ML22124A306
| ML22124A306 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 05/08/2022 |
| From: | John Dixon NRC/RGN-IV/DORS/PBD |
| To: | Ferrick J Entergy Operations |
| References | |
| IR 2022001 | |
| Download: ML22124A306 (17) | |
See also: IR 05000382/2022001
Text
May 8, 2022
Mr. John Ferrick
Site Vice President
Entergy Operations, Inc.
17265 River Road
Killona, LA 70057
SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - INTEGRATED
INSPECTION REPORT 05000382/2022001
Dear Mr. Ferrick:
On March 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at Waterford Steam Electric Station, Unit 3. On April 12, 2022, the NRC inspectors 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.
Two findings of very low safety significance (Green) are documented in this report. One of these
findings 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 the significance or severity of the violation documented in this
inspection report, 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 Waterford Steam Electric Station, Unit 3.
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, Unit 3.
J. Ferrick 2
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,
John L. Dixon, Jr, Chief
Projects Branch D
Division of Operating Reactor Safety
Docket No. 05000382
License No. NPF-38
Enclosure:
Inspection Report 05000382/2022001
Distribution via Listserv
Signed by Dixon, John
on 05/08/22
X SUNSI Review ADAMS: Sensitive Non-Publicly Available Keyword
By: AAS X Yes No X Non-Sensitive X Publicly Available NRC-002
OFFICE ASRI:DORS/D RI:DORS/D BC:DORS/IPAT BC:DORS/EB1 BC:DORS/EB2
NAME CStott AChilds AAgrawal VGaddy NTaylor
SIGNATURE CAS AAC ARA VGG NHT
DATE 05/05/2022 05/05/2022 05/05/2022 05/05/2022 05/05/2022
OFFICE BC:DORS/RCB BC:DORS/OB BC:DRSS/RxIB SPE:DORS/D BC:DORS/D
NAME MHaire HGepford GWarnick ASanchez JDixon
SIGNATURE MSH HJG GW AAS JLD
DATE 05/05/2022 05/05/2022 05/05/2022 05/06/2022 05/08/2022
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number: 05000382
License Number: NPF-38
Report Number: 05000382/2022001
Enterprise Identifier: I-2022-001-0010
Licensee: Entergy Operations, Inc.
Facility: Waterford Steam Electric Station, Unit 3
Location: Killona, LA 70057
Inspection Dates: January 1, 2022, to March 31, 2022
Inspectors: N. Brown, Resident Inspector
D. Childs, Resident Inspector
S. Hedger, Sr Emergency Preparedness Inspector
D. Holman, Sr Physical Security Inspector
A. Patz, Sr Resident Inspector
S. Sanchez, Sr Emergency Preparedness Inspector
C. Stott, Acting Sr Resident Inspector
Approved By: John L. Dixon, Jr., Chief
Projects Branch D
Division of Operating Reactor Safety
Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting an integrated inspection 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.
List of Findings and Violations
Inadequate Work Instructions to Verify Availability of Temporary Emergency Diesel Generator
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.11] - 71152A
Systems FIN 05000382/2022001-01 Challenge the
Open Unknown
The inspectors identified a Green finding associated with the licensees failure to provide
adequate procedures for declaring the availability of the temporary emergency diesel
generator (TEDG). Specifically, Procedure OP-006-010, TEDG Operations, Revision 1 did
not include steps to verify the TEDG enclosure fire dampers open to ensure the availability of
the TEDG. With the fire dampers closed, the TEDG radiator could not provide its cooling
function and the TEDG would be unable to meet its 24-hour mission time.
Failure to Follow Startup Procedure Results in Discharge of Safety Injection Tank into Vessel
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.12] - Avoid 71152A
Systems NCV 05000382/2022001-02 Complacency
Open/Closed
A self-revealed Green finding and associated non-cited violation of Technical
Specification 6.8.1.a, Procedures and Programs, was identified when the licensee failed to
properly implement Procedure OP-010-003, Plant Startup, Revision 356, as required by
Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Revision 2,
Appendix A, Section 2, General Plant Operating Procedures. Specifically, the licensee failed
to follow steps in the startup procedure to open the safety injection tank 1A isolation valve
breaker. The associated isolation valve opened as designed via interlock when a valid
actuation signal was received as pressure increased above 515 psia which resulted in an
unplanned emergency core cooling system discharge into the reactor coolant system.
