ML23145A227
| ML23145A227 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 06/02/2023 |
| From: | Geoffrey Miller NRC/RGN-IV/DRSS |
| To: | Ferrick J Entergy Operations |
| References | |
| EA-22-033, EA-22-119, EA-23-036 IR 2023040 | |
| Download: ML23145A227 (27) | |
See also: IR 05000382/2023040
Text
June 2, 2023
EA-22-119
John Ferrick, Site Vice President
Entergy Operations, Inc.
17265 River Road
Killona, LA 70057
SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - 95001 SUPPLEMENTAL
INSPECTION REPORT 05000382/2023040 AND EXERCISE OF
Dear John Ferrick:
On May 16, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed a supplemental
inspection using Inspection Procedure 95001, Supplemental Inspection Response to Action
Matrix Column 2 (Regulatory Response) Inputs at the Waterford Steam Electric Station, Unit 3
(Waterford). The enclosed inspection report documents the inspection results which were
discussed with Mandy Halter, General Manager of Plant Operations, and other members of your
staff during an on-site meeting on March 3, 2023. In addition, the results were discussed during
an exit meeting on May 16, 2023, with you and other members of your staff.
The NRC performed this inspection to review your stations actions in response to two White
violations in the emergency preparedness cornerstone area. On February 15, 2023, you
informed the NRC that your station was ready for the supplemental inspection.
The NRC determined that your staffs evaluation identified the cause of the two White violations.
Specifically, the root cause evaluations for the two White violations, as well as a common-cause
root cause evaluation, identified the root causes. These included ineffective technical reviews of
radiation monitor calibration procedures and practices, resulting in deficiencies in calibration
practices over many years. Also included was a radiation monitor database configuration control
process that lacked measures to ensure that the associated system data and documentation
was complete, accurate, and up-to-date. Corrective actions to preclude repetition are discussed
in detail in the enclosed inspection report.
Overall, the NRC determined that Waterfords problem identification, causal analyses, and
corrective actions sufficiently addressed the performance issues that led to the two White
violations. All inspection objectives, as described in Inspection Procedure 95001, were met, and
this inspection is, therefore, closed. With the closure of the two White violations, and as a result
of our continuous review of plant performance, the NRC has updated its assessment of
Waterford. This assessment supplements, but does not supersede, the end-of-cycle letter
issued on March 1, 2023. Based on successful completion of the supplemental inspection, and
J. Ferrick 2
issuance of this inspection report, Waterford has transitioned to the licensee response column
of the NRC Action Matrix (Column 1) as of the date of the exit meeting. However, consistent
with IMC 0305, the violations will still be considered for agency actions in accordance with the
Reactor Oversight Process Action Matrix until December 31, 2023.
The NRC inspectors also reviewed five additional violations occurring between November 11,
1987, to May 16, 2023, identified by your staff. The NRC has evaluated these examples and
determined that four violations are not greater than White significance, and one violation is not
greater than Green significance. However, because these violations were identified by
Waterford personnel through an extent of condition review, their causes are similar to the
causes for the original violations, and the corrective actions for the original violations will also
correct these violations, the NRC has determined that enforcement discretion is warranted for
all five violations as described in the NRC Enforcement Policy, Section 3.3.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a
copy of this letter, its enclosure, and your response, if you choose to provide one, will be made
available electronically for public inspection in the NRC Public Document Room and from the
NRCs Agencywide Documents Access and Management System (ADAMS), accessible from
the NRC website at http://www.nrc.gov/reading-rm/adams.html.
Sincerely,
Rivera-Varona, Aida signing on behalf
of Miller, Geoffrey
on 06/02/23
Geoffrey B. Miller, Director (Acting)
Division of Radiological Safety & Security
Docket No. 05000382
License No. NPF-38
Enclosure:
Supplemental Inspection Report 2023040
cc w/ encl: Distribution via LISTSERV
SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:
By: JGK Yes No Publicly Available Sensitive NRC-002
OFFICE SES:ACES HP:RCB SEP:RCB C:RCB C:PBD ATL:ACES
NAME JKramer DAntonangeli SHedger BAlferink JDixon RKumana
SIGNATURE /RA/ E /RA/ E /RA/ E /RA/ E /RA/ E /RA/ E
DATE 05/30/23 05/26/23 05/25/23 05/30/23 05/25/23 05/26/23
OFFICE RC OE DD:DORS D:DRSS
NAME DCylkowski DJones MHay GMiller
SIGNATURE /RA/ E /RA/ E /RA/ E /RA/ ARivera-Varona for
DATE 05/31/23 05/31/23 06/01/23 6/2/2023
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number: 05000382
License Number: NPF-38
Report Number: 05000382/2023040
Enterprise Identifier: I-2023-040-0000
Licensee: Entergy Operations, Inc.
Facility: Waterford Steam Electric Station, Unit 3
Location: Killona, LA
Inspection Dates: February 27, 2023 to May 16, 2023
Inspectors: S. Hedger, Senior Emergency Preparedness Inspector
D. Antonangeli, Health Physics Inspector
Approved By: Beth S. Alferink, Chief (Acting)
Response Coordination Branch
Division of Radiological Safety & Security
Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting an inspection procedure 95001 supplemental inspection at the
Waterford Steam Electric Station, Unit 3, in accordance with the Reactor Oversight Process.
The Reactor Oversight Process is the NRCs program for overseeing the safe operation of
commercial nuclear power reactors. Refer to
https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
Type Issue Number Title Report Section Status
NOV 05000382/2022091-01 Failure to Maintain Accurate 95001 Closed
Dose Assessment Methods
NOV 05000382/2022501-01 Failure to Maintain Accurate 95001 Closed
EAL Thresholds and Dose
Assessment Methods
EDG EA-23-036 Main Steam Line B 95001 Closed
Radiation Monitor
(ARMIRE5500B) - Dose
Assessment (Example 1)
EDG EA-23-036 Boron Waste Management 95001 Closed
and Liquid Waste
Management Radiation
Monitors (PRMIRE0627,
PRMIRE0547) - Emergency
Action Level Classification
(Example 2)
EDG EA-23-036 Fuel Handling Building 95001 Closed
WRGM Mid-Range Detector
(PRMIRE3032) -
Emergency Action Level
Classification and Dose
Assessment (Example 3)
EDG EA-23-036 Containment High Range 95001 Closed
Radiation Monitors A and B
(ARMIRE5400AS,
ARMIRE5400BS) -
Emergency Action Level
Classification (Example 4)
EDG EA-23-036 Main Steam Line A 95001 Closed
Radiation Monitor
(PRMIRE5500A) - Dose
Assessment (Example 5)
2
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
complete when the IP requirements most appropriate to the inspection activity were met
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors reviewed selected procedures and records,
observed activities, and interviewed personnel to assess licensee performance and compliance
with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES - TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
95001 - Supplemental Inspection Response to Action Matrix Column 2 (Regulatory Response)
Inputs
The inspectors reviewed and selectively challenged aspects of the licensees problem
identification, causal analysis, and corrective actions in response to two White findings in the
Emergency Preparedness cornerstone. The NRC communicated the licensees entry into
Reactor Oversight Process Action Matrix Column 2, Regulatory Response Column, in the
cover letter of NRC Inspection Report 05000382/2022090, dated September 12, 2022
(Agencywide Document and Management System (ADAMS) Accession Number
ML22241A143). Further, the NRC indicated with the second White finding that licensee
performance continued to be assessed in Action Matrix Column 2 in the cover letter of NRC
Inspection Report 05000382/2023090, dated February 1, 2023 (ML23035A384). The findings
are summarized below:
The licensee failed to follow and maintain the effectiveness of an emergency plan in
accordance with 10 CFR 50.54(q)(2). 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.
