IR 05000382/2018001

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Waterford Steam Electric Station, Unit 3 - NRC Integrated Inspection Report 05000382/2018001
ML18128A066
Person / Time
Site: Waterford Entergy icon.png
Issue date: 05/08/2018
From: Miller G B
NRC/RGN-IV/DRP/RPB-D
To: Dinelli J
Entergy Operations
Miller G B
References
IR 2018001
Download: ML18128A066 (29)
v • d • e


Text

May 8, 2018

Mr. John Dinelli Site Vice President Entergy Operations, Inc.

17265 River Road Killona, LA 70057-0751

SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NRC INTEGRATED INSPECTION REPORT 05000382/2018001

Dear Mr. Dinelli:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Waterford Steam Electric Station, Unit 3. On April 12, 2018, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented one Severity Level IV violation with no associated finding. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

From April 2017 to April 2018, the NRC issued three Severity Level IV traditional enforcement violations associated with impacting the ability of the NRC to perform its regulatory oversight function.

This includes the one Severity Level IV violation documented in this report

. However, the NRC will not conduct Inspection Procedure 92723, "Follow Up Inspection for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12

-Month Period," because one of the violations occurred in 2006 and is not representative of present performance.

If you contest the violation or significance of th is 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; and the NRC resident inspector at the Waterford Steam Electric Station, Unit 3. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading

-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding.

"

Sincerely,/RA/ Geoffrey Miller, Branch Chief Project Branch D Division of Reactor Projects Docket No. 50

-382 License No. NPF-38

Enclosure:

Inspection Report 05000382/2018001 w/ Attachment s: 1. Documents Reviewed 2. Occupational Radiation Safety Inspection Request for Information

Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 05000382 License Number: NPF-38 Report Number: 05000382/2018001 Enterprise Identifier:

I-2018-001-0002 Licensee:

Entergy Operations, Inc.

Facility:

Waterford Steam Electric Station, Unit 3 Location:

17265 River Road Killona, LA 70057 Inspection Dates: January 1, 2018, to March 31, 2018 Inspectors:

F. Ramírez, Senior Resident Inspector C. Speer, Resident Inspector J. Choate, Project Engineer J. Dixon, Senior Project Engineer N. Greene, PhD, Senior Health Physicist S. Money, Health Physicist J. O'Donnell, CHP, Health Physicist Approved By:

G. Miller, Chief 2 SUMMARY The U.S. Nuclear Regulatory Commission (

NRC) continued monitoring the licensee's performance by conducting an integrated inspection at Waterford Steam Electric Station

, Unit 3, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRC's program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. An NRC-identified violation and additional items are summarized in the table s below. List of Findings and Violations Failure to Obtain NRC Staff Authorization Prior to Changing a Procedure that Impacts Implementation of Technical Specification s Cornerstone Significance Cross-cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000382/2018001

-01 Closed Not Applicable 71152 The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.59, "Changes, Tests, and Experiments," Section (c)(1), for the licensee's failure to submit and obtain authorization prior to implementation procedures described in the Final Safety Analysis Report.

Additional Tracking Items Type Issue number Title Report Section Status LER 05000382/2017

-002-00 Automatic Reactor Scram due to the Failure of Fast Bus Transfer Relays to Automatically Transfer Station Loads to Off

-site Power on a Main Generator Trip 71153 Closed 3 PLANT STATUS Waterford Steam Electric Station Unit 3 operated at or near 100 percent rated thermal power for the entire inspection period.

INSPECTION SCOPE S Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading

-rm/doc-collections/insp

-manual/inspection

-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, "Light

-Water Reactor Inspection Program - Operations Phase." The inspectors performed plant status activities described in IMC 2515, Appendix D, "Plant Status," and conducted routine reviews using IP 71152, "Problem Identification and Resolution." The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY 71111.01 - Adverse Weather Protection Impending Severe Weather (1 Sample) The inspectors evaluated readiness for impending adverse weather conditions prior to the onset of and during extreme low temperatures for the area on January 16, 2018. 71111.04 - Equipment Alignment Partial Walkdown (3 Samples) The inspectors evaluated system configuration s during partial walkdowns of the following systems/trains

