IR 05000382/2014002
| ML14128A528 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 05/08/2014 |
| From: | Greg Werner NRC/RGN-IV/DRP/RPB-E |
| To: | Chisum M Entergy Operations |
| Werner G | |
| References | |
| Download: ML14128A528 (49) | |
Text
May 8, 2014
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 NRC INTEGRATED INSPECTION REPORT 05000382/2014002
Dear Mr. Chisum:
On March 31, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Waterford Steam Electric Station, Unit 3 facility. On April 1, 2014, the NRC inspectors discussed the results of this inspection with Mr. Carl Rich, Jr., Director , Regulatory and Performance Improvement, and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report. NRC inspectors documented four findings of very low safety significance (Green) in this report.
All of these findings involved violations of NRC requirements.
The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the NRC Enforcement Policy.
If you contest the violations or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspectors at the Waterford Steam Electric Station, Unit 3 facility.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV; and the NRC resident inspectors at the Waterford Steam Electric Station, Unit 3. In accordance with Title 10 of the Code of Federal Regulations Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/ Gregory E. Werner, Chief Project Branch E Division of Reactor Projects Docket No.: 50-382 License No.: NPF-38 Enclosure: Inspection Report 05000382/2014002 w/ Attachment: Supplemental Information cc w/ encl: Electronic Distribution
- 1 - Enclosure -
- 2 - Four findings of very low safety significance (Green) are documented in this report. All of these findings involved violations of NRC requirements. -- - Green. The inspectors identified a non-cited violation of Technical Specification 6.8.1.a because the licensee did not establish written procedures to fill the diesel fuel oil storage tanks for their emergency onsite power sources. Specifically, the licensee did not establish procedures to fill the fuel oil storage tanks for the emergency diesel generators using the credited safety-related, seismic category 1 emergency fill line. The licensee entered this condition into their corrective action program as Condition Report CR-WF3-2014-00636. The immediate corrective action taken to restore compliance was to develop procedures to fill the emergency diesel generator fuel oil storage tanks using the safety-related, seismic category 1 emergency fill line and evaluate other alternative methods. The inspectors concluded that the failure to establish procedures to fill the fuel oil storage tanks for the emergency onsite power sources was a performance deficiency. The performance deficiency was more than minor because it was associated with the procedure quality attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, it reduced sources following a loss of offsite power or extreme weather event (e.g., a seismic or flooding event) that may last longer than seven days. The inspectors performed the initial significance determination for this issue. The inspectors used NRC Inspection Manual Chapter 0609, to evaluate the issue. The initial screening directed the inspectors to use Inspector Manual Chapter 0609, - Exhibit 2, Section A, to determine the significance of the issue. The finding required a detailed risk evaluation because the performance deficiency could have resulted in a loss of safety function (onsite ac power) because the system may not have remained operable for its 30-day design basis accident mission time. Therefore, a Region IV senior reactor analyst performed a detailed risk evaluation for this issue. The analyst determined that the finding was of very low safety significance (Green) because the diesel generators would have remained functional for the 24-hour probabilistic risk assessment mission time. This detailed risk evaluation used the shorter mission time because after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the NRC assumed
- 3 - that the licensee had substantially more resources available to help mitigate the accident. The dominant core damage sequences included longer-term loss of offsite power events and the common cause failure of the diesel generators due to potential problems to refill the diesel fuel oil storage tanks after seven days. The relatively long period prior to ultimate diesel generator failure helped to minimize the risk. Additionally, the finding was not a significant contributor to the large early release frequency. The inspectors concluded that the finding reflected current licensee performance and involved an avoiding complacency cross-cutting aspect of the human performance area in that the licensee did not [H.12] (Section 1R04). A self-revealing, non-cited violation of Technical Specification 6.8.1.a. occurred because the licensee did not develop a preventative maintenance schedule to inspect or replace an item that has a specific lifetime. Specifically, the licensee did not develop a preventative maintenance schedule to inspect or replace the essential chiller oil pump motors prior to exceeding their duty life. As a result, the essential chiller oil pump B motor failed in-service. The licensee entered this condition into their corrective action program as Condition Report CR-WF3-2014-0095. The immediate corrective action taken to restore compliance was to issue an action request to establish the periodic replacement of the essential chiller oil pumps prior to the end of their vendor recommended service life. The inspectors concluded that the failure to develop a preventative maintenance schedule to inspect or replace the essential chiller oil pump motors prior to the end of the vendor provided duty life was a performance deficiency. The performance deficiency was more than minor because it was associated with the equipment performance attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, it affected the availability and reliability of the essential chillers to provide a heat sink for the removal of process and operating heat from selected safety-related equipment during design basis accidents. -The inspectors also concluded