Additional Tracking Items
Type Issue Number Title Report Section Status
LER 05000382/2021-002-00 Loss of Offsite Power Due to 71153 Closed
2
PLANT STATUS
The unit began the inspection period at rated thermal power. On March 27, 2022, the unit began
coast down operation in preparation of a scheduled refueling outage.
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 performed activities described in IMC 2515, Appendix D, Plant
Status, observed risk significant activities, and completed on-site portions of IPs. 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
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
(1) The inspectors evaluated the adequacy of the overall preparations to protect
risk-significant systems from impending severe weather during a tornado watch on
March 22, 2022.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) Low pressure safety injection system train B while train A was inoperable due to
planned maintenance on January 14, 2022
(2) Instrument air system train B while train A was inoperable due to planned
maintenance on January 25, 2022
(3) Auxiliary component cooling water system train A while train B was inoperable due to
planned maintenance on February 15, 2022
(4) Essential chilled water system train A while train B was inoperable due to emergent
maintenance on February 23, 2022
3
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a
walkdown and performing a review to verify program compliance, equipment functionality,
material condition, and operational readiness of the following fire areas:
(1) Fire Area NS-TB-001, elevation +15.00' turbine building east general area on
January 13, 2022
(2) Fire Area RAB 24-001, elevation +21.00' reactor auxiliary building decontamination
room on February 10, 2022
(3) Fire Area RAB 44-001, elevation +41.00' reactor auxiliary building flex diesel
generator enclosure on February 8, 2022
(4) Fire Area FHB-001, all elevations fuel handling building on February 24, 2022
(5) Fire Area LLRWSF, grade elevation low level radwaste storage facility on
March 24, 2022
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
(1 Sample)
(1) The inspectors observed and evaluated licensed operator performance in the control
room during troubleshooting efforts following a containment spray pump B failure to
start on March 21, 2022.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1) The inspectors observed and evaluated licensed operator performance in the
simulator that involved two dropped control element assemblies and subsequent
manual reactor scram and a small loss of coolant accident inside containment on
February 14, 2022.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following
structures, systems, and components (SSCs) remain capable of performing their intended
function:
(1) Essential services chilled water system on March 5, 2022
(2) Chemical volume control charging pump during week of March 7, 2022
4
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the
following planned and emergent work activities to ensure configuration changes and
appropriate work controls were addressed:
(1) Unplanned action statement entry for Technical Specification 3.8.1.1 for emergency
diesel generator B outage following failure to reach required max load test as
required by the quarterly diesel run during the week of October 29, 2021
(2) Planned yellow risk due to low pressure safety injection pump A and control room
emergency filtration unit A outages during the week of January 10, 2022
(3) Planned yellow risk due to emergency ventilation outages during the week of
January 31, 2022
(4) Planned yellow risk due to auxiliary component cooling water train B outage during
week of February 14, 2022
(5) Planned yellow risk during shutdown cooling heat exchanger inlet valve relay
maintenance on February 28, 2022
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1) Essential services chilled water chiller B operability following a plant service air leak
from the hot gas bypass actuator on February 23, 2022
(2) Auxiliary component cooling water pump B operability following a failure to actuate
during a simulated test actuation on March 21, 2022
(3) Component cooling water pump B after discovery of oil leakage from motor inboard
bearing on March 29, 2022
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system
operability and/or functionality:
(1) Auxiliary component cooling water throttle valve, ACC-126B, following valve controller
maintenance on February 15, 2022
(2) Essential services chilled water chiller B following emergent maintenance after finding
low refrigerant on February 23, 2022
(3) Control room air handling unit train A following planned maintenance on recirculation
damper on March 2, 2022
(4) Chemical volume control charging pump train A following planned overhaul
maintenance on March 10, 2022
(5) Essential services chilled water chiller B following trip due to high chiller compressor
temperature on March 17, 2022
5
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability
and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (5 Samples)
(1) High pressure safety injection pump B on January 26, 2022
(2) Low pressure safety injection pump B on March 14, 2022
(3) Emergency diesel generator B on March 21, 2022
(4) Emergency feedwater pump AB on March 24, 2022
(5) Main steam safety valves train A on March 30, 2022
Inservice Testing (IP Section 03.01) (1 Sample)
(1) Essential services chilled water train B inservice valve test on March 23, 2022
71114.01 - Exercise Evaluation
Inspection Review (IP Section 02.01-02.11) (1 Sample)
(1) The inspectors evaluated the biennial emergency plan exercise conducted on
March 15 and 16, 2022. The exercise scenario simulated a release of asphyxiant gas
in the condenser polisher building, a steam generator tube leak necessitating a
reactor plant shutdown, a steam generator tube rupture, a stuck open main steam
safety valve, indication of fuel failure, and a release of radioactive materials offsite
requiring the issuance of Protective Action Recommendations. The exercise also
included demonstration of one of the stations extensive damage mitigation guideline
strategies per the requirements of 10 CFR 50.155(b)(2).
