ML23312A183
| ML23312A183 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/14/2023 |
| From: | John Dixon NRC/RGN-IV/DORS/PBD |
| To: | Sullivan J Entergy Operations |
| Sanchez A | |
| References | |
| IR 2023003 | |
| Download: ML23312A183 (26) | |
See also: IR 05000382/2023003
Text
November 14, 2023
Joseph Sullivan, Site Vice President
Entergy Operations, Inc.
17265 River Road
Killona, LA 70057
SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - INTEGRATED
INSPECTION REPORT 05000382/2023003 AND NOTICE OF VIOLATION
Dear Joseph Sullivan:
On September 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at Waterford Steam Electric Station, Unit 3. On October 16, 2023, 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 inspection report.
The enclosed report discusses a violation associated with a finding of very low safety
significance (Green). The NRC evaluated this violation in accordance with Section 2.3.2 of the
NRC Enforcement Policy, which can be found at http://www.nrc.gov/about-
nrc/regulatory/enforcement/enforce-pol.html. The violation is cited in Enclosure 1, Notice of
Violation (Notice). The violation did not meet the criteria to be treated as a non-cited violation
because Entergy Operations, Inc. (licensee) failed to periodically calibrate and process radiation
monitors in a timely manner to restore compliance from the previous non-cited violation.
Specifically, the licensee failed to ensure that instruments (33 area and radiation monitors) and
equipment used for quantitative radiation measurements were calibrated periodically for the
radiation measured.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. If you have additional information that you
believe the NRC should consider, you may provide it in your response. The NRCs review of
your response will also determine whether further enforcement action is necessary to ensure
your compliance with regulatory requirements.
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.
J. Sullivan 2
If you disagree with a cross-cutting aspect assignment 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.
This letter, its enclosures, 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,
Signed by Dixon, John
on 11/14/23
John L. Dixon, Jr., Chief
Reactor Projects Branch D
Division of Operating Reactor Safety
Docket No. 05000382
License No. NPF-38
Enclosures:
1) Notice of Violation
2) Inspection Report 05000382/2023003
cc w/ encl: Distribution via LISTSERV
X Non-Sensitive X Publicly Available
X SUNSI Review
Sensitive Non-Publicly Available
OFFICE SRI:DRP/D RI:DRP/D SES:ACES SPE:DORS/D
NAME APatz/ADP AChilds JKramer ASanchez/AAS
DATE 11/08/23 11/13/23 11/09/23 11/08/23
OFFICE BC:DORS/D DD:DRSS
NAME JDixon TBloomer
DATE 11/14/23 11/13/23
NOTICE OF VIOLATION
Entergy Operations, Inc. Docket No. 05000382
Waterford Steam Electric Station, Unit 3 License No. NPF-38
During an NRC inspection conducted from July 1 through September 30, 2023, a violation of
NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation
is listed below:
10 CFR 20.1501(c) states, in part, that the licensee shall ensure that instruments and
equipment used for quantitative radiation measurements are calibrated periodically for
the radiation measured.
Contrary to the above, from November 2021 to September 30, 2023, the licensee failed
to ensure that instruments (radiation monitors) and equipment used for quantitative
radiation measurements were calibrated periodically for the radiation measured.
Specifically, the licensee failed to periodically calibrate 33 area and process radiation
monitors.
This violation is associated with a Green significance determination process finding.
Pursuant to 10 CFR 2.201, Entergy Operations, Inc. is hereby required to submit a written
statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control
Desk, Washington, DC 20555-001, with a copy to the Regional Administrator, U.S. Nuclear
Regulatory Commission, Region IV, 1600 East Lamar Blvd., Arlington, Texas 76011-4511, and
the NRC Resident Inspector at Waterford Steam Electric Station, Unit 3 and email it to
R4Enforcement@nrc.gov within 30 days of the date of the letter transmitting this Notice of
Violation. This reply should be clearly marked as a Reply to a Notice of Violation, NRC
Inspection Report 05000382/2023003, and should include for the violation: (1) the reason for
the violation, or, if contested, the basis for disputing the violation or severity level; (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.
Your response may reference or include previous docketed correspondence if the
correspondence adequately addresses the required response. If an adequate reply is not
received within the time specified in the Notice of Violation, the NRC may issue an order or a
demand for information requiring you to explain why your license should not be modified,
suspended, or revoked, or why such other action as may be proper should not be taken. Where
good cause is shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with
your basis for denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory
Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room and from the NRCs ADAMS, accessible from the NRC website at
http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not include any
personal privacy or proprietary information so that it can be made available to the public without
redaction.
Enclosure 1
If personal privacy or proprietary information is necessary to provide an acceptable response,
then please provide a bracketed copy of your response that identifies the information that
should be protected and a redacted copy of your response that deletes such information. If you
request that such material is withheld from public disclosure, you must specifically identify the
portions of your response that you seek to have withheld and provide in detail the bases for your
claim (e.g., explain why the disclosure information will create an unwarranted invasion of
personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for
withholding confidential commercial or financial information).
In accordance with 10 CFR 19.11, you are required to post this Notice of Violation within 2
working days of receipt.
Dated this 14th day of November 2023
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U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket No. 05000382
License No. NPF-38
Report No. 05000382/2023003
Enterprise Identifier: I-2023-003-0009
Licensee: Entergy Operations, Inc.