that the finding did not have a cross-cutting aspect because the most significant contributor to the performance deficiency occurred more than 3 years ago, and did not reflect current licensee performance (Section 1R12). The inspectors identified a non-cited violation of License Condition 2.C.9 because the licensee did not implement Procedure EN-DC-rol of Combustibles, which requires, in part, that a transient combustible evaluation shall be processed or compensatory actions shall be established if a flammable liquid exceeds one pint in an approved container. Specifically, the licensee did not implement Section 5.6 of Procedure EN-DC-161 after a fuel oil leak from the standby fuel oil pump for the train B emergency diesel generator exceeded one pint in an approved container which eventually failed to hold the fuel oil while in service. The licensee entered this condition into their corrective action program as Condition Reports CR-WF3-2013-6020 and CR-WF3-2013-06123. The immediate corrective actions taken to restore compliance was to remove the leaking fuel oil from around the emergency diesel generator, implement an
- 4 - hourly fire watch, and repair the standby fuel oil pump leak and returned the emergency diesel generator to an operable status on January 3, 2014. The inspectors concluded that the failure to implement a fire protection program procedure was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection against external factors (i.e., fire) attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to perform a transient combustible evaluation when a flammable liquid above one pint in an approved container was present in the B emergency diesel generator room prevented the licensee from implementing required compensatory measures in response to the presence of transient combustibles surrounding and on the B emergency diesel generator. In addition, similar to NRC Inspection Manual Chapter 0612, Appendix E, Section 4, Example k, of a more than minor violation, the failure of the leak collection device resulting in fuel oil around the B emergency diesel generator represented a credible fire scenario involving transient combustibles that could affect equipment important to safety. The inspectors used to evaluate this issue. Since this finding was related to controls for transient combustible materials, tinspectors categorized the finding under Fire Prevention and Administrative Controls and qualitatively screened it as very low safety significance (Green) because the impact of the fire finding was limited to no more than one train of equipment important to safety. The inspectors concluded that the finding reflected current licensee performance and involved a conservative bias cross-cutting aspect in the human performance area in that the licensee did not use decision making practices that emphasized prudent choices over those that are simply allowable [H.14] (Section 1R15). A self-revealing, non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, occurred because the licensee did not establish design control measures for the selection and review for the suitability of application of a molded case circuit breaker that was essential to the safety-related function of a shutdown cooling heat exchanger fan cooler. Specifically, the licensee did not select and review for the suitability of the correct safety-related circuit breaker for the application to provide circuit fault protection to the train B shutdown cooling heat exchanger air handling unit fan motor. The licensee entered this condition into their corrective action program as Condition Reports CR-WF3-2013-02316 and CR-WF3-2013-04644. The immediate corrective action taken to restore compliance included the replacement of the breaker with a breaker more suitable for the application to protect the air handling unit fan motor. The planned corrective actions included an extent of condition review for other installed breakers and the revision of work order instructions to eliminate the practice of substituting and using the factory acceptance testing for pre-installation and post-maintenance tests, respectively. The inspectors concluded that the failure to establish design control measures for the selection and review for suitability of application for the correct safety-related circuit breaker was a performance deficiency. The performance deficiency was more than minor because it was associated with the design control attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the incorrect breaker affected the availability, reliability, and capability of the
- 5 - shutdown cooling heat exchanger fan coolers to remove heat from the shutdown cooling heat exchanger areas following a design basis accident. The inspectors performed the initial significance determination. The inspectors used the NRC Inspection Manual 0609, AttachmThe initial screening Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Section A, to determine the significance of the finding. The finding required a detailed risk evaluation because it involved a potential loss of one train of safety-related equipment for longer than the technical specification allowed outage time. The total exposure period was 23 days. The allowed outage time was 7 days. A Region IV senior reactor analyst performed the detailed risk evaluation and determined that the change to the core damage frequency was 5E-13/year (Green). The dominant core damage sequences included loss of offsite power events, failure of both trains of containment spray, and the failure of a pressurizer safety relief valve to remain closed. The equipment that helped mitigate the risk included the emergency diesel generators and the essential feedwater systems. The inspectors concluded that the finding reflected current licensee performance and involved a cross-cutting aspect of avoiding complacency in the human performance area because the licensee did not recognize and plan for the possibility of mistakes, latent issues, and inherent risk on relying on 21 year old vendor information and installing a breaker without pre-installation and adequate post-maintenance testing [H.12] (Section 4OA2.2).
- 6 - a. - - Alternate direct current system b.