The licensee failed to follow and maintain the effectiveness of an emergency plan in
accordance with 10 CFR 50.54(q)(2). Specifically, 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 the licensee had conversion factor errors that would result in inaccurate dose
assessments for a radiological release through the plant vent stack exhaust path.
The correspondence communicating the changes in action matrix status documented the
issuance of two White Notices of Violation (NOVs). For the first White NOV, the licensee
responded in correspondence submitted on October 12, 2022 (ML22285A214). The licensees
response to the second White NOV was documented on February 20, 2023 (ML23051A002).
The inspectors reviewed these responses as part of the inspection.
3
The licensee staff informed the NRC staff by letter, dated February 15, 2023, of their readiness
for this supplemental inspection (ML23046A375). The licensee performed three root cause
evaluations (RCEs) in preparation for the inspection to identify the process and organizational
weaknesses that resulted in the two White findings. The key RCEs reviewed were:
RCE CR-WF3-2022-3999, Condenser Wide Range Gas Monitor RD72 Incorrect
Calibration Methodology, Revisions 1 through 3
RCE CR-WF3-2022-6367, Incorrect Calibration of Wide Range Gas Monitors Used in
Emergency Response Procedures, Revisions 1 through 3
RCE CR-WF3-2022-7836, Waterford 3 Steam Electric Station Collective Review of
Radiation Monitors Issues, Revisions 1 through 3
As part of the evaluations, the licensee also assessed their safety culture to identify any
contribution to the root or contributing causes. In addition, due to their having two White Action
Matrix inputs, the licensee conducted a common-cause analysis to assess potential
programmatic weaknesses in performance (RCE CR-WF3-2022-7836). The licensee provided
the NRC inspectors a copy of their RCEs on February 16, 2023, along with other supporting
evaluations and documentation by February 21, 2023. Subsequently, the NRC performed the
onsite portion of this supplemental inspection during the week of February 27-March 3, 2023.
The objectives of this supplemental inspection included the following:
Provide assurance that the root causes and contributing causes of risk-significant
performance issues were understood.
Provide assurance that the extent of condition and extent of cause of risk-significant
performance issues were identified.
Provide assurance that the licensees corrective actions for risk-significant performance
issues were sufficient to address the root and contributing causes and prevent
recurrence.
Evaluate additional examples of failures to maintain the effectiveness of the Waterford
Steam Electric Station, Unit 3 emergency plan occurring between 1987 and February 27,
2023, as identified by the licensee through their review of legacy radiation monitor
calibration practices, supporting technical documentation maintenance, and equipment
maintenance issues, as part of their overall corrective action review for the two White
findings.
The inspectors reviewed the licensees RCEs and other corrective action program evaluations
the licensee conducted in support of, or as a result of, the RCEs. The inspectors reviewed
corrective actions that the licensee had taken to address the identified causes. The inspectors
also held discussions, conducted field walkdowns reviewing subject radiation monitoring
equipment, and conducted interviews with licensee personnel to determine if the root and
contributing causes, and the contribution of safety culture components, were understood, as
well as whether completed or planned corrective actions were adequate to address the causes
and prevent recurrence.
4
Supplemental Inspection Response to Action Matrix Column 2 (Regulatory Response) Inputs
(1 Sample)
(1) This supplemental inspection is being conducted in response to the licensee being
placed in the Regulatory Response column due to two White findings in the
Emergency Preparedness Cornerstone.
INSPECTION RESULTS
Assessment 95001
1) Problem Identification
a) Identification
The issues resulting in the two White findings were identified by the licensee. The
situations leading to their identification are described in detail within the Event
Narrative of RCE CR-WF3-2022-3999 and CR-WF3-2022-6367.
RCE CR-WF3-2022-3999 - Reviews of questions involving the licensees
maintenance of calibration source information led to a review of calibration
documentation and performance starting in late 2021. On January 18, 2022,
the licensee identified that the main condenser wide range gas monitor
(WRGM) mid- and high-range detectors post replacement calibrations did not
correctly account for source decay correction.
RCE CR-WF3-2022-6367 - Engineering reviews of post-corrective maintenance
documentation on September 8, 2022, revealed engineering conversion factors
for the plant stack WRGM had been updated with incorrect values on
June 6, 2022.
b) Exposure Time
The issues had the following exposure times:
RCE CR-WF3-2022-3999 - The main condenser WRGM detectors had been in
this condition since January 18, 2011, until February 4, 2022 (approximately
11 years).
RCE CR-WF3-2022-6367 - The plant stack WRGM high-range detectors had
incorrect factors in use from June 6, 2022, until September 11, 2022
(approximately 97 days).
c) Identification Opportunities
The licensee had multiple prior opportunities to identify the conditions leading to the two
White findings, including operating experience, previous detector failures, response to
previous regulatory issues with calibration and maintenance practices, and system
reviews. The licensees RCEs sufficiently addressed these prior opportunities to identify
these conditions, as discussed below.
5
d) Risk and Compliance
With emergency preparedness issues being evaluated from a deterministic
perspective, no formal risk analysis was performed for the two White findings.
However, using the existing criteria, the two issues had violations of White significance
issued in their respective inspection reports. The licensee did evaluate the risk and
consequences as part of the Analysis of Risk and Safety Consequences sub-section
of Section 3.0, Analysis of the Event, in each RCE. The described consequences and
risk insights were consistent with the NRC assessments.
NRC Assessment:
The inspectors determined that the licensee had multiple opportunities to identify and address
the conditions that led to the White findings, prior to their recent licensee identification.
However, the root and common cause evaluations adequately addressed prior opportunities to
identify. The licensee appropriately understands the risk and compliance aspects of the White
findings.