Facility: Waterford Steam Electric Station, Unit 3
Location: Killona, LA 70057
Inspection Dates: July 1, 2023, to September 30, 2023
Inspectors: C. Alldredge, Health Physicist
D. Childs, Resident Inspector
C. Harrington, Operations Engineer
S. Hedger, Sr Emergency Preparedness Inspector
J. O'Donnell, Senior Health Physicist
A. Patz, Senior Resident Inspector
H. Strittmatter, Emergency Preparedness Inspector
T. Weir, Physical Security Inspector
D. You, Operations Engineer
Approved By: John L. Dixon, Jr., Chief
Reactor Projects Branch D
Division of Operating Reactor Safety
Enclosure 2
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
Failure to Periodically Calibrate Radiation Monitors
Cornerstone Significance Cross-Cutting Report
Aspect Section
Occupational Green [P.3] - 71124.05
Radiation Safety NOV 05000382/2023003-01 Resolution
Open
The inspectors identified a violation (Green) of 10 CFR 20.1501(c) for failure to periodically
calibrate area, process, and effluent radiation monitoring equipment used to perform (e.g.,
dose rate and effluent monitoring) measurements. Specifically, on or around July 2006, the
licensee began changing the periodic calibrations of process, effluent, and area radiation
monitors without proper technical justification or documented bases.
Additional Tracking Items
Type Issue Number Title Report Section Status
LER 05000382/2022-001-02 Non-Compliance with 71153 Closed
Technical Specifications Due
to Incorrect Procedural
Guidance for Radiation
Monitors
LER 05000382/2022-001-01 Non-Compliance with 71153 Closed
Technical Specifications Due
to Incorrect Procedural
Guidance for Radiation
Monitors
LER 05000382/2022-001-00 Non-Compliance with 71153 Closed
Technical Specifications Due
to Incorrect Conversion
Factors in Three Gaseous
Radiation Monitors
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PLANT STATUS
Unit 3 operated at or near rated thermal power for the entire inspection period.
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
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (2 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) emergency diesel generator B during emergency diesel generator A planned outage
from August 7-8, 2023
(2) auxiliary component cooling water train B and component cooling water train B
following unplanned failure of auxiliary component cooling water pump A on
August 31, 2023
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (1 Sample)
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 RAB-22-001, elevation +21.00' reactor auxiliaries building drumming station
(hot tool room) on August 4, 2023
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Examination Results (IP Section 03.03) (1 Sample)
(1) The inspectors reviewed and evaluated the licensed operator examination failure
rates for the requalification annual operating exam administered on June 19, to
July 20, 2023.
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71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
(1) Biennial Requalification Written Examinations
The inspectors evaluated the quality of the licensed operator biennial requalification
written examination administered on June 28, 2023.
Annual Requalification Operating Tests
The inspectors evaluated the adequacy of the facility licensees annual requalification
operating test.
Administration of an Annual Requalification Operating Test
The inspectors evaluated the effectiveness of the facility licensee in administering
requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility
licensee is effectively evaluating their licensed operators for mastery of training
objectives.
Requalification Examination Security
The inspectors evaluated the ability of the facility licensee to safeguard examination
material, such that the examination is not compromised.
Remedial Training and Re-examinations
The inspectors evaluated the effectiveness of remedial training conducted by the
licensee, and reviewed the adequacy of re-examinations for licensed operators who
did not pass a required requalification examination.
Operator License Conditions
The inspectors evaluated the licensees program for ensuring that licensed operators
meet the conditions of their licenses.
Control Room Simulator
The inspectors evaluated the adequacy of the facility licensees control room
simulator in modeling the actual plant, and for meeting the requirements contained in
Problem Identification and Resolution
The inspectors evaluated the licensees ability to identify and resolve problems
associated with licensed operator performance.
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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 reactor trip circuit breaker testing and during preparations for a planned
outage of emergency diesel generator A on August 6, 2023.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1) The inspectors observed and evaluated licensed operator simulator training involving
a component cooling water pump room fire and a faulted steam generator tube
rupture general emergency on August 15, 2023.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 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) elevated green risk due to a planned emergency diesel generator A outage from
August 7-9, 2023
(2) yellow risk due to heavy work in the Waterford switchyard concurrent with
safety-related equipment surveillances from August 14-18, 2023
(3) yellow risk due to unplanned failure of component cooling water cross-connect valve
between pump A and pump AB from September 20-21, 2023
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1) high pressure safety injection train A operability following high leakage during testing
on July 11, 2023
(2) containment spray pump A operability following identification of low component
cooling water flow on July 25, 2023
(3) reactor protection system operability following identification of errors in the steam
generator narrow range reactor trip setpoint on August 9, 2023
(4) startup transformers A and B following failure and isolation of multiple 230 kV
breakers in the Waterford switchyard on September 14, 2023
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71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
(1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
(1) auxiliary component cooling water pump A motor was replaced with the component
cooling water pump AB motor on September 4, 2023
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system
operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (8 Samples)
(1) control room air conditioning train B following unplanned failure to start of air handler
AH-12B on July 20, 2023
(2) high pressure safety injection pump A following relief valve replacement on July 27,
2023
(3) dry cooling tower fan 11B after planned maintenance on August 16, 2023
(4) emergency diesel generator B after planned maintenance on August 23, 2023
(5) auxiliary component cooling water pump A following failure of motor on
September 4, 2023
(6) containment particulate radiation monitors following failure on September 25, 2023
(7) containment fan cooling train B following failure of temperature control valve on
September 26, 2023
(8) spent fuel pool pump B following pump replacement on September 28, 2023
Surveillance Testing (IP Section 03.01) (3 Samples)
(1) high pressure safety injection pump B on July 26, 2023
(2) reactor trip circuit breaker testing on August 6, 2023
(3) emergency diesel generator A overspeed testing on August 10, 2023
Reactor Coolant System Leakage Detection Testing (IP Section 03.01) (1 Sample)
(1) reactor coolant system leakage calculation on July 20, 2023
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
June 21, 2023. The exercise scenario simulated a reactor coolant pump seal failure
followed by a loss of coolant accident, increasing plant and containment radiation
levels, multiple failures in high pressure safety injection sub-systems, followed by
continued escalating containment radiation levels coupled with a loss of containment
spray function. This scenario was complicated later with a penetration failure in
containment, involving a simulated radiological release offsite. The licensee
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completed its critique process for the exercise on July 10, 2023, and the inspectors
subsequently evaluated the effectiveness of the critique process to identify
performance weaknesses and deficiencies to ensure they were entered into the
corrective action program for resolution.
