IR 05000382/2015004
| ML16021A448 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 01/21/2016 |
| From: | Sowa J NRC/RGN-IV/DRP/RPB-D |
| To: | Chisum M Entergy Operations |
| Melfi J | |
| References | |
| IR 2015004 | |
| Download: ML16021A448 (47) | |
Text
UNITED STATES ary 21, 2016
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED INSPECTION REPORT 05000382/2015004
Dear Mr. Chisum:
On December 31, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford Steam Electric Station, Unit 3. On January 14, 2016, the NRC inspectors discussed the results of this inspection with you and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.
NRC inspectors documented one finding of very low safety significance (Green) in this report.
This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the NRC Enforcement Policy.
If you contest the violation or significance of the NCV, 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 inspector at the Waterford Steam Electric Station, Unit 3. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public 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/
Jeffrey R. Sowa, Acting Chief Project Branch D Division of Reactor Projects Docket No. 50-382 License No. NPF-38
Enclosure:
Inspection Report 05000382/2015-004 w/ Attachment: Supplemental Information
REGION IV==
Docket: 0500032 License: NPF-38 Report: 05000382/2015004 Licensee: Entergy Operations, Inc.
Facility: Waterford Steam Electric Station, Unit 3 Location: 17265 River Road Killona, LA 70057 Dates: October 1 through December 31, 2015 Inspectors: F. Ramirez, Senior Resident Inspector C. Speer, Acting Senior Resident Inspector T. Sullivan, Acting Resident Inspector J. Choate, Acting Resident Inspector N. Greene, PhD, Health Physicist M. Phalen, Senior Health Physicist I. Anchondo, Reactor Inspector J. Sowa, Senior Resident Inspector Approved Jeffrey R. Sowa, Acting Chief By: Project Branch D Division of Reactor Projects-1- Enclosure
SUMMARY
IR 05000382/2015004; 10/01/2015 - 12/31/2015; Waterford Steam Electric Station, Unit 3;
Maintenance Effectiveness The inspection activities described in this report were performed between October 1 and December 31, 2015, by the resident inspectors at Waterford 3 and inspectors from the NRCs Region IV office. One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609, Significance Determination Process.
Their cross-cutting aspects are determined using Inspection Manual Chapter 0310,
Aspects within the Cross-Cutting Areas. Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.
Cornerstone: Initiating Events
- Green.
The inspectors reviewed a self-revealing, non-cited violation of Technical Specification 6.8.1.a, associated with the licensees failure to properly pre-plan and perform maintenance in accordance with EN-DC-153, Preventative Maintenance Component Classification. The licensee entered this condition into their corrective action program as condition report CR-WF3-2015-06438. The licensee restored compliance by properly classifying the components as High Critical in accordance with EN-DC-153, Revision 2, and by initiating development of appropriate preventative-maintenance for the control element assembly calculators (CEACs). In addition, the licensee initiated work to improve the reliability of the CEACs, including reviewing card refurbishments to ensure circuit card reliability is enhanced.
The performance deficiency was more than minor because it is associated with the Equipment Performance attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, inappropriate preventative maintenance on the circuit cards associated with the CEACs ultimately resulted in a plant trip on October 3, 2015. The inspectors screened the finding in accordance with NRC Inspection Manual Chapter (IMC) 0609, Significance Determination Process. Using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, the inspectors determined that the finding was of very low significance (Green) because the finding did not cause a trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition.
Because the performance deficiency occurred in 2008, the inspectors concluded that the finding does not reflect current licensee performance and therefore did not assign a cross-cutting aspect. (Section 1R12)
PLANT STATUS
The Waterford Steam Electric Station, Unit 3, began the inspection period at 100 percent power.
