IR 05000382/2021001
| ML21124A277 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 05/10/2021 |
| From: | John Dixon NRC/RGN-IV/DRP/RPB-D |
| To: | Ferrick J Entergy Operations |
| References | |
| IR 2021001 | |
| Download: ML21124A277 (22) | |
Text
May 10, 2021
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - INTEGRATED INSPECTION REPORT 05000382/2021001
Dear Mr. Ferrick:
On March 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Waterford Steam Electric Station, Unit 3. On April 15, 2021, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
A licensee-identified violation which was determined to be of very low safety significance 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 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, John L. Digitally signed by John L. Dixon Dixon Date: 2021.05.10 09:26:36 -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: 05000382/2021001 Enterprise Identifier: I-2021-001-0089 Licensee: Entergy Operations, Inc.
Facility: Waterford Steam Electric Station, Unit 3 Location: Killona, LA 70057 Inspection Dates: January 1, 2021 to March 31, 2021 Inspectors: B. Baca, Health Physicist D. Childs, Resident Inspector N. Greene, Senior Health Physicist J. O'Donnell, Senior Health Physicist A. Patz, Senior Resident Inspector E. Simpson, Health Physicist 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
Failure to Follow Procedures with an Improper Entry into a High Radiation Area Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.11] - 71124.01 Radiation Safety NCV 05000382/2021001-01 Challenge the Open/Closed Unknown The inspectors reviewed a self-revealed Green finding and associated non-cited violation of Waterford-3 Technical Specification 6.8.1.a for a workers failure to follow procedures resulting in an improper entry into a high radiation area. Specifically, on October 13, 2020, a worker received a dose rate alarm on a self-reading dosimeter after entering a high radiation area when the worker had not been briefed by radiation protection personnel prior to entering the area.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000382/2020-002-00 Operation or Condition 71153 Closed Prohibited by Technical Specifications for Technical Specification 3.4.5.1 (Reactor Coolant System Leakage Detection Instrumentation) due to Personnel Error
PLANT STATUS
Waterford, Unit 3, began the inspection period at full power. On March 30, 2021, the licensee moved reactor power to approximately 87 percent to isolate a leak in the low pressure feedwater heater string. On March 31, 2021, the licensee began down power of the unit to hot shutdown to repair the leak in feedwater heater 6B. This down power was still in progress at the end of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors 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 2019 (COVID-19),resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week; conducted plant status activities as described in IMC 2515, Appendix D, Plant Status; 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
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Component cooling water (CCW) pumps A and AB while CCW pump B was out of service for planned maintenance on January 20, 2021
- (2) Instrument air system following failure of instrument air compressor B on February 25, 2021
- (3) Emergency diesel generator (EDG) A, EDG B, and startup transformer (SUT) A while SUT B was out of service for planned maintenance on March 19, 2021
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (3 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 31-001, volume control tank room on February 22, 2021
- (3) Fire area NS-YD-003, transformer yard on March 19, 2021
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 de-energization and energization of SUT A on March 2, 2021 and SUT B on March 19, 2021.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated a training drill that involved a medium-break loss-of-coolant accident on March 3, 2021.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Planned high risk for multiple safety system outages for Train A CCW, emergency feedwater (EFW), and high-pressure safety injection (HPSI) systems from January 11-15, 2021
- (2) Planned yellow risk for SUT A outage from March 1-4, 2021
- (3) Emergent high risk for down power to repair feedwater heater 6B from March 30-31, 2021
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (2 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Operability determination of EDG B following manual shutdown in response to annunciators indicating bearing damage on January 25, 2021
- (2) Operability determination of the core protection calculators with reactor coolant pump 2B differential pressure indication degraded on February 12, 2021
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) Component cooling water pump B following planned maintenance on January 20, 2021
- (2) Component cooling water train A following planned maintenance on the associated pumps suction cross-connect valves on February 10, 2021
- (3) Essential feedwater train A injection isolation valves following failure of pressure sensor for nitrogen backup on February 18, 2021
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Instrument air accumulator test for dry cooling tower A bypass and isolation valves on
February 4, 2021 Inservice Testing (IP Section 03.01) (2 Samples)
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
The inspectors evaluated instructions to workers including radiation work permits used to access high radiation areas.
