05000382/LER-2018-001, For Waterford Unit 3 Regarding Failure to Enter Limiting Condition of Operation Action Statement Due to Lack of Procedure Guidance Results in a Condition Prohibited by Technical Specifications
| ML18051B502 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 02/20/2018 |
| From: | Jarrell J Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LER 2018-001-00 | |
| Download: ML18051B502 (7) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 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) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 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)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i) |
| 3822018001R00 - NRC Website | |
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10 CFR 50.73 W3F1-2018-0012 February 20, 2018 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Subject: Licensee Event Report (LER) 2018-001-00 Failure to Enter Limiting Condition of Operation Action Statement due to Lack of Procedure Guidance Results in a Condition Prohibited by Technical Specifications Waterford Steam Electric Station, Unit 3 (Waterford 3)
License No. NPF-38 Docket No. 50-382
Dear Sir or Madam:
The attached report is being sent pursuant to 10 CFR 50.73.
There are no regulatory commitments contained in this correspondence.
Should you have questions regarding this report, please contact John P. Jarrell, Regulatory Assurance Manager, at (504) 739-6685.
Sincerely, John Jarrell Regulatory Assurance Manager JPJ/MMZ
Attachment:
LER 2018-001-00 Entergy Operations, Inc.
17265 River Road Killona, LA 70057-3093 Tel 504 739 6685 Fax 504 739 6698 jjarrel@entergy.com John P. Jarrell III Manager, Regulatory Assurance Waterford 3
W3F1-2018-0012 Page 2 cc:
Mr. Kriss Kennedy, Regional Administrator U.S. NRC, Region IV RidsRgn4MailCenter@nrc.gov U.S. NRC Project Manager for Waterford 3 April.Pulvirenti@nrc.gov U.S. NRC Senior Resident Inspector for Waterford 3 Frances.Ramirez@nrc.gov Chris.Speer@nrc.gov
Attachment to W3F1-2018-0012 Licensee Event Report 2018-001-00 (4 pages)
NRC FORM 366 (04-2017)
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION (04-2017)
LICENSEE EVENT REPORT (LER)
(See Page 2 for required number of digits/characters for each block)
(See NUREG-1022, R.3 for instruction and guidance for completing this form http://www.nrc/gov/reading-rm/doc-collections/nuregs/staff/sr1022/r3/)
APPROVED BY OMB: NO. 3150-0104 EXPIRES: 03/31/2020 the NRC may not conduct or sponsor, and a person is not required to respond to, the information collection.
- 1. FACILITY NAME Waterford Steam Electric Station, Unit 3
- 2. DOCKET NUMBER 05000382
- 3. PAGE 1 OF 4
- 4. TITLE Failure to Enter Limiting Condition of Operation Action Statement due to Lack of Procedure Guidance Results in a Condition Prohibited by Technical Specifications
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FACILITIES INVOLVED MONTH DAY YEAR YEAR SEQUENTIAL NUMBER REV NO.
MONTH DAY YEAR FACILITY NAME DOCKET NUMBER 12 20 2017 2018 -
001
- - 00 2
20 2018 FACILITY NAME DOCKET NUMBER
- 9. OPERATING MODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply) 1 20.2201(b) 20.2203(a)(3)(i) 50.73(a)(2)(ii)(A) 50.73(a)(2)(viii)(A) 20.2201(d) 20.2203(a)(3)(ii) 50.73(a)(2)(ii)(B) 50.73(a)(2)(viii)(B) 20.2203(a)(1) 20.2203(a)(4) 50.73(a)(2)(iii) 50.73(a)(2)(ix)(A) 20.2203(a)(2)(i) 50.36(c)(1)(i)(A) 50.73(a)(2)(iv)(A) 50.73(a)(2)(x)
- 10. POWER LEVEL 20.2203(a)(2)(ii) 50.36(c)(1)(ii)(A) 50.73(a)(2)(v)(A) 73.71(a)(4) 100 20.2203(a)(2)(iii) 50.36(c)(2) 50.73(a)(2)(v)(B) 73.71(a)(5) 20.2203(a)(2)(iv) 50.46(a)(3)(ii) 50.73(a)(2)(v)(C) 73.77(a)(1) 20.2203(a)(2)(v) 50.73(a)(2)(i)(A) 50.73(a)(2)(v)(D) 73.77(a)(2)(i) 20.2203(a)(2)(vi) 50.73(a)(2)(i)(B) 50.73(a)(2)(vii) 73.77(a)(2)(ii) 50.73(a)(2)(i)(C)
OTHER Specify in Abstract below or in SR 4.6.3.2 requires that each containment isolation valve shall be demonstrated OPERABLE by verifying that on a containment Radiation-High test signal, each containment purge valve actuates to its isolation position.