- 7 - -- On January 2, 2014, temporary emergency diesel generators with emergency diesel generator B out of service for maintenance On February 12, 2014, auxiliary component cooling water train A with train B out of service for maintenance On February 24, 2014, emergency feedwater trains A and B with the steam driven emergency feedwater pump AB out of service for maintenance - -mergency diesel generator fuel oil storage and transfer system- - The inspectors identified a Green, non-cited violation of Technical Specification 6.8.1.a because the licensee did not establish written procedures to fill the diesel fuel oil storage tanks for their emergency onsite power sources. Specifically, the licensee did not establish procedures to fill the fuel oil storage tanks for the emergency
- 8 - diesel generators using the credited safety-related, seismic category 1 emergency fill line following any design basis event and loss of offsite power --an extreme weather event (e.g., seismic, tornado, or flooding) ------------an extreme weather andevent with a loss of offsite power. -to fill the diesel fuel oil storage tanks using the -The licensee entered this condition into their corrective action program as Condition Report CR-WF3-2014-00636. The immediate corrective action taken to restore compliance was to develop procedures to fill the emergency diesel generator fuel oil storage tanks using the alternate emergency fill line and to evaluate other alternative methods. failure to establish procedures to fill the fuel oil storage tanks for the emergency onsite power sources was a performance deficiency
- 9 - fuel oil storage tanks for the onsite power sources following a loss of offsite power or extreme weather event (e.g., a seismic or flooding event) that may last longer than seven days. ---- The inspectors concluded that the finding reflected current licensee performance and involved an avoiding complacency cross-cutting aspect of the human performance area in that the licensee did not [H.12]. the licensee did not establish procedures to fill the fuel oil storage tanks for the emergency diesel generators using the credited safety-related, seismic category 1 alternate emergency fill line following any design basis accident and loss of offsite power--- --
- 10 - On January 14, 2014, fire area CT4-001, wet cooling tower train B - - -- -- February 13, 2014,- Flooding analysis zone 35, Wing Area
- 11 - -- -- -- -
- 12 - a. - - On February 25, 2014, emergency feedwater to steam generator number 2 backup isolation valve (EFW-229B) dissimilar metal issue
- 13 - - A self-revealing Green, non-cited violation of Technical Specification 6.8.1.a occurred because the licensee did not develop a preventative maintenance schedule to inspect or replace an item that has a specific lifetime. Specifically, the licensee did not develop a preventative maintenance schedule to inspect or replace the essential chiller oil pump motors prior to the end of their vendor provided service life --- --
- 14 - The immediate corrective action taken to restore compliance was to issue an action request to establish the periodic replacement of the essential chiller oil pumps prior to the end of their vendor recommended service life. exceedingit affected the availability and reliability of the essential chiller to provide a heat sink for the removal of process and operating heat from selected safety-related equipment during design basis accidents-- --- --
- 15 - On February 24, 2014, emergency feedwater train AB outage On February 11, 2014, feedwater to emergency feedwater header pressurizing check valves FW-1763A and FW-1763B
- 16 - - On February 10, 2014, operability determination for emergency feedwater pump AB Failure to Perform an Evaluation for Transient Combustibles Introduction. The inspectors identified a Green, non-cited violation of License Condition 2.C.9, because the licensee did not implement Procedure EN-DC-processed or compensatory actions shall be established if a flammable liquid exceeds one pint in an approved container. Specifically, the licensee did not implement Section 5.6 of Procedure EN-DC-161 after a fuel oil leak from the standby fuel oil pump for the train B emergency diesel generator exceed one pint in an approved container which failed while in service. Description. On December 4, 2013, the licensee discovered a fuel oil leak coming from the standby fuel oil pump for emergency diesel generator B. The licensee initiated Condition Report CR-WF3-2013-5962. As a part of the operability evaluation, the licensee quantified the leak at 10 drops per minute (dpm) and put a leak collection device in place to contain the leaking fuel. At this time, the licensee declared the emergency diesel generator B fully operable with no compensatory actions. On December 14, 2013, the fuel oil leak increased from 10 dpm to 45 dpm. The licensee initiated another Condition Report CR-WF3-2013-6020 and concluded that the fuel oil leak although showing degradation did not affect the operability of the emergency diesel generator B. The licensee established a leak of 60 dpm as the limit to take action. The inspectors reviewed the condition reports and operability evaluations, and questioned the licensee about the operability of the emergency diesel generator B and standby fuel oil pump condition. The licensee replied that although Procedure EN-OP-104, ,recommended that oil leaks from safety-related