- (1) The inspectors reviewed the following:
Radiation Work Permits (RWP)
- RWP 2020-0606, "Refuel 23 - Reassembly of Reactor Head and Associated Walkdowns, and inspections inside Reactor Containment Building, No work on Contaminated Valves, Reactor Coolant Pump Motors/Pumps, or the Reactor Head," Revision 0.
- RWP 2020-0706, "Refuel 23 - Reassembly of Reactor Head and Associated Work Activities including Staging/Destaging of Equipment," Revision 0.
- RWP 2021-0101, "Work activities in the Spent Fuel Pool and the Transfer Canal," Revision 0.
- RWP 2021-0001, "Radiation Protection to Perform Job Coverage, Routine Surveys, Inspections and Walkdowns," Revision 0 Electronic Alarming Dosimeter Alarms
- CR-WF3-20-2665 for a self-reading dosimeter dose rate alarm in a high radiation area at the north letdown valve gallery of -4 foot elevation reactor auxiliary building
- CR-WF3-20-2673 for a self-reading dosimeter dose rate alarm outside a posted high radiation area at the north letdown valve gallery of -4 foot elevation reactor auxiliary building
- CR-WF3-20-5569 for a self-reading dosimeter dose rate alarm in a high radiation area at the reactor coolant pump 1A pedestal of -11 foot elevation reactor containment building
Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)
The inspectors evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
- (1) The inspectors verified the following sealed sources are accounted for and were intact:
- Neutron Source S/N 12009 (PuBe)
- Shepherd Model 89 Calibrator (Cs-137)
- (2) The inspectors observed radiological controls in the following areas:
- Tools and personnel surveys for release from a spent fuel pool contamination area
- Tools and personnel surveys for release from the radiologically controlled area
Radiological Hazards Control and Work Coverage (IP Section 03.04) (2 Samples)
The inspectors evaluated the following in-plant radiological conditions during facility walkdowns and observation of radiological work activities:
- (1) Removal of items from the spent fuel pool under RWP 2021-0101
- (2) Radiological surveys for the high radiation area down posting of the -4 foot elevation ion exchange valve gallery in the auxiliary building under RWP 2021-0001 High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (4 Samples)
The inspectors evaluated licensee controls of the following high radiation areas and very high radiation areas:
- (1) Unit 3 purification ion exchange rooms A and B
- (2) Unit 3 pre-concentrator ion exchange rooms A and B
- (3) Unit 3 fuel pool filter cubicle and hoist pendant
- (4) Unit 3 process shield No. 1 in the radioactive waste solidification building.
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP
Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.02 - Occupational ALARA Planning and Controls
Radiological Work Planning (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensees radiological work planning. The inspectors reviewed the following activities:
- (1) Radiation Work Permit (RWP) 20190610, "Refuel 22 - Erect/Dismantle Scaffolding in the Reactor Containment Building," Revision 0
- (2) RWP 20190705, "Refuel 22 - Reassembly of Reactor Head and Associated Work Activities," Revision 0
- (3) RWP 20190708, "Refuel 22 - ICI Removal/Installation/Cut up of ICIs, Work on ICI Equipment and Replacement Swageloc Bodies," Revision 1
- (4) RWP 20200705, "Reassembly of Reactor Head and Associated Work Activities,"
Revision 0 Verification of Dose Estimates and Exposure Tracking Systems (IP Section 03.02) (5 Samples)
The inspectors evaluated dose estimates and exposure tracking. The inspectors reviewed the following as low as reasonably achievable planning documents:
- (1) RWP 20190613, "ALLOY 600 Inspections in Containment and support activities including Decon and Prep Support," Revision 0
- (2) RWP 20190702, "Refuel 22 - Disassembly of Reactor Head and All Associated Work Activities," Revision 0
- (3) RWP 20200128, "Loading of Dry Fuel Storage Cask #28 with Spent Fuel and Transport including All DFS Support Activities to Include Set Up/Demob," Revision 0
- (4) RWP 20200702, "Refuel 23 - Disassembly of Reactor Head and All Associated Work Activities," Revision 0
- (5) Additionally, the inspectors reviewed the following radiological outcome evaluations:
- Waterford-3 RF23 Outage Summary Report, February 4, 2021
- Waterford-3 RF22 Post Outage ALARA Report, January 14, 2020
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (2 Samples)
The inspectors evaluated permanently installed ventilation systems used to mitigate the potential for airborne radioactivity were correctly configured to perform their intended function.
- (1) Control room emergency filtration, Units A and B.