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) (1 Sample)
(1) January 1, 2021, through December 31, 2021
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (1 Sample)
(1) January 1, 2021, through December 31, 2021
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (1 Sample)
(1) January 1, 2021, through December 31, 2021
6
71152A - Annual Follow-up Problem Identification and Resolution
Annual Follow-up of Selected Issues (Section 03.03) (3 Samples)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issue:
(1) Main steam isolation valve No. 2 actuator piston ring hydraulic fluid leak by since
June 16, 2021
(2) Temporary emergency diesel generator (TEDG) availability after fire suppression
system actuations within TEDG enclosure since August 29, 2021
(3) Safety injection tank 1A injection into RCS during plant heat up on
September 5, 2021
71153 - Follow Up of Events and Notices of Enforcement Discretion
Event Report (IP Section 03.02) (1 Sample)
The inspectors evaluated the following licensee event reports (LERs):
(1) LER 05000382/2021-002-00, Loss of Offsite Power Due to Hurricane Ida (ADAMS
Accession No. ML21327A021). The inspectors determined that it was not reasonable
to foresee or correct the cause discussed in the LER therefore no performance
deficiency was identified. The inspectors did not identify a violation of NRC
requirements.
INSPECTION RESULTS
Inadequate Work Instructions to Verify Availability of Temporary Emergency Diesel Generator
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.11] - 71152A
Systems FIN 05000382/2022001-01 Challenge the
Open Unknown
The inspectors identified a Green finding associated with the licensees failure to provide
adequate procedures for declaring the availability of the temporary emergency diesel
generator (TEDG). Specifically, Procedure OP-006-010, TEDG Operations, Revision 1 did
not include steps to verify the TEDG enclosure fire dampers open to ensure the availability of
the TEDG. With the fire dampers closed, the TEDG radiator could not provide its cooling
function and the TEDG would be unable to meet its 24-hour mission time.
Description: The TEDG is a permanently installed 4MW, 4kV diesel generator installed in an
environmental enclosure located at the southeast side of the turbine building. The enclosure
also contains the TEDG switchgear and fire protection system. The purpose of the TEDG is
to extend the technical specification (TS) allowed outage time for either of the emergency
diesel generators from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 10 days, as allowed by TS 3.8.1.1.
On August 29, 2021, high winds and rain during Hurricane Ida damaged a TEDG enclosure
door allowing water intrusion into the space. This led to a fire suppression system actuation
resulting in the closure of the associated fire dampers. The inspectors determined that an
operator opened the east and west suppression dampers for visibility purposes but did not
7
know about the south end damper, which remained closed. The south end damper is directly
in front of the TEDG radiator which provides a cooling function to the diesel.