This documents completion of this inspection sample which was documented as a
partial sample in Inspection Report 05000382/2023002 (ADAMS Accession No.
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)
(1 Sample)
(1) The inspectors evaluated an emergency preparedness drill involving an earthquake
and spent fuel pool loss of coolant inventory on August 30, 2023
Drill/Training Evolution Observation (IP Section 03.02) (2 Samples)
The inspectors evaluated:
(1) simulator based training for a loss of reactor coolant accident on August 29, 2023
(2) simulator based training for a security threat and automatic failure to shut down the
reactor on September 6, 2023
RADIATION SAFETY
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (8 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant
walkdowns:
(1) portable survey instruments ready for use at the west side access to the
radiologically controlled area
(2) portable survey instruments in storage, but available for use in the instrument lab
(3) area radiation monitors in auxiliary building
(4) process radiation monitors in the auxiliary building
(5) effluent radiation monitors in the auxiliary building
(6) personnel contamination monitors at the exit(s) to the radiologically controlled area
(east and west)
(7) chemistry count room instruments (gamma spectroscopy and liquid scintillation)
(8) portal monitors and friskers at the exit to the protected area
Calibration and Testing Program (IP Section 03.02) (12 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection
instruments:
(1) Ludlum Model 177, CHP-CR-192, frisker
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(2) Ludlum Model 3030, CHP-C-060, scaler
(3) Thermo Scientific AMS-4, HP-RD-264, continuous air sampler
(4) Mirion TelePole II, CHP-TEL173, wide range telescopic survey meter
(5) Ludlum Model 9-3, CHP-Dr-400, ion chamber
(6) Ludlum Model 12-4, CHP-MF-154, neutron dose rate
(7) Mirion iSolo, HP-CS-020, scaler
(8) Mirion GEM-5, HP-DS-094, gamma exit monitor
(9) Mirion ARGOS-5AB, HP-DS-103, personnel contamination monitor
(10) Mirion CRONOS, HP-DS-110, tool/equipment monitor
(11) General Atomic ARMIR0300,2, fuel handling building airborne isolation radiation
monitor
(12) General Atomic ARMIR5500-A, main steam line radiation monitor
Effluent Monitoring Calibration and Testing Program Sample (IP Section 03.03) (2 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive
effluent monitoring and measurement instrumentation:
(1) PRMIR0647, waste condensate and laundry waste discharge radiation monitor
(2) PRMIR5700, component cooling water loop return header radiation monitor
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &
Transportation
Radioactive Material Storage (IP Section 03.01) (3 Samples)
The inspectors evaluated the licensees performance in controlling, labeling, and securing
the following radioactive materials:
(1) intermodal containers containing oil drums, dry active waste, and outage supplies and
shielding of boxes and refuel equipment in the west yard and south yard
(2) source storage lockers and J.L. Shepherd calibrator in primary chemistry lab.
(3) two process shields for resin and one process shield for filter in the solidification
building
Radioactive Waste System Walkdown (IP Section 03.02) (1 Sample)
The inspectors walked down the following accessible portions of the solid radioactive waste
systems and evaluated system configuration and functionality:
(1) liquid waste management system and portions of the resin waste management
system
Waste Characterization and Classification (IP Section 03.03) (3 Samples)
The inspectors evaluated the following characterization and classification of radioactive
waste:
(1) reactor coolant system 2023 10 CFR Part 61 waste stream
(2) liquid waste management 2023 Part 61 waste stream
(3) resin waste management 2022 Part 61 waste stream
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Shipment Preparation (IP Section 03.04)
No shipment was available for observation during this inspection.
Shipping Records (IP Section 03.05) (4 Samples)
The inspectors evaluated the following non-excepted radioactive material shipments through
a record review:
(1) RSN-22-1010 dry active waste/metal, May 19, 2022
(2) RSN-22-1017 CVC resin, July 28, 2022
(3) RSN-23-1001 dry active waste/metal, April 5, 2023
(4) RSN-23-2048 reactor coolant pump seal, September 7, 2022
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)
(1) Unit 3 (July 1, 2022, through June 30, 2023)
MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)
(1) Unit 3 (July 1, 2022, through June 30, 2023)
MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)
(1) Unit 3 (July 1, 2022, through June 30, 2023)
71152S - Semiannual Trend Problem Identification and Resolution
Semiannual Trend Review (Section 03.02) (1 Sample)
(1) The inspectors reviewed the licensees corrective action program for potential
adverse trends that might be indicative of a more significant safety issue. The
inspectors performed an in-depth review of repeat equipment failures. During this
review, the inspectors noted an adverse trend in the number of issues that fail at least
twice. This trend is detailed in an observation in the results section of this report. No
more than minor concerns were identified.
