W3F1-2023-0055, Reply to a Notice of Violation

Reply to a Notice of Violation

ML23348A253
Person / Time
Site:	Waterford
Issue date:	12/14/2023
From:	Sullivan J Entergy Operations
To:	Office of Nuclear Reactor Regulation, NRC Region 4, Document Control Desk
References
W3F1-2023-0055
Download: ML23348A253 (1)

Text

enterg j Joseph Sullivan Site Vice President Waterford Steam Electric Station, Unit 3 504-739-6660 W3F1-2023-0055 10 CFR 2.201 December 14, 2023 ATTN: Document Control Desk US. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Reply to a Notice of Violation 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 Integrated Inspection Report and Notice of Violation; NRC Inspection Report 05000382/2023003, (ADAMS Accession No. M L233 1 2A 183),

dated November 14, 2023 In accordance with 10 CFR 2.201, Entergy Operations, Inc. (Entergy) hereby submits the Reply to a Notice of Violation 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 John Twarog, Manager, Regulatory Assurance, at 504-739-6747.

Respectfully, Joseph Sullivan JS/jrt Entergy Operations, Inc, 17265 River Road, Killona, LA 70057

Enclosure:

Reply to a Notice of Violation 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(nrcgov

Enclosure W3FI -2023-0055 Reply to a Notice of Violation

W3F1 -2023-0055 Enclosure Page 1 of 3 Entergy Operations, Inc.

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

Waterlord Steam Electric, Unit 3 NRC letter to Entergy, Waterford Steam Electric Station, Unit 3 Integrated Inspection Report and Notice of Violation; NRC Inspection Report 05000382/2023003, (ADAMS Accession No. ML23312A183), dated November 14, 2023, the NRC issued Notice of Violation to Entergys Waterford Steam Electric Station, Unit 3 (Waterford

3) as restated below:

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 the provisions of 10 CFR 2.201, this enclosure provides Entergys reply to the Notice of Violation.

W3F1 -2023-0055 Enclosure Page 2 of 3 Reply to Notice of Violation

1) Reason for the violation During the 2021 Radiation Protection Radiation Monitoring Instrumentation (71124.05) inspection, it was discovered that calibration frequencies for 46 Waterford Steam Electric Station, Unit 3 (Waterford 3) radiation monitors were not in compliance with 10 CFR 20.1501.

Waterford 3 received a non-cited Green violation for failure to ensure that instruments (radiation monitors) and equipment used for quantitative radiation measurements were calibrated periodically for the radiation measured. Waterford 3 performed a causal analysis and determined that the violation was caused by multiple, incorrectly performed preventative maintenance change requests (PMCRs). The PMCRs did not contain basis documentation and were incorrectly coded as assigned non-essential tasks on non-critical components.

In 2022, corrective actions were taken to revise the Preventative Maintenance (PM) frequencies and the PM category code for the calibration task for PMs associated with the population of radiation monitors that were not in compliance. Sixteen of the 46 monitors were scheduled past the 3 year frequency. Thirty of the monitors were scheduled within their 3 year frequency. The site incorrectly scheduled some of these PMs with a grace period applied. Operating Experience (OE) from Comanche Peak in 2022 indicated that a grace period can only be applied to Technical Specification and Technical Review Manual radiation monitors. The site missed the opportunity to utilize OE from Comanche Peak and did not capture the learnings in the pre inspection self-assessment for the 2023 Radiation Monitoring Inspection.

A causal analysis product was performed after the 2023 inspection and determined that during the implementation of corrective actions to resolve the 2021 violation, future due dates were set for radiation monitor calibrations that were beyond the 3 year (plus grace period) calibration frequency. This was due to the site not understanding the impacts of the due date extensions on the PM program, resulting in the scheduling of radiation monitor calibrations that exceeded the periodicity required to ensure compliance with 10 CFR 20.1501(c).

2) Corrective Steps That Have Been Taken and the Results Achieved Entergy has scheduled calibrations for the population of affected radiation monitors to ensure compliance with 10 CFR 20.1501(c). The following monitors have been calibrated.

Name Equipment Description Date of Calibration ARM 1RE5204 Accident Monitor (Post Accident Sampling November 21, 2023 System)

ARMIRE5007 Chemistry Sample Room Area November 22, 2023 ARMIRE52O8 Accident Monitor (CCW Heat Exchanger November 27, 2023 Room)

ARM 1RE5209 Accident Monitor (Boron & Waste Mgmt November 29, 2023 Panel Area)

PRMIRE6777 Reactor Building Sump December 3, 2023

W3F1 -2023-0055 Enclosure Page 3 of 3

3) Corrective Steps That Will Be Taken

• PMCRs will be implemented to ensure that no additional radiation monitors are scheduled beyond a 3 year periodicity to ensure compliance with 10 CFR 20.1501(c)

The current projected completion time is January 31, 2024.

• The affected population of functioning radiation monitors will be calibrated on or before September 1, 2024.

4) Date When Full Compliance Will Be Achieved Compliance with 10 CFR 20.1501(c) for the affected population of functioning radiation monitors is currently projected to be restored on or before September 1, 2024. Radiation monitors that are currently non-functional will be calibrated as part of return to service actions following repair/replacement activities.