Prior to planned surveillance testing of emergency diesel generator B, questions arose during
licensee daily status meetings regarding the ability to credit the TEDG due to the fire
suppression system discharge. On two separate occasions, the response from site leadership
was that the TEDG can still be credited because the fire suppression system is not required
to be operable when crediting the TEDG to extend the allowed outage time. On
October 29, 2021 at 0910, emergency diesel generator B was declared inoperable after
failing a max load test. The licensee readied the TEDG in accordance with Procedure
OP-06-0010, TEDG Operations, Revision 1, to extend the allowed outage time for
emergency diesel generator B from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 10 days, consistent with TS 3.8.1.1. Later
that day at 1605, the licensee declared the TEDG available to extend the allowed outage
time. On November 1, work was completed on the emergency diesel generator B, and it was
tested satisfactory at 1440.
The inspectors questioned the functionality of the temporary emergency diesel generator and
any potential impacts from closed fire dampers. The licensee determined that closing the
south fire suppression damper of the TEDG enclosure would prevent the TEDG from meeting
its 24-hour mission time. Therefore, the licensee should not have credited the TEDG to
extend the allowed outage time of an inoperable emergency diesel generator.
The licensee did not properly establish procedures appropriate to the circumstances for
verifying that the TEDG was available to be credited for the technical specification allowed
outage time. Procedure OP-06-0010, TEDG Operations, did not include steps to verify the
position of the fire dampers prior to declaring the TEDG available. Consequently, on
October 29, 2021, the TEDG was determined to be available during the emergency diesel
generator B outage at a time when it would not be able to meet its 24-hour mission time.
Corrective Actions: The licensee updated Procedure OP-006-010, TEDG Operations, to
include verification that the east and west dampers in the engine room and the single set of
dampers in the south damper room of the TEDG enclosure are verified in the open position to
ensure functionality. The licensee also included language to ensure the correct indication is
referenced for fire protection system status on the fire panel and verify that the gravity
dampers on the south side are passing air after the TEDG is running.
Corrective Action References: Condition Report CR-WF3-2021-6180
Performance Assessment:
Performance Deficiency: The inspectors determined that the failure to provide adequate
procedures for declaring the availability of the TEDG was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Procedure Quality 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, Procedure OP-006-010, TEDG Operations, Revision 1, did not
adequately provide the steps required to ensure TEDG availability.
Significance: The inspectors assessed the significance of the finding using Appendix A, The
Significance Determination Process (SDP) for Findings At-Power. dated November 30, 2020.
8
Specifically, using Exhibit 2, Mitigating Systems Screening Questions, the inspectors
determined that this finding is of very low safety significance (Green), because it did not
represent a loss of a probabilistic risk assessment (PRA) function greater than its allowed TS
allowed outage time, a loss of PRA function for two separate TS systems for greater than
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, a loss of a PRA system or function defined in the Plant Risk Information e-Book or
licensees PRA for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or loss of the PRA function of one or more non-TS
trains of equipment designated as risk-significant in accordance with the licensees
maintenance rule program for greater than 3 days.
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with
uncertain conditions. Risks are evaluated and managed before proceeding. Specifically,
although site leadership questioned the impact of the fire suppression system discharge on
the availability of the TEDG, the question was quickly dispositioned because the fire
suppression system is not required to be operation for the TEDG to perform its design
function. The licensee did not fully understand or further challenge the impacts of the fire
suppression system discharge and subsequent closure of the TEDG fire protection dampers
on the cooling function of the TEDG radiator. This resulted in an extension of the emergency
diesel generator B allowed outage time when it would not be able to meet its 24-hour mission
time.
Enforcement: Inspectors did not identify a violation of regulatory requirements associated with
this finding.
Failure to Follow Startup Procedure Results in Discharge of Safety Injection Tank into Vessel
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.12] - Avoid 71152A
Systems NCV 05000382/2022001-02 Complacency
Open/Closed
A self-revealed Green finding and associated non-cited violation of Technical Specification 6.8.1.a, Procedures and Programs, was identified when the licensee failed to properly
implement Procedure OP-010-003, Plant Startup, Revision 356, as required by Regulatory
Guide 1.33, Quality Assurance Program Requirements (Operation), Revision 2, Appendix A,
Section 2, General Plant Operating Procedures. Specifically, the licensee failed to follow
steps in the startup procedure to open the safety injection tank 1A isolation valve
breaker. The associated isolation valve opened as designed via interlock when a valid
actuation signal was received as pressure increased above 515 psia which resulted in an
unplanned emergency core cooling system discharge into the reactor coolant system.
