IR 05000382/2024011

State Fire Protection Team Inspection Report 05000382/2024011

ML24274A079
Person / Time
Site:	Waterford
Issue date:	10/01/2024
From:	Nick Taylor NRC/RGN-IV/DORS/EB2
To:	Sullivan J Entergy Operations
References
IR 2024011
Preceding documents:	ML24150A385 (4 June 2024)
Download: ML24274A079 (12)

Text

October 1, 2024

SUBJECT:

WATERFORD STEAM ELECTRIC STATION - FIRE PROTECTION TEAM INSPECTION REPORT 05000382/2024011

Dear Joseph Sullivan:

On August 20, 2024, 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.

One finding of very low safety significance (Green) is documented in this report. This finding did not involve a violation of NRC requirements.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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, Nicholas H. Taylor, Chief Engineering Branch 2 Division of Operating Reactor Safety Signed by Taylor, Nicholas on 10/01/24 Docket No. 05000382 License No. NPF-38

Enclosure:

As stated

Inspection Report

Docket No. 05000382

License No. NPF-38

Report Number: 05000382/2024011

Licensee: Entergy Operations, Inc.

Facility: Waterford Steam Electric Station

Location: Killona, LA

Inspection Dates: July 08, 2024 to August 20, 2024

Inspectors: S. Makor, Senior Reactor Inspector T.Dinh, Fire Protection Engineer J. Mejia, Reactor Inspector A. Saunders, Reactor Inspector

Approved By: Nicholas H. Taylor, Chief Engineering Branch 2 Division of Operating Reactor Safety

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a fire protection team 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 Ensure Minimum Flow Through the Start-up and Main Transformer Deluge System Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.3] - 71111.21N.

Systems FIN 05000382/2024011-01 Resolution 05 Open/Closed A self-revealed Green finding was identified when the licensee failed to comply with a self-imposed standard and code of record, NFPA 15-1973, "Water Spray Fixed Systems for Fire Protection." Specifically, the licensee failed to ensure the transformer deluge system provided more than 0.25 gpm per square foot of water to the surface of the main and start-up transformers to minimize the impact of fires.

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.05 - Fire Protection Team Inspection (FPTI)

Structures, Systems, and Components (SSCs) Credited for Fire Prevention, Detection, Suppression, or Post-Fire Safe Shutdown Review (IP Section 03.01)===

The inspectors verified that components and/or systems will function as required to support the credited functions stated for each sample. Additional inspection considerations are in the fire hazards analysis (FHA) or safe shutdown analysis (SSA).

(1) Ensured Switchgear Room RAB8-A Fire Area manual and recovery actions could be completed as assumed in licensing documents.

(2) Verified the Component Cooling Water System time critical and manual actions could be accomplished as assumed in licensing documents.

(3) Performed walk downs of fire pumps to verify material conditions and that appropriate actions are taken to manage aging.

(4) Verified pre-action sprinklers installation per code by reviewing analysis, calculations, and performing physical observations.

(5) Inspected probabilistic risk assessment (PRA) configuration control (PCC) using the Operating Experience Smart Sample (OpESS) 2023-02 to verify that the licensee has a process in place to reasonably ensure PCC activities.

Fire Protection Program Administrative Controls (IP Section 03.02) (2 Samples)

The inspectors verified that the selected control or process is implemented in accordance with the licensees current licensing basis. If applicable, ensure that the licensees fire protection program (FPP) contains adequate procedures to implement the selected administrative control. Verify that the selected administrative control meets the requirements of all committed industry standards.

(1) Combustible Control Program and Fire Impairment Program

(2) Fire Brigade Drills, Training, and Qualifications

Fire Protection Program Changes/Modifications (IP Section 03.03) (6 Samples)

The inspectors verified the following:

a. Changes to the approved FPP do not constitute an adverse effect on the ability to safely shutdown.

b. The adequacy of the design modification, if applicable.

c. Assumptions and performance capability stated in the SSA have not been degraded through changes or modifications.

d. The FPP documents, such as the Updated Final Safety Analysis Report, fire protection report, FHA, and SSA were updated consistent with the FPP or design change.

e. Post-fire safe shutdown operating procedures, such as abnormal operating procedures, affected by the modification were updated.