- 17 - pumps be classified as operable-degraded/nonconforming, operable-op/evaluation, inoperable, or inoperable-op/evaluation, it was not a requirement. On December 20, 2013, the inspectors identified that the leak collection device did not adequately contain the leaking fuel oil from the standby fuel oil pump. The inspectors found fuel oil leaking on the floor around the emergency diesel generator B. At that time, the inspectors considered this to represent a credible fire scenario that could affect safety-related equipment and further questioned the categorization of the standby fuel oil pump condition since no transient combustible evaluation or compensatory actions of having a fire watch was in place. The licensee took action to clean the leaking fuel oil, initiated another Condition Report CR-WF3-2013-6123 and determined that Procedure EN-DC-,evaluation or compensatory actions. Specifically, the licensee designated the emergency diesel room B as a Level 2 Combustible Control Zone in Attachment 9.8 of the procedure. Section 5.6 of Procedure EN-DC-161, allows only one pint of flammable liquid in approved containers in the area without an evaluation or appropriate compensatory measures. The inspectors noted that the leak collection device could hold up to two gallons, which would exceed the one-pint limit. Following discussions with the inspectors, the licensee promptly established an hourly fire watch and performed the required transient combustible evaluation. In addition, the licensee revised the operability of the diesel as operable with compensatory measures and established that personnel monitor the leak every six hours. The inspectors determined that if the licensee followed the recommended classification per the operability determination procedure, then the licensee might have recognized that this degraded condition needed a transient combustible evaluation or compensatory measures. The licensee repaired the standby fuel oil pump on January 3, 2014, and returned emergency diesel generator B to a fully operable status. Analysis. The failure to implement a fire protection program procedure was a performance deficiency. The inspectors determined that this deficiency was reasonably more than minor because it was associated with the protection against external factors (i.e., fire) attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to perform a transient combustible evaluation when a flammable liquid above one pint in an approved container was present in the B emergency diesel room prevented the licensee from implementing required compensatory measures in response to the presence of transient combustibles. In addition, similar to NRC Inspection Manual Chapter 0612, Appendix E, Section 4, Example k, of a more than minor violation, the failure of the leak collection device resulted in fuel oil around the emergency diesel generator B, which represented a credible fire scenario that involve transient combustibles that could potentially affect equipment important to safety. The inspectors used NRC Inspection Manual Chapter Since this finding was related to controls for transient combustible materials, the initial screening directed the inspectors to use Appendix F, the finding. The inspectors categorized the finding under Fire Prevention and Administrative Controls and qualitatively screened it as very low safety significance (Green) because the impact of the fire finding was limited to no more than one train of
- 18 - equipment important to safety. The inspectors concluded that the finding reflected current licensee performance and involved a conservative bias cross-cutting aspect in the human performance area in that the licensee did not use decision making practices that emphasized prudent choices over those that are simply allowable [H.14]. Enforcement. License Condition 2.C.9, requires, in part, that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report. Final Safety Analysis Report, Section 9.5.1.6.3, specifies Procedure UNT-005-responsibilities, controls, and implementing requirements for the Waterford 3 Fire Protection Program. Procedure UNT-005-013, Section 5.4.2, specifies that transient combustibles shall be controlled in accordance with Procedure EN-DC--DC-161, Attachment 9.8, identifies the train B emergency diesel generator room as a Level 2 area and in Section 5.6, states, in part, that a transient combustible evaluation shall be processed for Level 2 Plant Areas combustibles associated exceed one pint in approved containers. Contrary to the above, from December 4 until December 20, 2013, the licensee failed to comply with License Condition 2.C.9 to implement and maintain in effect all provisions of the approved fire protection program as described in the final safety analysis report for the facility and as approved in the Safety Evaluation Report. Specifically, the licensee failed to perform a transient combustible evaluation as required by EN-DC-161 when it was required. The licensee entered this condition into their corrective action program as Condition Reports CR-WF3-2013-6020 and CR-WF3-2013-06123. Because this violation was of very low safety significance and the licensee entered the issue into their corrective action program, this violation was treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy: NCV 05000382/2014002-03Implement a Fire Protection Program Procedure to - -
- 19 - - -- On February 14, 2014, auxiliary component cooling water pump B following significant maintenance - ---- - - - On January 16, 2014, essential chilled water pump A operability test On February 10, 2014, refueling water storage pool isolation valves
- 20 - FS-404 and FS-423 On January 13, 2014, emergency diesel generator train A operability test On January 17, 2014, emergency feedwater pump A operability test On February 28, 2014, ultimate heat sink thermal performance test train A a. --- - - b.
- 21 - --- - -
- 22 - - -
- 23 - - -- - .1 Failure to Establish Adequate Design Control Measures for the Selection and Review for the Suitability of Application of Molded Case Circuit Breakers Introduction. A self-revealing, Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, occurred because the licensee did not establish design control measures for the selection and review for the suitability of application of a molded case circuit breaker that was essential to the safety-related function of a shutdown cooling heat exchanger fan cooler. Specifically, the licensee did not select and review the suitability of the correct safety-related circuit breaker for the application to provide circuit fault protection for the train B shutdown cooling heat exchanger air handling unit fan motor. Description. On April 18, 2013, during a preventive maintenance task for an installed molded case circuit breaker, the train B shutdown cooling heat exchanger fan motor
