Text

– Design Basis Assurance Inspection (Programs) Inspection Report 05000382/2022013
	ML22321A317
Person / Time
Site:	Waterford
Issue date:	11/28/2022
From:	Vincent Gaddy; NRC/RGN-IV/DORS/EB1
To:	Ferrick J; Entergy Operations
References
	IR 2022013
	Download: ML22321A317 (19)
	v • d • e

November 28, 2022

SUBJECT:

WATERFORD STEAM ELECTRIC STATION - DESIGN BASIS ASSURANCE INSPECTION (PROGRAMS) INSPECTION REPORT 05000382/2022013

Dear John Ferrick:

On October 27, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Waterford Steam Electric Station and 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.

Three findings of very low safety significance (Green) are documented in this report. Three 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.

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.

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 Operating Reactor Safety Docket No. 05000382 License No. NPF-38

Enclosure:

As stated

Inspection Report

Docket Number:

05000382

License Number:

NPF-38

Report Number:

05000382/2022013

Enterprise Identifier:

I-2022-013-0002

Licensee:

Entergy Operations, Inc.

Facility:

Waterford Steam Electric Station

Location:

Killona, LA

Inspection Dates:

September 19, 2022 to October 07, 2022

Inspectors:

D. Bryen, Reactor Inspector

W. Cullum, Senior Reactor Inspector

R. Kopriva, Senior Reactor Inspector

D. Loveless, Senior Reactor Analyst

F. Thomas, Reactor Inspector

Approved By:

Vincent G. Gaddy, Chief

Engineering Branch 1

Division of Operating Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (programs) inspection at Waterford Steam Electric Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Failure to follow the corrective action program procedure Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000382/2022013-01 Open/Closed

[H.11] -

Challenge the Unknown 71111.21N.

The inspectors identified a Green finding and associated Non-cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," when the licensee failed to follow their corrective action program procedure EN-LI-102.

Failure to promptly identify and correct a condition adverse to quality Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000382/2022013-02 Open/Closed

[H.11] -

Challenge the Unknown 71111.21N.

Inspectors identified a Green finding and associated Non-cited Violation (NCV) of 10 CFR 50,

Appendix B, Criterion XVI, "Corrective Action," when the licensee failed to promptly identify and correct a condition adverse to quality. Specifically, the licensee failed to identify and correct missing screws, washers, and insulators within the DC motor actuator for MS-401A/B,

"Steam Supply Valve to Emergency Feedwater Pump Turbine."

Failure to maintain design control of a safety-related component Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000382/2022013-03 Open/Closed

[H.12] - Avoid Complacency 71111.21N.

Inspectors identified a Green finding and associated Non-cited Violation (NCV) of 10 CFR 50,

Appendix B, Criterion III, "Design control," when the licensee did not maintain design requirements for the MS-401A/B DC motor actuator resulting in an unanalyzed seismic condition.

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.

REACTOR SAFETY

71111.21N.02 - Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements POV Review (IP Section 03)

Main article: IP 71111.21

The inspectors:

a. Determined whether the sampled POVs are being tested and maintained in accordance with NRC regulations along with the licensees commitments and/or licensing bases.

Specific Guidance b. Determined whether the sampled POVs are capable of performing their design-basis functions.

c. Determined whether testing of the sampled POVs is adequate to demonstrate the capability of the POVs to perform their safety functions under design-basis conditions.

d. Evaluate maintenance activities including a walkdown of the sampled POVs (if accessible).

(1) EFW-223A - Emergency Feedwater Flow Header to Steam Generator A, Air Operated Valve

(2) MS-124B - Main Steam Isolation Valve, Hydraulically Operated Valve

(3) SI-407A - Shutdown Cooling Isolation Valve, Motor Operated Valve

(4) CC-135A - Dry Cooling Tower A CCW Inlet Header Isolation Valve, Air Operated Valve

(5) FW-173A - Steam Generator 1 Main Feedwater Regulating Valve, Air Operated Valve

(6) SI-401A - Shutdown Cooling Suction Isolation Valve, Motor Operated Valve

(7) SI-121B - Safety Injection Recirculating Header B to Refueling Water Storage Pool Downstream Isolation Valve, Motor Operated Valve

(8) MS-401B - Emergency Feedwater Pump AB Turbine Steam Supply from Steam Generator, Motor Operated Valve

(9) EFW-229B - Emergency Feedwater to SG [Steam Generator] 2 Backup Isolation Valve, Air Operated Valve

(10) ACC-110A - Auxiliary Component Cooling Water Pump A Discharge Line Isolation Valve, Motor Operated Valve

INSPECTION RESULTS

Failure to follow the corrective action program procedure Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000382/2022013-01 Open/Closed

[H.11] -

Challenge the Unknown 71111.21N.0 The inspectors identified a Green finding and associated Non-cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," when the licensee failed to follow their corrective action program procedure EN-LI-102.