Description: Procedure OP-010-003, Plant Startup, Revision 356, requires at least three of
the four safety injection tank isolation valves to be open prior to reaching 392 psia in the
reactor coolant system when transitioning from cold shutdown to hot standby. The safety
injection tanks with open isolation valves are kept at a lower pressure than reactor coolant
system during this transition. A series of two check valves per safety injection tank injection
line prevents the rising reactor coolant system pressure from backflowing into the safety
injection tanks. The startup procedure includes steps that allow the isolation of a single safety
injection tank in Modes 3 and 4 if desired, such as a safety injection tank experiencing
in-leakage when a lower differential pressure exists across the check valves. Normally, the
licensee shuts the associated isolation valve and breaker via the startup procedure to ensure
the isolation valve of the isolated safety injection tank does not open upon receipt of the
expected interlock signal as reactor coolant system pressure increases above 515 psia.
9
Additionally, the safety injection tank pressure is raised to within the normal operating band
as required by technical specification 3.5.1, Safety Injection Tanks, for Modes 1 and 2.
On September 5, 2021, the licensee opened all four-safety injection tank isolation valves prior
to entering Mode 4 per the startup procedure. Each safety injection tank isolation valve
breaker was then verified unlocked and shut by the licensee as indicated by the initials in
step 9.1.50 of Attachment 9.1, Heatup to 195°F, of the startup procedure denoting that all
safety injection tank isolation valve breakers were verified unlocked and shut. In a case
where one of the safety injection tank isolation valves was shut, the licensee would have
marked N/A.
While maneuvering the plant toward Mode 4, the licensee identified that safety injection tank
1A did have in-leakage. The licensee then decided to isolate safety injection tank 1A after the
step was already performed to verify the isolation was open. Step 9.2.21.4.8 of
Attachment 9.2, Heatup to Hot Shutdown (Mode 5 to Mode 4), of the startup procedure
states to lock open all safety injection tank isolation valves except if one was previously shut,
in which case that valve should be maintained in the shut position. The licensee
inappropriately used this step to shut the safety injection tank 1A isolation valve; however,
this step did not give instructions to manipulate the valve or to open the associated breaker.
Additionally, there is a caution before step 9.2.21.4.8 which states that pressure in one safety
injection tank may have been raised in Attachment 9.1, and the associated safety injection
tank outlet isolation breaker for this safety injection tank must remain open to prevent an
inadvertent opening of the associated safety injection tank outlet valve when RC pressure is
raised above 515 psia.
After the plant entered Mode 4, reactor coolant system pressure was being raised by the
licensee. When the pressure reached approximately 515 psia, the safety injection tank 1A
isolation valve received a valid open signal from the designed interlock and repositioned
open. Approximately 5.5 percent of its volume, or about 75 gallons, discharged into the
reactor coolant system before the operating crew took control of the valve from the control
room and shut the valve.
Corrective Actions: The licensee created a new step in Attachment 9.2 of
Procedure OP-010 003, Plant Startup, for the intent of ensuring the breaker is open for a
safety injection tank that has been isolated prior to exceeding 515 psia. The licensee also
communicated the event throughout the operating crews and required observations to ensure
procedure use and adherence met expectations.
Corrective Action References: Condition Reports 2021-05242 and 2021-05244
Performance Assessment:
Performance Deficiency: The failure to properly implement Procedure OP-010-003, Plant
Startup, Revision 356, when starting up the reactor was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Human Performance 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 licensee did not open the breaker for the associated isolation
valve for safety injection tank 1A as the pressure of the reactor coolant system was raised to
515 psia. As a result, the safety injection tank isolation valves all received signals to open,
10
which caused safety injection tank 1A to reposition and inadvertently discharge into the
Significance: The inspectors assessed the significance of the finding using Appendix A, The
Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, Mitigating
Systems Screening Questions, the inspectors determined the finding to be of very low safety
significance (Green), because it did not represent a loss of a probabilistic risk assessment
(PRA) function greater than its allowed technical specification allowed outage time, a loss of
PRA function for two separate TS systems for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, a loss of a PRA system
or function defined in the Plant Risk Information e-Book or licensees PRA for greater than
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or loss of the PRA function of one or more non-TS trains of equipment designated
as risk-significant in accordance with the licensees maintenance rule program for greater
than 3 days.