On October 4, 2015, an automatic reactor trip occurred due to the failure of core element assembly calculator (CEAC) 2. Following repairs to CEAC 2, the operators restarted the reactor on October 5, 2015, and achieved 100 percent power on October 7, 2015. The licensee initiated a plant shutdown on October 24, 2015, to begin refueling outage 20. On December 15, 2015, operators commenced a reactor startup. On December 21, 2015, the unit achieved full power. The unit remained at full power for the remainder of the inspection period.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
Readiness to Cope with External Flooding
a. Inspection Scope
On December 14, 2015, the inspectors completed an inspection of the stations readiness to cope with external flooding. After reviewing the licensees flooding analysis, the inspectors chose two plant areas that were susceptible to flooding:
- Main Steam Isolation Valve #1 Area
- Main Steam Isolation Valve #2 Area The inspectors reviewed plant design features and licensee procedures for coping with flooding. The inspectors walked down the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether credited operator actions could be successfully accomplished.
These activities constituted one sample of readiness to cope with external flooding, as defined in Inspection Procedure 71111.01.
b. Findings
No findings were identified.
1R04 Equipment Alignment
.1 Partial Walkdown
a. Inspection Scope
The inspectors performed partial system walk-downs of the following risk-significant systems:
- November 16, 2015, containment spray train B
- November 19, 2015, high pressure safety injection train B
- December 16, 2015, component cooling water train B The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the trains were correctly aligned for the existing plant configuration.
These activities constituted three partial system walk-down samples as defined in Inspection Procedure 71111.04.
b. Findings
No findings were identified.
1R05 Fire Protection
Quarterly Inspection
a. Inspection Scope
The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on four plant areas important to safety:
- November 3, 2015, fire area RCB 1, reactor containment building general area
- November 10, 2015, fire area NS-TB 5, turbine building operating floor +67
- November 19, 2015, fire area RAB 32, auxiliary component cooling water room
- December 10, 2015, fire area RAB 15, emergency diesel generator B For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.
These activities constituted four quarterly inspection samples, as defined in Inspection Procedure 71111.05.
b. Findings
No findings were identified.
1R06 Flood Protection Measures
a. Inspection Scope
On December 8, 2015, the inspectors completed an inspection of underground bunkers susceptible to flooding. The inspectors selected two underground bunkers that contained risk-significant or multiple-train cables whose failure could disable risk-significant equipment:
- Manhole M348-NA
- Manhole M351-NA The inspectors observed the material condition of the cables and splices contained in the bunkers and looked for evidence of cable degradation due to water intrusion. The inspectors verified that the cables and vaults met design requirements.
These activities constitute completion of one bunker/manhole sample, as defined in Inspection Procedure 71111.06.
b. Findings
No findings were identified.
1R07 Heat Sink Performance
a. Inspection Scope
On November 16, 2015, the inspectors completed an inspection of the readiness and availability of risk-significant heat exchangers. The inspectors verified the licensee used the industry standard periodic maintenance method outlined in EPRI NP-7552 for the essential chillers. Additionally, the inspectors walked down all three essential chillers to observe its performance and material condition.
These activities constitute completion of one heat sink performance annual review sample, as defined in Inspection Procedure 71111.07.
b. Findings
No findings were identified.
1R08 Inservice Inspection Activities
The activities described in subsections 1 through 5 below constitute completion of one inservice inspection sample, as defined in Inspection Procedure 71111.08.
.1 Non-destructive Examination (NDE) Activities and Welding Activities
a. Inspection Scope
The inspectors directly observed the following nondestructive examinations:
SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Safety Injection 14-inch pipe to elbow Ultrasonic (Weld No.21-009) Testing (UT)
Safety Injection 45 Deg. Elbow to 14-inch pipe UT (Weld No.21-007)
SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Reactor Cooling Instrument Nozzle Tube to Flange No. 93 UT (Weld No. 02-T-93X1)
The inspectors reviewed records for the following nondestructive examinations:
SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Safety Injection Elbow to 14-inch Pipe UT (Weld No.21-004)
Reactor Cooling Instrument Nozzle Tube to Flange No. 94 UT (Weld No. 02-T-94X1)
Reactor Cooling Instrument Nozzle Tube to Flange No. 95 UT (Weld No. 02-T-95X1)
During the review and observation of each examination, the inspectors observed whether activities were performed in accordance with the ASME Code requirements and applicable procedures. The inspectors also reviewed the qualifications of all nondestructive examination technicians performing the inspections to determine whether they were current.