2) Causal Analysis
a) Methodology
The RCE for the first White finding (CR-WF3-2022-3999) employed multiple causal
analysis methods to identify root and contributing causes. Methods included a
comparative timeline, event, and causal factor charting; barrier analysis, organization
and programmatic screening; and performance gap analyses.
For the second White finding RCE (CR-WF3-2022-6367), the licensee used similar
causal analysis methods to the first, with additional ones added in the effort to identify
root and contributing causes. Methods included event and causal factor charting;
barrier analysis, task analysis, performance gap analyses, organizational and
programmatic screening; and human performance evaluation.
To identify additional broader root or contributing causes related to both White findings,
the common-cause analysis RCE (CR-WF3-2022-7836) utilized similar analysis tools.
Common methods included event and causal factor charting (including Why Trees);
barrier analysis, and organization and programmatic screening. In addition, the
licensee employed a common cause analysis. The scope for using these tools included
not only the events associated with the two White findings, but also other radiation
monitoring system (RMS) events captured in the corrective action program over the
previous two years.
The inspectors determined that the different methods provided a reliable and scrutable
evaluation. Also, the inspectors determined these analyses were performed with
sufficient rigor to identify root and contributing causes.
b) Level of Detail
The inspectors determined that each of the three RCEs was of sufficient detail
commensurate with the significance and complexity of the issues and regulatory
requirements.
6
c) Operating Experience
For each of the three evaluations, the licensee conducted reviews of internal and
external operating experience. The reviews looked for occurrences of same or similar
performance issues where knowledge gained could be used to improve the evaluation.
RCE CR-WF3-2022-3999: Review of internal operating experience found one issue
previously identified that had applicability to this evaluation: a 2009 issue where
questions regarding the appropriate actions and calibration procedure accuracy with
respect to a RD-72 detector replacement in the plant stack WRGM mid-range detector
(CR-WF3-2009-1101). Additional text addressing calibration practice review after
detector replacement was added to an existing RMS desk guide (MI-005-906), but no
requirements to review and revise calibration procedures were implemented. This was
a missed opportunity to identify the lack of direction to correctly replace and calibrate
WRGM RD-72 detectors. Regarding external operating experience the licensee found
that there were missed opportunities to detect the White finding based on review of
NRC Information Notice 2013-13 and RMS users group feedback on engineering
conversion factor replacement requirements with detector replacements (CR-WF3-
2022-0284). The inspectors concluded the operating experience review was
appropriate.
RCE CR-WF3-2022-6367: Internal operating experience review considered whether
reviews of the RMS database update process were appropriate while evaluating and
correcting the first White finding (CR-WF3-2022-0284, -3999). However, since the first
White finding involved historical technical errors in WRGM calibration methods, and
dealt with RMS factor database configuration control processes, the issues appeared to
be separate. Regarding external operating experience, the licensee concluded there
were no specific opportunities where instrument database configuration control events
could have resulted in this issue being avoided. The inspectors concluded that the
operating experience review was appropriate.
RCE CR-WF3-2022-7836: Internal operating experience review included events with all
types of RMS equipment over the last two years. These provided input in the common
cause analysis conducted within the evaluation. Regarding external operating
experience the licensee found that there were missed opportunities to detect the White
findings based on review of NRC Information Notice 2013-13 and other industry
information. The inspectors concluded that the operating experience review was
appropriate.
d) Extent of Condition and Cause
RCE CR-WF3-2022-3999: The extent of condition started with the review of
methodology used to calibrate WRGM detectors needing calibration after replacement.
The same condition was confirmed to exist in other WRGM detectors. Based on this,
the licensee extended the review to include all other radiation detectors that need
calibration after replacement. There was the potential that inadequate calibration
practices mentioned as part of the root cause statement affected other radiation
monitors at the plant. Therefore, an additional expansion in review scope took place,
including site radiation monitors with questions about their calibrations with same or
similar conditions to those originally being evaluated. In some cases, the licensee
7
identified radiation monitor issues that constituted failures to maintain the effectiveness
of the emergency plan. This resulted in identification of the following:
Conflicts between directions in Procedure MI-005-906, Radiation Monitor
System Desk Guide, and specific radiation monitor calibration procedures, led
to incorrect calibration practices.
Additional radiation monitors were found to be out of calibration with similar
conditions. This included WRGMs and area radiation monitors which support
emergency preparedness, Technical Specifications, and other licensing basis
assumptions. Some examples are detailed in the enforcement discretion
descriptions (examples 2, 3, and 4).
Detectors calibrated without calibration certificates being maintained.
Detectors with incorrect supporting equipment installed. An example is detailed
in the enforcement discretion descriptions (example 4).
Detectors not calibrated on required intervals.
Area radiation monitor calibrations that did not account for needed calibration
practice changes based on changes in equipment configuration and design
basis changes. An example is detailed in the enforcement discretion
descriptions (example 5).
The extent of cause scope included a review of all radiation detector calibration
procedures and instrument calibrations to see if changes made over the years had
resulted in calibration methodologies that were invalid in some respect. This was
because the licensee recognized the practice of making procedural changes without
adequate technical reviews, a key part of the root cause, most likely caused issues
elsewhere. For the procedure change review process, it was identified that past efforts
to ensure cross discipline reviews of technical procedure changes with supporting
documentation, using document W2.109, Procedure Development, Review &
Approval, were incomplete. Therefore, changes were needed in the process
(CR-WF3-2022-3999, CA-04) (associated with enforcement discretion example 1). This
lack of adequate procedure change reviews contributed to an example in the
enforcement discretion descriptions (example 2). This resulted in identification of the
following:
Calibration procedures lacked transfer calibration datasheets, as well as steps
for correct detector replacement.
Area radiation detectors did not have their specific reference values and dates
of calibration.
Area radiation detectors did not have their own isotope half-life calculation
worksheets.
The inspectors concluded that the licensees root cause evaluation adequately
addressed the extent of condition and extent of cause.
RCE CR-WF3-2022-6367: The extent of condition review included an assessment of
computer database constant values for the WRGMs in the plant, as well as other
radiation monitors that have computer database constant values maintained. The
values were compared with the controlled printed copy of the database values located
in the control room. Further, the controlled database values were verified versus vendor
information to ensure that the controlled copy had the correct values. This resulted in
identifying needed corrections in another electronic reference set of the controlled
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values, separate from those used for controlling the radiation instrumentation, as well
as actions to check engineering changes and work orders over the last two years to
see if they had any effects on the computer database constant values being
maintained.
The extent of cause included review of equipment important to emergency response
with digital parameters that could be negatively affected if configuration control is not
completed correctly for parameter changes. Control mechanisms of other
documentation that can affect RMS equipment function, both licensee-developed and
vendor supplied, were part of this review as well. The inspectors concluded that the
licensees root cause evaluation adequately addressed the extent of condition and
extent of cause.