- 24 - breaker (HVREBKR313B-4D) failed to function. The failed breaker was a Gould 10-amp breaker with an instantaneous rating of 58 amps. The licensee did not have a like-for-like breaker replacement due to obsolescence. At that time, the licensee generated Engineering Change Request 15610 to install a Westinghouse 7-amp breaker with an instantaneous rating of 56 amps. The licensee selected the breaker based on design drawing B289, sheets 2 and 80, which contain generic motor data for motor control center breaker settings. On May 8, 2013, the licensee received an annunciator alarm in the control room that indicated a loss of power to shutdown cooling heat exchanger room B air handling unit (HVRAHU0032-B). The licensee initiated troubleshooting and attempted to start the air handling unit fan motor. However, the 7-amp breaker tripped and the air handling unit failed to start on demand. The licensee attempted to start the unit once more but the breaker tripped again. The licensee entered an unplanned 7-day shutdown limiting condition of operation since this affected the operability of the train B containment spray system. Additionally, the licensee initiated an apparent cause evaluation Condition Report CR-WF3-2013-2316. As a follow-up to this issue, the inspectors reviewed the apparent cause evaluation report, preventive maintenance tasks for the breaker, work orders, operator logs, design documents, and post-maintenance tests. The inspectors determined that the licensee installed the incorrect circuit breaker following the replacement of the obsolescent Gould 10-amp breaker when the licensee could not locate a like-for-like replacement. The inspectors noted that as a part of the engineering change request conducted by the licensee, the licensee identified the incorrect breaker and established the wrong instantaneous setting of 56 amps. The inspectors noted that the design documents used for the selection of the 7-amp replacement breaker did not account for the shutdown cooling heat exchanger room B air handling unit motor locked rotor current because it was unknown at the time of the selection. The inspectors also noted that the licensee did not set the instantaneous setting to twice the locked rotor current as described in the design drawing for breaker settings and the final safety analysis report, as updated. The inspectors mentioned to the licensee that the locked rotor current information should be contained on the nameplate rating for the fan motor. The licensee ing 1564-8954. Based on the locked rotor current information, the licensee generated another engineering change request to install a 15-amp breaker with an instantaneous setting of 75 amps. Additionally, the inspectors identified that the licensee had the wrong instantaneous setting for the shutdown cooling heat exchanger room A breaker because it was not set to twice the locked rotor current as described in design documentation. The licensee entered this condition into their corrective action program as Condition Report CR-WF3-2013-04644 and conducted an extent of condition review. In addition to the design control issues, the inspectors identified that the licensee did not perform pre-installation and post-maintenance tests of molded case circuit breakers if the vendor had already conducted factory acceptance tests. The inspectors noted that work order instructions allowed the licensee to substitute factory acceptance test for the pre-installation and post-maintenance tests, respectively. The inspectors noted that the factory acceptance tests were at times more than 21 years old. The immediate corrective actions taken to restore compliance included the replacement of the breaker with a breaker more suitable for the application to protect the air handling unit fan motor. The planned corrective action included an extent of condition review for other installed breakers and the revision of work order instructions to eliminate the practice of
- 25 - substituting and using the factory acceptance testing for pre-installation and post-maintenance tests, respectively. The failure to establish design control measures for the selection and review for suitability of application for the correct safety-related circuit breaker was a performance deficiency. The performance deficiency was more than minor because it was associated with the design control attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the incorrect breaker affected the availability, reliability, and capability of the shutdown cooling heat exchanger fan coolers to remove heat from the shutdown cooling heat exchanger areas following a design basis accident. The inspectors performed the initial significance determination. The inspectors used the NRC Inspection Manual 0609, AttThe initial screening directed the inspectors to use Inspection Manual At-The finding required a detailed risk evaluation because it involved a potential loss of one train of safety-related equipment for longer than the technical specification allowed outage time. The total exposure period was 23 days. The allowed outage time was 7 days. A Region IV senior reactor analyst performed the detailed risk evaluation. The analyst noted that the containment spray pumps affected both the mitigating systems and barrier integrity cornerstone objectives. However, NRC Inspection Manual Chapter 0609, -Related Structures, Systems and Components Considered for Larcontainment sprays are important to late containment failure and source term but not LERF the unmitigated releases from containment in a time frame prior to the effective evacuation of the close-in population. While containment failure was possible, it would not occur before the licensee and local emergency preparedness personnel would evacuate the close-in population. Therefore, the analyst only considered the impact to internal events. The analysts performed simplified calculations to determine the change to the core damage frequency (delta-CDF) for the containment spray pump failure. The analyst used the Waterford-3 Standardized Plant Analysis Risk model, Revision 8.16, with a truncation limit of E-20. This truncation limit was needed because most of the sequences where the containment spray pump failed were truncated when the analyst used an E-11 truncation limit. The containment spray system as only modeled in the loss of offsite power event tree. Therefore, the analyst solved only the loss of offsite power sequences. The following definitions are important to this analysis: Nominal case this is the baseline risk for the developed sequences. This case does not include equipment failures associated with the performance deficiency. Current case this case includes the equipment failures associated with the performance deficiency.
