05000382/LER-2019-001, Past Inoperability of Effluent Accident Monitor Exceeds Allowed Outage Time Resulting in Condition Prohibited by Technical Specifications
| ML19042A787 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 02/11/2019 |
| From: | Signorelli J Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| W3F1-2019-0010 LER 2019-001-00 | |
| Download: ML19042A787 (6) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(b)(5) |
| 3822019001R00 - NRC Website | |
text
Entergy Operations, Inc.
17265 River Road Killona, LA 70057-3093 Tel 504-739-6032 John V. Signorelli Manager, Regulatory Assurance (Acting) 10 CFR 50.73 W3F1-2019-0010 February 11, 2019 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 The attached report is being sent pursuant to 10 CFR 50.73. A supplemental report to LER 2019-001-00 is expected to be submitted by April 30, 2019 to provide the safety significance determination that is not yet complete.
There are no regulatory commitments contained in this correspondence.
If you have any questions or require additional information, please contact the Acting Regulatory Assurance Manager, John V. Signorelli, at (504) 739-6032.
Respectfully, John V. Signorelli JVS/rd cc:
NRC Region IV Regional Administrator NRC Senior Resident Inspector - Waterford Steam Electric Station, Unit 3 NRR Project Manager
Subject:
Licensee Event Report (LER) 2019-001-00 Past Inoperability of Effluent Accident Monitor Exceeds Allowed Outage Time Resulting in Condition Prohibited by Technical Specifications Waterford Steam Electric Station, Unit 3 (Waterford 3)
NRC Docket No. 50-382 Renewed Facility Operating License No. NPF-38
Enclosure:
Waterford 3 Licensee Event Report 2019-001-00
ENCLOSURE W3F1-2019-0010 Entergy Operations, Inc.
Waterford 3 Licensee Event Report 2019-001-00
NRC FORM 366 (06-2016)
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION (04-2018)
LICENSEE EVENT REPORT (LER)
(See Page 2 for required number of digits/characters for each block)
(See NUREG-1022, R.3 for instruction and guidance for completing this form http://www.nrc/gov/reading-rm/doc-collections/nuregs/staff/sr1022/r3/)
APPROVED BY OMB: NO. 3150-0104 EXPIRES: 03/31/2020 Estimated burden per response to comply with this mandatory collection request: 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />.
Reported lessons learned are incorporated into the licensing process and fed back to industry.
Send comments regarding burden estimate to the Information Services Branch (T-2 F43), U.S.
Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150-0104), Office of Management and Budget, Washington, DC 20503. If a means used to impose an information collection does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
- 1. FACILITY NAME Waterford Steam Electric Station, Unit 3
- 2. DOCKET NUMBER 05000382
- 3. PAGE 1 OF 4
- 4. TITLE Past Inoperability of Effluent Accident Monitor Exceeds Allowed Outage Time Resulting in Condition Prohibited by Technical Specifications
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR SEQUENTIAL NUMBER REV NO.
MONTH DAY YEAR FACILITY NAME DOCKET NUMBER 12 13 2018 2019 -
001
- - 00 02 11 2019 FACILITY NAME DOCKET NUMBER
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply) 1 20.2201(b) 20.2203(a)(3)(i) 50.73(a)(2)(ii)(A) 50.73(a)(2)(viii)(A) 20.2201(d) 20.2203(a)(3)(ii) 50.73(a)(2)(ii)(B) 50.73(a)(2)(viii)(B) 20.2203(a)(1) 20.2203(a)(4) 50.73(a)(2)(iii) 50.73(a)(2)(ix)(A) 20.2203(a)(2)(i) 50.36(c)(1)(i)(A) 50.73(a)(2)(iv)(A) 50.73(a)(2)(x)
- 10. POWER LEVEL 20.2203(a)(2)(ii) 50.36(c)(1)(ii)(A) 50.73(a)(2)(v)(A) 73.71(a)(4) 100 20.2203(a)(2)(iii) 50.36(c)(2) 50.73(a)(2)(v)(B) 73.71(a)(5) 20.2203(a)(2)(iv) 50.46(a)(3)(ii) 50.73(a)(2)(v)(C) 73.77(a)(1) 20.2203(a)(2)(v) 50.73(a)(2)(i)(A) 50.73(a)(2)(v)(D) 73.77(a)(2)(i) 20.2203(a)(2)(vi) 50.73(a)(2)(i)(B) 50.73(a)(2)(vii) 73.77(a)(5)(ii) 50.73(a)(2)(i)(C)
OTHER (Specify in Abstract below or in the actual air flow of the FHB ventilation system. These formulas for the traverse air flow measurement contain the area of the orifice plates that are bypass inlets into the FHB ventilation system.
The change to the orifice plate area that was made via engineering change ER-W3-2004-0518 did not get incorporated into the work order for measuring the FHB ventilation system traverse air flow. The engineering change was approved February 25, 2005; the 'A' Train orifice plate was re-sized on August 31, 2008 and the 'B' Train orifice plate was re-sized on August 23, 2017.
The engineering change was implemented for Train A on August 31, 2008, however, use of the incorrect orifice size was not discovered until October 1, 2018. Upon researching the past operability, it was determined this error did not affect the WRGM calibration until January 16, 2017, as the prior calibrations and air flow measurements were either performed using an alternative method or with HVF201A damper closed; thus the error affected operability of the FHB WRGM from January 16, 2017 to November 30, 2018 exceeding the allowed outage time per Technical Specification 3.3.3.1. This condition is reportable pursuant to 10 CFR 50.73(a)(2)(i)(B).
CORRECTIVE ACTIONS
The model work order for performing the air flow measurement was revised to correct the air flow calculation by using the actual orifice area.
The model work order will be revised to remove the steps for taking FHB ventilation system air flows and include these instructions in mechanical maintenance procedure MM-003-047, which will include a note to verify orifice plate sizes in the field.
SAFETY SIGNIFICANCE
There were no actual consequences due to this condition prohibited by TS. If during the period that the FHB WRGM was inoperable a radiological event had occurred in the Fuel Handling Building and the FHB emergency filtration units were initiated, the magnitude of the release would be underestimated by the FHB WRGM. There were no other actual consequences to safety of the general public, nuclear safety, industrial safety and radiological safety for this event.
The significance of the effect on the emergency classification if there had been an event is being evaluated and will be reported in a planned follow up LER.
BASIS FOR REPORTABILITY This event is reportable pursuant to 10 CFR 50.73(a)(2)(i)(B):
Any operation or condition which was prohibited by the plants Technical Specifications except when:
(1) The Technical Specification is administrative in nature; (2) The event consisted solely of a case of a late surveillance test where the oversight was corrected, the test was performed, and the equipment was found to be capable of performing its specified safety functions; or (3) The Technical Specification was revised prior to discovery of the event such that the operation or condition no longer prohibited at the time of the discovery of the event.
ADDITIONAL INFORMATION
10 CFR 50.73(b)(5) states that this report shall contain reference to any previous similar events at the same plant that are known to the licensee. NUREG 1022 reporting guidance states that term previous occurrences should include previous events or conditions that involved the same underlying concern or reason as this event, such as the same root cause, failure, or sequence of events.
A review of the Waterford Steam Electric Station corrective action program and LERs for the previous three years was performed and no similar events were found to be applicable.