RCE CR-WF3-2022-7836: The extent of condition review was largely an assessment
to see if extent of condition items identified in the other two RCE addressed the
appropriate scope. The licensee added an additional review to CR-WF3-2022-6367 to
perform a comprehensive evaluation for other potential conditions affecting radiation
monitors that could create vulnerabilities for operability or functionality. The extent of
cause reviewed the root and contributing causes from the other two RCEs to identify
any gaps in scope for corrective action that may have existed. Of note, this review
identified that earlier efforts with RCE CR-WF3-2022-3999 ensuring technically
defensible reviews of procedure changes using Procedure W2.109 were not fully
effective (CR-WF3-2022-7836, CA-08). Therefore, actions addressing the procedure
change review process were re-opened and addressed as a root cause in this
evaluation (focus of enforcement example 1). The inspectors concluded that the
licensees root cause evaluation adequately addressed the extent of condition and
extent of cause.
e) Safety Culture
The licensee addressed the safety culture aspects of the events within each of the
three evaluations. In each, there was a provided matrix discussing each of the
performance issues resulting in the subject White finding(s) with respect to each of the
safety culture traits noted in NUREG-2165, Safety Culture Common Language. The
licensee provided appropriate corrective actions for any of the performance deficiencies
that aligned with safety culture aspects. The inspectors concluded that the licensees
root cause evaluation appropriately considered safety culture traits.
NRC Assessment:
The licensee identified the following root causes and contributing causes for each of the
problem identification statements associated with the three RCEs:
Root Cause: Technical reviews of procedure revisions to MI-003-387, Condenser
Vacuum Pump Discharge Wide Range Noble Gas Radiation Monitor Channel
Calibration PRMIR0002, were inadequate to account for validation methodology
changes to ensure proper setup and calibration to within requirements for dose
assessment for the RD-72 detectors (detector type in WRGMs).
9
Contributing Cause 1: The instrumentation and control (I&C) maintenance group had
not established requirements for calibrating the RD-72 detector to account for
infrequent performance and unique requirements for calibration when the detector is
replaced.
Contributing Cause 2: The I&C maintenance group had not obtained equipment to
validate specific count rates for replaced equipment or utilized vendor support with
available equipment (for example, a Multi-level Channel Analyzer) to verify detector
replacement setup is adequate.
Contributing Cause 3: Standards had not been reinforced for the I&C maintenance
group to incorporate lessons learned from post maintenance activities when additional
information was required to complete task.
Contributing Cause 4: Condition Reports related to calibration and replacement of the
RD-72 detectors had not been screened appropriately to require thorough evaluation
(level of evaluation and extent of condition) and effective corrective actions assigned.
This would have identified proper calibration actions after detector replacement and
would have provided assessments of equipment post-calibration ensuring the tasks
were completed correctly.
Root Cause: The configuration control process for radiation monitoring system (RMS)
monitors (Procedure UNT-007-029, Control of the Radiation Monitoring System
Database) had not been consistently implemented for the affected equipment.
Verification that the RMS data and documentation was complete, accurate, and
up-to-date was not consistently occurring when returning equipment to service.
Contributing Cause 1: Engineering and I&C Maintenance supervision had not
reinforced standards with their personnel requiring documentation to be maintained
complete, accurate, and up-to-date for radiation monitoring equipment.
Contributing Cause 2: WRGM calibration and functional test instructions were not
explicit as to what actions were needed to verify accuracy of RMS databases, what
information should be maintained for documentation, and what documentation is
required to be up-to-date and accurate prior to return to service.
Contributing Cause 3: Previous corrective actions had focused specifically on correctly
updating the equipment data points and the technical procedure for replacing RD-72
detectors. Corrective actions did not fully evaluate the administrative process for
updating the RMS database, leading to unforeseen issues after return to service.
Root Cause 1: Historic technical issues with RMS maintenance instructions were not
identified and addressed during the procedure revision process.
Root Cause 2: Maintenance instructions and change processes did not have clear
guidance that would ensure documentation for radiation monitoring systems was
maintained up-to-date and accurate.
10
Contributing Cause 1: I&C maintenance and engineering management had not been
enforcing corporate standards for procedural use and adherence. This includes
processes for updating procedures and performance of maintenance activities on RMS
equipment.
Contributing Cause 2: I&C maintenance and engineering management had not ensured
internal and external operating experiences, including industry best practices, had been
integrated into the RMS program and processes.
Contributing Cause 3: Plant management had not ensured that risks were identified,
evaluated, and mitigated for radiation monitoring maintenance activities through
systematic methods to ensure acceptable outcomes.
Contributing Cause 4: Historic corrective action process reviews associated with prior
RMS deficiencies have not resulted in aggregate reviews to identify larger issues.
Contributing Cause 5: Program governance had not been adequately established,
ensuring that periodic assessments and benchmarking activities resulted in system
improvements.
The inspectors determined that each of the three RCEs appropriately identified and
documented the root and contributing causes for the associated problem statements and
identified the appropriate extent of cause and condition.
3) Corrective Actions
a) Corrective Actions to Preclude Repetition
(1) Completed
(a) Revised the Fuel Handling Building WRGM calibration
procedure (MI-003-371) to include calibration instructions when
replacement of a RD-72 detector replacement is required. Revisions
address use of a multi-channel analyzer for replacement activities.
(b) Revised the Plant Stack WRGM calibration procedure (MI-003-383) to
include calibration instructions when replacement of a RD-72 detector
replacement is required. Revisions address use of a multi-channel analyzer
for replacement activities.
(c) Revised the Main Condenser WRGM calibration procedure (MI-003-387) to
include calibration instructions when replacement of a RD-72 detector
replacement is required. Revisions address use of a multi-channel analyzer
for replacement activities.
The effectiveness reviews for the Corrective Action to Preclude Repetition (CAPR)
involved an independent technical review of actions taken and produced
documentation following the next calibration following a RD-72 detector
replacement in one of the three subject WRGMs. The inspectors concluded
that the licensee has identified an appropriate effectiveness review for
11
b) Other Corrective Actions
(1) Completed
(a) Completed calibration verifications of multiple site radiation monitors due to
questions raised about past calibration practices, calibration equipment
usage, and maintenance or correct supporting documentation. Initiated and
completed corrective maintenance as identified (extent of condition and
cause).
(b) Revised WRGM calibration procedures to include transfer calibration
datasheets.
(c) Revised Procedure W2.109, Procedure Development and Approval, to
include independent technical review (engineering cross-discipline reviews
at minimum) for proposed revisions changing the methodology for
completing tasks, as well as changing the equipment used to address a
task.