Description:

While reviewing maintenance documentation for SI-121B (minimum flow recirculation valve), inspectors observed that the acceptance criteria was not met for an as-found diagnostic test of the valve. Specifically, on January 17, 2019, during an as-found diagnostic test under work order 52806249, the minimum Control Switch Trip (CST) thrust was 16,041 lbs when the requirement was 17,302 lbs or greater for the close direction. When inspectors asked to review the condition report associated with this issue, the licensee could not find a condition report which documented the issue.

The SI-121B valve is a safety-related, 4 inch, motor-operated gate valve in the minimum recirculation line to enable the operators to manually isolate the Reactor Water Storage Pool (RWSP) from the High Pressure Safety Injection (HPSI), Low Pressure Safety Injection (LPSI), and Containment Spray (CS) pump discharge headers after a Recirculation Actuation Signal (RAS). The valve has a safety function in the open and closed position.

The station procedure EN-LI-102, "Corrective Action Program," states in Section 5.2.4 that "employees and contractors are required to initiate condition reports for adverse conditions and are encouraged to write condition reports for a broad range of conditions." Section 3.0.2 of this procedure defines an adverse condition as a general term which includes conditions adverse to quality plus undesirable conditions. Furthermore, Section 3.0.7 defines a condition adverse to quality as a failure, malfunction, deficiency, deviation, defective material or equipment, or nonconformance affecting the safety-related function of a structure, system, or component.

Accordingly, the failure of SI-121B to meet acceptance criteria during diagnostic testing was a condition adverse to quality and a condition report should have been generated to document the issue. Since a condition report was not generated, the present and past operability of the valve were not evaluated. There was a reasonable doubt concerning the operability of valve because the valve did not meet the acceptance criteria in the test. However, the licensee was able to demonstrate that, through an updated methodology for calculating uncertainty, the valve would have maintained positive margin and, therefore, remained operable.

Corrective Actions: Prior to returning SI-121B to service, the licensee adjusted the torque switch on the motor-operated valve. The as-left test showed that all acceptance criteria was satisfactory and there is no current operability concern for the valve. The licensee generated a condition report for the failure to follow the corrective action procedure.

Corrective Action References: CR-WF3-2022-06543

Performance Assessment:

Performance Deficiency: The licensee failed to follow a quality procedure in accordance with 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," when a condition report was not generated for a condition adverse to quality. Specifically, on January 17, 2019, a condition report was not written to document that SI-121B failed to meet the minimum required CST thrust in the close direction during a diagnostic test under WO 52806249 in accordance with EN-LI-102.

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 failure to meet the acceptance criteria in the as-found diagnostic test for the minimum CST thrust created a reasonable doubt regarding the operability of the valve.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power.

Inspectors screened the issue to Green using Exhibit 2, "Mitigating Systems Screening Questions," because the degraded condition did not represent a loss of the PRA function of one train of a multi-train Technical Specification (TS) system for greater than its TS allowed outage time.

Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. Inspectors assessed that the finding occurred within the nominal three-year period and therefore reflects current performance.

Enforcement:

Violation: 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings,"

requires, in part, "Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

Contrary to the above, on January 17, 2019, the licensee did not accomplish activities affecting quality in accordance with prescribed procedures. Specifically, the licensee did not follow the procedure, EN-LI-102, "Corrective Action Program." A condition report was not written to document a condition adverse to quality when the minimum CST thrust acceptance criteria was not met during an as found diagnostic test.

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

Failure to promptly identify and correct a condition adverse to quality Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000382/2022013-02 Open/Closed

[H.11] -

Challenge the Unknown 71111.21N.0 Inspectors identified a Green finding and associated Non-cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," when the licensee failed to promptly identify and correct a condition adverse to quality. Specifically, the licensee failed to identify and correct missing screws, washers, and insulators within the DC motor actuator for MS-401A/B, "Steam Supply Valve to Emergency Feedwater Pump Turbine."

