IR 05000382/2023002
| ML23216A106 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/08/2023 |
| From: | John Dixon NRC/RGN-IV/DORS/PBD |
| To: | Sullivan J Entergy Operations |
| References | |
| IR 2023002 | |
| Download: ML23216A106 (1) | |
Text
August 08, 2023
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - INTEGRATED INSPECTION REPORT 05000382/2023002
Dear Joseph Sullivan:
On June 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Waterford Steam Electric Station, Unit 3. On July 31, 2023, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
No NRC-identified or self-revealing findings were identified during this inspection.
A licensee-identified violation which was determined to be 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 violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Waterford Steam Electric Station, Unit 3. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, John L. Dixon, Jr., Chief Reactor Projects Branch D Division of Operating Reactor Safety Docket No. 05000382 License No. NPF-38
Enclosure:
As stated
Inspection Report
Docket Number:
05000382
License Number:
Report Number:
Enterprise Identifier:
I-2023-002-0009
Licensee:
Entergy Operations, Inc.
Facility:
Waterford Steam Electric Station, Unit 3
Location:
Killona, LA 70057
Inspection Dates:
April 1, 2023, to June 30, 2023
Inspectors:
D. Childs, Resident Inspector
S. Hedger, Sr Emergency Preparedness Inspector
A. Patz, Senior Resident Inspector
H. Strittmatter, Sr Emergency Preparedness Inspector
T. Weir, Physical Security Inspector
Approved By:
John L. Dixon, Jr., Chief
Reactor Projects Branch D
Division of Operating Reactor Safety
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: 71111.0
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000382/2022-003-00 Operation Prohibited by Technical Specifications Due to Radiation Monitor Calibration Error 71153 Closed LER 05000382/2022-004-00 Regarding Operation Prohibited by Technical Specifications Due to Inadequate Radiation Monitor Calibration Procedures 71153 Closed LER 05000382/2022-006-00 Non-Compliance with Technical Specifications Due to Incorrect Conversion Factors in Plant Stack and Fuel Handling Building Radiation Monitors 71153 Closed LER 05000382/2023-001-00 Non-Compliance with Technical Specifications Due to pico-ammeter circuit board fluctuations in Containment High Range Radiation Monitor B 71153 Closed
PLANT STATUS
Unit 3 operated at or near rated thermal power for the entire inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/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 performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of hurricane season for the following systems: emergency diesel generator system, ultimate heat sink, emergency feedwater system, and startup transformers on May 5, 2023.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)startup transformer A and associated electrical equipment following unplanned loss of startup transformer B on April 6, 2023 (2)emergency diesel generator A while emergency diesel generator B was inoperable due to planned maintenance on May 23, 2023
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 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 16A-001, emergency diesel fuel oil feed tank A space on April 20, 2023 (2)fire areas RAB 15-001 and RAB 16-001, emergency diesel generator A and B rooms on April 24, 2023 (3)fire areas RAB 8A-001 and RAB 8B-001, switchgear A and switchgear B rooms on May 8, 2023 (4)fire area RAB 40-001, diesel storage tank A space on May 25, 2023 (5)fire area RAB 41-001, diesel storage tank B space on May 25, 2023 (6)fire area RAB 23-001, corridor, concentrators, and hold-up rooms on June 12, 2023
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire drill in the +55.00' elevation of the reactor auxiliary building involving a cable tray fire in electrical penetration room B on June 13, 2023
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated internal flooding mitigation protections in:
Zone 11 - emergency diesel generator room B Zone 37 - diesel fuel oil feed tank room A Zone 38 - diesel fuel oil feed tank room B
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 emergency diesel generator overspeed testing on May 24, 2023.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated a licensed operator requalification exam on May 1, 2023.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
(1)component cooling water train A following failure of dry cooling tower fan 9B due to water in-leakage into motor bearing on April 4, 2023
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
(1)emergency diesel generator B from May 22 to May 25, 2023
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)yellow risk due to an offsite electrical grid spike isolating startup transformer B and generator output breaker B on April 6, 2023 (2)elevated green risk due to a load-balancing authority declaration of conservative operations to ensure grid stability on May 16, 2023 (3)yellow risk due to planned outage of auxiliary feedwater pump and heavy switchyard work from June 12-15, 2023