Because the channel A Containment Purge and Exhaust Isolation ARMs were both inoperable, this surveillance requirement could not be met, and the related containment isolation valves [CAP-103 (Containment Purge Inlet Inside Annulus), CAP-104 (Containment Purge Inlet Inside Containment), and CAR-200B (Containment Atmospheric Release Exhaust Header B Pressure Control Inlet)] [ISV] should have been declared inoperable and the actions of TS 3.6.3 should have been complied with.
CORRECTIVE ACTIONS
- 1) Add clarification to plant procedures to add guidance to comply with TS 3.6.3 actions if the Containment Purge and Exhaust Isolation ARMs operability requirement is not met. (Completed)
- 2) Perform an extent of condition review for any similar TS that need to be entered when applying SR 4.0.1 for related systems. Include additional guidance in procedures to assist with applying TS as needed.
SAFETY EVALUATION The objectives of the Area Radiation Monitoring System during postulated accidents are to provide the capability to alarm and initiate a Containment Purge Isolation Signal (CPIS) in the event of a loss-of-coolant accident (LOCA), fuel handling accident, or abnormally high radiation inside the containment. The CPIS is generated by the use of three local radiation monitors in each of the safety channels A & B. ARM-lRE-5025 and ARM-lRE-5026 (located inside the containment) and plant stack radiation monitor PRM-IRE-0100.1 [RI]
generate the channel A signal. One-out-of-three logic in each channel provides the CPIS, which acts as a permissive input for manual opening and automatic closing of the valves.
In this event, ARM-IRE-5025 and ARM-IRE-5026 were both inoperable. PRM-IRE-0100.1 remained operable and would have generated a channel A CPIS. There was no loss of safety function. Although the action to deactivate the automatic valves was not taken, all valves associated with the channel A CPIS (CAP-103, CAP-104, and CAR-200B) remained closed at all times. CAP-102 (normally closed) [ISV] remained available to automatically isolate the purge inlet line (Note: CAP-102 is not a Containment Isolation Valve and is not required by the TS; however, it receives a channel B CPIS and is tested per plant procedures.) For the containment atmospheric release exhaust header line, CAR-202B (normally closed) [ISV] remained available to automatically isolate the line. In addition, the automatic closure capability of these containment isolation valves on a Containment Isolation Actuation Signal remained available in the event of a Loss-of-Coolant Accident.
Event history for the past three years was reviewed for similar events. It was identified that there was one additional instance where TS 3.3.3.1 was entered for this condition when both containment purge radiation instruments in a single train were inoperable and TS 3.6.3 should have been complied with. The channel B instruments (ARM-IRE-5024 and -5027) [RI] were both inoperable from August 16, 2017 at 1930 to August 17, 2017 at 1340 (18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> and 10 minutes). For this event, PRM-IRE-0100.2 remained operable and would have generated a channel B CPIS. There was no loss of safety function. Although the action to deactivate the automatic valves was not taken, all valves associated with the channel A CPIS (CAP-203, CAP-204, and CAR-202B) [ISV] remained closed at all times. CAP-205 (normally closed) [ISV] remained available to automatically isolate the purge inlet line (Note: CAP-205 is not a Containment Isolation Valve and is not required by the TS; however, it receives a channel B CPIS and is tested per plant procedures.) For the
containment atmospheric release exhaust header line, CAR-200B (normally closed) remained available to automatically isolate the line.
In addition, the automatic closure capability of these containment isolation valves on a Containment Isolation Actuation Signal remained available in the event of a Loss-of-Coolant Accident.
There were no actual consequences to general safety of the public, nuclear safety, industrial safety or radiological safety for this event.
PREVIOUS OCCURRENCES
A review of Waterford 3s LERs for previous similar events for the past 5 years was performed. The LERs listed below are examples of Conditions Prohibited by TS where lack of procedure guidance were the cause were identified. Although they are similar to this event in that the reporting criterion and cause were similar, the corrective actions did not prevent this event because they were related to different TS.
LER 2016-001-00: Incorrect Core Protection Calculator Addressable Constant Entered Because of Inadequate Procedure Resulting in a Condition Prohibited by Technical Specifications LER 2013-004-00: Technical Specification Violation During Operation in Lower Mode with Reduced Channels of Excore Nuclear Instrumentation