(1) Emergency feedwater train A following maintenance on January 12, 2018 (2) Component cooling water train A with train B out of service for maintenance on January 24, 2018 (3) Low pressure safety injection train A with train B out of service for maintenance on March 13, 2018 71111.05 - Fire Protection Quarterly Inspection (5 Samples) The inspectors evaluated fire protection program implementation in the following selected areas: (1) Shutdown cooling heat exchanger rooms A and B, Fire Area RAB 33, on January 4, 2018 4 (2) Switchgear room B, Fire Area RAB 8B, E, and F on February 12, 2018 (3) Control room, Fire Area RAB 1A, B, C, and D on February 12, 2018 (4) Component cooling water heat exchanger B, Fire Area RAB 17 on March 13, 2018 (5) Component cooling water pump room A, Fire Area RAB 19 on March 14, 2018 71111.07 - Heat Sink Performance Heat Sink (1 Sample) The inspectors evaluated the ultimate heat sink performance test on January 23, 2018. 71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification (1 Sample) The inspectors observed and evaluated operator performance in the simulator during an evaluated emergency plan exercise on February 21, 2018. Operator Performance (1 Sample) The inspectors observed and evaluated control room operator performance during main turbine governor valve testing on January 19, 2018. 71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness (3 Samples) The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions
(1) Component cooling water on January 25, 2018 (2) 125 Vdc distribution system on March 12, 2018 (3) Plant protection system on March 28, 2018 Quality Control (1 Sample) The inspectors evaluated maintenance and quality control activities associated with the following equipment performance issues:

(1) Fuel oil storage tank A1 vendor and licensee quality documents related to receipt of segments from vendor and associated welding on March 7, 2018 71111.13 - Maintenance Risk Assessments and Emergent Work Control (3 Samples) The inspectors evaluated the risk assessments for the following planned and emergent work activities

5 (1) Risk assessment associated with maintenance on boric acid makeup tanks A and B on January 3, 2018 (2) Risk assessment and risk management actions associated with maintenance on emergency diesel generator A on January 31, 2018 (3) Control element assembly emergency work and unexpected limiting condition for operation on February 6, 2018 71111.15 - Operability Determinations and Functionality Assessments (6 Samples) The inspectors evaluated the following operability determinations and functionality assessments:

(1) Core element assembly calculator 2 unexpected trend on January 2, 2018 (2) Atmospheric dump valve A leakage on February 8, 2018 (3) Component cooling water heat exchanger B failed performance test on February 9, 2018 (4) Reactor coolant pump 2A oil leak on March 8, 2018 (5) Core protection calculator Channel C failure on March 26, 2018 (6) Ultimate heat sink on March 28, 2018 71111.18 - Plant Modifications (1 Sample) The inspectors evaluated the following temporary or permanent modifications:

(1) Dry cooling tower train A recirculation barrier installation, Phase 3, on March 16, 2018 71111.19 - Post Maintenance Testing (7 Samples) The inspectors evaluated the following post maintenance tests: (1) Reactor trip circuit breaker 6 on January 9, 2018 (2) High pressure safety injection train B on January 23, 2018 (3) Emergency diesel generator A on February 3, 2018 (4) Auxiliary component cooling water train B on February 21, 2018 (5) Component cooling water pump B to AB suction cro ss-connect valve solenoid valve replacement on March 8, 2018 (6) Component cooling water pump B to AB discharge cross

-connect valve solenoid valve replacement on March 8, 2018 (7) Low pressure safety injection pump B on March 14, 2018 6 71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests:

Routine (3 Samples) (1) Emergency diesel generator A monthly surveillance on January 8, 2018 (2) Safety Channel A nuclear instrumentation functional test on January 24, 2018 (3) Functional test of plant protective system Channel C on February 23, 2018 71114.06 - Drill Evaluation Emergency Planning Drill (1 Sample) The inspectors evaluated a site emergency plan drill on February 21, 2018. RADIATION SAFET Y 71124.01 - Radiological Hazard Assessment and Exposure Controls Radiological Hazard Assessment (1 Sample) The inspectors evaluated radiological hazards assessments and controls

. Instructions to Workers (1 Sample) The inspectors evaluated worker instructions

. Contamination and Radioactive Material Control (1 Sample) The inspectors evaluated contamination and radioactive material controls

. Radiological Hazards Control and Work Coverage (1 Sample) The inspectors evaluated radiological hazards control and work coverage

. High Radiation Area and Very High Radiation Area Controls (1 Sample) The inspectors evaluated risk

-significant high radiation area and very high radiation area controls. Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample) The inspectors evaluated radiation worker performance and radiation protection technician proficiency

. 71124.03 - In-Plant Airborne Radioactivity Control and Mitigation Engineering Controls (1 Sample) The inspectors evaluated airborne controls and monitoring

.