The inspectors reviewed records for the following welding activities:
SYSTEM WELD IDENTIFICATION EXAMINATION TYPE Safety Injection Spool to SI-512B Valve UT (Weld No. FW-20)
The inspectors reviewed whether the welding procedure specifications and the welders had been properly qualified in accordance with ASME Code Section IX requirements.
The inspectors also determined whether that essential variables were identified, recorded in the procedure qualification record, and formed the bases for qualification of the welding procedure specifications.
b. Findings
No findings were identified.
.2 Vessel Upper Head Penetration Inspection Activities
a. Inspection Scope
During this refueling outage RF20, the vessel upper head penetration inspection activities were not performed. The next bare metal visual inspection will occur during refueling outage RF21. The next volumetric examination will occur during refueling outage RF24.
b. Findings
No findings were identified.
.3 Boric Acid Corrosion Control (BACC) Inspection Activities
a. Inspection Scope
The inspectors reviewed the licensees implementation of its boric acid corrosion control program for monitoring degradation of those systems that could be adversely affected by boric acid corrosion. The inspectors reviewed the documentation associated with the licensees boric acid corrosion control walk-down as specified in procedure EN-DC-319, Boric Acid Corrosion Control Program (BACCP), Revision 11, and CEP-BAC-001, Boric Acid Corrosion Control (BACC) Program Plan, Revision 1. The inspectors reviewed whether the visual inspections emphasized locations where boric acid leaks could cause degradation of safety significant components, and whether engineering evaluations used corrosion rates applicable to the affected components and properly assessed the effects of corrosion induced wastage on structural or pressure boundary integrity. The inspectors observed whether corrective actions taken were consistent with the ASME Code and 10 CFR 50, Appendix B requirements.
b. Findings
No findings were identified.
.4 Steam Generator Tube Inspection Activities
a. Inspection Scope
Steam generator inspections were not performed during refueling outage RF20.
b. Findings
No findings were identified.
.5 Identification and Resolution of Problems
a. Inspection Scope
The inspectors reviewed 11 condition reports which dealt with inservice inspection activities and found the corrective actions were appropriate. From this review the inspectors concluded that the licensee had an appropriate threshold for entering issues into the corrective action program and had procedures that direct a root cause evaluation when necessary. The inspectors also determined the licensee had an effective program for applying industry operating experience. Specific documents reviewed during this inspection are listed in the attachment.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
.1 Review of Licensed Operator Requalification
a. Inspection Scope
On November 25, 2015, the inspectors observed simulator training for an operating crew. The inspectors assessed the performance of the operators and the evaluators critique of their performance.
These activities constitute completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
.2 Review of Licensed Operator Performance
a. Inspection Scope
On October 4, 2015, the inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened activity due to responding to a plant trip. The inspectors observed the operators performance of the following activities:
- Evaluation of technical specifications
- Work prioritization
- Alarm response In addition, the inspectors assessed the operators adherence to plant procedures, including conduct of operations and other operations department policies.
These activities constitute completion of one quarterly licensed operator performance sample, as defined in Inspection Procedure 71111.11.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed two instances of degraded performance or condition of safety-related structures, systems, and components (SSCs):
- November 16, 2015, startup channel #1
- December 17, 2015, core element assembly calculators The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensees characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.
These activities constituted completion of two maintenance effectiveness samples, as defined in Inspection Procedure 71111.12.
b. Findings
Introduction.
The inspectors reviewed a self-revealing, Green, non-cited violation of Technical Specification 6.8.1.a associated with the licensees failure to properly pre-plan and perform maintenance in accordance with EN-DC-153, Preventative Maintenance Component Classification.
