ML22217A008

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Regulatory Conference - NRC Slides (Enc 2)
ML22217A008
Person / Time
Site: Waterford Entergy icon.png
Issue date: 07/29/2022
From:
NRC Region 4
To:
References
EA-22-033
Download: ML22217A008 (23)
v • d • e


Text

Nuclear Regulatory Commission Regulatory Conference Entergy Operations, Inc.

Waterford Steam Electric Station, Unit 3 USNRC Region IV Friday, July 29, 2022 To hear the audio portion of this presentation, dial 1-888-324-8110 and enter participant code # 9931673.

Meeting Logistics

  • Operation of WebEx and Bridge Line
  • Please MUTE cellular phones
  • Scheduled break (15-minute)
  • NRC caucus (Team Meetings)
  • Public Question Session
  • Question session between NRC and the public (at close of business portion of meeting; not discussion with the licensee)
  • How to ask questions? -Press *1 on phone to raise hand, then await for the Moderator to acknowledge you To hear the audio portion of this presentation, dial 1-888-324-8110 and enter participant code # 9931673.

Agenda Topic Participants NRC Opening Remarks and Introductions John Monninger Licensee Opening Remarks and Introductions Entergy Operations (Entergy) /

Waterford Steam Electric Station, Unit 3 (Waterford 3)

Regulatory Conference Process Geoff Miller Summary of the Issues, White Finding, Violations Sean Hedger Performance Deficiency and NRCs Dispositioning Process Mark Haire Possible Outcomes and Licensee Appeal Rights Jeremy Groom Licensee Presentation Entergy / Waterford 3 Staff Questions and Discussion NRC and Licensee Participants Break and NRC Caucus (via Teams Meeting)

NRC and Licensee Participants Questions and Discussion NRC and Licensee Participants Licensee Closing Remarks Entergy / Waterford 3 Staff NRC Closing Remarks John Monninger Public Question and Answer Session Public Attendees MEETING AGENDA To hear the audio portion of this presentation, dial 1-888-324-8110 and enter participant code # 9931673.

NRC Principal Participants To hear the audio portion of this presentation, dial 1-888-324-8110 and enter participant code # 9931673.

Name Title John Monninger RIV Deputy Administrator Geoff Miller RIV DRSS Deputy Director Jeremy Groom RIV ACES Team Leader Mark Haire DRSS/RCB Chief Sean Hedger DRSS/RCB Sr. EP Inspector

Entergy Operations Inc.

Opening Remarks / Introductions To hear the audio portion of this presentation, dial 1-888-324-8110 and enter participant code # 9931673.

Name Title Bill Maguire Chief Operating Officer, Nuclear Operations John Ferrick Site Vice President John Jarrell Director, Regulatory & Performance Improvement Stephenie Pyle Director, Regulatory Compliance John Giddens Senior Manager, Fleet Regulatory Assurance John Lewis Regulatory Assurance Manager Billy Steelman Engineering Systems &

Components Manager Dean Burnett Director, Emergency Planning Stephen Smith Operations Manager, Shift

Purpose of Regulatory Conference

  • The NRC normally provides an opportunity for a licensee to address apparent violations before the NRC takes escalated enforcement action, or makes a final decision on the significance.

and gain their perspective on the apparent violations.

  • The significance assessment determines whether an escalated enforcement action will be considered (i.e., a Notice of Violation associated with a white, yellow, or red SDP finding). Licensee input during this conference is also considered in making a final decision.

To hear the audio portion of this presentation, dial 1-888-324-8110 and enter participant code # 9931673.

Todays Meeting

  • No Final Decision on safety significance or enforcement action will be made today.
  • Our NRC Inspection Report provided our current understanding and perspective on the issue.
  • We Want Your Perspective
  • Any additional details NRC should consider
  • Whether findings/violations occurred
  • Perceived significance of the findings/violations
  • Corrective actions implemented and/or Planned Timeline To hear the audio portion of this presentation, dial 1-888-324-8110 and enter participant code # 9931673.

Public Meeting Disclaimer The public is invited to observe the meeting and will have one or more opportunities to communicate with the NRC after the business portion, but before the meeting is adjourned.

To hear the audio portion of this presentation, dial 1-888-324-8110 and enter participant code # 9931673.

Summary of the Waterford 3 Wide Range Gas Monitor Issue The NRC became aware that the licensee identified calibration and maintenance issues with several of their wide range gas monitors (WRGMs) on January 18, 2022, based on review of entries in their correction action program. It was determined that incorrect calibration and engineering conversion factors for the condenser exhaust WRGM had been in place since January 1, 2011.

The condenser exhaust WRGM was used by emergency preparedness for implementation of EALs, as well as currently for an input to radiological dose projection modeling software.

The cumulative effects of the errors on emergency preparedness functions were evaluated for the condenser WRGM.

Errors would result in the radiation monitor reading roughly 70% higher than it should if it was reading correctly.