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (1 Sample)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
(1)emergency diesel generator B following blown fuse replacement on May 26, 2023
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
(1)temporary modification EC54002032 to decrease core protection calculator A sensitivity due to degrading excore nuclear instrument on May 24, 2023
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (5 Samples)
(1)containment spray pump A following planned maintenance on April 12, 2023 (2)emergency feedwater pump A after motor oil change and calibration of pressure discharge sensor on April 13, 2023 (3)inlet damper hydramotor to the train A control room air handling unit after motor refurbishment on May 9, 2023 (4)containment fan coolers A and C following corrective maintenance on train A temperature control valve on May 11, 2023 (5)shield building ventilation train B and reactor auxiliary building normal ventilation train B following post-maintenance test failures on May 18, 2023
Surveillance Testing (IP Section 03.01) (1 Sample)
(1)emergency diesel generator B overspeed trip testing on May 24, 2023
Diverse and Flexible Coping Strategies (FLEX) Testing (IP Section 03.02) (1 Sample)
(1)operational testing of the FLEX N and N+1 diesel fuel oil transfer pumps on May 16, 2023
71114.01 - Exercise Evaluation
Inspection Review (IP Section 02.01-02.11) (1 Partial)
(1)
(Partial)
The inspectors evaluated the biennial emergency plan exercise conducted on June 21, 2023. However, as of the end of the 2nd quarter 2023, the licensee had not completed its critique process for the exercise. As such, the inspectors had not completed the full evaluation of the exercise and the critique process. The inspectors will complete the inspection in the 3rd quarter, and the results of the inspection will be documented in NRC Inspection Report 05000382/2023003.
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The inspectors evaluated changes to the Alert/Notification System (ANS) Design Report, revision 9 (effective February 13, 2023). This involved review of a selection of additional licensee screening and evaluation documentation. These evaluations and reviews do not constitute NRC approval.
71114.08 - Exercise Evaluation - Scenario Review
Inspection Review (IP Section 02.01 - 02.04) (1 Sample)
- (1) The inspectors reviewed the licensee's preliminary exercise scenario that was submitted to the NRC on April 24, 2023 (ML23114A222), for the exercise scheduled to occur on June 21, 2023. The inspectors discussed the preliminary scenario with J. Lewis, Manager, Emergency Preparedness, and other members of the emergency preparedness staff on May 18, 2023. The inspectors' review does not constitute NRC approval of the scenario.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===
- (1) April 1, 2022, through March 31, 2023
MS06: Emergency AC Power Systems (IP Section 02.05) (1 Sample)
- (1) April 1, 2022, through March 31, 2023
MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)
- (1) April 1, 2022, through March 31, 2023
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)
- (1) October 1, 2022, through March 31, 2023 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
- (1) October 1, 2022, through March 31, 2023 EP03: Alert and Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
- (1) October 1, 2022, through March 31, 2023
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 05000382/2022-003-00, Operation Prohibited by Technical Specifications Due to Radiation Monitor Calibration Error (ADAMS Accession No. ML22164B005)
LER 05000382/2022-004-00, Operation Prohibited by Technical Specifications Due to Inadequate Radiation monitor Calibration Procedures (ADAMS Accession No.
LER 05000382/2022-006-00, Non-Compliance with Technical Specifications Due to Incorrect Conversion Factors in Plant Stack and Fuel Handling Building Radiation Monitors (ADAMS Accession No. ML22311A471)
LER 05000382/2023-001-00, Non-Compliance with Technical Specifications due to pico-ammeter circuit board fluctuations in Containment High Range Radiation Monitor B (ADAMS Accession No. ML23121A120)
The inspection conclusions associated with these LERs are documented in Inspection Report 05000382/2023040 (ADAMS Accession No. ML23192A764).
These LERs are closed.
INSPECTION RESULTS
Licensee-Identified Non-Cited Violation 71111.05 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: The Waterford Steam Electric Station, Unit 3 Renewed Facility Operating License, section 2.C(9), requires that the licensee implement and maintain in effect all provisions of the approved fire protection program. The approved fire protection program as described by procedure EN-DC-161, Control of Combustibles, revision 24, required that continuous administrative fire watches be established prior to the introduction of any non-exempt transient combustible materials into designated Level 1 areas.