(d) Updated radiation monitor engineering basis documentation to ensure it is
based on the most accurate source information.
(e) Revised other radiation detector calibration procedures (non WRGM) to
ensure that correct calibration methodology following detector replacement
was documented. In addition, revised these procedures to ensure that
correct calculations and reference documentation will be maintained with
subsequent calibrations.
(f) Updated I&C maintenance group training to better address infrequent
activities such as detector replacement practices.
(g) Revised arrangements and plans for RD-72 detector replacements to
ensure that appropriate equipment and expertise are involved replacement
activities.
(h) Documented risk mitigation expectations for site management, providing
training on site-wide expectations.
(i) Revised both corrective action and performance improvement process
documentation to better address the level of rigor desired in condition report
reviews.
a) Corrective Actions to Preclude Repetition
(1) Completed
(a) Revised RMS calibration procedures with instruction ensuring database
values are maintained complete, accurate, and up to date prior to returning
affected equipment to service.
(b) Define reviewer and supervisor roles ensuring database values are
addressed during maintenance correctly. Individuals in these roles ensure
any database value change is implemented correctly as required.
(c) Define engineering reviews for database value changes to ensure impacts
are reviewed and addressed prior to returning affected equipment to
service.
The effectiveness reviews for the CAPR involve a sample review of work activity
documentation associated with replacement and calibration of radiation monitors.
This review activity will verify that correct vendor information is being documented,
12
actions to ensure accurate database values are in place and are being completed
appropriately, supervisory reviews are correctly being performed, and that
engineering reviews of proposed changes are taking place correctly. The
inspectors concluded that the licensee has identified an appropriate effectiveness
review for RCE CR-WF3-2022-6367.
b) Other Corrective Actions
(1) Completed
(a) Performed a review of RMS database values in place to ensure that correct
ones are being used for all associated radiation monitors.
(b) Reviewed work orders over the last two years affecting radiation monitors to
see if anything affecting database values was being documented correctly
and updated in the respective database.
(c) Reviewed radiation monitor database values and supporting basis
documentation to ensure that traceability of correct values can be
established to support their design functions.
(d) Established and communicated standards for RMS database value
maintenance to engineering and I&C maintenance supervision. Standards
were documented in observation tools used by supervision to ensure that
activities affecting the RMS database values are addressed appropriately.
(e) Revised radiation monitor calibration and functional test procedures (not just
those affecting WRGMs) to include database value verification activities
before and after doing work affecting the associated monitor. This included
line-by-line independent verification of actions steps, and revisions to
technician training on completing these tasks.
(f) Provided training on the RMS database change process to ensure staff
understand standards to improve audit quality and issue identification. Also
included was an action to audit the database change process semiannually.
a) Corrective Actions to Preclude Repetition
(1) Completed
(a) Root Cause 1: Revised Procedure W2.109, Procedure Development and
Approval, with direction in the editorial review process ensuring that
proposed changes get categorized as editorial or non-editorial changes
properly. This procedure revision ensures that technical issues are reviewed
by the appropriate licensee personnel. This was an additional action beyond
what was taken as part of corrective actions associated with RCE CR-WF3-
2022-3999 addressing a gap in previous efforts ensuring calibration
procedure changes get appropriate cross discipline reviews and have
technical background documentation supporting the changes adequacy.
(b) Root Cause 2: No additional corrective actions were identified following
review of RCE CR-WF3-2022-7836. CAPR RCE CR-WF3-2022-6367 (a)(1)
remains sufficient to address maintenance instructions and change
processes.
The effectiveness review for the CAPR involves sampling calibration procedure changes to
see if the changes to Procedure W2.109 are being implemented as designed. This will
involve reviewing the procedure change documentation, as well as radiation monitor work
orders and condition reports to see if the RMS database values are being maintained up to
13
date, and if there are any other needed corrections to see if any issues with radiation
monitor procedures and equipment are being identified that were previously missed. The
inspectors concluded that the licensee has identified an appropriate effectiveness review
for RCE CR-WF3-2022-7836.
b) Other Corrective Actions
(1) Completed - None
(2) Planned
(a) Perform an independent technical review of site maintenance instructions
for radiation monitors using vendor technical guidance. Identify any
discrepancies and address them using the corrective action program.
(b) Complete a health assessment of the RMS in the next year. Document any
identified common deficiencies, repetitive issues, and outstanding
maintenance activities which could negatively affect the systems health.
(c) Perform a review of procedure revisions categorized as editorial changes
over the last 24 months to see if the process described in
Procedure W2.109 was followed correctly. This involves radiation protection
procedures, as well as other types of procedures onsite (extent of cause).
(d) Complete training on lessons-learned and desired behaviors in procedural
adherence for leadership, managers, and supervisors. Leaderships
observation tools for work will be reviewed and documentation from required
observations will be evaluated to verify training effectiveness.
(e) Incorporate lessons learned from response to the two White findings into the
model work orders used for radiation monitor work activities.
(f) Perform a radiation monitor program self-assessment on a 12-month
periodicity. This is to ensure RMS equipment parameters are being
maintained accurately, and calibrations are being performed error-free.
NRC Assessment:
The inspectors determined that the licensee implemented or planned appropriate and timely
corrective actions to preclude repetition. The licensee also identified appropriate effectiveness
reviews for these actions. With respect to evaluating the licensees response to the two White
NOVs, the licensee demonstrated actions addressing the reasons for the violations, have
taken or planned for corrective actions with achievable results, and have addressed restoration
of full compliance. The inspectors identified the following weaknesses/performance
deficiencies (no significant weaknesses identified) in this inspection:
Weaknesses:
The inspectors identified that one of the actions for the first White findings root cause
(RCE CR-WF3-2022-3999, RC-CA4) was appropriately identified, but was not
appropriately implemented. Corrective action to revise document W2.109, Procedure
Development, Review & Approval, included revising parts of the process to include
independent technical reviews (cross-discipline, at a minimum including engineering)
for revisions changing methodology or equipment requirements to carry out tasks.
While procedure changes were implemented to address this as part of the normal
procedure revision process, no changes were made in the Editorial Correction (EC)
Review Process to ensure that proposed changes, which were not editorial by nature,
were identified, and assigned the necessary independent technical reviews. As a result,
this contributed to the issue with Main Steam Line B Radiation Monitor ARMIRE5500B
14
not reading correctly in October-November 2022 (CR-WF3-2022-6367) (see
enforcement discretion example 1). However, the inspectors noted the licensee
reevaluated this process issue in RCE CR-WF3-2022-7836; elevating actions from a
contributing cause to a CAPR; and completing the new actions in a prompt manner,
which fully addressed process vulnerabilities.