Effects - EALs up to and including a General Emergency being classified when not warranted by the emergency conditions. In addition, in the event that a radiological release occurs through the main condenser vent path, the dose projection process for radiological releases would be higher than they should by the same percentage. This does not appear to meet the requirement to provide for a technically adequate estimate of material releases or projected offsite doses.

Time conditions existed: From January 1, 2011 to February 4, 2022 With the available information, the NRC determined that the failure to maintain the correct function of the main condenser WRGM equipment was performance deficiency.

To hear the audio portion of this presentation, dial 1-888-324-8110 and enter participant code # 9931673.

Waterford 3 Failure to Maintain Accurate EAL Thresholds and Dose Assessment Methods NRC issued a Choice Letter to Waterford 3 on June 11, 2022 (ML22159A275; EA-22-033)

To hear the audio portion of this presentation, dial 1-888-324-8110 and enter participant code # 9931673.

Performance Deficiency

  • Per our understanding, the failure to maintain correct function of the condenser WRGM equipment was a performance deficiency. By not maintaining correct calibration and engineering conversion factors, it resulted in (a) not establishing and maintaining adequate EALs, and (b) the incapability, in some cases, of providing a technically adequate estimate of offsite doses using their dose assessment process. The effects adversely impacted the ability to classify a potential emergency condition associated with effluent releases accurately and in a timely manner, as well as the capability to accurately estimate offsite releases.

To hear the audio portion of this presentation, dial 1-888-324-8110 and enter participant code # 9931673.

Reactor Oversight Process:

Significance Determination Process To hear the audio portion of this presentation, dial 1-888-324-8110 and enter participant code # 9931673.

IMC 0609, Appendix B:

Emergency Preparedness Significance Determination Process To hear the audio portion of this presentation, dial 1-888-324-8110 and enter participant code # 9931673.

Significance Examples - Emergency Action Levels To hear the audio portion of this presentation, dial 1-888-324-8110 and enter participant code # 9931673.

Significance Examples - Dose Assessment Examples To hear the audio portion of this presentation, dial 1-888-324-8110 and enter participant code # 9931673.

Apparent Violation 10 CFR 50.54(q)(2) requires, in part, that a holder of a license under 10 CFR Part 50 shall follow and maintain the effectiveness of an emergency plan that meets the requirements in 10 CFR Part 50, Appendix E, and the planning standards of 10 CFR 50.47(b).

10 CFR 50.47(b)(4) requires, in part, that a standard emergency classification and action level scheme is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.

10 CFR 50.47(b)(9) requires, in part, that adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

Contrary to the above, from January 1, 2011, to February 4, 2022, the licensee failed to follow and maintain the effectiveness of an emergency plan which met the requirements in 10 CFR Part 50 Appendix E and the planning standards of 10 CFR 50.47(b). Specifically, the licensee failed to maintain a standard emergency classification scheme as required by 10 CFR 50.47(b)(4) because PRM-IRE-0002 had errors in its output that could result in an over-classification up to a General Emergency, resulting in unnecessary public protective actions. Also, the licensee failed to use adequate methods, systems, and equipment for assessing and monitoring actual and potential offsite consequences of a radiological emergency as required by 10 CFR 50.47(b)(9), because those same errors would result in inaccurate dose assessments for a radiological release through the main condenser exhaust path.

Possible Outcomes

  • The NRC determines there is no violation resulting in no enforcement action.
  • The NRC determines the apparent violations are of very low safety significance resulting in non-escalated enforcement (Green Non-Cited Violation).
  • The NRC determines the apparent violations are of low to moderate safety significance resulting in escalated enforcement (a White Finding and an associated Notice of Violation).

To hear the audio portion of this presentation, dial 1-888-324-8110 and enter participant code # 9931673.

Licensee's Appeal Rights

  • A licensee has the right to challenge any NRC determination/action that may be presented.
  • Instructions for challenging a NRC enforcement action are included in our transmittal letter and the action itself.

To hear the audio portion of this presentation, dial 1-888-324-8110 and enter participant code # 9931673.

Entergy Operations/Waterford 3 Presentation Agenda (Insert When Provided)

To hear the audio portion of this presentation, dial 1-888-324-8110 and enter participant code # 9931673.

NRC and Entergy/Waterford 3 Staff Q&A Session To hear the audio portion of this presentation, dial 1-888-324-8110 and enter participant code # 9931673.

NRC Regulatory Conference with Entergy Operations Waterford 3 NRC Caucus in Session Returning Shortly To hear the audio portion of this presentation, dial 1-888-324-8110 and enter participant code # 9931673.

Conference Closing Remarks

  • Entergy / Waterford 3s Closing Remarks
  • NRCs Closing Remarks
  • Next Steps / Expectations
  • The platform is now OPEN to questions from our public attendees PLEASE press *1 on your phone and await the Moderator to announce you.

To hear the audio portion of this presentation, dial 1-888-324-8110 and enter participant code # 9931673.

Any Questions from the Public Attendees?

(Please press *1 on your phone to identify yourself and await the Moderator)

To hear the audio portion of this presentation, dial 1-888-324-8110 and enter participant code # 9931673.

ML22217A008

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