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the
possibility of mistakes, latent issues, and inherent risk, even while expecting successful
outcomes. Individuals implement appropriate error reduction tools. Specifically, the licensee
performed the startup procedure with all the safety injection tanks operable but failed to
recognize and properly plan for the possibility of isolating one safety injection tank in the
middle of the procedure.
Enforcement:
Violation: Technical Specification 6.8.1.a requires, in part, that written procedures shall be
established, implemented, and maintained in accordance with Appendix A of Regulatory
Guide 1.33, Revision 2, February 1978, Section 2, General Plant Operating
Procedures. The licensee established Procedure, OP-010-003, Plant Startup,
Revision 356, to meet Regulatory Guide 1.33 requirements.
Contrary to the above, on September 5, 2021, the licensee failed to properly implement
Procedure OP-010-003, Plant Startup. Specifically, the licensee failed to follow the
appropriate steps in the startup procedure to open the breaker for the associated safety
injection tank 1A isolation valve prior to reaching 515 psia which caused an emergency core
cooling system discharge into the reactor coolant system.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On March 31, 2022, the inspectors presented the emergency preparedness exercise
inspection results to Mr. J. Ferrick, Site Vice President and other members of the
licensee staff.
On April 12, 2022, the inspectors presented the integrated inspection results to
Mr. J. Ferrick, Site Vice President and other members of the licensee staff.
11
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.01 Procedures OP-901-521 Severe Weather and Flooding 338
71111.04 Miscellaneous SD-AIR Air Systems System Description 15
71111.04 Procedures OP-002-001 Auxiliary Component Cooling Water 317
OP-002-004 Chilled Water System 323
OP-003-106 Instrument Air 32
OP-009-008 Safety Injection System 47
71111.05 Fire Plans FHB-001 Fuel Handling Building +46.00', +21.00', +1.00', -35.00' 10
Elevations
LLRWSF Low Level Radwaste Storage Facility 3
NS-TB-001 Turbine Building +15.00' Elevation 16
RAB 24-001 RAB +21 Decon Area 8
RAB 3A-001 Reactor Auxiliary Building +69.00' Elevation 16
RAB 3A-002 Reactor Auxiliary Building +46.00' Elevation 4
RAB 3A-003 Reactor Auxiliary Building +21.00' Elevation 4
RAB 44-001 Flex Diesel Generator Enclosure 2
71111.11Q Procedures EP-001-001 Recognition and Classification of Emergency Conditions 36
71111.12 Corrective Action CR-WF3-YYYY- 2022-1235, 2022-1242
Documents NNNN
71111.12 Miscellaneous TD-G045.0025 Charging Pumps Technical Instruction Manual 6
71111.12 Procedures EN-DC-203 Maintenance Rule Program 5
EN-DC-204 Maintenance Rule Scope and Basis 7
EN-DC-205 Maintenance Rule Monitoring 8
71111.13 Procedures EN-WM-104 On Line Risk Assessment 23
ME-003-410 Motor-Operated Valve Thermal Overload Channel 311
Calibration
OI-037-000 Operations' Risk Assessment Guideline 317
OP-100-009 Control of Valves and Breakers 43
71111.13 Work Orders 535719
Work orders for 52927408, 52869231, 52919526
emergency diesel
generator A
12
Inspection Type Designation Description or Title Revision or
Procedure Date
outage
Work orders for 52946441, 52741847, 52936697, 52930193, 52950675,