The inspectors identified that appropriate measures of success for the CAPR with RCE
CR-WF3-2022-3999 had not been developed such that the corrective actions
effectiveness would be evaluated. This involved an effectiveness review assessing
calibration effectiveness of RD-72 detectors after replacement. As was stated in
Section 8.0 of the RCE, the time standard for conducting this effectiveness review
would be completed at the next detector calibration after CAPR completion. Since the
next RD-72 detector calibration may occur for various situations, one of which is if there
is a detector replacement, the scope of when the effectiveness review could be
completed may be implemented for a calibration activity that does not include the
appropriate circumstances to measure corrective action effectiveness. In addition, the
reviews success criteria did not include qualitative measures for evaluation. The
licensee initiated actions to revise the effectiveness reviews scope addressing this
issue in CR-WF3-2023-01052.
4) Conclusion
Overall, the inspectors determined that the licensees problem identification, causal analyses,
and corrective actions sufficiently addressed the performance issues that led to the two White
findings. All inspection objectives, as described in the Inspection Procedure 95001, were met.
Scheduled corrective action items will be inspected as part of the ongoing NRC baseline
inspection program. Therefore, this inspection is closed.
Enforcement Discretion Enforcement Action EA-23-036: Main Steam Line B 95001
Radiation Monitor (ARMIRE5500B) - Dose
Assessment (Example 1)
Description: During the licensees extent of cause reviews associated with RCEs
CR-WF3-2022-3999 and CR-WF3-2022-6367, they broadened the scope of their corrective
actions to look at all radiation monitor detector replacements and the associated procedures.
The licensee added steps into their procedure change process to include independent
technical reviews of procedure changes associated with calibration methodology. However, a
subject matter expert evaluation of the detector replacement of Main Steam Line B Radiation
Monitor on October 20, 2022, resulted in the monitor being declared inoperable since it was
replaced (CR-WF3-2022-07376). Based on a causal analysis review, a calibration after the
monitor was replaced did not take place and was required to restore operability. In 2022, the
procedure MI-003-389 was revised to include steps for detector replacement. However, no
independent technical review of this procedure change occurred, which could have recognized
the error of no calibration required after install being in the revised procedure. As a result,
there was no radiation monitor calibration after detector replacement in October 2022. For
ARMIRE5500B, during the affected time, the monitor would read 40 percent lower than it was
supposed to. The normal calibration range is plus or minus 10 percent. Similar to RCE CR-
WF3-2022-3999 and RCE CR-WF3-2022-7836, technical reviews of the change to Procedure
MI-003-389 were inadequate in order to ensure proper setup and calibration of the Main Steam
Line B Radiation Monitor after replacement to within requirements for dose assessment.
15
The inoperable radiation monitor resulted in a failure to comply with a risk significant planning
standard (RSPS), with a degraded RSPS function. This is due to there being some cases in
which the dose projection process would be incapable of providing technically adequate
estimates of radioactive material releases to the environment or projected offsite doses.
Corrective Action(s): The licensee corrected the condition and completed the necessary
calibration activities. The radiation monitor was returned to operable status on November 10,
2022. To prevent future issues with technical procedure changes being inappropriately
categorized as editorial changes, and thus receiving inadequate reviews, additional revisions
to Procedure W2.109, Procedure Development and Approval, were completed, addressing
the CAPR for RCE CR-WF3-2022-7836. Actions are documented in the licensees corrective
action program.
Corrective Action Reference(s): Condition Reports CR-WF3-2022-07376,
Enforcement:
Severity/Significance: The staff determined the significance of the violation is not greater than
White as determined by a bounding evaluation with Manual Chapter 0609, Appendix B,
Attachment 2.
Violation: Title 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
Title 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 October 20 to November 10, 2022, the licensee failed to follow
and maintain the effectiveness of an emergency plan in accordance with 10 CFR 50.54(q)(2),
which meets the planning standards of 10 CFR 50.47(b). Specifically, the licensee failed to
have adequate methods for assessing and monitoring offsite consequences for a radiological
release through the steam generator B release path as required by 10 CFR 50.47(b)(9).
Discretion Basis: The NRC exercised enforcement discretion in accordance with Section 3.3 of
the Enforcement Policy, because the violation was identified by Waterford Steam Electric
Station, Unit 3 staff as part of the extent of condition for a previous enforcement action, the
violation has the same or similar root causes as the violation for which enforcement action was
previously taken, the violation does not substantially change the safety significance or
character of the initial violation, and the violation was corrected.
Enforcement Discretion Enforcement Action EA-23-036: Boron Waste 95001
Management and Liquid Waste Management
Radiation Monitors (PRMIRE0627, PRMIRE0547) -
Emergency Action Level Classification (Example 2)
16
Description: During licensee extent of cause reviews associated with RCEs
CR-WF3-2022-3999 and CR-WF3-2022-6367, it was identified that the calibration of the Boron
Waste Management and Liquid Waste Management Radiation Monitors had not been done
correctly for some time. Errors in engineering conversion factors used, as well as an incorrect
background radiation assumption used in calibration caused the issues, similar to the root and
contributing causes associated with RCE CR-WF3-2022-3999. Site calibration procedures
allowed for using a background radiation level of 800 counts per minute (cpm), whereas the
primary calibration documents associated with the radiation monitors allow for a maximum of
100 cpm. Background radiation at the time was roughly 700 cpm. For the two monitors, during
the affected time, they read 16.4 percent lower than they were supposed to. The normal
calibration range is plus or minus 15 percent.
The non-functional radiation monitor resulted in a failure to comply with a risk significant
planning standard (RSPS), with no loss of PS function or a degraded RSPS function. This is
due to an emergency action level being rendered ineffective such that an Unusual Event
(AU1.1) would be declared in a degraded manner.
Corrective Action(s): The licensee initiated compensatory measures for their emergency
preparedness function while the calibration issues were being resolved. The licensee entered
these issues into the corrective action program.
Corrective Action Reference(s): Condition Reports CR-WF3-2022-07572,
Enforcement:
Severity/Significance: The staff determined the significance of the violation is not greater than
Green as determined by a bounding evaluation with Manual Chapter 0609, Appendix B,
Attachment 2.
Violation: Title 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
Title 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.
Contrary to the above, from January 1, 1989, to May 16, 2023, the licensee failed to follow and
maintain the effectiveness of an emergency plan in accordance with 10 CFR 50.54(q)(2),
which meets the planning standards of 10 CFR 50.47(b). Specifically, the licensee failed to
have a standard emergency classification and action level scheme in use by the nuclear facility
licensee as required by 10 CFR 50.47(b)(4).