(1) EC 77544, Replaced the existing broad range gas monitors with two ascent control module 150 air composition monitors and two RAEGuard 2 Photoionization Detectors (PIDs)

(2) EC 82601, Installed two miniature uninterruptible power supply panels within the skid area of essential chiller B and essential chiller AB

(3) EC 89638, Provided a new offsite power source for the admin buildings, primary access point, and supplemental chiller switchgear

(4) EC 90778, Installed a new turbine control & protection system room on Elevation +40' of the turbine building that supports the replacement of turbine control system

(5) EC 92374, Upgraded the WF3 site owner-controlled area intrusion detection system

(6) EC 89727, Replaced Automatic Sprinkler Company of America deluge valve

INSPECTION RESULTS

Failure to Ensure Minimum Flow Through the Start-up and Main Transformer Deluge System Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.3] - 71111.21N.0 Systems FIN 05000382/2024011-01 Resolution 5 Open/Closed A self-revealed Green finding was identified when the licensee failed to comply with a self-imposed standard and code of record, NFPA 15-1973, "Water Spray Fixed Systems for Fire Protection." Specifically, the licensee failed to ensure the transformer deluge system provided more than 0.25 gpm per square foot of water to the surface of the main and start-up transformers to minimize the impact of fires.

Description:

During the fire protection team inspection, the inspectors reviewed the site response to the automatic reactor trip due to a catastrophic failure and subsequent fire on the main transformer B. Specifically, the inspectors reviewed the main transformer deluge systems response to the event and determined that the deluge system was not maintained and tested appropriately as required by its design basis.

Waterford is committed to NFPA 15-1973, as described in their updated final safety analyses report. The licensee translated the NFPA 15-1973 requirement of a minimum of 0.25 gpm per square foot of water into the site procedures and calculations. Specifically, for both EC-F02-004, Hydraulic Calculation - Sprinkler Systems for Start-Up Transformers, Rev 1 and EC-F02-003, Hydraulic Calculation for Sprinkler System in Aux Transformers, Rev 1, it is noted in Section 2, Conclusion and Section 4, Input Criteria, in both calculations that the systems were calculated to deliver a density of 0.25 gpm per square foot and the system design criterion is 0.25 gpm per square foot over the protected area based on NFPA 15-1973.

Starting in 2021, multiple issues were identified on both deluge systems including deluge valve leakage, and as a result, the deluge system was tagged out and isolated December 2, 2023. At the time of the fire, March 21, 2024, the deluge system was still tagged out and did not actuate as expected. Additionally, the transformer fire drill package dated March 27, 2024, noted that the deluge system was tagged out and an attempt was made to realign but did not prove effective. As a result, the lack of deluge system made the fire response more complicated for the fire brigade.

Corrective Actions: The licensee repaired/replaced the damaged fire sprinkler system and upgraded the piping to provide 40 percent more margin in flow. Additionally, the site has work orders to fix the train A deluge system.

Corrective Action References: CR-WF3-2022-04528 and CRWF3-2024-01330

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensees failure to ensure the minimum amount of deluge system flow as required by NFPA 15-1973, was a performance deficiency. Specifically, the licensee had not replaced deficient components in a timely manner that impacted the suppression response during an event.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors 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 nonfunctioning deluge system affected the fire protection defense in depth strategy involving suppression/minimization of fire damage reducing the strategy to safely shutdown the facility (minimize the fire impact). Additionally, the inspectors reviewed IMC 0612, Appendix E, Minor Examples, and determined that the performance deficiency was similar to the more than minor examples for 12.B and 12.D in Section 12, "External Events."

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. Using Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, the inspectors determined that the degraded condition affected the mitigating system cornerstone, external event (Fire).

From Table 3, "SDP Appendix Router," the inspectors determined that the finding involved a fixed fire protection systems or the ability to confine a fire and proceeded to Inspection Manual Chapter 0609, Appendix F. Using the guidance of Inspection Manual Chapter 0609, Appendix F, Attachment 2, the deficiency was determined to have a high degradation rating because the deluge system did not function as designed. From the phase 1 worksheet, the inspectors determined that this performance deficiency affected fixed fire protection systems (category 1.4.2), however, the condition required no further analysis because the degraded deluge system is not credited and does not adversely impact the ability for the licensee to safely shutdown ("No" to question 1.4.2-A).

Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to address issues in a timely manner commensurate with their safety significance. The inspectors determined that the licensee failed to properly evaluate the risk of operating for prolonged periods of time with the transformer deluge system tagged out.

Enforcement:

The inspectors did not identify a violation of regulatory requirements associated with this finding.