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):
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(1) LER 05000382/2022-001-00, 05000382/2022-001-01, and 05000382/2022-001-02,
Non-Compliance with Technical Specifications Due to Incorrect Procedural Guidance
for Radiation Monitors (ADAMS Accession No. ML23053A354). The inspection
conclusions associated with this LER and two updates are documented in Inspection
Report 05000382/2023040. An additional inspection conclusion regarding reporting
timeliness is documented in this report under Inspection Results Section 71153. This
LER and updates are closed.
INSPECTION RESULTS
Failure to Periodically Calibrate Radiation Monitors
Cornerstone Significance Cross-Cutting Report
Aspect Section
Occupational Green [P.3] - 71124.05
Radiation Safety NOV 05000382/2023003-01 Resolution
Open
The inspectors identified a violation (Green) of 10 CFR 20.1501(c) for failure to periodically
calibrate area, process, and effluent radiation monitoring equipment used to perform (e.g.,
dose rate and effluent monitoring) measurements. Specifically, on or around July 2006, the
licensee began changing the periodic calibrations of process, effluent, and area radiation
monitors without proper technical justification or documented bases.
Description: As a result of the previous radiation safety inspection conducted in November
2021, the licensee was issued a non-cited violation (NCV) for failure to ensure monitors used
for quantitative radiation measurements were calibrated periodically for the radiation
measured. The failure to periodically calibrate area, process, and effluent radiation monitors
was documented in inspection report 05000382/2021004 as NCV 05000382/2021004-01,
Failure to Periodically Calibrate Radiation Monitors, (ADAMS Accession Number
ML22028A000). The original violation documented 29 of 41 radiation monitors as being
overdue on their required calibration frequencies. This NCV was entered into the licensees
corrective action program as condition report CR-WF3-2022-00851.
There were two aspects to the prior NCV: (1) the changing of the calibration frequencies
without technical justification and (2) the failure to periodically calibrate the radiation monitors
themselves. During the onsite inspection, July 24-28, 2023, the inspectors determined the
aspect of changing the calibration frequencies without a technical justification was addressed
by the licensee. The licensees Final Safety Analysis Report in chapter 11, section 2.5.2
specified an 18-month calibration frequency for process and effluent monitors. The inspectors
reviewed several change requests, dated October 21, 2021, to remove the unjustified
extension of the calibration frequencies, specifically the 6.75-year and 9-year frequencies.
These change requests were more encompassing and included more than the 41 radiation
monitors as described in the prior NCV. The change requests were submitted through the
licensees preventive maintenance program which included a work order process to schedule
the calibrations at specified frequencies. However, the inspectors determined that the
licensee had not periodically calibrated the radiation monitors within their specified
frequencies.
The NRC Enforcement Policy (Accession Number ML22336A179), section 2.3.2.a described
the conditions that allow the NRC to issue NCVs to licensees with credited corrective action
programs. Section 2.3.2.a.2 states, in part, that the licensee must restore compliance (or
demonstrate objective evidence of plans to restore compliance) within a reasonable period
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after a violation has been identified.
Since November 2021, the licensee had not demonstrated progress toward restoring
compliance by calibrating the overdue radiation monitors. The inspectors determined
approximately 68 percent of the 41 radiation monitors were outside their new calibration
frequencies. In addition, the information requested by the inspectors showed that only one of
the 29 radiation monitors had been calibrated since the previous inspection.
During the review of the licensees progress toward restoring compliance, the licensee
provided information on the calibration status of 44 area and process radiation monitors not
specifically covered by technical specifications, technical requirements manual, or the offsite
dose calculation manual. Of the 44 radiation monitors described, 33 were shown as past due
for the new calibration frequencies, with three additional radiation monitor calibrations due
within two months after the inspection. This information also showed that 20 of the
33 monitors were already beyond the 6.75-year frequency. Of these 20, three exceeded the
9-year frequency and six were simply identified as greater than 8 years.
The licensees preventive maintenance program and work order process failed to adequately
schedule and complete the radiation monitor calibrations in a timely manner to restore
compliance. The prior violation had identified 29 radiation monitors overdue at the time of that
inspection. Of the 29 radiation monitors, four were process radiation monitors that required
repair prior to calibration. The inspectors observed two of these process radiation monitors
not functioning (turned off) during one of the walkdowns (plant tours). In the 20 months since
the previous inspection, the calibration of process radiation monitors should have been
conducted at least once with an 18-month calibration frequency.
Corrective Actions: The prior NCV's corrective action focused on correcting the calibration
frequency in the work management process. At the conclusion of the current inspection, the
licensee had calibrated only one radiation monitor as identified in the previous NCV within the
last 20 months (since November 2021). The licensee has entered this repetitive issue in their
corrective action program to create a plan to restore compliance with 10 CFR 20.1501(c).
Corrective Action References: CR-WF3-2023-14818
Performance Assessment:
Performance Deficiency: Failure to periodically calibrate area and process radiation monitors
in accordance with license commitments and regulatory requirements.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Plant Facilities/Equipment and Instrumentation attribute of
the Occupational Radiation Safety cornerstone and adversely affected the cornerstone
objective to ensure the adequate protection of the worker health and safety from exposure to
radiation from radioactive material during routine civilian nuclear reactor operation.
