W3F1-2022-0008, SR-22-001-00, Waterford Steam Electric Station, Unit 3, Radiation Monitors Inoperable Greater than 7 Days

SR-22-001-00, Waterford Steam Electric Station, Unit 3, Radiation Monitors Inoperable Greater than 7 Days

ML22032A066
Person / Time
Site:	Waterford
Issue date:	02/01/2022
From:	Lewis J Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2022-0008 SR-22-001-00
Download: ML22032A066 (5)

Text

Entergy Operations, Inc.

17265 River Road Killona, LA 70057-3093 Tel 504-739-6028 John Lewis Manager, Regulatory Assurance 10 CFR 50.4 W3F1-2022-0008 February 1, 2022 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Special Report SR-22-001-00 Radiation Monitors Inoperable Greater Than 7 Days Waterford Steam Electric Station, Unit 3 NRC Docket No. 50-382 Renewed Facility Operating License No. NPF-38 Entergy Operations, Inc. is submitting Special Report SR-22-001-00 for Waterford Steam Electric Station, Unit 3 (Waterford 3). This Special Report is submitted in accordance with Waterford 3 Technical Specification (TS) 3.3.3.1, which requires the minimum number of Effluent Accident Monitor channels shown in TS Table 3.3-6 to be operable. If the monitor is not restored to operable status within 7 days after the failure, a special report is required to be submitted in accordance with TS 6.9.2 within 14 days after the failure outlining the actions taken, the cause of the inoperability and the plans and schedule for restoring the system to operable status.

This letter contains no new regulatory commitments.

Should you have any questions or require additional information, please contact John Lewis, Regulatory Assurance Manager, at 504-739-6028.

Respectfully, John Lewis JL/dbb/jkb

Enclosure:

Waterford 3 Special Report SR-22-001-00 John D Lewis Digitally signed by John D Lewis Date: 2022.02.01 08:15:37

-06'00'

W3F1-2022-0008 Page 2 of 2 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 W3F1-2022-0008 Waterford 3 Special Report SR-22-001-00

W3F1-2022-0008 Enclosure Page 1 of 2 SPECIAL REPORT SR-22-001-00 Radiation Monitors Inoperable Greater Than 7 Days

SUMMARY

The Condenser Vacuum Pump and Plant Stack wide range gas monitors (WRGMs) were declared inoperable due to calibration errors discovered on January 18, 2022. Operability could not be restored within the required 7-day period as specified in Waterford Steam Electric Station, Unit 3 (Waterford 3) Technical Specification (TS) 3.3.3.1, "Radiation Monitoring Instrumentation," Table 3.3-6, due to the unavailability of a multi-channel analyzer (MCA) needed to perform the re-calibrations. Because the WRGMs were not restored to service within 7 days after the failure, this report is submitted to the Nuclear Regulatory Commission (NRC) as required by TS 6.9.2 within 14 days after the failure outlining the actions taken, the cause of the inoperability and the plans and schedule for restoring the system to operable status.

NARRATIVE The Condenser Vacuum Pump WRGM monitors condenser vacuum pump discharge continuously to detect steam generator tube leakage and to quantify release rate. The Plant Stack WRGM monitors air being released from the plant stack and measures the radiation being released to the environment, if any, during both normal and accident conditions.

The operability of the subject WRGM channels ensures that: (1) the radiation levels are continually measured in the areas served by the individual channels; (2) the alarm or automatic action is initiated when the radiation level trip setpoint is exceeded; and (3) sufficient information is available on selected plant parameters to monitor and assess these variables following an accident. The radioactive gaseous effluent WRGM instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in gaseous effluents during actual or potential releases of gaseous effluents. The alarm/trip setpoints for these instruments are calculated and adjusted in accordance with the methodology and parameters in the Offsite Dose Calculation Manual (ODCM) to ensure that the alarm (and/or trip, if applicable) will occur prior to exceeding the limits of Title 10 of the Code of Federal Regulations (10 CFR) Part 20.

ACTIONS TAKEN Waterford 3 TS 3.3.3.1, Table 3.3-6, Action 27, requires, in part, that the preplanned alternate method of monitoring be established within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of equipment inoperability. Alternate monitoring of the condenser vacuum pump and plant stack effluent path was established at 1134 CST on January 18, 2022. The alternate monitoring methods will remain in place until the subject monitors are restored to an operable status.

W3F1-2022-0008 Enclosure Page 2 of 2 CAUSE OF INOPERABILITY The engineering conversion factor for WRGM detector types is specific to each detector.

Review of historical data confirmed that the engineering conversion factors associated with the original detectors were still being applied to the subject WRGM channels. These values were not revised when the original detectors were replaced due to insufficient procedural guidance.

While the correct Condenser Vacuum Pump WRGM conversion factors were eventually applied, the correct Plant Stack WRGM conversion factors have yet to be applied. A detector using a non-conservative engineering conversion factor will not alarm when actual radiological conditions reach the alarm setpoint value.

In addition to the engineering conversion factors, an adjustment factor must be applied to the calibration count-rate when a WRGM high range detector is replaced. This guidance did not exist when the subject detectors were replaced. The application of an incorrect adjustment factor can result in the associated channel indication being non-conservative (i.e., read lower than actual radiation level).

RESTORATION SCHEDULE The re-calibrations are expected to be performed during the week of January 31, 2022. The current schedule indicates that both monitors should be returned to an operable status by Monday, February 14, 2022. The re-calibration and testing are being tracked by the work management system.