Description.
The Core Element Assembly Calculators (CEACs) gather information regarding individual core element assembly (CEA) deviations in the core and provide penalty factors to the core protection calculators (CPCs), which calculate the core safety limits related to the departure from nucleate boiling ratio trip and the local power density trip.
At approximately 2200 on Saturday, October 3, 2015, the licensee noted indications of degradation of a circuit card associated with CEAC 2. At 2208, the control room received a CEA-withdrawal-prohibit annunciator and a CEA-channel-C-deviation annunciator. Operators noted on CEAC 2 that the indications were that CEA 50 and CEA 51 were oscillating up and down several inches. Using other parameters, the operators determined that neither CEA 50 nor CEA 51 was moving, and that the CEAC 2 indications were erroneous. The licensee decided to remove CEAC 2 from service, and began doing so. However, at 2307, the oscillations associated with CEAC 2 became large enough to generate a penalty factor transmitted to the CPCs which prompted the CPC to generate trip signals based on local-power density and departure-from-nucleate-boiling ratio, and those trip signals caused the reactor to trip.
During troubleshooting of CEAC 2, the licensee found that a circuit card in slot 5 of CEAC 2 had failed. The failed circuit card was associated with CEAs 50 and 51, and resulted in the CEAC transmitting data to the CPCs indicating large CEA deviations and an associated large penalty factor. As noted above, that penalty factor resulted in the reactor trip.
In their review of the event, the licensee found that as part of a maintenance-optimization program in 2008, they had changed the classification of the CEACs from High Critical to Low Critical. Consequently, the licensee discontinued the preventive-maintenance programs that had previously affected the CEACs, and had begun replacing them only as required.
The inspectors review of the associated circumstances found no documented basis for changing the classification of the CEACs from High Critical to Low Critical components.
Instead, the inspectors noted that because certain failures of CEACs can result in reactor trips, classifying the CEACs as Low Critical was not consistent with certain guidance in licensee procedure EN-DC-153, Preventative Maintenance Component Classification. Specifically, EN-DC-153 requires the licensee to classify as High Critical those components whose failures can cause reactor trips. Furthermore, for High Critical components, EN-DC-153 step 5.2[6](c)(4) requires the licensee to develop and implement appropriate preventative maintenance activities at appropriate frequencies for the components.
Analysis.
The failure to pre-plan and perform preventative maintenance on CEAC components as required by EN-DC-153 step 5.2[6](c)(4) was a performance deficiency which was reasonably within the licensees ability to foresee and correct. The performance deficiency is more than minor, and therefore is a finding, because it is associated with the Equipment Performance attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, inappropriate preventative maintenance on the circuit cards associated with the CEACs ultimately contributed to a plant trip on October 3, 2015.
The inspectors initially screened the finding in accordance with NRC Inspection Manual Chapter (IMC) 0609, Significance Determination Process, issued April 29, 2015. Using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012, the inspectors determined that the finding was of very low significance (Green) because the finding did not cause a trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. Specifically, following the plant trip, all mitigation equipment relied upon to transition the plant to a stable shutdown condition responded as designed.
Because the performance deficiency occurred in 2008, the inspectors concluded that the finding does not reflect current licensee performance and therefore did not assign a cross-cutting aspect.
Enforcement.
Technical Specification 6.8.1.a, requires, in part, that procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2. Section 9.a of Appendix A to Regulatory Guide 1.33, Revision 2, requires, in part, that maintenance that can affect the performance of safety-related equipment be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. The licensee established procedure EN-DC-153, Preventative Maintenance Component Classification, Revisions 2-12, to satisfy the Regulatory Guide 1.33 requirement. Step 5.2[6](c)(4) of EN-DC-153 requires the licensee to develop and implement appropriate preventive maintenance strategies for High Critical components.
Contrary to the above, from 2008 to October 3, 2015, the licensee failed to develop and implement appropriate preventive maintenance strategies for High Critical components.
