05000382/LER-2023-004, Non-Compliance with Technical Specifications Due to Performing Startup Channel 1 Functional Testing During Fuel Movement
| ML24045A179 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 02/14/2024 |
| From: | Twarog J Entergy Operations |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| W3F1-2024-0005 LER 2023-004-00 | |
| Download: ML24045A179 (1) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 3822023004R00 - NRC Website | |
text
E) entergy W3F1-2024-0005 February 14, 2024 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 John Twarog Manager Regulatory Assurance 504-739-6747 10 CFR 50.73
Subject:
License Event Report 50-382/2023-004-00, Non-Compliance with Technical Specifications due to Performing Startup Channel 1 Functional Testing during Fuel Movement Waterford Steam Electric Station, Unit 3 NRC Docket No. 50-382 Renewed Facility Operating License No. NPF-38 Entergy Operations, Inc. (Entergy) submits the enclosed Licensee Event Report (LER) 50-382/2023-004-00 for Waterford Steam ElectriG Station, Unit 3. This event is reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as any operation or condition which was prohibited by the plant's Technical Specifications. The LER describes non-compliance with Technical Specifications during refueling operations which occurred on December 17, 2023.
This letter contains no new commitments.
Should you have any questions concerning this issue, please contact me.
Respectfully, John Twarog JRT/rrp Entergy Operations, Inc., 17265 River Road, Killona, LA 70057
W3F1 -2024-0005 Page 2 of 2 Enclosure: Licensee Event Report 50-382/2023-004-00 cc:
NRC Region IV Regional Administrator NRC Senior Resident Inspector - Waterford Steam Electric Station, Unit 3 NRC Project Manager - Waterford Steam Electric Station, Unit 3 Louisiana Department of Environmental Quality
Enclosure to W3F1-2024-0005 Licensee Event Report 50-382/2023-004-00
Abstract
On December 17, 2023, while in Mode 6 with refueling operations in progress, Waterford Steam Electric Station Unit 3, identified that Technical Specification (TS) 3.9.2, Refueling Operations Instrumentation, Action (a) to suspend core alterations was not entered during Startup Channel 1 functional testing. The functional test renders the Startup Channel, being tested, inoperable. This resulted in non-compliance with the Technical Specification for Refueling Operations Instrumentation, 3.9.2, which requires that at a minimum, two source range neutron flux monitors shall be OPERABLE and operating, each with continuous visual indication in the control room and one with audible indication in the containment and control room in MODE 6.
Startup Channel 1 was restored to operable following the performance of the functional test. The associated functional test procedure has been updated to include TS 3.9.2 requirements.
This condition is reportable under 1 0CFR 50. 73(a)(2)(i)(B), any operation or condition which was prohibited by the plant's Technical Specifications.
EVENT DESCRIPTION
050 052 APPROVED BY 0MB: NO. 3150-0104 EXPIRES: 03/31/2024
- 2. DOCKET NUMBER
- 3. LER NJMBER YEAR SEQUENTIAL REV NUMBER NO.
00382 2023
- - 004
- - 00 On December 17, 2023, with Waterford Steam Electric Station Unit 3 (WF3) in Mode 6, with refueling operations in progress, Technical Specification (TS) 3.9.2, Refueling Operations Instrumentation, Action (a) to suspend all core alternations was not entered during Startup Channel 1 functional testing.
OP-903-101, Startup Channel [MON] Functional Test Startup Channel 1 and 2, is a 7-day surveillance that is only applicable when WF3 is in Mode 6. On December 14, 2023, performance of OP-903-101 was completed satisfactory and documented in the station logs. Performance of this surveillance was necessary to complete the 'Pre-Core Alteration' checklist prior to moving fuel. When this surveillance was completed satisfactorily, there was not a TS log addendum generated to track the deviation from the routine 7-day schedule. On December 17, 2023, at the nightshift brief, the on-shift operators understood incorrectly that OP-903-101 was required to be performed prior to December 18, 2023. The operators were unaware this surveillance had been completed on December 14, 2023, prior to commencing fuel movements. During a pre-job brief with the Control Room Supervisor, the operators discussed the 7-day surveillance and TS 3.1.2.9, Boron Dilution Monitors, as referenced in the 'precautions and limitations' section of OP-903-101. All the requirements for TS 3.1.2.9 were met and the CRS gave the permission to the Reactor Operators to perform OP-903-101.