Discretion Basis: The NRC exercised enforcement discretion in accordance with Section 3.3 of
the Enforcement Policy, because the violation was identified by Waterford Steam Electric
Station, Unit 3 staff as part of the extent of condition for a previous enforcement action, the
violation has the same or similar root causes as the violation for which enforcement action was
previously taken, the violation does not substantially change the safety significance or
character of the initial violation, and the violation was corrected.
17
Enforcement Discretion Enforcement Action EA-23-036: Fuel Handling 95001
Building WRGM Mid-Range Detector
(PRMIRE3032) - Emergency Action Level
Classification and Dose Assessment (Example 3)
Description: During licensee extent of cause reviews associated with RCEs CR-WF3-2022-
3999 and CR-WF3-2022-6367, the licensee identified that the Fuel Handling Building WRGM
mid-range detector was out of calibration. Past operability review established that it had been
inoperable since November 11, 1987. The cause was found to be the removal of the
requirement to use a multi-channel analyzer during the calibration from the controlling
procedure, similar to the cause identified in RCE CR-WF3-2022-3999. A calibration of the Fuel
Handling Building WRGM mid-range detector was conducted using appropriate equipment
(multi-channel analyzer and a Barium-133 alignment source).
The as-found condition was that the detector was reading 18 percent higher than it was
supposed to (LER 2022-01-02, CR-WF3-2022-08104). The normal calibration range is plus or
minus 10 percent.
The inoperable radiation monitor resulted in a failure to comply with a risk significant planning
standard (RSPS), with a degraded RSPS function. This is due to there being some (but not all)
cases in which the dose projection process would be incapable of providing technically
adequate estimates of radioactive material releases to the environment or projected offsite
doses. Also, an emergency action level was rendered ineffective because it could have
resulted in an overclassification of a General Emergency (AG1.1), leading to unnecessary
protective actions being issued to the public.
Corrective Action(s): Adjustments and calibration were completed, returning it to operable
service on December 15, 2022. The licensee entered these issues into the corrective action
program.
Corrective Action Reference(s): Condition Reports CR-WF3-2022-03999,
Enforcement:
Severity/Significance: The staff determined the significance of the violation is not greater than
White as determined by a bounding evaluation with Manual Chapter 0609, Appendix B,
Attachment 2.
Violation: Title 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).
Title 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.
18
Title 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 November 11, 1987, to December 15, 2022, the licensee failed
to follow and maintain the effectiveness of an emergency plan in accordance with
10 CFR 50.54(q)(2), which meets the planning standards of 10 CFR 50.47(b). Specifically,
the licensee failed to have adequate methods for assessing and monitoring offsite
consequences for a radiological release through the steam generator B release path as
required by 10 CFR 50.47(b)(9). In addition, the licensee failed to have a standard emergency
classification and action level scheme in use by the nuclear facility licensee as required by
Discretion Basis: The NRC exercised enforcement discretion in accordance with Section 3.3 of
the Enforcement Policy, because the violation was identified by Waterford Steam Electric
Station, Unit 3 staff as part of the extent of condition for a previous enforcement action, the
violation has the same or similar root causes as the violation for which enforcement action was
previously taken, the violation does not substantially change the safety significance or
character of the initial violation, and the violation was corrected.
Enforcement Discretion Enforcement Action EA-23-036: Containment High 95001
Range Radiation Monitors A and B
(ARMIRE5400AS, ARMIRE5400BS) - Emergency
Action Level Classification (Example 4)
Description: During licensee extent of cause reviews associated with RCE CR-WF3-2022-
3999, it was identified that Containment High Range Radiation Monitors A and B had both
been inoperable for varying time periods. For Containment High Range Monitor A, the cause
was due to a installed pico-ammeter board and a detector signal cable that were incapable
of providing for its design performance functions. The engineering conversion factors for
Containment High Range Monitor B were incorrect, negatively affecting the monitors
calibration. Further, for Containment High Range Monitors A and B, there was a failure
to account for the keep-alive source during half-life calculations, which is necessary for
correct calibration. The calibration practice issues were caused by inadequate legacy
instructions in their calibration Procedure MI-003-360, similar to the causes identified in
The as-found condition was that Containment High Range Radiation Monitor A indication
during that affected time could not be used for reliable indication. Containment High Range
Radiation Monitor B was reading 29.8 percent lower than it was supposed to, with a normal
calibration range of plus or minus 15 percent.
The inoperable radiation monitors resulted in a failure to comply with a risk significant planning
standard (RSPS), with a degraded RSPS function. This is due to an emergency action level
rendered ineffective such that a General Emergency (FG1.1) would not be declared for a
particular off-normal event but an appropriate declaration would have been made in a
degraded manner.
Corrective Action(s): Containment High Range Radiation Monitor A was returned to operable
service on May 14, 2022. On May 11, 2022, Containment High Range Radiation Monitor B
was returned to operable service. The licensee entered these issues into the corrective action
program.
19
Corrective Action Reference(s): Condition Report CR-WF3-2022-03097
Enforcement:
Severity/Significance: The staff determined the significance of the violation is not greater than
White as determined by a bounding evaluation with Manual Chapter 0609, Appendix B,
Attachment 2.
Violation: Title 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
Title 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.
Contrary to the above, from July 11, 2012, to May 11, 2022, the licensee failed to follow and
maintain the effectiveness of an emergency plan in accordance with 10 CFR 50.54(q)(2),
which meets the planning standards of 10 CFR 50.47(b). Specifically, the licensee failed to
have a standard emergency classification and action level scheme in use by the nuclear facility
licensee as required by 10 CFR 50.47(b)(4).
Discretion Basis: The NRC exercised enforcement discretion in accordance with Section 3.3 of
the Enforcement Policy, because the violation was identified by Waterford Steam Electric
Station, Unit 3 staff as part of the extent of condition for a previous enforcement action, the
violation has the same or similar root causes as the violation for which enforcement action was
previously taken, the violation does not substantially change the safety significance or
character of the initial violation, and the violation was corrected.
Enforcement Discretion Enforcement Action EA-23-036: Main Steam Line A 95001
Radiation Monitor (PRMIRE5500A) - Dose
Assessment (Example 5)
Description: During licensee extent of condition reviews associated with
RCE CR-WF3-2022-3999, the licensee identified that Main Steam Line A Radiation Monitor
failed numerous calibrations since detector replacement. Previous calibrations did not
correctly track new reference ion chamber output dose-rate values, which would be needed
to correctly calibrate the monitor on subsequent occasions. The cause was that calibration
Procedure MI-003-389 did not have steps directing recording these values for later use, similar
to the causes identified in RCE CR-WF3-2022-3999. Based on past reviews, the monitor had
not been operating with a satisfactory calibration, and therefore inoperable, since March 17,
2004.
