05000382/LER-2022-006, Non-Compliance with Technical Specifications Due to Incorrect Conversion Factors in Plant Stack and Fuel Handling Building Radiation Monitors
| ML22311A471 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/07/2022 |
| From: | Milster L Entergy Operations |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| W3F1 -2022-0062 LER 2022-006-00 | |
| Download: ML22311A471 (1) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(iii) |
| 3822022006R00 - NRC Website | |
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S) entergy W3F1 -2022-0062 November 7, 2022 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Leia Milster Manager Regulatory Assurance 504-739-6250 10 CFR 50.73
Subject:
Licensee Event Report 50-382/2022-006-00, Non-Compliance with Technical Specifications Due to Incorrect Conversion Factors in Plant Stack and Fuel Handling Building Radiation Monitors Waterford Steam Electric Station, Unit 3 NRC Docket No. 50-382 Renewed Facility Operating License No. NPF-38 Entergy Operations, Inc. (Entergy) submits the enclosed Licensee Event Report (LER) 50-382/2022-006-00 for Waterford Steam Electric Station, Unit 3. The event is reportable in accordance with 1 O CFR 50.73(a)(2)(i)(B), any operation or condition *which.was pronibited by the plant's Technical Specifications.
The LER describes a non-compliance with TS 3.3.3.1 due to incorrect conversion factors applied to the Plant Stack and Fuel Handling Building radiation monitors.
This letter contains no new commitments.
Should you have any questions concerning this issue, please contact Leia Milster, Manager, Regulatory Assurance, at 504-739-6250.
Respectfully, Leia Milster LEM/mrp Entergy Operations, Inc., 17265 River Road, Killona, LA 70057
W3F 1-2022-0062 Page 2 of 2 Enclosure: Licensee Event Report 50-382/2022-006-00 cc:
NRC Region IV Regional Administrator NRC Senior Resident Inspector - Waterford Steam Electric Station, Unit 3 NRC Project Manager - Waterford Steam Electric Station, Unit 3 Louisiana Department of Environmental Quality
Enclosure W3F1-2022-0062 Licensee Event Report 50-382/2022-006-00
U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY 0 MB: NO. 3150-0104 EXPIRES: 08/31/2023
- 1. Facility Name LICENSEE EVENT REPORT (LER)
(See Page 3 for required number of digits/characters for each block)
(See NUREG-1022, R. 3 for instruction and guidance for completing this form https://www.nrc.gov/reading-rm/doo-collections/nuregs/staff/sr1022/r3/)
Waterford Steam Electric Station, Unit 3
- 4. Title
- 2. Docket Number
. Page 05000382 1 OF4 Non-Compliance with Technical Specifications Due to Incorrect Conversion Factors in Plant Stack and Fuel Handling Building Radiation Monitors
- 5. Event Date
- 6. LER Number
- 7. Report Date
- 8. Other Facilities Involved Sequential Number Rev No.
Facility Name Docket Number Month Day Year Year Month Day Year 05000 Facility Name Docket Number 09 08 2022 2022
- 006 -
00 11 07 2022 05000
- 9. Operating Mode
- 10. Power Level 100 rt is Submitted Pursuant to the R uirements of 10 CFR Check all that a D 50.36(c)(2) 0 50.73(a)(2)(iv)(A)
D 50.46(a)(3)(ii) 0 50.73(a)(2)(v)(A) 0 20.2201(d)
D 50.69(9) 0 50.73(a)(2)(v)(B)
D 73.71(a)(4)
D 20.2203(a)(1) 0 50.73(a)(2)(i)(A) 0 50.73(a)(2)(v)(C)
D 73.71(a)(5)
D 20.2203(a)(2)(i)
~ 50.73(a)(2)(i)(B)
D 50.73(a)(2)(v)(D)
D 73.77(a)(1)(i)
D 20.2203(a)(2)(ii)
D 50.73(a)(2)(i)(C) 0 50.73(a)(2)(vii)
D 73.77(a)(2)(i)
D 20.2203(a)(2)(iil) 0 50.73(a)(2)(ii)(A)
D 50.73(a)(2)(viii)(A)
D 73.77(a)(2)(ii) 0 20.2203(a)(2)(iv) 0 50.73(a)(2)(ii)(B) 0 50.73(a)(2)(viii)(B) 0 20.2203(a)(2)(v) 0 50.73(a)(2)(iii) 0 50. 73(a)(2)(i.x)(A) 0 Other (Specify here, in Abstract, or in NRC 366A).