The reactor operators completed OP-903-101 for Startup Channel 1, including restoring Startup Channel 1 to operable status. Following test completion, Reactor Engineering contacted the Control Room to question the loss of indication on Startup Channel 1 while fuel movements were occurring. At this point, it was identified that TS 3.9.2 action (a.) entry to suspend core alternations was missed while Startup Channel 1 was inoperable. TS 3.9.2 limiting condition for operation requires at a minimum, two source range neutron flux monitors shall be OPERABLE and operating, each with continuous visual indication in the control room and one with audible indication in the containment and control room in MODE 6. Startup Channel 1 was inoperable during the performance of OP-903-101 due to the test configuration of the Startup Drawer.
This condition is reportable under 1 0CFR 50. 73(a)(2)(i)(B), any operation or condition which was prohibited by the plant's Technical Specifications.
EXTENT OF CONDITION Mode 5 and 6 surveillance tests were reviewed to identify weaknesses in application of Technical Specifications requirements and reference to the appropriate Technical Specifications. The review did not identify any additional weaknesses in other surveillance test performed during Mode 5 and 6.
SAFETY ASSESSMENT
Shutdown margin in the refueling cavity is verified in accordance with OP-010-006, Outage Operations and UNT-006-033, Technical Specification Surveillance Frequency. The required boron concentration of the reactor cavity was maintained during this event and all fuel moves were in accordance with the planned and analyzed sequence for the core reload.
As a result of performing the Startup Channel Functional Test during core reload, one required monitor was made inoperable. The prevention of a reactivity event was never lost since the required shutdown margin was maintained and all fuel moves were in accordance with the analyzed reload sequence.
There was no actual impact to the health and safety of the public or plant personnel due to this condition.
EVENT CAUSES 050 052 APPROVED BY 0MB: NO. 3150-0104 EXPIRES: 03/31/2024
- 2. DOCKET NUMBER
- 3. LER NUMBER YEAR SEQUENTIAL REV NUMBER NO.
00382 2023
- - 004
- - 00 Procedural guidance was inadequate. The precautions and limitations section, of OP-903-101, only referenced Technical Specification 3.1.2.9, Boron Dilution Monitors. At the time, OP-903-101 did not reference Tech Spec 3.9.2 in the precautions and limitations section, nor does the procedure have a circle/slash sign off step to verify core alterations are not in progress.
The Reactor Operators and Control Room Supervisor confirmed that current plant conditions met TS 3.1.2.9, Limited Condition Operation.
Licensed operators did not effectively manage proficiency gaps in the performance of OP-903-101. Specifically, they failed to identify that TS 3.9.2 applied to the performance of this test during refueling operations. OP-903-101 is routinely performed every 7 days in Mode 6 and immediately prior to moving fuel when the application of TS 3.9.2 is not required. The test procedure did not reference that TS 3.9.2 applies if performing refueling operations. The on-shift, licensed operators briefing included the requirements of TS 3.1.2.9, Boron Dilution Monitors, but did not include the requirements of TS 3.9.2. Training on the performance of this test is included in the qualification card for licensed operators. The system and refueling outage operating experience lesson plans are being revised to include this operating experience.
CORRECTIVE ACTIONS
A review and verification of the Pre-Core Alteration Checklist was completed to confirm that all surveillances were current and continuous communication and level monitoring had not been lost during fuel movement.
Performed a communication stand-down with Operations personnel to discuss the event and the lessons learned.
Qualifications for individuals involved were revoked until remediation was complete. Operating experience from this event is being incorporated into the system lesson plan and the refueling outage operating experience lesson plan.
OP-903-101, Startup Channel Functional Test Startup Channel 1 and 2 has been revised to include TS 3.9.2 requirements.
PREVIOUS SIMILAR EVENTS
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