IR 05000382/2019010
| ML19179A065 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 06/28/2019 |
| From: | Nick Taylor NRC/RGN-IV/DRS/EB-2 |
| To: | Dinelli J Entergy Operations |
| Taylor N | |
| References | |
| IR 2019010 | |
| Download: ML19179A065 (14) | |
Text
June 28, 2019
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - DESIGN BASIS ASSURANCE INSPECTION (PROGRAMS) INSPECTION REPORT 05000382/2019010
Dear Mr. Dinelli:
On May 23, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford Steam Electric Station, Unit 3, 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 involved a violation of NRC requirements. 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 significance of the NCV, 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 the 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Nicholas H. Taylor, Chief Engineering Branch 2 Division of Reactor Safety
Docket No. 50-382 License No. NPF-38
Enclosure: Inspection Report 05000382/2019010
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number:
05000382
License Number:
Report Number:
Enterprise Identifier: I-2019-010-0040
Licensee:
Entergy Operations, Inc.
Facility:
Waterford Steam Electric Station, Unit 3
Location:
Killona, Louisiana
Inspection Dates:
May 6, 2019, to May 23, 2019
Inspectors:
R. Kopriva, Senior Reactor Inspector
J. Braisted, Reactor Inspector
C. Smith, Health Physicist
Approved By:
Nicholas H. Taylor, Chief
Engineering Branch 2
Division of Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (programs)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. NRC-identified and self-revealed findings, violations, and additional items are summarized in the table below.
List of Findings and Violations
Failure to Identify and Evaluate Storage and Shelf-Life Requirements Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000382/2019010-01 Open/Closed None (NPP)71111.21N The inspectors identified a Green finding and associated non-cited Violation (NCV) of Title 10 of the Code of Federal Regulations 10 CFR Part 50, Appendix B, Criterion V, Instructions,
Procedures, and Drawings, for the licensees failure to identify and evaluate storage and shelf-life requirements in accordance with a quality licensee procedure.
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 - Design Bases Assurance Inspection (Programs)
The inspectors evaluated the licensee's equipment Environmental Qualification program implementation through the sampling of the following components:
Select Sample Components to Review - Primary Containment (Inside Containment)
(IP Section 02.01)===
- (1) RC IHTE0111-A, Reactor Coolant Level Monitor Heated Junction Thermocouple Channel 1
- (2) RC ITE0112-HA1, Reactor Coolant Loop 1 Hot Leg Temperature Resistance Temperature Detector
- (3) SG ILT1125-B, Steam Generator 2 Level Indicator
Select Sample Components to Review - Risk Significant/Low Design (Inside/Outside
Containment) (IP Section 02.01) (7 Samples)
- (1) ACCEMTR3A, Auxiliary Component Cooling Pump Motor
- (2) AMNAAA110, Auxiliary Component Cooling Pump Discharge Valve
- (4) CC ISV0413-A, Emergency Diesel Generator A Heat Exchangers Component Cooling Water Outlet Isolation Valve Solenoid
- (5) CC ISV0823-A, Containment Fan Cooler A Component Cooling Water Outlet Isolation Valve Solenoid
- (6) RC IPT9120-A, Pressurizer Pressure Wide Range Reactor Coolant System Pressure Transmitter
INSPECTION RESULTS
Failure to Identify and Evaluate Storage and Shelf-Life Requirements Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000382/2019010-01 Open/Closed
None (NPP)71111.21N The inspectors identified a Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to identify and evaluate storage and shelf-life requirements in accordance with a quality licensee procedure.
Description:
The inspectors reviewed storage and shelf-life requirements for the selected samples. The inspectors noted that the vendor manual for a Rosemount 1154 flow transmitter stated to Store all spare transmitters and spare component parts in accordance with ANSI N45.2.2 level B. Furthermore, the vendor manual stated that Qualified transmitters, spare circuit boards, spare O-rings: the qualified life (as defined in Qualification Test Report D8400102) plus the shelf-life is equal to the typical design life of the plant (40 years) when the ambient storage temperature is below 90 °F.