- (2) Control room emergency breathing air system, dry cooling tower, -35 foot elevation.
Temporary Ventilation Systems (IP Section 03.02) (1 Sample)
The inspectors evaluated temporary ventilation systems used to mitigate the potential for airborne radioactivity were correctly configured to perform their intended function.
- (1) HEPA ventilation system for filter transfer process shield, radioactive waste solidification building.
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensee's use of respiratory protection devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 03.01) ===
- (1) January 1, 2020 through December 31, 2020 IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 03.02) (1 Sample)
- (1) January 1, 2020 through December 31, 2020
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 03.03) (1 Sample)
- (1) January 1, 2020 through December 31, 2020
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 03.15) (1 Sample)
- (1) October 1, 2020 through December 31, 2020 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 03.16) (1 Sample)
- (1) October 1, 2020 through December 31, 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 issue:
- (1) Incorrect engineering factor for radioactive particulate detectors identified on August 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 05000382/2020-002-00, Operation or Condition Prohibited by Technical Specifications for Technical Specification 3.4.5.1 (Reactor Coolant System Leakage Detection Instrumentation) due to Personnel Error (ADAMS Accession No. ML20297A536). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section
INSPECTION RESULTS
Failure to Follow Procedures with an Improper Entry into a High Radiation Area Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.11] - 71124.01 Radiation Safety NCV 05000382/2021001-01 Challenge the Open/Closed Unknown The inspectors reviewed a self-revealed Green finding and associated non-cited violation of Waterford-3 Technical Specification 6.8.1.a for a workers failure to follow procedures resulting in an improper entry into a high radiation area. Specifically, on October 13, 2020, a worker received a dose rate alarm on a self-reading dosimeter after entering a high radiation area when the worker had not been briefed by radiation protection personnel prior to entering the area.
Description:
On October 13, 2020, a worker entered a high radiation area (HRA) when they had not been briefed by radiation protection personnel and received a dose rate alarm. The worker was authorized on radiation work permit (RWP) RWP 2020-0606 Task 1, which allowed entry into HRAs. The worker was briefed for work and radiological conditions near the -11 foot elevation reactor cavity drain tank in the reactor containment building. The worker was not briefed for other locations in the -11 foot elevation reactor containment building. The RWP had a self-reading dosimeter dose alarm set point of 40 millirem and a dose rate alarm setpoint of 200 millirem per hour (mrem/hr). The dose rates briefed for the travel path and work area ranged from 5 mrem/hr to 15 mrem/hr.
A pre-job walkdown for this work activity identified and flagged the suspect snubber at the Reactor Coolant Pump (RCP) 1A pedestal, which was on the other side of a shielding wall from the reactor cavity drain tank. On route to the reactor cavity drain tank, the worker noticed the flagged snubber at the RCP 1A pedestal through the -4 foot elevation floor grating. When the worker could not locate the snubber at the reactor cavity drain tank as instructed in the work package, the worker proceeded back to the RCP 1A pedestal flagged snubber. At the RCP 1A pedestal, the reactor coolant system hot leg drain line runs around the RCP at chest level to workers. While working at the pedestal near the hot leg drain line, the worker received an unanticipated dose rate alarm of 207 mrem/hr. Radiological hot spots identified along the hot leg drain line near the snubber ranged from 1 Rem/hr on contact with a 30 centimeter dose rate of 200 mrem/hr and 260 mrem/hr on contact with a 30 centimeter dose rate of 100 mrem/hr. Upon receipt of the unanticipated dose rate alarm, the worker left the area and reported to radiation protection.
Procedure EN-RP-101, Access Controls for Radiologically Controlled Areas (RCA),
Revision 15, Section 5.4, required HRA access controls which included a brief of personnel entering HRAs using Attachment 9, Typical HRA/Locked High Radiation Area/Very High Radiation Area Brief Checklist. Attachment 9 stipulated that, prior to entering HRAs, workers must be briefed and knowledgeable of radiological conditions in the work area and the travel path. In addition, the attachment stated that workers must only enter areas that they have been briefed on.
Corrective Actions: The licensee assessed this issue and implemented multiple immediate corrective actions. Some of the actions taken included:
- The workers access was restricted from radioactive material areas and the RCA.
- All work in HRA and above required a reverse brief from radiation workers to include scope of work, radiological conditions, and positive identification of travel path and work location (positively point out on a survey map, picture, or virtual tour).