- 26 - For the nominal and current cases, the analyst set the basic event for alternate room cooling to 1.0. The NRC had a prior finding where inspectors determined that the alternate room cooling would not function because the licensee did not have a safety-related power source for the fans, did not have procedures to direct the action, and did not train operators on the action (see NRC Inspection Report 05000382/2011007). For the current case, the analyst also set the basic event for the train B containment spray pump (failure to start) to 1.0. This was consistent with a condition were the common cause failure of both containment spray pumps was ruled out. The dominant core damage sequences included loss of offsite power events, failure of both trains of containment spray, and failure of a pressurizer safety relief valve to remain closed. Equipment that helped mitigated the risk included emergency diesel generators and the essential feedwater system. To isolate the cutsets of interest, the analyst used the slice function to identify cutsets that included the failed containment spray pump. The conditional core damage probability was 8E-12. This represented a full year of exposure. To determine the delta-CDF, the analyst factored in the 23-day mission time. The delta-CDF was 5E-13/year. Therefore, the finding was of very low safety significance (Green). The inspectors concluded that the finding reflected current licensee performance and involved a cross-cutting aspect of avoiding complacency in the human performance area because the licensee did not recognize and plan for the possibility of mistakes, latent issues, and inherent risk on relying on 21 year old vendor information and installing a breaker without pre-installation and adequate post-maintenance testing [H.12]. shall also be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems and components. Contrary to the above, prior to May 2013, the licensee did not establish design control measures for the selection and review for the suitability of application of a molded case circuit breaker that was essential to the safety-related function of a shutdown cooling heat exchanger fan cooler. Specifically, the licensee did not select and review the suitability of the correct safety-related circuit breaker for the application to provide circuit fault protection for the train B shutdown cooling heat exchanger air handling unit fan motor. As a result, with the incorrect breaker installed this affected the availability, reliability, and capability of the shutdown cooling heat exchanger fan coolers to remove heat from the shutdown cooling heat exchanger areas that rendered one train of containment spray inoperable greater than its allowed outage time. The licensee entered this condition into their corrective action program as Condition Reports CR-WF3-2013-02316 and CR-WF3-2013-04644. Because this violation of is of very low safety significance and the licensee entered it into their corrective action program, it is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy: NCV 05000382/2014002-04Failure to Establish Adequate Design Control Measures for the Selection and Review for the Suitability of Application of Molded Case Circuit B
- 27 - - -- . --- On several occasions, the licensee declared auxiliary component cooling water train A inoperable due to excessive seat leakage on an air operated temperature control valve (ACC-126A). The licensee attributed the causes of the leakage to a calibration drift of the valve operator and degraded valve internals. The inspectors reviewed previous revisions of this event and identified a Non-Cited Violation 05000382/2012004-02, Failure to Identify and Correct Degraded Conditions Associated with the Auxiliary Component Cooling Water Heat Exchanger Temperature Outlet Control Valve. The inspectors documented this violation in Section 1R12 of the NRC Inspection Report 05000382/2012004 prior to the final revision of this licensee event report being issued. -- On May 20, 2013, during an operational surveillance run, the emergency diesel generator room temperature reached 118°F in less than one hour. The rise in room temperature was due to a failed exhaust fan. The exhaust fan failed because the fan hub assembly separated from the hub sleeve, which effectively separated the fan from the fan motor. The licensee identified that the train B emergency diesel generator exhaust fan blades were not rotating while the fan motor was operating. This condition made the emergency diesel generator inoperable since the purpose of the emergency diesel generator ventilation system is to remove the heat associated with diesel operation from the emergency diesel generator B room. As a part of the review of this event, the inspectors identified an apparent violation 05000382/2013008-01, Failure to Establish an Adequate Test Program to Demonstrate that the Train B Emergency Diesel Generator Exhaust Fan Would Perform Satisfactorily In-Service. The inspectors documented this violation in Section 1R22 of the NRC Inspection Report 05000382/2013008. -- On May 8, 2013, a safety-related circuit breaker tripped open on two consecutive start attempts of the shutdown cooling heat exchanger room B air handling unit by operation personnel. The breaker tripped because the licensee installed the wrong breaker during