7 Use of Respiratory Protection Devices (1 Sample) The inspectors evaluated respiratory protection

. Self-Contained Breathing Apparatus for Emergency Use (1 Sample) The inspectors evaluated the licensee's self-contained breathing apparatus program. OTHER ACTIVITIES

- BASELINE 71151 - Performance Indicator Verification (5 Samples) The inspectors verified licensee performance indicator submittals listed below: (1) IE01: Unplanned Scrams per 7000 Critical Hours Sample (January 1, 2017, through December 31, 2017) (2) IE03: Unplanned Power Changes per 7000 Critical Hours Sample (January 1, 2017, through December 31, 2017) (3) IE04: Unplanned Scrams with Complications (USwC) Sample (January 1, 2017, through December 31, 2017) (4) OR01: Occupational Exposure Control Effectiveness Sample (April 1, 2017, through December 31, 2017) (5) PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (April 1, 2017, through December 31, 2017) 71152 - Problem Identification and Resolution Annual Follow

-up of Selected Issues (1 Sample) The inspectors reviewed the licensee's implementation of its corrective action program related to the following issue:

(1) Implementation of change to technical specification and technical requirements compliance procedure 71153 - Follow-up of Events and Notices of Enforcement Discretion Licensee Event Reports (1 Sample) The inspectors evaluated the following licensee event reports which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx

(1) Licensee Event Report (LER) 05000382/2017-002-00, Automatic Reactor Scram due to the Failure of Fast Bus Transfer Relays to Automatically Transfer S tation Loads to Off-site Power on a Main Generator Trip

, on July 17, 2017 8 INSPECTION RESULTS Failure to Obtain NRC Staff Authorization Prior to Changing a Procedure that Impacts Implementation of Technical Specifications Cornerstone Significance Cross-cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000382/2018001

-01 Closed Not Applicable 71152 The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.59, "Changes, Tests, and Experiments," Section (c)(1), for the licensee's failure to submit and obtain authorization prior to implementation procedures described in the Final Safety Analysis Report. Description

Waterford Technical Specification 3.7.4, states, in part, that two independent trains of ultimate heat sink cooling towers shall be Operable in Modes 1, 2, 3, and 4. Each train consists of a dry cooling tower and a wet cooling tower and its associated water basin.

Action c of Technical Specification 3.7.4 states that with a tornado watch in effect, all nine dry cooling tower fans under the missile protected portion of the dry cooling tower shall be Operable. If the number of Operable fans is less than required, restore the inoperable fan(s) to Operable status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, or be in at least Hot Standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Hot Shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The licensee established Procedure OP-100-014, "Technical Specification and Technical Requirements Compliance," Revision 336, to provide guidance for determining Operability of equipment and ensuring compliance with the technical specifications and technical requirements manual. Procedure OP-100-014, Attachment 6.6, "Specific System Guidelines," provides guidelines on actions when declaring a system inoperable.

One of the systems listed and discussed is the ultimate heat sink and its associated Technical Specification 3.7.4. The Process Applicability Determination process is a method for determining which plant licensing basis documents and processes are affected by a proposed activity and must be revised to reflect that activity.

The licensee revised Procedure OP-100-014, Revision 336, using a Process Applicability Determination Evaluation [

PAD-OP-100-014, Revision 337] to provide additional guidance on implementation of Technical Specification 3.7.4. Procedure OP-100-014, Revision 337, was implemented in February 2017 with an added note stating, in part

, if the dry cooling tower fans are declared inoperable solely due to wet cooling tower fans being out of service (

cascading technical specification), then Technical Specification 3.7.4.c does not need to be applied upon a tornado watch/warning. The licensee performed a technical analysis and concluded that the missile

-protected dry cooling tower fans were to be considered Operable for the tornado event because wet cooling tower fan operation is not credited in the tornado event analysis

. The licensee used Procedure EN-LI-100, "Process Applicability Determination

," to evaluate the change in licensing basis documents.

When answering the question

, "does the proposed activity affect, invalidate, or render incorrect, OR have the potential to affect, invalidate, or render incorrect, information contained in any of the following Licensing Basis Documents?" the licensee answered "no" for impact on Operating License/Technical Specifications.

However, the inspectors determined that this addition to the site procedure could adversely impact the bases for the acceptability to ultimate heat sink design and operations.