- The site performed focused observations on radiological briefs to ensure radiation workers and their leadership were meeting the required standard.
Multiple additional actions taken by the licensee were documented in a work ticket (WT-WTWF3-2020-329). Some of the actions included:
- The development of detailed snubber maps for use during radiological briefs.
- The establishment of a cross-discipline outage impact team to identify outage activities that present radiological risk to the site, personnel, or environment and development of prevention strategies to eliminate the risk during Refueling Cycle 24 (RF-24).
Multiple corrective actions were taken by the Entergy nuclear sites (fleet response) and some of the actions included:
- The suspension of all self-briefing for RCA access.
- The establishment of a tool in Sentinel during RWP access to communicate relevant fleet Operating Experience associated with radiation worker performance.
Corrective Action References: CR-WF3-2020-05569
Performance Assessment:
Performance Deficiency: The failure to follow a radiological protection procedure for entry into a high radiation area is a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, the failure to follow requirements involving radiological controls had the potential to increase the workers dose. The failure to follow procedural requirements by making an improper entry into a high radiation area for which the worker was not briefed resulted in an increase to worker exposure of radiation dose rates greater than the general area dose rates (roughly 13 times greater) for which the worker was briefed.
Significance: The inspectors assessed the significance of the finding using Appendix C, Occupational Radiation Safety SDP. The inspectors determined the finding to be of very low safety significance (Green) because
- (1) it was not associated with as low as is reasonably achievable (ALARA) planning or work controls,
- (2) there was no overexposure,
- (3) there was no substantial potential for an overexposure, and
- (4) the ability to assess dose was not compromised.
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. Specifically, the worker failed to stop and assess the radiological conditions they may enter beyond the area that was briefed. The worker failed to determine that accessible radiological conditions in the area of the flagged snubber were higher than the conditions briefed for at the reactor cavity drain tank location. The worker was not briefed on the dose rates for the location of the flagged snubber at the RCP-1A pedestal, and therefore was unaware of the radiological hazard.
Enforcement:
Violation: Waterford-3 Technical Specification 6.8.1.a requires, in part, that written procedures be established, implemented, and maintained covering the applicable procedures in Appendix A to Regulatory Guide 1.33. Appendix A, Section 7.e.(1) recommends radiation protection procedures for access control to radiation areas including a radiation work permit system. The licensee established Procedure EN-RP-101, Access Controls for Radiologically Control Areas, Revision 15, for access control to radiation areas which included the use of a radiation work permit system.
Procedure EN-RP-101, Section 5.4, required a brief of personnel entering HRAs on radiological conditions using Attachment 9, Typical HRA/Locked High Radiation Area/Very High Radiation Area Brief Checklist. Attachment 9 contained requirements to enter HRAs, including:
- (1) the worker be briefed and knowledgeable of radiological conditions in the work area and associated travel path, and
- (2) the worker enter areas of which they have been briefed.
Contrary to the above, on October 13, 2020, a worker failed to implement Procedure EN-RP-101 for properly entering a high radiation area. Specifically, a worker failed to follow Attachment 9 which required workers entering HRAs be briefed and knowledgeable of radiological conditions in the work area and associated travel path, and that the worker enter areas of which they have been briefed. The worker entered an area for which he was neither briefed nor knowledgeable of the radiological conditions and where the workers self-reading dosimeter alarmed.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Licensee-Identified Non-Cited Violation 71153 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: Technical Specification (TS) 3.4.5.1, Leakage Detection Instrumentation, requires that one containment atmosphere particulate radioactivity monitor shall be operable in Modes 1, 2, 3, and 4. The associated action statement for TS 3.4.5.1 for the containment atmosphere particulate radioactivity monitor being inoperable is to analyze grab samples of the containment atmosphere once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and restore the monitor to operable status within 30 days or be in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5 in the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Contrary to the above, the licensee failed to maintain an operable containment atmosphere particulate radiation monitor since the beginning of plant life. When the containment atmosphere radiation monitor was installed, the calculation to convert the output from the radiation monitor (measured in counts per minute) to engineering units (micro Curies per cubic centimeter) was incorrectly input by a vendor. The licensee did not identify this error before placing the radioactivity monitor into service. This incorrect calculation caused the radiation monitor output to be lower than measured and therefore would not alarm upon detecting reactor coolant system leakage exceeding 1 gallon per minute.