- 12. Licensee Contact for this LER Licensee Contact Phone Number (Include Area Code)
Leia Milster - Mana 504. 739-6250 nent Failure Described in this Re rt
Cause
System Component Manufacturer Reportable To IRIS
Cause
System Component Manufacturer Reportable To IRIS D
IL MON G063 y
- 14. Supplemental Report Expected Month Day Year 1:8]
D Yes (If yes, complete 15. Expected Submission Date)
- 15. Expected Submission Date No
Abstract
On September 8, 2022, while operating in Mode 1 at 100% power, Waterford Steam Electric Station, Unit 3 (Waterford 3), identified that an incorrect engineering conversion factor (ECF) was applied to the plant stack wide range gas monitor (WRGM) high range detector. An extent of condition review subsequently identified that an incorrect ECF was also applied to the fuel handling building WRGM mid-range detector. This caused both monitors to be incorrectly calibrated and inoperable, which resulted in the monitors not meeting the minimum channels operable requirements for periods longer than allowed by Waterford 3 Technical Specification (TS) 3.3.3.1 and TS Table 3.3-6, ction 27. The required actions were taken in accordance with TS 3.3.3.1, TS Table 3.3-6, and the site established the pre-planned alternate method of monitoring as required.
he CR Database Manual was updated with the correct ECF and the monitors recalibrated and returned to service on September 9, 2022 and September 10, 2022.
he root cause identified the configuration control process (UNT-007-029, Control of the Radiation Monitoring System Database) has not been maintained for the Radiation Monitoring System (RMS) to verify complete, accurate, and up-to-date for the RMS databases and ffected documentation prior to returning equipment to service. This event is reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) - any o eration or condition which was rohibited b the lant's TSs.
4NRC FORM 366A (08-2020)
Page 1 of 4 PLANT ST A TUS 05000-382 YEAR 2022 SEQUENTIAL NUMBER
- - 006 On September 8, 2022, Waterford Steam Electric, Unit 3 (Waterford 3) was operating at 100% power in Mode 1. There were no other structures, systems, or components that were inoperable at the time that contributed to the event.
EVENT DESCRIPTION
REV NO.
- - 00 In January 2022, the Radiation Monitor System (RMS) engineer identified during a document revision review, that the calibration steps were incorrect for source decay calibration in the main condenser [COND] wide range gas monitor [MON] (WRGM) mid and high range detectors [IL, DET] due to a procedure revision in 1985. The extent of condition identified that the plant stack [CHIM] (PS) WRGM high range detector (HRD) and the fuel handling building [ND] (FHB) WRGM mid-range detector (MRD) were not calibrated with the use of a multi-channel analyzer [CHMA] and contained incorrect engineering conversion factor(s) (ECF(s)) and affected the operability of both monitors.
On February 2 and 3, 2022, Waterford 3 personnel calibrated the PS HRD and FHB WRGM MRD using a multi channel analyzer as per the corrective action with the correct ECF. The RMS Control Room (CR) Database Manual was not updated to reflect the corrected ECF change.
Subsequent!y, separate maintenance activities were performed on May 25, 2022 and June 6, 2022 that required the FHB WRGM MRD and PS WRGM HRD microprocessor databases to be reloaded. Both monitors were reloaded with incorrect ECF values from the RMS CR Database Manual.
On September 8, 2022, during an engineering change review, it was identified that the incorrect ECF was applied to the PS WRGM HRD during the maintenance work performed on June 6, 2022 and PS WRGM HRD was declared inoperable at 2013 CDT.
Waterford 3 TS 3.3.3.1 and TS Table 3.3-6 of TS 3.3.3.1 requires that this monitor be operable in Modes 1 through 4. Action 27 of TS Table 3.3-6 requires that, with the number of operable channels less than required by the minimum channels operable requirement, either restore the inoperable channel(s) to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or initiate the preplanned alternate method of monitoring the appropriate parameter(s), and if
~he monitor is not restored to operable status within 7 days after the failure, prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within 14 days. The required actions were taken in accordance with TS 3.3.3.1, TS Table 3.3-6, and the site established the pre-planned alternate method of monitoring as required. The PS WRGM HRD ECF was updated in the RMS CR Database Manual and the monitor was recalibrated. Operability was restored on September 9, 2022. A special report was not required due to the condition being corrected.
4NRC FORM 366A (08-2020)
Page 2 of 4 (08-2020)
U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY 0MB: NO. 3150-0104 EXPIRES: 08/31/2023
- 3. LERNUMBER YEAR Waterford Steam Electric, Unit 3 05000-382 2022 SEQUENTIAL NUMBER
- - 006 REV NO.
- - 00 An extent of condition was performed and RMS engineer discovered that the FHB WRGM MRD was updated with the incorrect ECF during the maintenance performed on May 25, 2022. At 1838 CDT on September 9,
~ 2022, Operations personnel declared the FHB WRGM MRD inoperable. The required actions were taken in accordance with TS 3.3.3.1, TS Table 3.3-6, and the site established the pre-planned alternate method of monitoring as required. FHB WRGM MRD ECF was updated in the RMS CR Database Manual and the monitor was recalibrated. Operability was restored on September 10, 2022.
This event is being reported under 10 CFR 50.73(a)(2)(i)(B), any operation or condition which was prohibited by the plant's Technical Specifications.