Specifically, the licensee did not pre-plan and perform maintenance that could affect the performance of the safety-related circuit cards associated with the CEACs, and the failure of one of those cards consequently caused a reactor trip. The licensee entered this condition into their corrective action program as condition report CR-WF3-2015-06438. The licensee restored compliance by properly classifying the components as High Critical in accordance with EN-DC-153, Revision 12, and by initiating development of appropriate preventative-maintenance for the CEACs. In addition, the licensee initiated work to improve the reliability of the CEACs, including reviewing card refurbishments to ensure circuit card reliability is enhanced.
Because this violation was of very low safety significance and the licensee entered the issue into their corrective action program, this violation is treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy: NCV 05000382/2015004-01, Failure to Properly Pre-Plan and Perform Maintenance on the Core Element Assembly Calculators.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed two risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:
- October 16, 2015, risk assessment associated with repairs performed on startup transformer
- November 2, 2015, risk assessment associated with lowered inventory operations The inspectors verified that these risk assessment were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments.
The inspectors also observed portions of two emergent work activities that had the potential to affect the functional capability of mitigating systems:
- October 5, 2015, emergent work associated with charging pump B
- November 14, 2015, emergent work associated with safety train B under voltage relays The inspectors verified that the licensee appropriately developed and followed a work plan for these activities. The inspectors verified that the licensee took precautions to minimize the impact of the work activities on unaffected SSCs.
These activities constitute completion of four maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13.
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed one operability determination that the licensee performed for degraded or nonconforming SSCs:
- November 6, 2015, motor control center 315B The inspectors also reviewed operator actions taken or planned to compensate for degraded or nonconforming conditions. The inspectors verified that the licensee effectively managed these operator workarounds to prevent adverse effects on the function of mitigating systems and to minimize their impact on the operators ability to implement abnormal and emergency operating procedures.
These activities constitute completion of two operability and functionality review samples, which included one operator work-around sample, as defined in Inspection Procedure 71111.15.
b. Findings
No findings were identified.
1R18 Plant Modifications
a. Inspection Scope
On November 13, 2015, the inspectors reviewed a permanent plant modification of emergency diesel generator B electronic governor replacement that affected risk-significant SSCs.
The inspectors reviewed the design and implementation of the modification. The inspectors verified that work activities involved in implementing the modification did not adversely impact operator actions that may be required in response to an emergency or other unplanned event. The inspectors verified that post-modification testing was adequate to establish the operability of the SSC as modified.
These activities constitute completion of one samples of permanent modifications, as defined in Inspection Procedure 71111.18.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed six post-maintenance testing activities that affected risk-significant SSCs:
- October 8, 2015, startup channel #1
- October 21, 2015, reactor drain tank outlet inside containment isolation valve BM-109
- November 4, 2015, emergency feedwater header B to steam generator 2 backup flow control valve EFW-223B
- November 11, 2015, startup transformer B
- November 14, 2015, emergency diesel generator B
- November 23, 2015, startup transformer A The inspectors reviewed licensing- and design-basis documents for the SSCs and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs.
These activities constitute completion of six post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.
b. Findings
No findings were identified.
1R20 Refueling and Other Outage Activities
.1 Refueling Outage 20
a. Inspection Scope
During the stations refueling outage that concluded on December 15, 2015, the inspectors evaluated the licensees outage activities. The inspectors verified that the licensee considered risk in developing and implementing the outage plan, appropriately managed personnel fatigue, and developed mitigation strategies for losses of key safety functions. This verification included the following:
- Review of the licensees outage plan prior to the outage
- Review and verification of the licensees fatigue management activities
- Monitoring of shut-down and cool-down activities
- Verification that the licensee maintained defense-in-depth during outage activities
- Observation and review of reduced-inventory and mid-loop activities
- Observation and review of fuel handling activities
- Walkdown of containment prior to startup
- Monitoring of heat-up and startup activities These activities constitute completion of one refueling outage sample as defined in Inspection Procedure 71111.20.