Contrary to the above, from March 11 to April 25, 2022, the licensee failed to establish fire watches in accordance with the approved fire protection program. Specifically, the licensee failed to establish continuous administrative fire watches in Level 1 designated areas containing non-exempt transient combustible materials. On April 25, 2022, the licensee entered condition report CR-WF3-2022-03147 into their corrective action program which states none of the required administrative continuous fire watches or hourly fire watches were found on station. These watches were required for transient combustible permits that have been open as early as March 11, 2022, and were still in place that day. The condition report notes four fire areas with Level 1 combustible control zones, as defined in attachment 4 of EN-DC-161, where fire watches were not identified:
- RAB 7, relay room
- RAB 8A, switchgear room A
- RAB 8B, switchgear room B
- RCB, reactor containment building
Section 7.5 of EN-DC-161, requires a continuous fire watch to be established in accordance with procedure EN-OP-139, Fire Watch Program, revision 6, as a minimum compensatory action prior to the introduction of any non-exempt transient combustible materials into designated Level 1 areas. The inspectors reviewed this condition report and identified a partial loss of fire detection and suppression from April 14 to 16, 2022, for fire zones RAB 8A and RAB 8B, that did not appear to have appropriate continuous fire watches. The inspectors requested documentation from the licensee to validate that these fire watches were performed. No conclusive documentation was found that demonstrated the fire watches were performed.
Significance/Severity: Green. The inspectors assessed the significance of the finding using IMC 0609.04, Initial Characterization of Findings, and IMC 0609, appendix F, attachment 1, and determined the finding to be of very low safety significance (Green) because the affected areas were protected with automatic detection and suppression.
Corrective Action References: CR-WF3-2022-03147
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On May 18, 2023, the inspectors presented the emergency preparedness exercise scenario inspection results to G. Taylor, Senior Project Manager, Emergency Preparedness, and other members of the licensee staff.
On June 29, 2023, the inspectors presented the EP performance indicator verification and emergency plan change review inspection results to N. Lawless, Director, Maintenance, and other members of the licensee staff.
On July 17, 2023, the inspectors presented the integrated inspection first exit inspection results to J. Sullivan, Site Vice President, and other members of the licensee staff.
On July 31, 2023, the inspectors presented the integrated inspection results to J. Sullivan Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
EN-FAP-EP-010
Severe Weather Response
OP-003-024
Sump Pump Operations
20
Procedures
OP-901-521
Severe Weather and Flooding
341
OP-006-010
TEDG Operations
Procedures
OP-009-002
360
5817-11881
Fire Detection System Device List
Drawings
G-FP0021
Fire Detection System Raceway and Equipment Layout
Reactor Auxiliary Building Elevation Plus 21 Feet
RAB 15-001
Emergency Diesel Generator 3B Room Fire Plan
RAB 16-001
Emergency Diesel Generator 3A Room Fire Plan
Emergency Diesel Oil Feed Tank A Space Fire Plan
RAB 23-001
Corridor, Concentrators, and Hold-up Rooms
RAB 40-001
Diesel Storage Tank A
RAB 41-001
Diesel Storage Tank B
RAB 5-001
Electrical Penetration Room B
Switchgear Room A
Fire Plans
Switchgear Room B
Engineering
Evaluations
MNQ3-5
Flooding Analysis Outside Containment
ME-004-021
OP-009-002
360
OP-901-111
307
OP-901-112
Charging or Letdown Malfunction
Procedures
OP-902-000
Standard Post Trip Actions
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
23-01697, 2023-01772, 2023-01788
Procedures
ME-004-021
Work Orders
541972, 564250, 565306, 567406, 571240, 52987991,
2993356
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
23-13734
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
On Line Risk Assessment
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
23-13411
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
23-02209, 2023-02238, 2023-13225
ENI Channel A Middle Detector Database Update
Engineering
Changes
ENI Channel A Subchannel Gain Change