Description:

Inspectors reviewed licensee condition report CR-WF3-2022-02645 as part of the inspection for motor-operated valve MS-401B. This condition report documented that two screws were missing from the DC motor brush plate assembly. This was identified by technicians during a routine inspection of the DC motor. The condition report was screened as a non-adverse condition and closed after the missing screws were replaced. Inspectors questioned if the screws were required for seismic qualification. The licensee discovered that the screws were required and visibly present during the seismic qualification according to pictures shown in the seismic qualification report for the DC motor, B0009. At this time, the licensee also discovered that washers and insulators were also missing in comparing the recent DC motor pictures with the pictures from the seismic qualification report. Inspectors also reviewed a document from 2008 when a failure had occurred with MS-401B. Pictures taken during that failure modes analysis (FMA) show that the same screws, washers, and insulators were missing at that time.

Corrective Action References: CR-WF3-2022-06892, CR-WF3-2022-06932

Performance Assessment:

Performance Deficiency: Inspectors identified a failure to promptly identify and correct a condition adverse to quality in accordance with 10 CFR 50, Appendix B, Criterion XVI, "Corrective Actions," when a condition adverse to quality existed in the plant for many years despite several opportunities for discovery.

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 missing internal components of the DC motor caused reasonable doubt as to the seismic qualification of the component since it was not in the same configuration in which it was qualified.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, "Mitigating Systems Screening Questions," inspectors were able to screen the issue to Green since the degraded condition did not represent a loss of the PRA function of one train of a multi-train TS system for greater than its TS allowed outage time. The licensee was able to demonstrate a reasonable expectation of operability through additional seismic analysis, diagnostic testing results, and in-service testing.

Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. Inspectors assessed that the finding occurred within the nominal three-year period and therefore reflects current performance.

Enforcement:

Violation: 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part, "Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected."

Contrary to the above, from 5/28/2008 until 4/15/2022, the licensee did not establish measures to assure that conditions adverse to quality are promptly identified and corrected.

Specifically, the licensee did not identify missing internal components on the DC motor actuator for MS-401B despite several opportunities for discovery.

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

Failure to maintain design control of a safety-related component Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000382/2022013-03 Open/Closed

[H.12] - Avoid Complacency 71111.21N.0 Inspectors identified a Green finding and associated Non-cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion III, "Design control," when the licensee did not maintain design requirements for the MS-401A/B DC motor actuator resulting in an unanalyzed seismic condition.

Description:

Inspectors reviewed documentation associated with MS-401A&B. These valves are required to admit steam to the emergency feedwater pump turbine (EFPT) on emergency feedwater actuation signal (EFAS). One valve is required in each steam line from the steam generator in order to permit feeding the turbine from either steam generator. Per design documents, MS-401A&B and the actuator are required to be seismic I qualified.

In 2008 during a Failure Modes Analysis for MS-401B, the DC motor actuator was disassembled to determine a cause for failure. Pictures indicated the brush plate assembly was missing 2 screws along with washers and insulators.

Based on review of Appendix E of the Seismic Qualification Review Team (SQRT) report SQ-MN-002, titled, "Actuator Qualification Report B0009," inspectors discovered that the original seismic qualification for the DC motor included 4 screws to secure the brush plate assembly.

Inspectors also observed that all screws had washers and insulators in the seismic qualification report.

Further discussion with the vendor revealed that 4 screws are required to secure the brush plate and if the brush plate is not secure, some arcing and intermittent failure of the DC motor is possible.

Also, while performing WO-52842031-01, titled Motor Inspect/Clean Brush Holders &

Commutator for MS MVAAA 401B, EFW Pump AB Turbine Steam Supply from S/G 2, technicians identified two screws missing from the DC motor brush plate assembly internal to the motor housing and wrote CR-WF3-2022-2545. These screws secure the brush plate assembly to the motor housing. The brush plate assembly was also found loose.

The as found condition in 2008 and 2022 are not consistent with the original seismic qualification report. Therefore, the seismic performance with missing screws on the DC motor actuator for MS-401A&B is not analyzed.

Further investigation by the licensee during the extent of condition revealed that the MS-401A valve also had missing internal components. The MS-401A DC motor was replaced in April of 2022. The new motor was found to have all four screws, and zero washers, and two insulators. The old motor was found to only have 2 screws.

Corrective Actions: The licensee installed the missing screws on MS-401A&B. Additional missing parts will be installed when items are procured. The vendor was notified and is performing an investigation into the missing components.