The inspectors inquired as to whether these restrictions were in place for storage of transmitters which were procured for use in applications requiring environmental qualification. The licensee confirmed that the transmitter was stored in a warehouse (7B) that conformed to ANSI Level B requirements, but that the 7B warehouse was not specifically climate controlled to maintain temperatures below 90 degrees Fahrenheit. The 7B warehouse was controlled between 40 and 140 degrees Fahrenheit with the temperature monitoring system alarming when temperatures exceed 122 degrees Fahrenheit.
Licensee Procedure EN-MP-125, Control of Material, Revision 12, is a quality procedure which identified that all inventories currently in stock and available for issue are expected to meet the requirements of ANSI N45.2.2-1972, Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants. ANSI N45.2.2, Section 6.1.2, Levels of Storage, stated that Minimum temperature shall be 40 degrees Fahrenheit and maximum temperature shall be 140 degrees Fahrenheit or less if so stipulated by a manufacturer for items classified Level B.
Licensee Procedure EN-DC-313, Procurement Engineering Process, Revision 15, is also a quality procedure which required that Receipt discrepancies that require technical disposition are documented using an Over Short Damaged Discrepant (OSD&D) initiated by Receiving personnel and forwarded to Procurement Engineering for disposition. Subsequently, Procedure EN-DC-313 required that The disposition may be documented within the discrepant document (OSD&D) if the disposition does not change the technical and quality requirements of the item. When changes to the technical or quality requirements are required, a Procurement Engineering Evaluation is performed.
The licensees purchase orders (POs) for Rosemount transmitters specified that they shall be certified to ANSI N45.2.2 Level B storage. However, Rosemount did not take exception to the PO clause related to the storage requirement, and during the receipt inspection, the licensee did not identify the more-restrictive temperature storage requirements (i.e., a receipt discrepancy) stated in the vendor manual and, therefore, did not perform a procurement engineering evaluation for technical disposition of the difference. (Procedure EN-DC-313 would also have required a procurement engineering evaluation had the vendor documented an exception). Additionally, other Rosemount transmitter model vendor manuals stated that the temperature requirement is -40 to 120 degrees Fahrenheit and less than 90 degrees Fahrenheit to avoid having any potential adverse impact on the qualified life of installed transmitters.
Therefore, the inspectors determined that the licensee did not accomplish activities affecting quality in accordance with Procedure EN-DC-313. Specifically, the licensee did not identify and perform an evaluation of the more-restrictive, vendor-specified temperature storage requirements to ensure that the transmitters would be stored in a manner which preserved their qualified life.
Corrective Actions: The licensee reviewed temperature monitoring data covering a period of 1 year and verified that the average daily temperature within the 7B warehouse, where the transmitters were stored, did not exceed 90 degrees Fahrenheit and that temperatures had not exceeded 120 degrees Fahrenheit either.
Corrective Action References: CR-WF3-2019-04661
Performance Assessment:
Performance Deficiency: The licensees failure to identify and evaluate storage and shelf-life requirements in accordance with a quality licensee procedure was a performance deficiency. Specifically, the licensee failed to evaluate the more-restrictive, vendor-specified, temperature storage requirements of Rosemount transmitters to ensure that they were stored in an appropriate location.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, failing to identify and evaluate vendor-specified storage and shelf-life requirements for any equipment that requires environmental qualification could lead to that equipment being stored such that its qualified life could be shortened (without the licensees knowledge) and render it unable to perform its specified safety function.
Significance: The inspectors assessed the significance of the finding using Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations. Utilizing Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined the finding was of very low safety significance (Green) because the finding was a deficiency affecting the design or qualification of a mitigating structure, system, or component (SSC) and the SSC maintained its operability or functionality.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion V, required, in part, that 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. Licensee Procedure EN-DC-313, Procurement Engineering Process, Revision 15, is a quality procedure that provided instructions for performing procurement engineering evaluations when a receipt discrepancy was identified that required technical disposition.
Contrary to the above, on November 5, 2015, the licensee did not ensure that activities affecting quality were accomplished in accordance with prescribed procedures. Specifically, the licensee failed to identify a receipt discrepancy and perform a procurement engineering evaluation for technical disposition in accordance with Procedure EN-DC-313 when the licensee received transmitters whose vendor-specified storage and shelf-life requirements were different than anticipated.