EXIT MEETINGS AND DEBRIEFS

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

• On August 20, 2024, the inspectors presented the fire protection team inspection results to Joseph Sullivan and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.21N.05 Calculations ECF14-029 WF3 Fire Safety Analysis - Fire Area RAB-23 2

ECF91-025 Combustible Loading Calculation for Fire Area RAB-23 3

Corrective Action CR-WF3-2021-02262, 2021-05235, 2022-03147, 2024-01400,

Documents 2024-02582

CR-WF3-2023-Internal Inspection of Dry Piping for Fire Suppression 09/06/2023

15405 System FPM-3A

Drawings G285SH 02 Main One Line Diagram 4.16 KV Paralleling Switchgear 01

G289_0_029 Main One Line Diagram 029

Engineering EC-0054076686 Functionality Determination for Fire Suppression System 0

Changes FPM-3A, A Revision to EC-0054070683

EC-0054083296 Functionality Determination for Fire Suppression System 0

FPM-17

EC-0054084007 Functionality Determination for Fire Suppression System 0

FPM-18

EC-0054087372 Functionality Determination for Fire Suppression System 0

FPM-4B

EC-0054087373 Functionality Determination for Fire Suppression System 0

FPM-25B

EC-0054087375 Functionality Determination for Fire Suppression System 0

FPM-29

Engineering PSA-WF3-03-Waterford 3 Fire PRA Quantification Report 0

Evaluations FQ-01

PSA-WF3-03-Waterford 3 Fire PRA Summary Report 0

FQ-02

PSA-WF3-03-Waterford 3 Main Control Room Abandonment HRA 0

FSS-08 Analysis

PSA-WF3-07-01 Re-Examination of external Evaluation in the IPEEE 1

WF3-FP-10- WF3 Code Compliance Report for NFPA 20 "Centrifugal 001

00015 Fire Pumps"

WF3-FP-13-Recovery Action Feasibility & Reliability Review 1

00003

Procedures EN-DC-115 Engineering Change Process 034

Inspection Type Designation Description or Title Revision or

Procedure Date

EN-DC-127 Control of Hot Work and Ignition Sources 22

EN-DC-128 Fire Protection Impact Reviews 015

EN-DC-136 Temporary Modifications 023

EN-DC-161 Control of Combustibles 26

EN-DC-313 Procurement Engineering Process 022

EN-DC-330 Fire Protection Program 010

EN-NE-G-034 Fire PRA Maintenance and Use 001

EN-OP-115 Conduct of Operations 034

EN-OP-123 Time Critical Action Program Standard 008

FP-001-015 Fire Protection Systems Impairments 330

ME-003-009 Fire-Rated Walls, Floors, and Ceilings 312

ME-003-100 Fire Pump Diesel Starting Battery 015

ME-003-110 Fire Pump Diesel Starting Battery (Quarterly) 012

ME-003-120 Fire Pump Diesel Starting Battery (18 Month) 010

ME-004-476 Fire Pump Diesel Starting Battery 013

ME-004-476 Fire Pump Diesel Starting Battery 013

ME-013-021 Fire Pump Diesel, Auxiliary Diesel and EOF Emergency 013

Diesel Starting Battery

Replacement

NS-YD-003 YNS-YD-003 Transformer Yard Pre-Fire Plan 14

OP-009-004 Fire Protection 327

OP-901-502 Evacuation of Control Room and Subsequent Plant 043

Shutdown

OP-901-524 Fires in Areas Affecting Safe Shutdown 18

OP-903-055 Fire Main Flush and Hydrant Inspection 12

RAB 8A-001 Switchgear Room A RAB 8A-001 014

UNT-005-013 Fire Protection Program 14

W3-DBD-018 10 CFR 50.48 Fire protection Level Design Basis 003

Document

WFAM-OPS-FBL Waterford 3 Fire Brigade Leader Familiarization Guide 0

WLP-FPFB-Fire Brigade Leader/Incident Commander Initial and 10

FBL02 Refresher

WLP-FPFB-Fire Brigade Safety Systems Training 4

Inspection Type Designation Description or Title Revision or

Procedure Date

FBS04

WLP-OPS-500 Series Off Normal Procedures 032

WLP-OPS-FP00 Fire Protection System 26

WLP-OPS-Off-Normal Procedures: 009

PPO00

WLP-OPS-Evacuation of Control Room and Subsequent Plant 031

PPO51 Shutdown

Self-LO-WLO-2022-Pre-NRC Triennial Fire Protection Inspection Self- 0

Assessments 00085 Assessment

9