Corrective Action References: CR-WF3-2022-7091, CR-WF3-2022-6932

Performance Assessment:

Performance Deficiency: Inspectors identified a failure to maintain design control of safety-related equipment in accordance with 10 CFR 50, Appendix B, Criterion III, "Design Control,"

when the existing plant configuration for the DC motor actuator for MS-401A/B does not match original design and is not analyzed for seismic qualification.

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, the missing internal components represents a departure from the original design. The seismic qualification of the DC motor actuators is not analyzed for the missing parts. Therefore, the degraded condition will negatively affect the availability and reliability of the DC motor actuators to respond to initiating events.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors used Exhibit 2, "Mitigating Systems Screening Questions," to assess the impact on the Mitigating Systems cornerstone. The inspectors found that the issue screened to a detailed risk evaluation because the degraded condition represented a loss of PRA function of one train of a multi-train TS system for greater than its allowed. Specifically, since both steam supply valves to the turbine driven EFW pump, MS-401A/B, were not seismically qualified, there was reasonable doubt that the EFW turbine driven pump could perform it's function.

In performing the detailed risk evaluation, the analyst assumed that the missing screws in valves MS-401A and MS-401B would have an increase the failure rate of those valves above and beyond their nominal failure rate. To estimate this failure rate the analyst used 2 failures in 20 years for the two valves, based on plant data. This yielded an estimated failure rate from the deficiency of 5.0E-2. The analyst used this new failure rate in the Waterford SPAR model, Version 8.80, run on SAPHIRE, Version 8.2.6, using a one-year exposure time. This yielded an increase in core damage frequency of 3.2E-8/year for internal, hurricane, high wind, and tornado events. This estimate was below the value to require determining the increase in core damage frequency from other external events, but the analyst reviewed the impact of the valves increased seismic vulnerability on core damage frequency. For this review, the analyst conservatively assumed that both valves would fail during all ranges of earthquakes because of the deficiency. Using a one-year exposure time, this yielded an estimate of the increase in core damage frequency of 7.4E-7/year from seismic events.

Combining internal events and seismic inputs, the total increase in core damage frequency was estimated to be 7.7E-7/year. The analyst reviewed the finding for large early release frequency using Manual Chapter 0609, Appendix H, Containment Integrity Significance Determination Process, and determined that the dominant sequences would not result in a significant increase in large early release frequency. As a result, the analyst determined that this finding was of very low safety significance (Green). The dominant core damage sequences were earthquakes and the most important remaining mitigating equipment was the motor driven emergency feedwater pumps and offsite power.

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Inspectors assessed that the finding occurred within the nominal three-year period and therefore reflects current performance.

Enforcement:

Violation: 10 CFR 50, Appendix B, Criterion III, "Design Control," requires, in part, "Measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. These measures shall include provisions to assure appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled."

Contrary to the above, from September 2017 until April 2022, the licensee did not establish measures to assure that applicable regulatory requirements are correctly translated into specification, drawings, procedures, and instructions. Specifically, the DC motor actuators for MS-401A&B were installed in the plant with missing internal components which led to an unanalyzed seismic qualification.

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 October 27, 2022, the inspectors presented the design basis assurance inspection (programs) inspection results to John Ferrick and other members of the licensee staff.

On October 27, 2022, the inspectors presented the Exit Meeting inspection results to John Ferrick and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

v t e Inspection Report - Waterford - 2022013
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 \|
2022 Quarterly Integrated 1Q (0) 2Q (0) 3Q (0) 4Q (0) Assessments Mid Cycle End of Cycle 10(0) 11(0) 12(0) 13(0) 90(0) 91(0) Security 401(0) 402(0) 403(0) Operator Exams 301(0) Emergency Planning 501(0) Other

IR 05000382/2022013

Text

SUBJECT:

Dear John Ferrick:

Enclosure:

Inspection Report

SUMMARY

List of Findings and Violations

Additional Tracking Items

INSPECTION SCOPES

REACTOR SAFETY

71111.21N.02 - Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements POV Review (IP Section 03)

INSPECTION RESULTS

Description:

Performance Assessment:

Enforcement:

Description:

Performance Assessment:

Enforcement:

Description:

Performance Assessment:

Enforcement:

EXIT MEETINGS AND DEBRIEFS

DOCUMENTS REVIEWED

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