Enforcement Action: This violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
On May 23, 2019, the inspectors presented the Inspection Procedure 71111.21N, design basis assurance inspection (programs) to Mr. J. Dinelli, Site Vice President, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.21N Calculations
EC-S90-14
Containment Pressure and
Temperature Response
0, 1, 2
EC-S94-007
Containment Temperature
Monitoring and Trending - Fuel
Cycle 6
Drawings
B-424, Sht
7545
Entergy Operation Inc, Waterford
S.
- E.S. Unit 3, Control Wiring
Diagram ACCW Pump A
Discharge Line Isolation Valve
G-M-0001
Radiation and Temperature
Charts
G-M-00010
Environmental Zone Map
T.P.H.C.S. Reactor Bldg.
Plan El. +49
G-M-0005
Environmental Zone Map
T.P.H.C.S. Reactor Aux. Bldg.
Plan El. +21
G-M-0009
Pressure and Temperature Profile
for Annulus and Containment
G-M-0015
Waterford Steam Electric Station
Environmental Zone Map
Radiation, Reactor Aux, Bldg.
Plan -4.00
G-M-0016
Waterford Steam Electric Station
Environmental Zone Map
Radiation, Reactor Aux, Bldg.
Plan -35.00
Engineering
Changes
0000007153
Approve use of MOV Long Life
Grease in Limitorque Motor
Actuators
0000039941
Update TD-F130.0035
Section 1.04 with August 2012
and Areva ACC/CC Replacement
Motor
0000044455
Comparison of PO 10379607 for
Replacement of Existing Allis
Chalmers ACCW Pump Motor 'A'
with Siemens Motor Purchased
from Areva
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
0000080325
Resolve Right Type of Oil for
Containment Spray Pump Motors
Comparison Between Mobil
DTE797 Oil with Exxonmobil DTE
2 Oil
0000081320
Update EQMI-4.02 and
LPLEQA4.2B to Include the
Replacement Oil Mobil DTE-732
as a Replacement for DTE-797
Evaluated in EC 80325 for The
Containment Motors at WF3
0000082386
CR-WF3-2018-05994 Resolution
Update of LPLEQA4.2B and
EQMI-4.2 for ACCW Motors
5000084904
EQMI 4.2 Document Update
Per Evaluation
ER-W3-1999-0989-00-01
Miscellaneous
Field Notification Concerning the
Qualified Life of ASCO Catalog
NP-1 Valves
08/27/1993
Qualified Life Manual Calculation
Report
08/11/2004
00809-0100-
4514
Rosemount 1154 Alphaline
Nuclear Pressure Transmitter
BA
1989
Report
Clarification of Information Related
to the environmental Qualification
of Limitorque Motorized Valve
Operators
08/1989
3017-
335951-4
Installation/Instruction/Operation
Manual
351R2
Investigation into Eliminating the
Use of Lubricants on the NP
Series of Valves
05/25/2004
763-6
ITT Barton Model 763 Gage
Pressure Electronic Transmitter
AQR-67368
ASCO Catalog NP-1 Solenoid
Valves for Safety-Related
Applications in Nuclear Power
Generating Stations
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
D8400102
Qualification Report for Pressure
Transmitters Rosemount
Model 1154
G
Control of Material
ER-W3-
2006-0314-
000
Prime Transmitter Connector
Assembly Replacement Parts
LO-WLO-
2017-00079
Environmental Qualification (EQ)
Program Assessment
2/28/2018
LPL-EQA-
03.02
ASCO NP-1 Solenoid Valves
LPL-EQA-
08.01B
Rosemount 1154 Transmitters
LPL-EQA-
08.02A
ITT Barton Model 763 Gage
Transmitters
LPL-EQA-
08.02C
ITT Barton Model 764 & 352
Transmitters
LPL-EQA-
3.1A
Environmental Qualification
Assessment on Limitorque
Actuators (SMB Series with Class
B Motors) used in the Waterford
S.E.S. Unit 3
LPL-EQA-
39.04
Weed Resistance Temperature
Detector Models N9004E-2B,
N9004S-2A-CL, and SPN9004E-