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed three risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the SSCs were capable of performing their safety functions:
In-service tests:
- October 15, 2015, charging pump A Containment isolation valve surveillance tests:
- November 6, 2015, containment atmosphere radiation monitor suction header inside containment isolation valve ARM-109
- November 23, 2015, reactor coolant loop 2 shutdown cooling suction inside containment isolation valve SI-405A The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing.
These activities constitute completion of three surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.
b. Findings
No findings were identified.
2.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
.1 Emergency Preparedness Drill Observation
a. Inspection Scope
The inspectors observed an emergency preparedness drill on December 16, 2015, to verify the adequacy and capability of the licensees assessment of drill performance.
The inspectors reviewed the drill scenario, observed the drill from the emergency operations facility, and attended the post-drill critique. The inspectors verified that the licensees emergency classifications, off-site notifications, and protective action recommendations were appropriate and timely. The inspectors verified that any emergency preparedness weaknesses were appropriately identified by the licensee in the post-drill critique and entered into the corrective action program for resolution.
These activities constitute completion of one emergency preparedness drill observation sample, as defined in Inspection Procedure 71114.06.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstones: Public Radiation Safety and Occupational Radiation Safety
2RS1 Radiological Hazard Assessment and Exposure Controls
a. Inspection Scope
The inspectors assessed the licensees performance in assessing the radiological hazards in the workplace associated with licensed activities. The inspectors assessed the licensees implementation of appropriate radiation monitoring and exposure control measures for both individual and collective exposures. The inspectors walked down various portions of the plant and performed independent radiation dose rate measurements. The inspectors interviewed the radiation protection manager, radiation protection supervisors, and radiation workers. The inspectors reviewed licensee performance in the following areas:
- The hazard assessment program, including a review of the licensees evaluations of changes in plant operations and radiological surveys to detect dose rates, airborne radioactivity, and surface contamination levels
- Instructions and notices to workers, including labeling or marking containers of radioactive material, radiation work permits, actions for electronic dosimeter alarms, and changes to radiological conditions
- Programs and processes for control of sealed sources and release of potentially contaminated material from the radiologically controlled area, including survey performance, instrument sensitivity, release criteria, procedural guidance, and sealed source accountability
- Radiological hazards control and work coverage, including the adequacy of surveys, radiation protection job coverage and contamination controls, the use of electronic dosimeters in high noise areas, dosimetry placement, airborne radioactivity monitoring, controls for highly activated or contaminated materials (non-fuel) stored within spent fuel and other storage pools, posting and physical controls for high radiation areas and very high radiation areas
- Radiation worker and radiation protection technician performance with respect to radiation protection work requirements
- Audits, self-assessments, and corrective action documents related to radiological hazard assessment and exposure controls since the last inspection These activities constitute completion of one sample of radiological hazard assessment and exposure controls as defined in Inspection Procedure 71124.01.
b. Findings
No findings were identified.
2RS2 Occupational ALARA Planning and Controls
a. Inspection Scope
The inspectors assessed licensee performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA). During the inspection, the inspectors interviewed licensee personnel and reviewed licensee performance in the following areas:
- Site-specific ALARA procedures and collective exposure history, including the current 3-year rolling average, site-specific trends in collective exposures, and source-term measurements
- ALARA work activity evaluations/postjob reviews, exposure estimates, and exposure mitigation requirements
- The methodology for estimating work activity exposures, the intended dose outcome, the accuracy of dose rate and man-hour estimates, and intended versus actual work activity doses and the reasons for any inconsistencies
- Records detailing the historical trends and current status of tracked plant source terms and contingency plans for expected changes in the source term due to changes in plant fuel performance issues or changes in plant primary chemistry
- Radiation worker and radiation protection technician performance during work activities in radiation areas, airborne radioactivity areas, or high radiation areas
- Audits, self-assessments, and corrective action documents related to ALARA planning and controls since the last inspection These activities constitute completion of one sample of occupational ALARA planning and controls as defined in Inspection Procedure 71124.02.
