W3F1-2022-0008, SR-22-001-00, Waterford Steam Electric Station, Unit 3, Radiation Monitors Inoperable Greater than 7 Days: Difference between revisions
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{{#Wiki_filter:Entergy Operations, Inc. | {{#Wiki_filter: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 | 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:== | ==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 | 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 001-00 for Waterford Steam Electric Station, Unit 3 (W aterford 3). This Special Report is submitted in accordance with Waterford 3Technical 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. | 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. | Should you have any questions or require additional information, please contact John Lewis, Regulatory Assurance Manager, at 504-739-6028. | ||
Respectfully, Digitally signed by John D John D Lewis | |||
Respectfully, Digitally signed by John D John D Lewis Lewis Date: 2022.02.01 08:15:37 | |||
-06'00' John Lewis JL/dbb/jkb | |||
==Enclosure:== | ==Enclosure:== | ||
Waterford 3 Special Report SR-22-001-00 | Waterford 3 Special Report SR-22-001-00 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 | |||
W3F1-2022-0008 | Waterford 3 Special Report SR 001-00 W3F1-2022-0008 | ||
Enclosure | Enclosure Page 1 of 2 | ||
SPECIAL REPORT SR-22-001- 00 | |||
Radiation Monitors Inoperable Greater Than 7 Days | |||
==SUMMARY== | ==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. | 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. | ||
W3F1-2022-0008 Enclosure Page 2 of 2 CAUSE OF INOPERABILITY The engineering conversion factor for WRGM detector types is specific to each detector. | ACTIONS TAKEN | ||
Review of historical data confirmed that the engineering conversion factors associated with the original detectors were still being applied to the subject WRGM | |||
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 hours of equipment inoperability. Alternate monitoringof thecondenser 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 channel s. 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. | 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). | 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.}} | |||
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.}} | |||
Revision as of 19:00, 18 November 2024
| 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
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 001-00 for Waterford Steam Electric Station, Unit 3 (W aterford 3). This Special Report is submitted in accordance with Waterford 3Technical 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, Digitally signed by John D John D Lewis Lewis Date: 2022.02.01 08:15:37
-06'00' John Lewis JL/dbb/jkb
Enclosure:
Waterford 3 Special Report SR-22-001-00 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
Waterford 3 Special Report SR 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 monitoringof thecondenser 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.
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 channel s. 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.