Specifically, an ineffective radiation program barrier was identified when radiation monitors
were observed to be non-functional (i.e., turned off).
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix C, Occupational Radiation Safety SDP. The inspectors determined the finding had
a very low safety significance (Green) because: (1) it was not associated with ALARA
planning and work controls, (2) it was not an overexposure, (3) there was no potential for an
overexposure; and (4) the ability to assess dose was not compromised.
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Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to
address issues in a timely manner commensurate with their safety significance. Specifically,
the licensee failed to schedule and perform timely calibrations of radiation monitors to restore
compliance from a previous NCV documented in CR-WF3-2022-00851.
Enforcement:
Violation: Title 10 CFR 20.1501(c) states, in part, that the licensee shall ensure that
instruments and equipment used for quantitative radiation measurements are calibrated
periodically for the radiation measured.
Contrary to the above, from November 2021 to September 30, 2023, the licensee failed to
ensure that instruments (radiation monitors) and equipment used for quantitative radiation
measurements were calibrated periodically for the radiation measured. Specifically, the
licensee failed to periodically calibrate 33 area and process radiation monitors.
Enforcement Action: This violation is being cited because the licensee failed to restore
compliance within a reasonable period after the violation was identified consistent with
Section 2.3.2 of the Enforcement Policy.
Observation: 71152S
The inspectors reviewed the licensees corrective action program to identify performance
trends that might indicate the existence of a more significant safety issue The inspectors
noted a trend in human performance. Specifically, the inspectors noted six events in which
the licensee had repeat issues that significantly impacted plant operations over the last cycle,
from May 2022 to October 2023. Examples include:
- CR-WF3-2022-04112: Auxiliary component cooling water pump B failed due to a
bearing high temperature on May 8, 2022. The bearing was repaired and failed again
on May 23, 2022.
- CR-WF3-2022-05956: Control element assembly 45 caused an alarm in the control
room for high voltage on December 9, 2021. The assembly was returned to normal
service and the issue repeated on August 18, 2022.
- CR-WF3-2022-06302: Plant protection system power supply 28 tripped on
overvoltage on April 1, 2021. The licensee attempted to identify the cause during the
subsequent refueling outage. The power supply tripped again on overvoltage on
September 6, 2022.
- CR-WF3-2023-15308: One of the two let down pressure control valves failed on
August 27, 2023. The licensee identified water in the compressed air line and returned
the valve to service. The valve caused another transient on August 31, 2023.
- CR-WF3-2023-15909: Spent fuel pool pump B experienced leakage issues on
March 24, 2023. The reworked pump was brought back onsite after 6 months and had
similar issues on September 28, 2023.
- CR-WF3-2023-15947: The train B containment fan cooler flow control valve was not
providing adequate flow rates on September 19, 2023. The valve was returned to
service and exhibited issues again on October 2, 2023.
The inspectors did not identify any findings or more-than-minor violations. The licensee
identified and performed initial corrective actions as well as follow-up corrective actions for all
E2-12
these issues. In response to this observation, the licensee documented the trend in CR-WF3-
2023-16108.
Minor Violation 71153
Minor Violation
Minor Violation: All safety-related radiation monitors were being examined as part of an
extent of condition review beginning in January 2022 following identification of incorrect
engineering conversion factors for multiple wide range gas monitors. These issues were first
described in Licensee Event Report 05000382/2022-001-00, Non-Compliance with Technical
Specifications Due to Incorrect Conversion Factors in Three Gaseous Radiation Monitors.
These issues were dispositioned by the NRC as a White finding in inspection report
05000382/2022090 (ADAMS Accession Number ML22241A143) and reviewed via a
supplemental inspection in accordance with Inspection Procedure 95001 in inspection report
05000382/2023040 (ADAMS Accession Number ML23145A227).
On November 16, 2022, as part of the extent of condition review, the licensee identified that
three component cooling water radiation monitors had incorrect engineering correction
factors. These monitors check for radiation that leaks from connecting systems into the
normally clean, closed-circuit CCW system. The correction factors were based on the
detectors response to cobalt-60 instead of cesium-137, causing the sensitivity of the
detectors to be approximately 46 percent lower than the expected response. The licensee
recalibrated the CCW radiation monitors on November 17, 2022. The CCW radiation monitors
were found to have been incorrectly calibrated for longer than the allowed outage time in
technical specification 3.3.3.1 and therefore required an LER in accordance with
10 CFR 50.73(a)(2)(i)(B). The licensee provided this information to the NRC in LER 05000382/2022-001-02 on February 22, 2023, or about 98 days after identification of the
issue. This delay does not meet the requirements of 10 CFR 50.73(a)(1) to submit a Licensee
Event Report within 60 days of discovery of the event.
Screening: The inspectors determined the violation was minor. The failure to submit a LER in
accordance with 10 CFR 50.73 is an example of a Severity Level IV violation in accordance
with section 6.9 of the NRC Enforcement Policy. However, the event report was submitted by
the licensee before NRC identification and did not impact the ability of the NRC to perform its
regulatory oversight function. Therefore, the violation is considered minor in accordance with
section 2.2.1 of the NRC Enforcement Policy.
Enforcement: This failure to comply with 10 CFR 50.73(a)(1) constitutes a minor violation that
is not subject to enforcement action in accordance with the NRCs Enforcement Policy. This
minor violation, in addition to inspection report 05000382/2023040 (ADAMS Accession No.
ML23192A764), closes LER 05000382/2022-001-02.