b. Findings
No findings were identified.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security
4OA1 Performance Indicator Verification
.1 Reactor Coolant System Specific Activity (BI01)
a. Inspection Scope
The inspectors reviewed the licensees reactor coolant system chemistry sample analyses for the period of October 2014 through September 2015 to verify the accuracy and completeness of the reported data. The inspectors observed a chemistry technician obtain and analyze a reactor coolant system sample on December 22, 2015. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
These activities constituted verification of the reactor coolant system specific activity performance indicator Waterford Steam Electric Station, Unit 3, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.2 Reactor Coolant System Total Leakage (BI02)
a. Inspection Scope
The inspectors reviewed the licensees records of reactor coolant system or total leakage for the period of October 2014 through September 2015 to verify the accuracy and completeness of the reported data. The inspectors observed the performance of OP-903-024, Reactor Coolant System Water Inventory Balance, Revision 22 on December 21, 2015. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
These activities constituted verification of the reactor coolant system leakage performance indicator Waterford Steam Electric Station, Unit 3, as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.3 Occupational Exposure Control Effectiveness (OR01)
a. Inspection Scope
The inspectors verified that there were no unplanned exposures or losses of radiological control over locked high radiation areas and very high radiation areas during the period of April 1, 2014 to September 30, 2015. The inspectors reviewed a sample of radiologically controlled area exit transactions showing exposures greater than 100 mrem. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
These activities constituted verification of the occupational exposure control effectiveness performance indicator as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.4 Radiological Effluent Technical Specifications (RETS)/Offsite Dose Calculation Manual
(ODCM) Radiological Effluent Occurrences (PR01)
a. Inspection Scope
The inspectors reviewed corrective action program records for liquid or gaseous effluent releases that occurred between April 1, 2014 and September 30, 2015, and were reported to the NRC to verify the performance indicator data. The inspectors used definitions and guidance contained in Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data.
These activities constituted verification of the radiological effluent technical specifications (RETS)/offsite dose calculation manual (ODCM) radiological effluent occurrences performance indicator as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review
a. Inspection Scope
Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.
b. Findings
No findings were identified.
.2 Semiannual Trend Review
a. Inspection Scope
The inspectors reviewed the licensees corrective action program, performance indicators, system health reports, and other documentation to identify trends that might indicate the existence of a more significant safety issue. The inspectors verified that the licensee was taking corrective actions to address identified adverse trends.
These activities constitute completion of one semiannual trend review sample, as defined in Inspection Procedure 71152.
b. Observations and Assessments On November 28, 2015, during preparations for plant startup, the licensee started the auxiliary feedwater pump. On November 30, 2015, personnel in the area reported smoke coming from the outboard mechanical seal of the pump and noted sparking from the seal area. The pump was secured and the licensee undertook troubleshooting activities and made repairs to the pump. The pump was returned to service on December 8, 2015.
On December 3, 2015, during preparations for plant startup, the licensee started condensate pump A. Approximately one minute after the pump started, operators in the area noted sparks coming from the stationary gland plate and rotating gland seal ring.
The pump was secured and the licensee undertook troubleshooting. Repairs were made and the pump was returned to service on December 19, 2015.
On December 7, 2015, during preparations for plant startup, the licensee started condensate pump B. Within seconds of the pump starting, the pump tripped. Operators in the area noted smoke coming from the pump motor. The licensee subsequently undertook troubleshooting. Repairs were made and the pump was returned to service on December 15, 2015.
The inspectors questioned the licensee regarding potential common trends and causes regarding the failures of the three pumps. The licensee found that the motor-to-pump alignment was not performed on the condensate pumps following maintenance performed during the outage. However, the licensee indicated that no common or adverse trends had been noted regarding the condensate pump failures and the auxiliary feedwater pump failure.