- 28 - and engineering change request to replace the original breaker. As a part of the review of this event, the inspectors identified a Non-Cited Violation 05000382/2014002-04, Failure to Establish Adequate Design Control Measures for the Selection and Review for the Suitability of Application of Molded Case Circuit Breakers. The inspectors documented this violation in Section 4OA2 of this report. - - Mr. C. Rich Jr., Director, Regulatory and Performance Improvement A-1 Attachment A-2 -- -- -- Failure Implement a Fire Protection Program Procedure to Perform an Evaluation for Transient Combustibles -- Failure to Establish Adequate Design Control Measures for the Selection and Review for the Suitability of Application of Molded Case Circuit Breakers (Section 4OA2.2) --- --- - --- --- -- -- ---
A-3 --- -- - -- -- -- -- -- -- -- -- -- --- -- - --- --- --- --- --- ---
A-4 - - -- -- - - - -- -- MNQ-9-EC42927 Wet Cooling Tower Losses During LOCA 5 MNQ9-9EC34480 Wet Cooling Tower Losses During LOCA 5 MNQ9-9 EC8465 Wet Cooling Tower Losses During LOCA 5 MNQ9-3 EC8465 Heat Removal Capacities of DCT and WCT After LOCA 4 MNQ9-3 EC2918 Heat Removal Capacities of DCT and WCT After LOCA 4 ECM95-008 EC8465 Ultimate Heat Sink Design Basis 3 ECM95-008 EC2918 Ultimate Heat Sink Design Basis 3 MNQ9-9 Wet Cooling Tower Losses During LOCA 5 MNQ9-3 Heat Removal Capacities of DCT and WCT After LOCA 3 A-5 EC-M96-013 Auxiliary Component Cooling Water (ACCW) Jockey Pump Analysis 0 5-T EC43927 Essential Chilled Water Cooling Loads and Coil Performance Determination 005 EC-M97-001 Component Cooling Water Flow to the HPSI/LPSI Pumps 0 5-T Essential Chilled Water Cooling Loads and Coil Performance Determination 005 ER-W3-1998-0888-000 DC 3556 Containment Fan Coolers Temperature Control Valves (CC-835 A and B) Enhancements Documentation 1 PM 00004371 Replacement Frequency: Replace Regulators for CC Train 0 PM 00004359 Replacement Frequency: Replace Regulators for CC Train 0 N/A W3 CCW System Health Report Q4-2013 0 N/A W3 ACCW System Health Report Q4-2013 0 SD-CC Component Cooling Water System Description 21 1564-4590 EC2188 Engineering Change Markup: Fouling Factor Bottom Supply Counter Flow Design 5 1564-4589 EC2188 Engineering Change Markup: Fouling Factor Bottom Supply Counter Flow Design 5 457000087 Instruction Manual for Component Cooling Water Heat Exchangers 0 W3-DBD-4 EC41355 Engineering Change Markup: Component Cooling Water Auxiliary Component Cooling Water 302 W3-DBD-4 EC47283 Engineering Change Markup: Table 4.1.3: Water Consumption Plan 302 W3-DBD-4 EC8458 Engineering Change Markup: Component Cooling Water Auxiliary Component Cooling Water 301 W3-DBD-4 EC47125 Engineering Change Markup: Table 4.1.3: Water Consumption Plan 302 W3-DBD-4 EC40195 Engineering Change Markup: Component Cooling Water Auxiliary Component Cooling Water 302 Chemistry Data Waterford III NRC 3 Year Ultimate Heat Sink Assessment Chemistry Data 0 A-6 OLE-3-2 13.3.18.B Visual Examination System Leakage (VT-2) 0 CC-ECT-BOP-VE-12-004 Eddy Current Examination 0 CC-ECT-RF-16 0 PMRQ 00003256-06 WalkdowPiping for Leakage 0 PMRQ 00006233-01 Coils 0 PMRQ 00005440-01 Perform Eddy Current Test of CCW Heat Exchanger Tubes 0 CCW Heat Exchanger Performance Test 2013 Draft Results DRAFT: 2013 CCW Heat Exchanger Performance Evaluation 0 OLE-3-2 13.3.09 Visual Examination System Leakage (VT-2) 0 PETT370012 M&TE Laboratory Calibration Report: Cooling Tower AS4W1/4-155 0 PETT369046 M&TE Laboratory Calibration Report: Cooling Tower ASCRZ-2005 0 PEET342001 M&TE Laboratory Calibration Report: Helios DAQ Serial Number 6066002 0 W3P90-0207 Response to Generic Letter 89-13 0 LN 95-0014 NRC Inspection Report 50-382/94-26 and Notice of Violation 0 P-24636 Commitment List 12: Verbal Commitment to Test and Trend Containment Fan Cooler Air Flow On at Refueling Intervals 0 P-24342 Commitment List 11: Verbal Commitment to Perform a Flush of the ACCW to EFW Cross-tie Line and Evaluate the Need for Periodic Flushing 0 P-22658 Commitment List 10: Program for Commitments in Response to GL 89-13 has not been Formalized 0 A-25356 Commitment List 9: Design Basis Review Open Item No. EFW-130 will be Performed 0 A-24746 Commitment List 8: Verbal Commitment to Test and Trend Containment Fan Cooler Air Flow On at Refueling Intervals 0 A-7 A-24296 Commitment List 7: Verbal Commitment to Test and Trend Containment Fan Cooler Air Flow On at Refueling Intervals 0 A-23536 Commitment List 6: W3 Will Perform a Flush of the ACCW to EFW Cross-tie Line and Evaluate the Need for Periodic Flushing 0 A-22301 Commitment List 5: Program for Commitments in Response to GL 89-13 has not been Formalized 0 A-16992 