E2-13
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On June 29, 2023, the inspectors presented the exam technical debrief inspection
results to Robbie Ledet, Operations Director, and other members of the licensee staff.
- On July 12, 2023, the inspectors presented the emergency preparedness exercise
inspection results to John Ferrick, Site Vice President, and other members of the
licensee staff.
- On August 7, 2023, the inspectors presented the public radiation safety inspection
results to Joseph Sullivan, Site Vice President, and other members of the licensee staff.
- On August 14, 2023, the inspectors presented the exam exit meeting inspection results
to Joseph Sullivan, Site Vice President, and other members of the licensee staff.
- On October 16, 2023, the inspectors presented the integrated inspection results to
Joseph Sullivan, Site Vice President, and other members of the licensee staff.
E2-14
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.04 Procedures OP-002-001 Auxiliary Component Cooling Water 320
71111.04 Procedures OP-002-003 Component Cooling Water 322
71111.04 Procedures OP-009-002 Emergency Diesel Generator 360
71111.05 Drawings G-FP-0021 Fire Detection System Raceway & Equipment Layout 0
Reactor Auxiliary Building EL +21.00'
71111.05 Fire Plans RAB 22-001 Drumming Station (Hot Tool Room) 7
71111.11B Corrective Action CR-WF3-YYYY- 2021-04665, 2022-03323, 2022-05400, 2022-06858
Documents NNNN
71111.11B Miscellaneous Waterford Credit for Standing Watch Logs (8/1/21 to
5/25/23)
71111.11B Miscellaneous Checklist for Upgrading from Inactive to Active Status 314
71111.11B Miscellaneous 2023 Week 2 SRO/RO Written Exam
71111.11B Miscellaneous Waterford Operator Medical Records
71111.11B Miscellaneous Waterford 2023 Week 1 and 2 Scenarios and JPMs
71111.11B Miscellaneous SBT Package - 2022 NRC Initial Exam Scenario 3 11/28/2021
71111.11B Miscellaneous Post-Event Simulator Test - April 12, 2023, and August 2,
2022
71111.11B Miscellaneous Simulator Baseline Testing Data 06/20/2023
71111.11B Miscellaneous Tracking Tool Prevent Overlap Written Exam - 2023
Written Exam Worksheet
71111.11B Miscellaneous Tracking Tool Prevent Overlap Operating Test - 2023
Annual Exam Tracking and 2023 JPM Matrix
71111.11B Miscellaneous 2021 Biennial Written SRO Remedial Exam
71111.11B Miscellaneous DR 17-0193
71111.11B Miscellaneous DR 21-0096
71111.11B Miscellaneous DR 23-0004
71111.11B Miscellaneous DR 23-0025
71111.11B Miscellaneous DR 23-0031
71111.11B Miscellaneous DR 23-0042
71111.11B Miscellaneous DR 23-0059
71111.11B Miscellaneous DR-23-0055
E2-15
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.11B Miscellaneous TQF-202-SRB Simulator Review Board (SRB) Meeting Minutes 02/01/2023
71111.11B Miscellaneous WSIM-DIR-003 Simulator Operability Testing - Cycle 25 11/23/2022
71111.11B Procedures Simulator Differences List 06/20/2023
71111.11B Procedures EN-NS-112 Medical Program 23
71111.11B Procedures EN-OP-115-06 Activation and Deactivation of Licenses, and Maintaining 3
Active License Status
71111.11B Procedures EN-TQ-100 Operations Training Program Description 3
71111.11B Procedures EN-TQ-202 Simulator Configuration Control 12
71111.11B Procedures EN-TQ-210 Conduct of Simulator Training 17
71111.11B Procedures EN-TQ-217 Exam Security 12
71111.11B Procedures TQF-210-CC01 Crew Critique
71111.11B Procedures WTRN-OPS- Site Simulator Exam Security Checklist 1
SIMEXAMSECURITY
71111.11Q Procedures EN-OP-115 Conduct of Operations 31
71111.11Q Procedures EP-001-001 Recognition and Classification of Emergency Conditions 37
71111.11Q Procedures OP-903-006 Reactor Trip Circuit Breaker Test 16
71111.11Q Work Orders 53036043, 54006929
71111.12 Miscellaneous TD G080.0095 General Electric Switchgear Magne Blast Breakers 6
71111.12 Procedures EN-DC-205 Maintenance Rule Monitoring 9
71111.12 Procedures ME-004-115 4.16/6.9 kV G.E. Magne-Blast Breaker Overhaul 6
71111.12 Work Orders 527902555, 00517244
71111.13 Procedures EN-WM-101 On-Line Work Management Process 25
71111.13 Procedures EN-WM-104 On-Line Risk Assessment 27
71111.15 Calculations ECI92-019 Plant Protection System Setpoint Uncertainty Calculation 5
71111.15 Corrective Action CR-WF3-YYYY- 2023-14217, 2023-14854, 2023-14895, 2023-15179,
Documents NNNN 2023-15245, 2023-15993, 2023-15602, 2023-15603,
2023-15604, 2023-15605
71111.15 Corrective Action OP-903-030 Safety Injection Pump Operability Verification 41
Documents
71111.15 Corrective Action CR-WF3-YYYY- 2023-14746, 2023-14747