Other plant systems can also provide early detection capability of reactor coolant system leakage including containment sump level, sump weir flow, and containment gaseous, iodine, and particulate levels.
Significance/Severity: Green. The inspectors assessed the significance of the finding using IMC 0609, Appendix A, Significance Determination Process for Findings At-Power. The finding was screened using Exhibit 1, Initiating Events Screening Questions, since it was associated with the ability to detect loss of reactor coolant system leakage. The finding was determined to be of very low safety significance (Green) because it did not prevent early detection of a reactor coolant system leak.
Corrective Action References: CR-WF3-2020-04019
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On January 28, 2021, the inspectors presented the occupational radiation safety inspection results to Mr. M. Lewis, General Manager of Plant Operations, and other members of the licensee staff.
- On March 18, 2021, the inspectors presented the occupational radiation safety inspection results to Mr. J. Ferrick, Site Vice President, and other members of the licensee staff.
- On April 15, 2021, the inspectors presented the integrated inspection results to Mr. J.
Ferrick and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.04 Procedures OP-002-003 Component Cooling Water 320
OP-003-016 Instrument Air 27
OP-006-008 Transformer Operation 311
OP-009-002 Emergency Diesel Generator 357
OP-901-511 Instrument Air Malfunction 17
71111.05 Fire Plans NS-YD-003 Prefire Strategy for Yard Area Southeast Quadrant 1
RAB 17-001 Prefire Strategy for Component Cooling Water Heat 8
Exchanger "B"
RAB 21-001 Prefire Strategy for Component Cooling Water Pump "B" 7
RAB 31-001 Prefire Strategy for Elevation -4' RAB General Area 9
71111.11Q Procedures EP-001-001 Recognition & Classification of Emergency Conditions 34
EP-003-060 Emergency Communications Guidelines 6
OP-006-008 Transformer Operation 311
OP-006-009 Electrical Bus Outages 029
OP-902-000 Standard Post Trip Actions 16
OP-902-002 Loss of Coolant Accident Recovery 21
71111.13 Procedures EN-WM-104 On Line Risk Assessment 22
OP-010-005 Plant Shutdown 339
OP-037-000 Operations Risk Assessment Guideline 315
Work Orders 52778635
71111.15 Corrective Action CR-WF3-YYYY- 2021-00381, 2021-00540, 2021-00803
Documents NNNN
Miscellaneous W3-DBD-012 Plant Protection System Design Basis Document 2
Procedures OP-009-002 Emergency Diesel Generator 355
OP-903-068 Emergency Diesel Generator and Subgroup Relay 326
Operability Verification
71111.19 Corrective Action CR-WF3-YYYY- 2021-00780, 2021-00814, 2021-00895
Documents NNNN
Procedures OP-903-050 Component Cooling Water and Auxiliary Component Cooling 43
Water Pump and Valve Operability Test
OP-903-119 Secondary Auxiliaries Quarterly Inservice Test Valve Test 36
Inspection Type Designation Description or Title Revision or
Procedure Date
Work Orders 52892030
71111.22 Procedures OP-903-030 Safety Injection Pump Operability Verification 40
OP-903-046 Emergency Feed Pump Operability Check 323
SEP-WF3-IST-1 WF3 Inservice Testing Bases Document 8
STA-001-005 Leakage Testing of Air and Nitrogen Accumulators for Safety 322
Related Valves
Work Orders 52951720
71124.01 Corrective Action CR-HQN- 2019-01521, 2019-01766, 2020-00239
Documents CR-WF3-YYYY- 2019-03960, 2019-03999, 2019-04091, 2019-05385,
NNNN 2019-05385, 2019-06606, 2019-06916, 2019-07289,
2019-07709, 2019-07794, 2019-08767, 2020-00917,
20-02618, 2020-02665, 2020-02673, 2020-03140,
20-04615, 2020-04957, 2020-05000, 2020-05569,
20-05924, 2020-06188
Procedures EN-RE-220 PWR Control of Miscellaneous Material in the Spent Fuel 1
