W3F1-2023-0014, Reply to a Notice of Violation; EA-22-119

Reply to a Notice of Violation; EA-22-119

ML23051A002
Person / Time
Site:	Waterford
Issue date:	02/20/2023
From:	Ferrick J Entergy Operations
To:	Office of Nuclear Reactor Regulation, NRC Region 4, Document Control Desk
References
W3F1-2023-0014, EA-22-119, IR 2023090
Download: ML23051A002 (1)

Text

S) entergy John Ferrick Site Vice President Waterford Steam Electric Station, Unit 3 504-739-6660 W3F1-2023-0014 10 CFR 2.201 February 20, 2023 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Reply to a Notice of Violation; EA-22-119 Waterford Steam Electric Station, Unit 3 NRC Docket No. 50-382 Renewed Facility Operating License No. NPF-38

Reference:

NRC letter to Entergy, "Waterford Steam Electric Station, Unit 3 - Final Significance Determination of a White Finding, Notice of Violation, and Follow-Up Assessment Letter; NRC Inspection Report 05000382/2023090," (ADAMS Accession No. ML23025A384), dated February 1, 2023 In accordance with 10 CFR 2.201, Entergy Operations, Inc. (Entergy) hereby submits the Reply to a Notice of Violation, EA-22-119, for Waterford Steam Electric Station, Unit 3 (Waterford 3).

As requested, the Enclosure contains the following: (1) the reason for the violation; (2) the corrective steps that have been taken and the results achieved; (3) the corrective steps that will be taken; and (4) the date when full compliance will be achieved.

This letter contains no new commitments.

Should you have any questions concerning this issue, please contact Leia Milster, Manager, Regulatory Assurance, at 504-739-6250.

Respectfully, John Ferrick JF/ lem Entergy Operations, Inc., 17265 River Road, Killona, LA 70057

W3F1-2023-0014 Page 2 of 2

Enclosure:

Reply to a Notice of Violation; EA-22-119 cc: NRC Region IV Regional Administrator NRC Senior Resident Inspector - Waterford Steam Electric Station, Unit 3 NRC Project Manager-Waterfo rd Steam Electric Station, Unit 3 Louisiana Department of Environmental Quality R4Enforcement@nrc.gov

Enclosure W3F1-2023-0014 Reply to a Notice of Violation; EA-22-119

W3F1-2023-0014 Enclosure Page 1 of 3 Entergy Operations, Inc.

Reply to Notice of Violation EA-22-119 In U.S. Nuclear Regulatory Commission (NRC) letter to Entergy Operations, Inc. (Entergy),

"Waterford Steam Electric, Unit 3 - Final Significance Determination of a White Finding, Notice of Violation, and Follow-Up Assessment Letter; NRG Inspection Report 05000382/2023090,"

(ADAMS Accession No. ML23025A384), dated February 1, 2023, the NRG issued Notice of Violation EA-22-119 to Entergy's Waterford Steam Electric Station, Unit 3 (Waterford 3) as restated below:

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)(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 June 6 to September 9, 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 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 the licensee had conversion factor errors that would result in inaccurate dose assessments for a radiological release through the plant vent stack exhaust path.

Pursuant to the provisions of 10 CFR 2.201, this enclosure provides Entergy's reply to Notice of Violation EA-22-119.

W3F1-2023-0014 Enclosure Page 2 of 3

1) Reason for the Violation On September 8, 2022, the Radiation Monitoring System (RMS) engineer identified that the Wide Range Gas Monitor (WGRM) for the plant stack, PRMIRE0110, high-range engineering conversion factor had been revised to an incorrect value. This error was discovered during an engineering change review of Waterford 3 Process and Effluent Radiation Monitor Range Basis Calculation. Specifically, the high range detector engineering conversion factor (ECF), Cl-11, had been reloaded with the incorrect value on June 6, 2022. The incorrect value was reloaded because the RMS Control Room database manual had not been revised after the calibration work that occurred in February 2022. This resulted in the plant stack WRGM high range detector being out of calibration starting on June 6, 2022.

A Root Cause Evaluation was performed and determined the configuration control process outlined in UNT-007-029, Control of the Radiation Monitoring System Database, had not been consistently implemented for the RMS to ensure complete, accurate, and up-to-date information is contained in the RMS databases and associated documentation prior to returning the equipment to service which is important to emergency response.

2) Corrective Steps That Have Been Taken and the Results Achieved Entergy took appropriate action by updating the Control Room database manual with the correct ECFs and the monitors were recalibrated and returned to service on September 9, 2022.

The Corrective Action to Prevent Recurrence (CAPR) was to revise maintenance Radiation Monitoring procedure's Calibration Instructions to incorporate database controls for radiation detector monitor and channel item(s). These actions specifically included:

• Ensuring maintenance instructions are sufficient to maintain that the RMS Database or Databases are complete, accurate, and up-to-date for all monitor and channel items prior to return of equipment to service.

• Defining and establishing engineering reviews of databases changes to ensure engineering concurs with changes and impact reviews are complete prior to return to service as required.

• Defining and establishing reviewer and supervisor roles to ensure requirements and process execution for ensuring that the database change process is being implemented and updated as required .

The updated procedures and instructions provide the necessary clarity to ensure that Radiation Monitoring System issues are promptly identified and corrected.

3) Corrective Steps That Will Be Taken No additional actions are necessary.

W3F 1-2023-0014 Enclosure Page 3 of 3

4) Date When Full Compliance Will Be Achieved Full compliance was achieved when the Plant Stack WRGM high-range detector was recalibrated and returned to service on September 9, 2022.