emergency 52925848
ventilation
outages
71111.15 Corrective Action CR-WF3-YYY- 2022-1562, 2022-1041, 2022-1720
Documents NNNN
71111.15 Procedures EN-OP-104 Operability Determination Process 17
OP-903-068 Emergency Diesel Generator and Subgroup Relay 326
Operability Verification
71111.19 Procedures OP-002-004 Chilled Water System 323
OP-002-005 Chemical and Volume Control 70
OP-003-014 Control Room Heating and Ventilation (HVC) 310
OP-903-003 Charging Pump Operability Check 313
OP-903-118 Primary Auxiliaries Quarterly IST Valve Tests 61
OP-903-118 Primary Auxiliaries Quarterly IST Valve Tests 61
STA-001-005 Leakage Testing of Air and Nitrogen Accumulators for Safety 326
Related Valves
71111.19 Work Orders Work Orders 535719, 574913
71111.22 Procedures MM-007-015 Main Steam Safety Valve Test 330
OP-009-002 Emergency Diesel Generator 360
OP-903-030 Safety Injection Pump Operability Verification 41
OP-903-030 Safety Injection Pump Operability Verification 41
OP-903-046 Emergency Feed Pump Operability Check 323
OP-903-118 Primary Auxiliaries Quarterly IST Valve Tests 61
71111.22 Work Orders Work Orders 52945674, 52991737, 52992666
71114.01 Corrective Action Condition Reports 2020-5153, 2020-5154, 2020-1325, 2020-7333, 2021- 0040,
Documents CR-WF3-YYYY- 2021-1825, 2021-2170, 2021-2171, 2021-2287, 2021-4678,
NNNN 2021-4805, 2021-7125, 2022-00651, 2022-0930,
2022-01454, 2022-01478, 2022-01512, 2022-01513,
2022-01675, 2022-1430
71114.01 Procedures EN-EP-202 Equipment Important to Emergency Response (EITER) 3
EN-EP-306 Drills and Exercises 11
13
Inspection Type Designation Description or Title Revision or
Procedure Date
EN-EP-308 Emergency Planning Critiques 7
EN-EP-313 Offsite Dose Assessment Using the Unified RASCAL 4
Interface
EN-EP-603 Emergency Notifications 1
EN-EP-609 Emergency Operations Facility (EOF) Operations 6
EN-EP-611 Operations Support Center (OSC) Operations 6
EP-002-050 Offsite Dose Assessment 308
EP-002-052 Protective Action Guidelines 27
EP-7-ALL Emergency Preparedness Forms 2
S-SAMG-01 Loss of Large Areas of the Plant Due to Fire/Explosion 23
71151 Corrective Action CR-WF3-YYYY- 2021-1172, 2021-1629, 2021-1682, 2021-2201, 2021-2347
Documents NNNN
71151 Miscellaneous W3F1-2021-0033 NRC Performance Indicator (PI) Data - QR (Quarterly 4/15/2021
Report) ROP 1st Quarter 2021
W3F1-2021-0052 NRC Performance Indicator (PI) Data - 2nd Quarter 2021 7/22/2021
W3F1-2021-0066 NRC Performance Indicator (PI) Data - 3rd Quarter 2021 10/19/2021
W3F1-2022-0002 NRC Performance Indicator (PI) Data - 4th Quarter 2021 1/19/2022
71152A Corrective Action CR-WF3-YYYY- 2005-01836, 2022-00049, 2022-00223, 2022-00334,
Documents NNNN 2022-00464, 2022-02846, 2021-03182, 2021-04165,
2021-04210, 2021-04231, 2021-04522, 2021-04874,
2021-04902, 2021-04922, 2021-05071, 2021-05102,
2021-05128, 2021-05146, 2021-05423, 2021-05481,
2021-05879, 2021-05901, 2021-05916, 2021-05957,
2021-05919, 2021-06369, 2021-06383, 2021-06397,
2021-06573, 2021-06635, 2021-06660, 2021-07129,
2021-07189, 2021-07224, 2022-00095, 2021-5242
71152A Engineering EC-0000090407 Operability Input for CR-WF3-2021-03182 06/16/2021
Changes
71152A Procedures OP-009-005 Shutdown Cooling 44
OP-009-008 Safety Injection System 46
OP-010-003 Plant Startup 356
14