Pool
EN-RP-100 Radiation Worker Expectations 12
EN-RP-102 Radiological Control 7
EN-RP-105 Radiological Work Permits 19
EN-RP-106-1 Radiological Survey Guidelines 6
EN-RP-108 Radiation Protection Posting 22
EN-RP-121 Radioactive Material Control 17
EN-RP-123 Radiological Controls for Highly Radioactive Objects 1
EN-RP-141-01 Job Coverage Using Remote Monitoring Technology 7
EN-RP-143 Source Control 14
HP-001-123 Plant Conditions and Radiological Concerns 9
HP-002-201 Radiological Survey Techniques 310
RW-002-310 Storage of Radioactive Waste and Radioactive Equipment 11
Radiation WF3-2006-00087 CVC-113B leak investigation 06/08/2020
Surveys WF3-2009-00303 Reactor Cavity Drain Pump Area 09/27/2020
WF3-2010-00088 -11 Reactor Containment Building: Refueling Cavity Drain 10/02/2020
Pump
WF3-2010-00538 Post Anticipated Dose Rate Alarm Survey: -11 Reactor 10/13/2020
Inspection Type Designation Description or Title Revision or
Procedure Date
Containment Building
WF3-2011-00059 -35 Reactor Auxiliary Building Boric Acid Condensate 11/05/2020
Storage Tanks: Post Decontamination
WF3-2011-00089 -4 Reactor Auxiliary Building East Wing Area Posting 11/07/2020
Radiation Work 20200606 Refuel 23 - Perform Minor Maintenance Activities, 0
Permits (RWPs) Walkdowns, and Inspections inside the RCB; NO Work on
Contaminated Valves, RCP Motors/Pumps, or Reactor Head
200702 Refuel 23- Disassembly of Reactor Head and All Associated 0
Work Activities and allows Staging/De-staging of Refuel
Equipment
200705 Refuel 23 - Reassembly of Reactor Head and Associated 0
Work Activities including Staging/De-staging
210101 Work Activities in the Spent Fuel Pool and the Transfer 0
Canal
Self-Assessments LO-WLO-2020- Radiological Hazard Assessment and Exposure Controls 09/22/2020
00042 CA-0006
71124.02 ALARA Plans 20190610 Refuel 22 - Erect/Dismantle Scaffolding in the Reactor 0
Containment Building
20190702 Refuel 22 - Disassembly of Reactor Head and All Associated 0
Work Activities
20190705 Refuel 22 - Reassembly of Reactor Head and Associated 0
Work Activities including Staging/Destaging of Equipment
20190708 Refuel 22 - ICI Removal/Installation/Cur up of ICIs, Work on 1
ICI Equipment and Replacement Swageloc Bodies
200705 Refuel 23 - Reassembly of Reactor Head and Associated 0
Work Activities including Staging/Destaging of Equipment
Corrective Action CR-WF3-YYYY- 2018-05720, 2018-06296, 2019-00063, 2019-00333,
Documents NNNN 2019-00637, 2019-00673, 2019-00751, 2019-00772,
2019-00830, 2019-01186, 2019-02453, 2019-03955,
2019-03999, 2019-07750, 2020-00209, 2020-02665,
20-02673, 2020-05544, 2020-06188, 2020-11511
Miscellaneous Waterford-3 RF23 Outage Summary Report 02/04/2021
Waterford-3 RF22 Post Outage ALARA Report 01/14/2020
Waterford-3 Abbreviated 5-Year Exposure Reduction Plan 01/11/2021
Inspection Type Designation Description or Title Revision or
Procedure Date
21-2025
Waterford-3 2019 Annual Radiation Protection Program 03/18/2020
Report
BMS 2020 Boron Management System Waste Stream Sample 02/03/2020
499999001 Screening and Evaluation
RCS 2020 Reactor Coolant System Waste Stream Sample Screening 02/03/2020
498902001 and Evaluation
SFP 2020 Spent Fuel Pool Waste Stream Sample Screening and 03/02/2020
498902002 Evaluation
Procedures EN-RP-102 Radiological Control 7
EN-RP-105 Radiological Work Permits 19
EN-RP-110-03 Collective Radiation Exposure (CRE) Reduction Guidelines 4
EN-RP-110-04 Radiation Protection Risk Assessment Process 8
Radiation WF3-2001-00275 RAB -4 Radiochemistry Lab 01/31/2020
Surveys WF3-2005-00088 RAB -35 Waste Condensate Tanks 05/10/2020
WF3-2006-00087 RAB -4 CVC-113B Leak Investigation 06/08/2020