SAFETY ASSESSMENT
ifhe inoperability of the PS and FHB WRGMs that contained incorrect ECFs resulted in the potential for incorrect dose calculations used in determining public protection action recommendations. The acceptable calibration tolerance for WRGMs is +/- 10%. With the incorrect ECF installed, the PS WRGM HRD reading would be 30.5% lower than actual cqnditions and the FHB WRGM MRD detector would be 10.5% lower than actual condition. There were no actual consequences to general safety of the public, nuclear safety, industrial safety and radiological safety for this event. These radiation monitors are not described in Chapter 6 or Chapter 15 of the Waterford 3 UFSAR for accident mitigation.
ifhe potential consequence to general safety of the public, nuclear safety, industrial safety and radiological safety if the correct WRGM dose calculation results were not used in a radiological event are inadequate public protection actions, inability to determine a significant risk of general safety to the public, and inaccurate or latent issuance of Protective Action Recommendation (PAR). The safety significance of this event is determined to be low. The basis for this determination is that multiple, alternative monitoring methods exist to monitor the site release points enabling Waterford 3 to accurately classify a radiological event and assess dose.
The PS WRGM HRD usage by Operations and Emergency Response Organization (ERO) personnel for event classification and dose assessment would not be impacted by the HRD. All applicable declarations would be made timely and accurately before the affected HRD is placed in service. Therefore, the HRD calibration issue has no impact on Emergency Action Level (EAL) Classification. The PS WRGM General Emergency classification would be made on the MRD of the WRGM and the associated initial PAR would be timely and
- echnically adequate. If due to the nature of the accident, available activity continues to rise driving the PS WRGM indication above the Accepted Range Point (ARP) for the HRD, the HRD would then be placed in service. Any dose projections beyond this point would be subject to the as-found 30.5% low inaccuracy.
The FHB WRGM MRD would not impact the event classification and dose assessment used by Operations and ERO personnel. All applicable classifications would be made timely and accurately after the affected MRD is removed from service. Therefore, the MRD calibration issue has no impact on EAL Classification. The General Emergency classification would be made on the HRD of the WRGM and the associated PAR would be timely and technically adequate. Any dose projections applicable to the associated event would be technically adequate and not impacted by the as-found 10.5% calibration inaccuracy.
4NRC FORM 366A (08-2020)
Page 3 of 4 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY 0MB: NO. 3150-0104 EXPIRES: 08/31/2023
- 3. LERNUMBER Waterford Steam Electric, Unit 3 05000-382 EVENT CAUSES YEAR 2022 SEQUENTIAL NUMBER
- - 006 REV NO.
- - 00
!The direct cause of the event is the failure to update the RMS CR Database Manual for the PS HRD and FHB MRD WRGM detectors after changing the ECF during a calibration in February 2022.
!The root cause identified the configuration control process (UNT-007-029, Control of the Radiation Monitoring System Database) has not been maintained for the RMS to verify complete, accurate, and up-to-date for the RMS databases and affected documentation prior to returning equipment to service that is imporant to
~mergency response.
CORRECTIVE ACTIONS
The PS and FHB WRGM databases were updated and operability was restored and the RMS CR Database Manual was updated with the correct ECFs for the PS and FHB WRGMs. (WO-585706 and WO-585710 on September 9, 2022, and September 10, 2022.)
Lessons Learned were shared with RMS qualified individuals and l&C and Fix It Now (FIN) supervision.
Maintenance l&C issued an "RMS Expectations" memo reinforcing use of the UNT-007- 029.
As an interim action, UNT-007-029 Rev. 5, Control of the Radiation Monitoring System Database, was issued to include a step for a separate person to confirm the RMS Database Manual has been updated and this verification has been added to the database change request form. A requirement has been added to use a Work Tracker (WT) assignment to track review/approval from the RMS Engineer and Chemistry for changes made to the CR RMS Database Manual to ensure completion within 7 days.
A corrective action to preclude repetition was created to establish improved RMS Database change controls for the RMS databases.
PREVIOUS SIMILAR EVENTS
LER 2022-001-00 reported a non-compliance with TS 3.3.3.1, Action b, and TS Table 3.3-6, Action 27, due to incorrect conversion factors used in three gaseous radiation monitors. LER 2022-003-00 reported a non-compliance with TS 3.3.3.1, Action b, and TS Table 3.3-6, Action 27, due to the calibration procedure for the containment high range radiation monitors containing incorrect procedural guidance to account for the keep alive source decay when the original Log Pico-ammeter and ADC circuit board was replaced. LER 2022-004-00, "Operation Prohibited by Technical Specifications Due to Inadequate Radiation Monitor Calibration Procedures," was a direct result of the extent of condition reviews and activities conducted as part of the corrective actions for LER 2022-001-00 and LER 2022-003-00.
4NRC FORM 366A (08-2020)