In their review of the events, the inspectors found that on December 4, 2015, CR-WF3-2015-09094 documented foreign material left in the internals of condensate pump A and B subsequent to maintenance performed during refueling outage 20.
Further, the inspectors found that on December 5, 2015, following the auxiliary feedwater pump failure, foreign material was found in the pump and documented in CR-WF3-2015-09385.
The inspectors presented the information to the licensee and asked if any evaluation was done or planned for the apparent adverse trend of foreign material intrusion into the pumps or associated workmanship issues. The licensee initiated condition report CR-WF3-2015-9528 to evaluate the potential adverse trend related to foreign materials and workmanship. As a result of their review of CR WF3-2015-9528, the licensee later concluded that an adverse trend exists.
c. Findings
No findings were identified.
4OA3 Follow-up of Events and Notices of Enforcement Discretion
(Closed) Licensee Event Report (LER) 05000382/2015-008-00, Automatic Reactor Trip Due to Failed Circuit Card in Control Element Assembly Calculator 2 At approximately 2200 on Saturday, October 3, 2015, the licensee noted indications of degradation of a circuit card associated with CEAC 2. At 2208, the control room received a CEA-withdrawal-prohibit annunciator and a CEA-channel-C-deviation annunciator. Operators noted on CEAC 2, the indications were that CEA 50 and CEA 51 were oscillating up and down several inches. Using other parameters, the operators determined that neither CEA 50 nor CEA 51 was moving, and that the CEAC 2 indications were erroneous. At 2307, the oscillations associated with CEAC 2 became large enough to generate a penalty factor transmitted to the CPCs which prompted the CPC to generate trip signals based on local-power density and departure-from-nucleate-boiling ratio, and those trip signals caused the reactor to trip. In their review of the event, the inspectors documented finding NCV 05000382/2015004-01 in section
1R12 of this report. This licensee event report is closed.
These activities constitute completion of one event follow-up sample, as defined in Inspection Procedure 71153.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On October 29, 2015, the inspectors presented the radiation safety inspection results to Mr. M. Chisum, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
On November 13, 2015, the inspectors presented the inspection results to Mr. M. Chisum, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
On January 14, 2016, the inspectors presented the inspection results to Mr. M. Chisum, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- M. Chisum, Site Vice President, Operations
- M. Richey, General Manager, Plant Operations
- J. Clavelle, Manager, Systems and Components
- R. Gilmore, Acting Director, Regulatory & Performance Improvement
- M. Haydel, Manager, Design & Program Engineering
- B. Hienlen, NDE Level III
- J. Jarrell, Manager, Regulatory Assurance
- B. Lanka, Director, Engineering
- N. Lawless Manager, Chemistry
- B. Lindsey, Senior Manager, Operations
- S. Meiklejohn, Senior Licensing Specialist
- L. Milster, Licensing Engineer, Regulatory Assurance
- N. Petit, Supervisor, Design Engineering
- J. Sarrell, Regulatory Affair Manager
- J. Signorelli, Simulator Supervisor
- R. Simpson, Superintendent, Operator Training
- J. Swan, Inservice Inspection Program Owner
- M. Zamber, Sr. Licensing Specialist
NRC Personnel
- F. Ramirez, Senior Resident Inspector
- C. Speer, Acting Senior Resident Inspector
- T. Sullivan, Acting Resident Inspector
- J. Choate, Acting Resident Inspector
- N. Greene, PhD, Health Physicist
- M. Phalen, Senior Health Physicist
- I. Anchondo, Reactor Inspector
- J. Sowa, Senior Resident Inspector
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
Failure to Properly Pre-Plan and Perform Maintenance on
- 05000382-2015004-01 NCV the Core Element Assembly Calculators (Section 1R12)
Attachment 1
Closed
Automatic Reactor Trip Due to Failed circuit Card in Control
- 05000382/2015004-008-00 LER Element Assembly Calculator 2 (Section 4OA3)