Radiation Work 20190501 Refuel 22 - Initial RCB Entry, RP Surveys, Postings, 0
Permits (RWPs) Inspections, Minor Work and Ops Valve Line-Ups
20190613 ALLOY 600 Inspections in Containment and Support 0
Activities including Decon and Prep Support
200128 Loading of Dry Fuel Storage Cask #28 with Spent Fuel and 0
Transport including All DFS Support Activities to Include Set
Up/Demob
200702 Refuel 23 - Disassembly of Reactor Head and All Associated 0
Work Activities
Self-Assessments LO-WLO-2019- Occupational ALARA Planning and Controls 10/11/2019
00041
LO-WLO-2020- Occupational ALARA Planning and Controls 01/27/2020
00013
LO-WLO-2021- Occupational ALARA Planning and Controls 01/14/2021
00020
71124.03 Corrective Action CR-HQN- 2018-00796 2018-00814 2020-00660 2020-00793
Documents CR-WF3-YYYY- 2018-00383, 2018-01033, 2018-01622, 2018-01936,
Inspection Type Designation Description or Title Revision or
Procedure Date
NNNN 2018-03409, 2018-04476, 2018-05301, 2019-04323,
2019-04651, 2019-04712, 2019-04934, 2019-05571,
2019-07640, 2020-00277, 2020-01817, 2020-02603,
20-03163, 2020-03573, 2020-05592, 2020-06867,
20-07245, 2020-07262, 2021-00099
Drawings 5817-7912 Emergency Breathing Air System N/A
Procedures EN-RP-122 Alpha Monitoring 10
EN-RP-131 Air Sampling 17
EN-RP-402 DOP Challenge Testing of HEPA Vacuums and Portable 4
Ventilation Units
EN-RP-404 Operation and Maintenance of HEPA Vacuum Cleaners and 9
HEPA Ventilation Units
EN-RP-502 Inspection and Maintenance of Respiratory Protection 10
Equipment
EN-RP-504 Breathing Air 4
EN-RP-505 PortaCount Respiratory Fit Testing 8
HP-002-603 Inspection and Use of Control Room EBA Filtration Panel 12
HP-002-609 Verification of Breathing Air Quality 5
MM-003-045 Control Room Air Conditioning System Surveillance 311
OP-002-019 Emergency Breathing Air 306
OP-003-014 Control Room Heating and Ventilation 308
OP-903-051 Control Room Emergency Filtration Unit Operability Check 12
Radiation Work 2019-0051 Testing of Contaminated System Valves/Piping 0
Permits (RWPs) 2019-0702 Disassembly of Reactor Head and All Associated Work 0
Activities
2019-0724 Fuel Transfer System Maintenance 1
20-0604 Perform Work Activities in Alpha Level Three Areas 0
20-0617 Various Decon Activities in the Upper Reactor Cavity 0
20-0705 Reassembly of Reactor Head and Associated Work Activities 0
Self-Assessments EN-LI-104, In-Plant Airborne Radioactivity Control and Mitigation 15
Work Orders Numerous Monthly Inspection on Respiratory Equipment N/A
71151 Calibration 2020-B2.28- Portable Instrumentation Calibration Data Sheet: AMS-4 02/19/2020
Inspection Type Designation Description or Title Revision or
Procedure Date
Records CALDAT-01567 Particulate Detector SN: P500, Plant ID: HP-RD-246
20-B2.28- Portable Instrumentation Calibration Data Sheet: AMS-4 05/05/2020
CALDAT-03370 Particulate Detector SN: P650, Plant ID: HP-RD-264
20-B2.28- Portable Instrumentation Calibration Data Sheet: AMS-4 07/13/2020
CALDAT-04575 Particulate Detector SN: 12910, Plant ID: CHPAMSD065
Corrective Action CR-WF3-YYYY- 2019-03960, 2019-03999, 2019-05385, 2019-05385,
Documents NNNN 2019-06916, 2019-07709, 2019-07794, 2020-01831,
20-02665, 2020-02673, 2020-03140, 2020-04615,
20-04957, 2020-05569, 2020-05924, 2020-06097
Miscellaneous NRC Performance Indicator Technique/Data Sheet: 4th 01/05/2021
Quarter 2020 - RETS/ODCM Radiological Effluent
Occurrence
Procedures EN-RP-113 Response to Contaminated Spills/Leaks 9
71152 Corrective Action CR-WF3-YYYY- 2020-0061, 2020-04019, 2020-04041
Documents NNNN
Miscellaneous 457000846 Particulate, Iodine and Gas Radiation Monitoring Systems 13
Equipment Manual
19