The as-found condition was that the detector was reading 17 to 24 percent higher than it
was supposed to (CR-WF3-2022-03392). The normal calibration range is plus or minus
15 percent.
20
The non-functional radiation monitor resulted in a failure to comply with a risk significant
planning standard (RSPS), with a degraded RSPS function. This is due to there being some
(but not all) cases in which the dose projection process would be incapable of providing
technically adequate estimates of radioactive material releases to the environment or projected
offsite doses.
Corrective Action(s): The licensee determined the correct values and revised the calibration
procedure. With the corrected procedure, the radiation monitor was calibrated correctly and
returned to service on May 5, 2022. The licensee entered these issues into the corrective
action program.
Corrective Action Reference(s): Condition Reports CR-WF3-2022-02539, CR-WF3-2022-
03392, CR-WF3-2022-03097
Enforcement:
Severity/Significance: The staff determined the significance of the violation is not greater than
White as determined by a bounding evaluation with Manual Chapter 0609, Appendix B,
Attachment 2.
Violation: Title 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
Title 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 March 17, 2004, to May 5, 2022, the licensee failed to follow and
maintain the effectiveness of an emergency plan in accordance with 10 CFR 50.54(q)(2),
which meets the planning standards of 10 CFR 50.47(b). Specifically, the licensee failed to
have adequate methods for assessing and monitoring offsite consequences for a radiological
release through the steam generator B release path as required by 10 CFR 50.47(b)(9).
Discretion Basis: The NRC exercised enforcement discretion in accordance with Section 3.3 of
the Enforcement Policy, because the violation was identified by Waterford Steam Electric
Station, Unit 3 staff as part of the extent of condition for a previous enforcement action, the
violation has the same or similar root causes as the violation for which enforcement action was
previously taken, the violation does not substantially change the safety significance or
character of the initial violation, and the violation was corrected.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On May 16, 2023, the inspectors presented the 95001 supplemental inspection results to
John Ferrick, Site Vice President, and other members of the licensee staff.
21
On March 3, 2023, the inspectors presented the 95001 supplemental inspection
preliminary inspection results to Mandy Halter, General Manager of Plant Operations,
and other members of the licensee staff.
22
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
95001 Corrective Action Condition Reports 2020-04019, 2022-0284, 2022-02010, 2022-02221, 2022-
Documents (CR-WF3-) 03999, 2022-06367, 2022-06378, 2022-06467, 2022-06477,
2022-06663, 2022-07326, 2022-07376, 2022-07572, 2022-
07593, 2022-07836, 2022-08104, 2023-00764, 2023-00765,
2023-00810
95001 Corrective Action Condition Reports 2023-0550, 2023-00978, 2023-00994, 2023-01001, 2023-
Documents (CR-WF3-) 01002, 2023-01003, 2023-01014, 2023-01016, 2023-01020,
Resulting from 2023-01052, 2023-01053, 2023-01055
Inspection
95001 Engineering EC 86890 Radiological Effluent EAL Values 0, 1
Changes
95001 Engineering EC 93677 Evaluate Impact of Detector Sensitivity Change For 0
Changes PRMIRE0110 & PRMIRE3032 Per CR-WF3-2022-02010 CA- 29 and Update Related Documents
95001 Miscellaneous CR-WF3-2022- Root Cause Evaluation, Condenser Wide Range Gas Monitor 1, 2, 3
03999 RD72 Incorrect Calibration Methodology
95001 Miscellaneous CR-WF3-2022- Root Cause Evaluation, Incorrect Calibration of Wide Range 1, 2, 3
6367 Gas Monitors Used in Emergency Response Procedures
95001 Miscellaneous CR-WF3-2022- Root Cause Evaluation, Waterford 3 Steam Electric Station 2, 3
7836 Collective Review of Radiation Monitor Issues
95001 Miscellaneous Work Task 2022-00095, 2023-0023, 2023-0024
Tracking
Documents (LO-
WLO-)
95001 Procedures EN-AD-106 Site Procedure Writer's Manual 2
95001 Procedures EN-HU-106 Procedure and Work Instruction Use and Adherence 9
95001 Procedures EN-LI-100 Process Applicability Determination 33
95001 Procedures EN-LI-101 10 CFR 50.59 Evaluations 21
95001 Procedures EN-LI-102 Corrective Action Program 47, 48
95001 Procedures EN-LI-118 Causal Analysis Process 35
95001 Procedures MI-003-350 Containment Purge Isolation Area Radiation Monitor Channel 302, 305
A or B Functional Test, ARMIR5024, ARMIR5025,
23
Inspection Type Designation Description or Title Revision or
Procedure Date
ARMIR5026, or ARMIR5027
95001 Procedures MI-003-360 Containment High Range Safety Channel A or B Area 309, 316
Radiation Monitor Calibration, ARMIR5400 A or ARMIR5400
B
95001 Procedures MI-003-370 Fuel Handling Building Ventilation Noble Gas Radiation 302, 304
Monitor Channel Functional Test PRMIR3032
95001 Procedures MI-003-371 Fuel Handling Building Ventilation System Emergency 311, 318
Exhaust High Range Noble Gas Radiation Monitor Channel
Calibration PRMIR3032
95001 Procedures MI-003-382 Plant Vent Stack High Range Noble Gas Radiation Monitor 6, 10
Channel Functional Test PRMIR0110
95001 Procedures MI-003-383 Plant Vent Stack High Range Noble Gas Radiation Monitor 21, 29
Channel Calibration PRMIR0110
95001 Procedures MI-003-386 Condenser Vacuum Pump Discharge High Range Noble Gas 301, 303
Radiation Monitor Channel Functional Test PRMIR0002
95001 Procedures MI-003-387 Condenser Vacuum Pump Discharge Wide Range Noble 19, 26
Gas Radiation Monitor Channel Calibration PRMIR0002
95001 Procedures MI-003-389 Main Steam Line Radiation Monitor Channel Calibration 312
ARMIR5500A or ARMIR5500B
95001 Procedures MI-005-906 Radiation Monitoring System Desk Guide 6
95001 Procedures MI-005-910 Mobile Airborne Radiation Monitor Calibration, ARMIR5132, 7, 9
ARMIR5144
95001 Procedures MI-005-919 Containment Post LOCA Area Radiation Monitor Safety 303, 309
Channel A or B Calibration, ARMIR5028, 5029, 5030, 5031
95001 Procedures UNT-007-029 Control of the Radiation Monitor System Database 4, 5, 7
95001 Procedures W2.109 Procedure Development, Review, and Approval 31, 32, 33,
35
95001 Work Orders Work Order 573242, 573245, 582053, 585706, 585710, 587031, 587955,
Number 588201, 588499
24