Documents NNNN
Resulting from
Inspection
E2-16
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.15 Procedures PE-004-024 309
71111.18 Corrective Action CR-WF3-YYYY- 2023-15311
Documents NNNN
71111.18 Engineering EC 54046818 ACCEMTR3A-3 Motor Comparison and EQ Evaluation 09/03/2023
Changes
71111.24 Corrective Action CR-WF3-YYY-NNNN 2023-15594, 2023-15671, 2023-15909, 2023-14384,
Documents 2023-14396
71111.24 Engineering EC 54056366 Containment PIG 09/25/2023
Evaluations
71111.24 Procedures ME-004-021 Emergency Diesel Generator 40
71111.24 Procedures ME-007-006 480 VAC and Less Squirrel Cage Induction Motors 22
71111.24 Procedures MI-003-377 Containment Atmospheric Particulate and Gaseous 318
Radiation Monitor
71111.24 Procedures OI-040-000 Reactor Coolant System Leakage Monitoring 18
71111.24 Procedures OP-002-003 Component Cooling Water 322
71111.24 Procedures OP-002-006 Fuel Pool Cooling and Purification 331
71111.24 Procedures OP-003-014 Control Room Heating and Ventilation 311
71111.24 Procedures OP-009-002 Emergency Diesel Generator 360
71111.24 Procedures OP-009-008 Safety Injection System 48
71111.24 Procedures OP-903-002 Emergency Diesel Generator and Subgroup Relay 327
Operability Verification
71111.24 Procedures OP-903-006 Reactor Trip Circuit Breaker Test 16
71111.24 Procedures OP-903-008 Reactor Coolant System Isolation Leakage Test 26
71111.24 Procedures OP-903-024 Reactor Coolant System Water Inventory Balance 26
71111.24 Procedures OP-903-030 Safety Injection Pump Operability Verification 41
71111.24 Procedures OP-903-037 Containment Cooling Fan Operability Verification 7
71111.24 Procedures OP-903-050 Auxiliary Component Cooling Water Pump and Valve 47
Operability Test
71111.24 Work Orders 52950139, 52988195, 54017890, 54026996
71114.01 Corrective Action Condition Reports 13881, 13921, 13922, 13931, 13932, 13951, 13952,
Documents (CR-WF3-) 13960, 13961, 13962, 13964, 13965, 13967, 13969,
13970, 13971, 14019, 14046, 14049, 14053, 14249
71114.01 Miscellaneous Management Debrief, 6/21/23 NRC/FEMA Evaluated 07/10/2023
E2-17
Inspection Type Designation Description or Title Revision or
Procedure Date
Exercise
71114.06 Procedures EP-001-001 Recognition and Classification of Emergency Conditions 37
71114.06 Procedures OP-901-111 Reactor Coolant System Leak 307
71114.06 Procedures OP-901-403 High Airborne Activity in Containment 4
71114.06 Procedures OP-901-405 Fuel Handling Incident 8
71114.06 Procedures OP-901-525 Security Threat 20
71114.06 Procedures OP-902-000 Standard Post Trip Actions 17
71114.06 Procedures OP-902-002 Loss of Coolant Accident Recovery 21
71114.06 Procedures OP-902-009 Standard Appendices 323
71124.05 Calibration 52982382-01 ARMIR5400-B Calibrate Radiation Monitor Electronics 06/13/2023
Records
71124.05 Calibration 52993552-01 AMIR5500-B Main Steam Line Radiation Monitor Chanel 06/25/2023
Records Calibration
71124.05 Calibration CHP-ARM046 Portable Instrumentation Calibration Data Sheet 10/10/2022
Records Amp-100, area radiation monitor
71124.05 Calibration CHP-CR-227 Portable Instrumentation Calibration Data Sheet 03/07/2022
Records LM-177, Frisker
71124.05 Calibration CHP-DR-664 Portable Instrumentation Calibration Data Sheet 07/19/2022
Records Model 9-3, ion chamber
71124.05 Calibration Detector 4 - 125 mL Efficiency Verification Worksheet 06/19/2023
Records Charcoal 125 milliliter charcoal bottles for Detector 4
71124.05 Calibration Detector 6 - 1 L Efficiency Verification Worksheet 09/15/2022
Records Marinelli 1 Liter Marinelli container for Detector 6
71124.05 Calibration Detector 6 - Filter Efficiency Verification Worksheet 09/27/2022
Records 47-millimeter glass fiber filter for Detector 6
71124.05 Calibration FastScan Calibration of the Dosimetry FastScan Whole-Body 03/08/2023
Records Counting System
71124.05 Calibration HP-RD-300 Portable Instrumentation Calibration Data Sheet 07/20/2022
Records AMS-4, airborne particulate detector
71124.05 Calibration Source 87-CS-S-117 Confirmation of J.L. Shephard Model 78-2M 03/30/2023
Records 400 Curie Cs-137 Source
71124.05 Calibration Source KR2723 Confirmation of J.L. Shephard Model 78-2M 03/30/2023
Records 130 millicurie Cs-137 Source
71124.05 Corrective Action CR-WF3-YYYY- 2015-00182, 2015-00186, 2016-05176, 2018-01348,
E2-18
Inspection Type Designation Description or Title Revision or
Procedure Date
Documents XXXXX 2019-04721, 2021-03832, 2022-00851, 2022-00852,
2022-01430, 2022-01699, 2022-03151, 2022-04636,