LPL-EQA-
4.2B
Environmental Qualification
Assessment on Allis-Chalmers
Form Wound Motors used in the
Waterford S.E.S. Unit 3
LPL-EQMI-
01.00
Environmental Qualification
Installation Configurations
LPL-EQMI-
03.02
ASCO NP-1 Solenoid Valves
LPL-EQMI-
04.02
Allis Chalmers Form Wound
Motors
LPL-EQMI-
08.01
Rosemount Model 1153 Series A,
B, & D; 1154 & 1154 Series H
Transmitters and 1159 Remote
Seals
LPL-EQMI-
Cameron Electronic Transmitters
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
08.02
(Previously ITT Barton
Instruments)
LPL-EQMI-
3.1
EQ Maintenance Input for
Limitorque Actuators used in the
Waterford S.E.S. Unit 3
LPL-EQMI-
39.04
Weed Resistance Temperature
Detector Models N9004E-2B,
N9004S-2A-CL, and SPN9004E-
MAI-421430
Header to RC Loop 1B Flow
Control Valve
10/29/2000
ME-004-
330-1
4KV Induction Motor Maintenance
303
NQ 890339-
Equipment Qualification for
Class 1E Safety-Related Service
in Power Generation Stations
Outside containment
PO-WF3-
10379607
Purchase Order - 300 HP, Safety-
Related Motor, Electric 300 HP
Report
B0003
Appendix D of Report B0058,
Qualification Type Test Report
Limitorque Valve Actuators for
Class 1E Service Outside Primary
Containment in Nuclear Power
Station Service
01/23/1975
Report
B0058
Limitorque Valve Actuator
Qualification for Nuclear Power
Station Service
01/11/1980
Report
B0119
Qualification Type Test Report of
Multi-Point Terminal Strips for use
in Limitorque Valve Actuators for
PWR Service
07/01/1982
SIMS-1108
Document Revision Input Form
03/03/1997
SIMS-1115
Document Revision Input Form
11/26 1997
TD
A610.0155
ASCO Installation and
Maintenance Instructions for
3-Way Solenoid Valves
Series 8316
TD-
I204.0045
ITT Barton Technical Manual
Model 763 Gage Pressure
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Electronic Transmitter
TD-
L200.0025
Limitorque Corporation Updates
TD-
L200.0035
Limitorque Corporation Updates
TD-
L200.0045
Limitorque Corporation Updates
TD-
L200.0055
Limitorque Corporation Updates
TD-
L200.0205
Limitorque Corporation Updates
TD-
L200.0215
Limitorque Corporation Updates
TD-
L200.0225
Limitorque Corporation Updates
TD-
L200.0265
Clarification of Information Related
to the Environmental Qualification
of Limitorque Motorized Valve
Operators
08/1989
TD-
S188.0015
Siemens Areva Horizontal
Induction Motors
Procedures
Environmental Qualification
Program
Environmental Qualification
Master List Control
Procurement Engineering Process
Preventive Maintenance Program
Offline Motor Electrical Testing
Shelf-Life Program
Operating Experience Program
ME-004-
703-0
Routine Electrical Equipment
Inspection and Maintenance
ME-007-
2-0
ME-007-
008-0
Motor Operated Valves
ME-007-
047-0
VOTES Testing of MOVs
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
ME-007-
057-0
MCE/EMAX Data Acquisition
309
OP-003-003
Condensate
310
OP-903-050
Component Cooling Water and
Auxiliary Component Cooling
Water Pump and Valve Operability
Test
OP-903-
100-0
MOV Overload Bypass Test
310
OP-903-121
Safety Systems Quarterly IST
valve Tests
SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword: NRC-002
By: RAK Yes No
Publicly Available Sensitive
OFFICE
SRI:EB1
RI:EB1
HP:RIB
C:EB2
C:PBD
C:EB2
NAME
RKopriva
JBraisted
CSmith
NTaylor
JDixon
NTaylor
SIGNATURE
/RA/
/RA/
/RA/
/RA/
/RA/
/RA/
DATE
6/26/2019
6/25/2019
6/25/2019
6/27/2019
6/27/2019
6/28/2019