Reports CR-WF3-2020-02649, CR-WF3-2020-02945, CR-WF3-2020-06462, CR-WF3-2020-07067, and CR-WF3-2020-07178.

Performance Assessment:

Performance Deficiency: The licensees failure to appropriately implement its preventive maintenance program for molded case and Magne-Blast circuit breakers was a performance deficiency. Specifically, the licensee failed to ensure that molded case and Magne-Blast circuit breaker overhaul frequencies were appropriately evaluated and the licensee failed to follow Procedure EN-DC-335, PM Basis Template, Revision 8, Step 5.2.6[4], which requires, in part, that preventative maintenance basis template deviations must contain sufficient technical basis documentation, providing a clear and concise justification why the preventative maintenance basis template deviation is appropriate.

Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, continued failure to analyze deviations from the Preventative Maintenance Optimization System template overhaul frequencies for safety-related breakers could lead to a failure to identify a necessary safety breaker overhaul preventive maintenance changes, in-service component deterioration, and resultant failure to perform their safety-related functions. This issue is also similar to IMC 0612, Appendix E, Example 13.a, which provides examples of issue significance.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, Mitigating Systems Screening Questions, of Inspection Manual Chapter (IMC) 0609, issued January 1, 2021, the inspectors determined this finding is not a deficiency affecting the design or qualification of a mitigating SSC; the finding does not represent a loss of function of a Technical Specification train, system, or two separate Technical Specification systems for greater than their Technical Specification allowed outage time; the finding does not represent a loss of system and/or function for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; and the finding does not represent an actual loss of function of one or more non-Technical Specification trains of equipment designated as risk-significant in accordance with the licensees maintenance rule program. Therefore, the inspectors determined the finding was of very low safety significance (Green).

Cross-Cutting Aspect: H.13 - Consistent Process: Individuals use a consistent, systematic approach to make decisions. Risk insights are incorporated as appropriate. Specifically, individuals did not demonstrate an understanding of the decision-making process and use it consistently, which resulted in the inadequate reviews [H.13].

Enforcement:

Violation: Waterford Steam Electric Station, Unit 3, Technical Specifications, Section 6.8.1, requires, in part, that procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision

2. Section 9.a of Appendix A to Regulatory Guide 1.33, Revision 2, requires, in part, that

maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. The licensee established Procedure EN-DC-335, PM Basis Template, Revision 8, in part, to meet Regulatory Guide 1.33 requirements. Step 5.2.6[4] of Procedure EN-DC-335 requires, in part, that preventative maintenance basis template deviations must contain sufficient technical basis documentation and provide a clear and concise justification why the preventative maintenance basis template deviation is appropriate. Contrary to the above, from 2006 until present, deviations from the requirements of the preventative maintenance basis templates were made without sufficient technical basis documentation and failed to provide a clear and concise justification why the preventative maintenance basis template deviations were appropriate. Specifically, the inspectors identified ten Magne-Blast circuit breakers exceeding the 12-year Preventative Maintenance Optimization System overhaul frequency without appropriate justification and ten molded case circuit breakers that had exceeded their Preventative Maintenance Optimization System preventative maintenance frequencies.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On January 7, 2021, the inspectors presented the design basis assurance inspection (teams) inspection results to Mr. Mathew Lewis, General Manager, Plant Operations and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.21M Calculations

CN-SCC-16-007

Waterford-3 Long-Term Containment Mass and Energy

Releases for Ultimate Heat Sink Evaluation

71111.21M Calculations

EC-E89-008

Electrical Design Criteria

71111.21M Calculations

EC-E91-055

AC Short Circuit Calculations

71111.21M Calculations

EC-E91-056

Relay Settings and Coordination Curves for 6.9kV 4.16kV

and 480 buses

71111.21M Calculations

ECE91-056

Relay Setting and Coordination Curves for 6.9KV 4.16KV

and 480 Buses

71111.21M Calculations

ECE91-193

Load Study for PDP 3A-DC-S and 3A1-DC-S

71111.21M Calculations

ECE91-250

Short Circuit Study for PDP 3A-DC-S and 3A-DC-S

71111.21M Calculations

ECE91-500

Degraded Voltage Impact on AC Starter/Contactors and

Auxiliary Devices

71111.21M Calculations

ECM07-002

Design Basis Requirements for Wet Cooling Tower Basin

Replenishment System

71111.21M Calculations

ECM95-008

Ultimate Heat Sink Design Basis Calculation

71111.21M Calculations

ECM97-022

Makeup Capacity to WCT Basins

71111.21M Calculations

ECS05-013

Ultimate Heat Sink Containment Heat Loads

71111.21M Corrective Action

Documents

Condition Reports CR-WF3-2020-01373, CR-WF3-2019-04959, CR-WF3-

2012-05680, CR-WF3-2012-06043, CR-WF3-2014-03932,

CR-WF3-2015-04459, CR-WF3-PEIR-61275, CR-WF3-

2017-02128, CR-WF3-2017-02129, CR-WF3-2017-08801,

CR-WF3-2018-04820, CR-WF3-2020-00623, CR-WF3-2019-

07055

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.21M Corrective Action

Documents

CR-PLP-2016-

256

71111.21M Corrective Action

Documents

Resulting from

Inspection

Condition Reports CR-WF3-2020-02086, CR-HQN-2020-01028, CR-WF3-

v t e Inspection Report - Waterford - 2020012
80 \| 81 \| 82 \| 83 \| 84 \| 85 \| 86 \| 87 \| 88 \| 89 \| 90 \| 91 \| 92 \| 93 \| 94 \| 95 \| 96 \| 97 \| 98 \| 99 00 \| 01 \| 02 \| 03 \| 04 \| 05 \| 06 \| 07 \| 08 \| 09 \| 10 \| 11 \| 12 \| 13 \| 14 \| 15 \| 16 \| 17 \| 18 \| 19 \| 20 \| 21 \| 22 \| 23 \| 24 \| 25 \|
2020 Quarterly Integrated 1Q (0) 2Q (0) 3Q (0) 4Q (0) Assessments Mid Cycle End of Cycle 10(0) 8(0) 10(0) 12(0) Security 410(0) 411(0) Operator Exams 301(0) Emergency Planning Other

IR 05000382/2020012

Text

SUBJECT:

Dear Mr. Ferrick:

Enclosure:

Inspection Report

SUMMARY

List of Findings and Violations

Additional Tracking Items

INSPECTION SCOPES

REACTOR SAFETY

Modification Review - Permanent Mods (IP Section 02.03) (6 Samples)

Review of Operating Experience Issues (IP Section 02.06) (2 Samples)

INSPECTION RESULTS

Description:

Performance Assessment:

Enforcement:

Description:

Performance Assessment:

Enforcement:

Description:

Performance Assessment:

Enforcement:

2. Section 9.a of Appendix A to Regulatory Guide 1.33, Revision 2, requires, in part, that

EXIT MEETINGS AND DEBRIEFS

DOCUMENTS REVIEWED

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