As a result, that question should have been answered "yes" and the licensee would have had to prepare a licensing basis document change request. The inspectors concluded that i f Procedure OP-100-014, Revision 337, would have been implemented as written, it would 9 have constituted a change affecting an evaluation that demonstrates the function of the ultimate heat sink

. The inspectors confirmed that between February 2017 and January 2018, there were no tornado watches that coincided with ultimate heat sink system work windows.

Therefore, during the time this note was in the procedure, the licensee did not invoke the provision.

Corrective Action(s)

The licensee removed the note from Procedure OP-100-014, and corrected the interpretation of the technical specification

. Procedure OP-100-014, Revision 342, which removed the note, became effective January 2018. Therefore, if the wet cooling tower fans are inoperable, and there is a simultaneous tornado watch/warning, the licensee will implement Technical Specification 3.7.4, Action c. Corrective Action Reference(s):

CR-WF3-2018-02111 Performance Assessment

Performance Deficiency
The licensee's failure to submit a licensing basis document change request when performing a change impacting technical specifications in accordance with Procedure EN-LI-100, "Process Applicability Determination," was a performance deficiency. Specifically, Procedure EN-LI-100 states that if proposed activities affect, invalidate, or render incorrect information contained in Licensing Basis Documents such as the Operating License/Technical Specifications, then the proper regulatory reviews are performed. The procedure instructs the licensee to prepare a licensing basis document change request in accordance with the licensing basis document change process.

Screening

The inspectors determined the performance deficiency was of minor significance because the licensee did not implement this procedure change and as a result, did not incur a violation of technical specifications

. However, because 10 CFR 50.59 violations could potentially impede or impact the regulatory process, the inspectors processed this performance deficiency using the traditional enforcement process and the examples in Section 6.1 of the Enforcement Policy

. Enforcement

Severity:

The ROP's significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRC's ability to regulate using traditional enforcement to adequately deter noncompliance. This violation was more than minor because there was a reasonable likelihood the change would require NRC review and approval prior to implementation, similar to violations assessed in Section 2.1.3 of the NRC Enforcement Manual.

The inspectors determined the violation to be a Severity Level IV violation similar to violation Example 6.1.d.2 in the NRC Enforcement Policy.

Violation: As stated

, in part, in 10 CFR 50.59, "Changes, Tests, and Experiments," Section (c)(1), a licensee may make changes in the facility as described in the final safety analysis report (as updated), make changes in the procedure as described in the final safety analysis report (as updated), and conduct tests or experiments not described in the final safety analysis report (as updated) without obtaining a license amendment pursuant to Sec. 50.90 only if:

(i) a change to the Technical Specifications incorporated in the license is not required.

The licensee established Procedure EN-LI-100, "Process Applicability Determination," Revision 19, to comply with this requirement. Attachment 9.1 of Procedure EN-LI-100 states, in part, to prepare a licensing basis document change request if 10 a proposed activity affects, invalidates, or renders incorrect, information contained in Technical Specifications.

Contrary to the above requirements, from February 2017, until December 2017, the licensee completed an activity that affected Technical Specifications and did not prepare a licensing basis document change request. Specifically, the licensee implemented a change to Technical Specification 3.7.4, Action c, through the implementation of Procedure OP-100-014, "Technical Specification and Technical Requirements Compliance," Revision 337, by adding a note that instructed Operations personnel to not enter Technical Specification 3.7.4.c in the event of a tornado watch/warning if the dry cooling tower fans were declared inoperable solely due to wet cooling tower fans being out of service. This action was inconsistent with the current licensing basis and would have constituted a violation of technical specifications.

Enforcement Action: Because this violation was not repetitive or willful, and was entered into the licensee's corrective action program as CR

-WF3-2018-02111, this violation is being treated as a non

-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy

. Licensee Event Report (Closed) Automatic Reactor Scram due to the Failure of Fast Bus Transfer Relays to Automatically Transfer Station Loads to Off-site Power on a Main Generator Trip 05000382/2017

-002-00 71153 Description

The NRC conducted a special inspection to better understand the facts and circumstances surrounding this event. The results and findings of that inspection are documented in NRC Inspection Report 05000382/2017011 (Agencywide Documents Access and Management System (ADAMS) Accession No.

ML17354A690). The inspectors did not identify any new deficiencies as a result of this review. This LER is closed.

11 EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report

. On January 25, 2018, the inspector s presented the radiation safety inspection results to M

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