NE-002-012
Linear Power Single Channel Adjustment for Excore
Detector Drift
Procedures
NE-006-001
Addressable Constant Administrative Controls
304
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
23-01874, 2023-02124, 2023-13169, 2023-13192,
23-13265, 2023-13293
Corrective Action
Documents
Resulting from
Inspection
CR-WF3-YYYY-
NNNN
23-01859, 2023-01909, 2023-01979
FIG-001
FLEX Implementing Guideline - Extended Loss of AC Power
FSG-005
Initial Assessment and FLEX Equipment Staging
ME-004-021
MM-007-029
Hydramotors Model NH96 B1
308
OP-008-008
Shield Building Ventilation
OP-903-035
Containment Spray Pump Operability Check
Procedures
OP-903-046
Emergency Feed Pump Operability Check
25
Work Orders
594839, 54002015, 582788, 53026685, 52939414
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
21-02170, 2021-05108, 2022-01454, 2022-01513,
22-03563, 2022-07220, 2023-01506, 2023-02182,
23-02225, 2023-13669, 2023-13671
Offsite Dose Assessment using the Unified RASCAL
Interface
Emergency Notifications
Emergency Operations Facility (EOF) Operations
Declared Emergency Recovery and Re-entry
Procedures
Recognition and Classification of Emergency Conditions
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Alert
311
Notifications and Communications
317
Offsite Dose Assessment
309
Protective Action Guidelines
Emergency Operations Facility (EOF) Activation, Operation,
and Deactivation
310
OP-901-130
Reactor Coolant Pump Malfunction
OP-901-510
Component Cooling Water System Malfunction
306
OP-902-000
Standard Post Trip Actions
OP-902-002
Loss of Coolant Accident Recovery
OP-902-009
Standard Appendices
23
Work Orders
Work Order
Number
560193
Corrective Action
Documents
Resulting from
Inspection
CR-WF3-YYYY-
NNNN
23-13931
10CFR50.54(Q)(2) Review for EN-EP-609 Revision 7
04/24/2023
10CFR50.54(Q)(2) Review for EPP-424 Revision 22
04/13/2023
10CFR50.54(Q)(2) Review for EPP-422 Revision 16
04/13/2023
10CFR50.54(Q)(3) Screening for Alert/Notification System
Design Report, Revision 9
2/13/2023
Miscellaneous
Emergency Preparedness Updated Alert/Notification
System (ANS) Design Report, Revision 9, September 2022;
Waterford Steam Electric Station, Unit 3; Docket No. 50-382;
Renewed Facility Operating License No. NPF-38
2/20/2023
Updated Alert/Notification System Design Report
Emergency Planning 10CFR50.54(q) Review Program
Emergency Operations Facility (EOF) Operations
Emergency Operations Facility (EOF) Operations
EPP-422
Siren and Helicopter Warning System Maintenance
15, 16
Procedures
EPP-424
Siren Testing and Siren System Administrative Controls
21, 22
Miscellaneous
Emergency Preparedness Full Participation Exercise
09/19/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Scenario, Waterford Steam Electric Station, Unit 3
(Waterford 3); Docket No. 50-382; Renewed Facility
Operating License No. NPF-38
Emergency Preparedness Full Participation Exercise
Scenario, Waterford Steam Electric Station, Unit 3
(Waterford 3); Docket No. 50-382; Renewed Facility
Operating License No. NPF-38
08/24/2021
Emergency Preparedness Full Participation Exercise
Scenario, Waterford Steam Electric Station, Unit 3; Docket
No. 50-382; Renewed Facility Operating License No. NPF-
04/24/2023
Emergency Notifications
Emergency Classifications
Recognition and Classification of Emergency Conditions
Procedures
Protective Action Guidelines
Corrective Action
Documents
CR-WF3-YYYY-
NNNN
22-07880, 2023-00128, 2023-0738
Corrective Action
Documents
Resulting from
Inspection
CR-WF3-YYYY-
NNNN
23-13798, 2023-14046
Entergy Operations, Inc., Waterford-3 Steam Electric
Station, Updated Alert/Notification System Design Report
1st Quarter 2023 Red Team EOF Tabletop, 02/01/2023
2/08/2023
1st Quarter 2023 Orange Team EOF Tabletop, 02/08/2023
2/09/2023
1st Quarter 2023 Blue Team EOF Tabletop, 02/15/2023
2/16/2023
WF3 03-21-23 Orange Team Site Drill - DEP Package
03/27/2023
WF3 (Red Team) 2nd 4th Quarter 2022 EOF Tabletop,
11/09/2022
11/10/2022
WF3 2022 2nd 4th Quarter (Orange Team) EOF Tabletop,
11/16/2022
11/17/2022
71151
Miscellaneous
WSXM-LOR-
25DEP
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
WSXM-LOR-231
EXM
23 Cycle 1 Simulator Exam
EN-FAP-EP-005
Emergency Preparedness Performance Indicators
Regulatory Performance Indicator Process
Procedures
EPP-424
Siren Testing and Siren System Administrative Controls
2