Commitment List 4: Review MD Program for ACCW to Ensure Adequate MD is being Performed (GL 89-13 Response) 0 A-16991 Commitment List 3: Walkdown ACCW to Confirm Hardware Features in FSAR Exist in Field, Document, and Retain (GL 89-13 Response) 0 A-16990 Commitment List 2: Add ACCW Components to Erosion/Corrosion Program and Inspection (GL 89-13 Response) 0 A-16989 Commitment List 1: Collection of Heat Exchange Data from PMC Evaluation (GL 89-13 Response) 0 LO 2013-00127 WF3 Triennial Heat Sink Pre NRC Inspection Self-Assessment 0 LO-WLO 2010-0144 0 Program Health Report Q-3 2013 Program Health Report: Q3-2013 Heat Exchanger Program 0 System Health Report Q-3 2013 System Health Report: Q3-2013 Component Cooling Water 0 System Health Report Q-3 2013 System Health Report: Q3-2013 Auxiliary Component Cooling Water 0 EC-WF3-0000000738 Engineering Change: Component Cooling Water Temperature Rerate from the SHUTDOWN COOLING HEAT EXCHANGER 738 0 ER-W3-2005-0430-000 Stroke Times for CCW Isolation Valves 0 ER-W3-1999-0726-000 Generic Letter 96-06 RCB Penetrations Overpressurization 0 ER-W3-1998-Potential to Void in ACCW to Essential Chillers 4 A-8 0590-000 ER-W3-1998-0590-000 Potential to Void in ACCW to Essential Chillers 3 ER-W3-1998-0590-000 Potential to Void in ACCW to Essential Chillers 2 ER-W3-1998-0590-000 Potential to Void in ACCW to Essential Chillers 1 ER-W3-1998-0590-000 Potential to Void in ACCW to Essential Chillers 0 EC-WF3-0000000530 Engineering Change: Ultimate Heat Sink Water Replenishment for Tornado Event 0 DC 3470 Design Change Closeout: ACCW System Waterhammer 1 DC 3470 Design Change Closeout: ACCW System Waterhammer 0 5817-10751 Setting Plan for Component Cooling Water Heat Exchanger 7 5817-10750 Bundle and Hinge Details for Component Cooling Water Heat Exchanger 0 5817-10747 Component Cooling Water Heat Exchanger 0 5817-10743 Component Cooling Water Heat Exchanger Name Plate Type III 1-74-06-32481A3 1 1564-4590 General Layout AH-17-3B0B 5 1564-4589 General Layout AH-17 5 1564-1466 Component Cooling Water Heat Exchanger 6 1564-724 HP Safety Injection Pump Seal Piping 2 W3-DBD-4 Design Basis Document: Component Cooling Water Auxiliary Component Cooling Water 302 A-9 LBDCR EC43474 LBDCR Form: EDG Air Start Air Compressor Replacement 0 004_Section 9_2 WSES-FSAR-UNIT-3: Section 9.2 Water Systems 11-A SEP-HX-WF3-001_000 Generic Letter 89-13 Heat Exchanger Test Basis 0 CE-002-013 Maintaining Essential Services Chill Water Chemistry 303 CE-002-007 Maintaining Component Cooling Water Chemistry 305 CE-002-003 Maintaining Auxiliary Component Cooling Water Chemistry 302 PE-004-033 Wet Cooling Tower A(B) Thermal Performance Test 305 PE-004-024 CCW/ACCW System Flow Balance 304 PE-004-021 CCW Heat Exchanger Performance Test 003 PE-004-024 ACCW and CCW System Flow Balance: Train B 303 PE-004-024 ACCW and CCW System Flow Balance: Train A 303 OP-902-009 Emergency Operating Procedure Standard Appendices 309 OP-901-510 Component Cooling Water System Malfunction 301 CR-WF3-2014-00001 CR-WF3-2014-00012 CR-WF3-2014-00171 CR-WF3-2014-00185 CR-WF3-2014-00209 CR-WF3-2014-00216 CR-WF3-2014-00230 CR-WF3-2014-00232 CR-WF3-2014-00255 CR-WF3-2014-00281 CR-WF3-2014-00288 CR-WF3-2014-00296 CR-WF3-2014-00303 CR-WF3-2014-00306 CR-WF3-2014-00316 CR-WF3-2014-00346 CR-WF3-2014-00349 CR-WF3-2014-00352 CR-WF3-2014-00354 CR-WF3-2014-00400 CR-WF3-2014-00446 CR-WF3-2014-00448 CR-WF3-2014-00461 CR-WF3-2014-00481 CR-WF3-2014-00501 CR-WF3-2014-00504 CR-WF3-2014-00539 CR-WF3-2014-00543 CR-WF3-2014-00551 CR-WF3-2014-00571 CR-WF3-2014-00575 CR-WF3-2013-01352 CR-WF3-2013-03855 CR-WF3-2013-04404 CR-WF3-2013-04479 CR-WF3-2013-05373 CR-WF3-2013-05815 CR-WF3-2012-01044 CR-WF3-2012-01395 CR-WF3-2012-04818 CR-WF3-2012-02332 CR-WF3-2011-01102 CR-WF3-2011-06480 CR-WF3-2011-06741 CR-WF3-2011-06894 CR-WF3-2011-07631 CR-WF3-2011-08150 A-10 52363868-01 52363867-01 52366804-01 52320900-01 52320899-01 00186585-01 52502569-01 52406548-01 52406917-01 52321058-01 00339214-01 00338398-01 00137285-01 52406917-01 52502569-01 52406548-01 00041082-01 52517159-01 52519717-01 52320900-01 52320899-01 52270563-01 52036749-01 -- - -- -- -- -- -- --
A-11 --- --- --- - - -- -- -- --- -- --- -- -- -- -- -- - --
A-12 --- --- --- --- --- --- --- -- -- --- --- - -- -- -- -- -- -- -- - --- --- --- --- --- --- --- ---
A-13 -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- --
A-14 -- -- -- -- -- - --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- --- ---
A-15 1564-8954 Motor Data AH-3, 3A-SA, 3B-SB, & AH-20, 3b-SB 0 1564-1018S Shutdown Heat Exchanger B Cooler AH-3(3B-SB), Control Wiring Diagram 16 B289, Sheet 2 Power Distribution & Motor Data MCC Breaker Settings 16 B289, sheet 80 Power Distribution & Motor Data 480V MCC 3B313-S, One Line Diagram 22 Miscellaneous Documents - - -- -- -- - -- --
A2-1 Attachment - -- -- -- -- - 1. - 2. - 3. -- 4. --
A2-2 5. - 6. 7. 8. 9. -- 10. 11. 12. 13. 14. 15. 16. 17. 18. 19.
A2-3 20. 21. 22. 23. - 24. 25. 26. - 27. - 28. 29. 30. -- 31. -- 32. -- -- -