2022-04815, 2022-07729, 2023-01153, 2023-13271,
2023-13721, 2023-13758, 2023-14157
71124.05 Corrective Action CR-WF3-YYYY- 2023-14488, 2023-14540, 2023-14818
Documents XXXXX
Resulting from
Inspection
71124.05 Miscellaneous ARMIRE5500-A/B Main Steam Line Radiation Monitor Readout Comparison 07/25/2023
71124.05 Miscellaneous PRM+46 Wing PS Plant Stack Process Flow Chart 01/01/2020
Process 2 Flow through
06/01/2023
71124.05 Miscellaneous W3F1-2023-0036 Special Report SR-2023-003-01 05/04/2023
Radiation Monitor Inoperable Greater Than 7 days
71124.05 Procedures EN-RP-317-08 Calibration of Portable Scalers 3
71124.05 Procedures MI-003-360 Containment High Range Safety Channel A or B Area 317
Radiation Monitor Calibration
ARMIR5400 A or ARMIR5400 B
71124.05 Procedures MI-003-365 Fuel Handling Building Ventilation Monitor Safety 15
Channel A or B Calibration
ARMIR300.1, ARMIR300.2, ARMIR300.3, or
ARMIR300.4
71124.05 Procedures MI-003-389 Main Steam Line Radiation Monitor Channel Calibration 314
ARMIR5500A or ARMIR5500B
71124.05 Procedures MI-003-459 Component Cooling Water Return Header from 307
Containment Liquid Radiation Monitor
Channel Calibration PRM-IR-5700
71124.05 Procedures MI-005-910 Mobile Airborne Radiation Monitor Calibration, 9
ARMIR5132, ARMIR5144
71124.05 Procedures MI-005-913 Reactor Auxiliary Building Duct Airborne Radiation 307
Monitor Calibration PRMIR6710 A, B, C, or D
71124.05 Procedures MI-005-918 General Atomic High Range Area Radiation Monitor 13
Assemblies 0359-470
71124.05 Procedures MI-005-920 General Atomic Area Radiation Monitor Assemblies 310
E2-19
Inspection Type Designation Description or Title Revision or
Procedure Date
0359-3501 and 0359-3502
71124.05 Procedures UNT-005-014 Offsite Dose Calculation Manual 309
71124.05 Self- LO-WLO-2021-0065 Pre-NRC Self-Assessment, IP71124.05 Radiation 05/31/2023
Assessments Monitoring Instrumentation
71124.05 Self- QA-2/6-2021-W3-1 Quality Assurance Audit Report: 10/05/2021
Assessments Combined Chemistry, Effluents and Environmental
Monitoring
71124.08 Corrective Action CR-WF3-YYYY- 2021-06506, 2021-06530; 2021-06613, 2022-00853,
Documents XXXXX 2022-01302, 2022-03092, 2022-03196, 2022-04189,
2022-05026, 2022-05444, 2022-06079, 2022-06708,
2022-06969, 2022-07572, 2022-07593, 2022-07668,
2022-00651, 2022-00916, 2022-00987, 2022-01936,
2022-01988
71124.08 Miscellaneous Annual Radioactive Effluent Release Report CY 2022 04/24/2023
71124.08 Miscellaneous EN-RP-143 Semi-Annual Sealed Source Leak Test 05/24/2023
71124.08 Miscellaneous IAW EN-RP-143 Semi-Annual Source Inventory 11/02/2022
71124.08 Miscellaneous LWM 2023 L97480 Liquid Waste Management Part 61 Analysis 09/14/2022
71124.08 Miscellaneous PMID 16018-01 Semi-Annual Sealed Source Leak Test 11/02/2022
71124.08 Miscellaneous RCS 2023 L98656-1 RCS 2023 Part 61 Analysis 01/23/2023
71124.08 Miscellaneous RWM 22 Apr Resin Waste Management Part 61 Analysis 05/22/2022
L96067-1
71124.08 Procedures EN-RP-121 Radioactive Material Control 18
71124.08 Procedures EN-RP-121-01 Receipt of Radioactive Material 7
71124.08 Procedures EN-RP-143 Source Control 14
71124.08 Procedures EN-RW-102 Radioactive Shipping Procedure 20
71124.08 Procedures EN-RW-104 Scaling Factors 14
71124.08 Procedures EN-RW-105 Process Control Program 5
71124.08 Procedures EN-RW-106 Integrated Transportation Security Plan 7
71124.08 Procedures Energy Solutions CS- Bead Resin/Activated Carbon Dewatering Procedure for 2
OP-PR-010-161017 Energy Solutions14-215 Or Smaller Liners, Utilizing
Energy Solutions Self-Engaging Dewatering System
(SEDS) at Waterford 3
71124.08 Self- LO-WLO-2021-00065 Focused Self-Assessment/ Formal Benchmark Report -
Assessments CA00003 IP 71124.08
E2-20
Inspection Type Designation Description or Title Revision or
Procedure Date
71124.08 Shipping Records 22-1010 DAW/Metal 05/19/2022
71124.08 Shipping Records 22-1017 CVC Resin 07/28/2022
71124.08 Shipping Records 22-3048 RCP Seal Box WF-501 and B-25 09/07/2022
71124.08 Shipping Records 23-1003 DAW/Metal 04/05/2023
71124.08 Work Orders Quarterly Packaging Inspection 12/13/2021
71124.08 Work Orders Quarterly Packaging Inspection 03/30/2022
71124.08 Work Orders Quarterly Packaging Inspection 06/15/2023
71124.08 Work Orders Quarterly Packaging Inspection 09/14/2022
71124.08 Work Orders Quarterly Packaging Inspection 12/01/2022
71124.08 Work Orders Quarterly Packaging Inspection 03/02/2023
71124.08 Work Orders Quarterly Packaging Inspection 06/14/2023
E2-21