Text

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
	Download: ML24274A079 (12)
	v • d • e

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

Enterprise Identifier:

I-2024-011-0000

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

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 Aspect Report Section Mitigating Systems Green FIN 05000382/2024011-01 Open/Closed

[P.3] -

Resolution 71111.21N.

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)

Main article: IP 71111.21

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 Aspect Report Section Mitigating Systems Green FIN 05000382/2024011-01 Open/Closed

[P.3] -

Resolution 71111.21N.0 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

Procedure

Type

Designation

Description or Title

Revision or

Date

ECF14-029

WF3 Fire Safety Analysis - Fire Area RAB-23

Calculations

ECF91-025

Combustible Loading Calculation for Fire Area RAB-23

CR-WF3-

21-02262, 2021-05235, 2022-03147, 2024-01400,

24-02582

Corrective Action

Documents

CR-WF3-2023-

15405

Internal Inspection of Dry Piping for Fire Suppression

System FPM-3A

09/06/2023

G285SH 02

Main One Line Diagram 4.16 KV Paralleling Switchgear

Drawings

G289_0_029

Main One Line Diagram

29

EC-0054076686