05000382/LER-2020-001, (Waterford 3), Violation of Technical Specification 3.3.3.7.3.a (Broad Range Gas Detection) Due to Operators and Maintenance Technicians Not Performing Procedure Step as Intended

(Waterford 3), Violation of Technical Specification 3.3.3.7.3.a (Broad Range Gas Detection) Due to Operators and Maintenance Technicians Not Performing Procedure Step as Intended

ML20128J906
Person / Time
Site:	Waterford
Issue date:	05/07/2020
From:	Wood P Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2020-0027 LER 2020-001-00
Download: ML20128J906 (6)

LER-2020-001, (Waterford 3), Violation of Technical Specification 3.3.3.7.3.a (Broad Range Gas Detection) Due to Operators and Maintenance Technicians Not Performing Procedure Step as Intended

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)
3822020001R00 - NRC Website

text

Entergy Operations, Inc.

17265 River Road Killona, LA 70057-3093 Tel (504) 464-3786 Paul Wood Manager, Regulatory Assurance 10 CFR 50.73 W3F1-2020-0027 May 7, 2020 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 The enclosed report is being sent pursuant to 10 CFR 50.73.

This letter contains no new regulatory commitments.

If you have any questions or require additional information, please contact the Regulatory Assurance Manager, Paul Wood, at (504) 464-3786.

Respectfully, Paul Wood PIW/jkb

Subject:

Licensee Event Report (LER) 2020-001-00 Violation of Technical Specification 3.3.3.7.3.a (Broad Range Gas Detection)

Due to Operators and Maintenance Technicians Not Performing Procedure Step as Intended 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 2020-001-00 cc:

NRC Region IV Regional Administrator NRC Senior Resident Inspector - Waterford Steam Electric Station, Unit 3 NRR Project Manager

ENCLOSURE W3F1-2020-0027 Entergy Operations, Inc.

Waterford 3 Licensee Event Report 2020-001-00

NRC FORM 366 (04-2020)

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION (04-2020)

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: 04/30/2020

1. FACILITY NAME Waterford Steam Electric Station, Unit 3

2. DOCKET NUMBER 05000382

3. PAGE 1 OF 4

4. TITLE Violation of Technical Specification 3.3.3.7.3.a (Broad Range Gas Detection) Due to Operators and Maintenance Technicians Not Performing Procedure Step as Intended

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 03 18 2020 2020 -

001

- 00 05 07 2020 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 A faulty assumption by operators and maintenance technicians lead to the inappropriate use of procedure EN-HU-102 to justify not performing a conditional step.

A. Completed Corrective Actions

1)

Update procedure MI-003-500 with a note that removal of actuation relays during this procedure will reset the Isolation signal for the associated train. The intent of this action is to add guidance in MI-003-500 that the removal of actuation relays during this procedure will reset the isolation signal for the associated train.

B. Planned Corrective Actions

1)

Update the work order impact statement for maintenance involving MI-003-500 with information that removal of the actuation relays during this procedure will reset the isolation signal for the associated train

2)

Evaluate procedure MI-003-500 to determine if there is a reason to remove actuation relays beyond the practice of preventing control room HVAC isolation while testing Chlorine Monitors A or B. The evaluation is to determine the feasibility of including an option to perform Chlorine Monitor Functional Testing without removal of actuation relays when control room ventilation in isolation must be maintained.

3)

Perform reviews of maintenance surveillances or tests that could lead to accidental actuation of other ventilation system valves to determine if work on these items could accidentally actuate valves and cause them to fail in a manner which would result in loss of control room isolation or recirculation.

4)

Perform an evaluation of testing or maintenance of select dual function valves to determine if any current testing or maintenance configurations on other components and equipment within the valves system would cause a loss of signal that would result in loss of isolation due to valve failure.

SAFETY EVALUATION The actual consequences as stated in the problem statement was that the Control Room Normal Ventilation outside air intake valves opened, which resulted in not complying with TS 3.3.3.7.3.a action. There were no other actual consequences to general safety of the public, nuclear safety, industrial safety or radiological safety for this event. These valves were closed by the control room operators in a short period of time.

There were no potential consequences to the general safety of the public, nuclear safety, industrial safety or radiological safety. Broad Range Gas Monitor A and Chlorine Monitor A remained operable at the time and would have functioned to close the outside air intake valves if an actual toxic chemical emergency would have occurred.

The risk if no action is taken is low. The basis for this determination is as follows: The chemical detection systems are the chlorine and broad range toxic gas detection systems. The operability of the chemical detection systems ensures that sufficient capability is available to promptly detect and initiate protective action in the event of an accidental chemical release. The chemical detection systems provide prompt detection of toxic gas releases which could pose an actual threat to safety of the nuclear power plant or significantly hamper site personnel in performance of duties necessary for the safe operation of the plant. Since one Train of BRGM and Chlorine Monitor remained operable, there was no potential for control room operator duties to be impacted by a toxic chemical event.

As an immediate/interim/mitigating action to reduce the frequency or consequence (pending implementation of final actions), the implementing procedure was revised to clearly state the required action and intent of the procedure step to reset the isolation signal to the Control Room Ventilation system.

PREVIOUS OCCURRENCES

A review of Waterford 3 condition reports for previous similar events over the past 3 years was performed.

LER 2019-006-00: Unplanned Loss of Both Trains of Broad Range Gas Monitors Results in a Condition that Could Have Prevented Fulfillment of a Safety Function. On June 25, 2019, at 0428, Waterford 3 declared both Broad Range Gas Monitor (BRGM) channels inoperable and the control room emergency air filtration system was manually placed in isolate mode at 0441 to comply with the 1-hr action requirement of Technical Specification (TS) 3.3.3.7.3, "Broad Range Gas Detection." With both BRGM channels declared inoperable, TS 3.7.6.1, "Control Room Emergency Air Filtration," was not met. For the 13 minutes prior to the control room being manually isolated, the Control Room Envelope Boundary was inoperable, resulting in an event or condition that could have prevented fulfillment of a safety function.

LER 2018-002-00: Unplanned Loss of a Train of Control Room Outside Air Intake Radiation Monitors Results in a Condition Prohibited by Technical Specifications. This condition was identified during an extent of condition review in response to LER 2018-001, Failure to Enter Limiting Condition of Operation Action Statement due to Lack of Procedure Guidance Results in a Condition Prohibited by Technical Specifications, to determine if there were other instances of misapplication of Surveillance Requirement 4.0.1 leading to a reportable condition.

Note: Energy Industry Identification System (EIIS) codes and component codes are identified in the text as [XX].