W3F1-2022-0058, Reply to a Notice of Violation; EA-22-033

Reply to a Notice of Violation; EA-22-033

ML22285A214
Person / Time
Site:	Waterford
Issue date:	10/12/2022
From:	Ferrick J Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation, NRC Region 4
References
EA-22-033, IR 2022090, W3F1-2022-0058
Download: ML22285A214 (5)

Text

) entergy John Ferrick Site Vice President Waterford Steam Electric Station, Unit 3 504-739-6660 W3F 1-2022-0058 10 CFR 2.201 October 12, 2022 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Reply to a Notice of Violation; EA-22-033 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 05000382/2022090," (ADAMS Accession No. ML22241A143), dated September 12, 2022 In accordance with 10 CFR 2.201, Entergy Operations, Inc. (Entergy) hereby submits the Reply to a Notice of Violation, EA-22-033, 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.

Respeclfull~

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

Enclosure:

Reply to a Notice of Violation; EA-22-033 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 R4Enforcement@nrc.gov

Enclosure W3F1-2022-0058 Reply to a Notice of Violation; EA-22-033

W3F 1-2022-0058 Enclosure Page 1 of 2 Entergy Operations, Inc.

Response to Notice of Violation EA-22-033 In U.S. Nuclear Regulatory Commission (NRC) letter to Entergy Operations, Inc. (Entergy) ,

"Waterford Steam Electric, Unit 3 - Final Determination of a White Finding, Notice of Violation, and Follow-Up Assessment Letter; NRC Inspection Report 05000382/2022090," (ADAMS Accession No. ML22241A143), dated September 12, 2022 , the NRC issued Notice of Violation EA-22-33 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)(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 (condenser exhaust wide range gas monitor, mid and high range detectors) 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.

Pursuant to the provisions of 10 CFR 2.201, this enclosure provides Entergy's reply to Notice of Violation EA-22-033.

W3F 1-2022-0058 Enclosure Page 2 of 2 Response to Notice of Violation

1) Reason for the violation In January 2022, the Radiation Monitoring System engineer identified Ml-005-906, "Radiation Monitoring System Desk Guide," required revision . It was discovered during document review the calibration steps did not correct for source decay when calibrating main condenser WRGM mid and high range detectors. Specifically, the engineer identified that the procedure did not contain the correct calibration information for RD-72 detector replacements. The RD-72 radiation monitor detectors are a cadmium telluride solid state device and are used to detect the mid and high range activity. Additionally, a multi-channel analyzer is required to ensure the source activity peak is used when calibrating the new detectors.

A complete review of sensitivity adjustment calculations in replacement detectors was performed and revealed that the original Cs-137 source strength was not corrected for decay for 27 years. This resulted in the main condenser WRGM mid and high range detectors reading higher than the allowable+/- 10%. When this condition was identified Waterford 3 took prompt and timely corrective actions including the necessary actions to understand the extent of condition and impact on other monitors.

A Root Cause was performed and determined that a legacy procedure revision in 1985 removed critical steps and equipment requirements which supported replacement, calibration, and troubleshooting issues for specific detectors. Specifically, the requirement to utilize a multi-channel analyzer during the RD-72 detector replacement calibration process was removed. The use of the multi-channel analyzer ensures that the radiation source peak is used during the calibration. This procedure change caused the future impact on detector replacements.

2) Corrective Steps That Have Been Taken and the Results Achieved Entergy took appropriate action by updating procedural guidance and recalibrating the condenser WRGM mid and high range detectors using the updated procedural guidance. Other EPLAN related detectors have been calibrated or compensatory measures have been established.

3) Corrective Steps That Will Be Taken Extent of condition actions were issued to validate calibrations and procedural guidance for other WRGM units that have been replaced .

Investigations for subsequent WRGM calibration discrepancies are ongoing .

4) Date When Full Compliance Will Be Achieved Full compliance was achieved when the main condenser WRGM mid and high range detectors were recalibrated and returned to service on February 04, 2022.