IR 05000382/1985033

Insp Rept 50-382/85-33 on 851201-31.Violation Noted:Failure to Establish & Implement Written Procedures for Control of Measuring & Test Equipment & to Visually Inspect Cell Plates of Fire Pump Diesel Starting 12-volt Battery Banks

ML20140E352
Person / Time
Site:	Waterford
Issue date:	01/23/1986
From:	Constable G, Luehman J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20140E326	List: IR 05000382/1985033 ML20140E322 ML20140E339
References
50-382-85-33, NUDOCS 8602030229
Download: ML20140E352 (8)

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APPEflDIX B U.S. NUCLEAR REGULATORY C0f411SSI0fi

REGION IV

NRC Inspection Report: 50-382/85-33 License: 11PF-38 Docket: 50-382 Licensee: Louisiana Power & Light Company (LP&L)

142 Delaronde Street New Orleans, Louisiana 70174 Facility Name: Waterford Steam Electric Station, Unit 3 Inspection At: Taft, Louisiana Inspection Conducted: December 1-31, 1985-79

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Inspectors: ,

J. G. Luehman, Senior Resident Inspector Date '

gs Approved: _ //tJ/fif

. . CoMstalile, Chief Date Project Section C, Reactor Projects Branch Inspection Summary Inspection Conducted December 1-31, 1985 (Report 50-382/85-33)

Areas Inspected: Routine, unannounced inspection of: (1) Plant Status; (2) Monthly liaintenance; (3) Monthly Surveillance; (4) ESF System Walkdown; (5) Routine Inspection; (6) Station Emergency Plan; (7) Cold Weather Preparation and(8)LicenseConditions. The inspection involved 94 inspector-hours onsite by one NRC inspector.

Results: .Within the area!. inspected, one violation was identified (failure to establish and implement wHtten procedures for control of measuring and test equipment, paragraph 3). One unresolved item was identified (failure to visually inspect cell plates of fire pump diesel starting 12 volt battery banks, paragraph 4).

0600030229 060129 PDR ADOCK0000g

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-2-DETAILS 1. Persons Contacted Principal Licensee Employees R. S. Leddick, Senior Vice President, Nuclear Operations

• R. P. Barkhurst, Plant Manager, Nuclear T. F. Gerrets, Corporate QA Manager S. A. Alleman, Assistant Plant Manager, Plant Technical Staff J. R. McGaha, Assistant Plant Manager, Operations and Maintenance J. N. Woods, QC Manager A. S. Lockhart, Site Quality Manager R. F. Burski, Engineering and Nuclear Safety Manager K. L. Brewster, Onsite Licensing Engineer G. E. Wuller, Onsite Licensing Coordinator

• T.11. Smith, Maintenance Superintendent, Nuclear

• N. S. Carns, Assistant Plant Manager, Nuclear Operations and Maintenance

• Present at exit interview In addition to the above personnel, the NRC inspectors held discussions with various operations, engineering, technical support, maintenance, and administrative members of the licensee's staf . Plant Status The plant began the inspection period at or near 100% power. On the evening of December 4,1985, power was reduced to approximately 65% for testing of the main turbine valves as required by Technical Specification (TS) Surveillance 4.3.4.2 and the testing of control element assemblies (CEA) by TS Surveillance 4.1.3.1.2. During the valve testing a number of valves did not initially operate properl In one case the problem was a defective solenoid operated valve and in the others the problems were attributed to particulate contamination in the control oil. The problems were corrected and all valves were tested satisfactoril While performing the CEA testing, CEA 91 dropped to the fully inserted position three times and CEA 83 could not be moved from the fully withdrawn position. Subsequently, the problem with CEA 91 was found to be a faulty circuitry car The card was replaced and the CEA was, tested satisfactoril In the case of CEA 83, the problem was determined to b a faulty silicon control rectifier (SCR) which was also replaced and the CEA was then satisfactorily tested. The plant was returned to 100% power early on the morning of December 6, 198 . . .

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-3-At 6:15 p.m. (CST) on December 6, 1985, a reactor trip from 100% power occurred. The trip was due to an operator erro In preparation for instrumentation and control (I&C) testing of Control Element Assembly Calculator 1 (CEAC), the reactor operator (RO) removed the departure from nucleate boiling ration (DNBR) low and local power density - high trips from bypass on Core Protection Calculator (CPC) Channel D. (The trips were due to a previously failed RTD.) The R0 then went to CPC Channel A and, instead of entering the code for CEAC 1 inoperable, he entered the code for both CEACs inoperable. The penalty factors input for removing both CEACs from power operation generated a DNBR low trip on Channel A which, along with the tripped condition on Channel D, completed the 2 of 4 logic and a reactor trip occurre The plant was subsequently taken to cold shutdown (Mode 5) for replacement of reactor coolant pump seals. Additionally, entry into cold shutdown required (TS 3.3.1, Table 3.3-1, Action 2) the licensee to repair the failed RTD associated with CPC Channel On December 12, 1985, at 7:26 p.m., with the plant in cold shutdown and the reactor coolant system (RCS) partially drained for the seal replacements, a total loss of offsite power occurred. The loss of power was caused by a lightning strike in an offsite switchyard. Both emergency diesel generators started and loaded, supplying power to vital loads until offsite power was restored about 30 minutes late The reactor was again taken critical early on December 18, 1985, and reached full power the next day. At 2:41 p.m. on December 19 the "A" main feedwater pump tripped due to a perturbation in condenser hot well level during a condenser water box leakage isolation procedure. The reactor subsequently tripped on low steam generator level. After the reactor was again taken critical, the plant operated at or about full power for the remainder of the inspection period with the cxception of two rampdowns necessitated by oil leakage problems on the "A" main feedwater pum No violations or deviations were identifie . Monthly Maintenance Station maintenance activities affecting safety-related systems and components were observed / reviewed to ascertain that the activities were conducted in accordance with approved procedures, regulatory guides and industry codes or standards, and in conformance with T On December 11, 1985, the NRC inspector observed a portion of the work done under Condition Identification and Work Authorization (CIWA) 22913 which involved Boric Acid Concentrator B Evaporator Liquid Level Indicator (BM-ILT-63888). One of the pieces of measuring and test equipment (M&TE) being used by the technicians was identified as MIPT-027.054 and it had an indicated calibration due date of November 20, 1985. When the NRC inspector questioned the technicians about the out of

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-4-calibration equipment they acknowledged it was past due; however, they felt that, since it was only being used for troubleshooting, the use of the M&TE was acceptabl Administrative Procedure " Calibration and Control of Measuring and Test Equipment" and " Installed Instrumentation and Control (I&C) Devices," ,,

QP-12-001, Revision 2, requires, in paragraph 4, that each cognizant department / group head procedurally establish controls for M&TE. The plant maintenance department uses Administrative Procedure

" Administrative Controls of Measuring and Test Equipment," MD-1-015, Revision 0, to implement the required procedural controls. Paragraph 5.10 of MD-1-015 requires, in part, that all M&TE be delivered to the metrology lab on or before its expiration date. This failure to follow approved procedures is an apparent violation and is identified as 50-382/8533-0 .

In part, this apparent violation occurred because the licensee did not properly control (remove to metrology lab) past due M&TE. However, the failure to implement a program to address the need for calibrating M&TE that is radiologically contaminated and cannot be decontaminated for release to the metrology lab appears to be more significan No additional violations or deviations were identifie . Monthly Surveillance The NRC inspectors observed / reviewed TS required testing and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that limiting conditions for operation (LCD) were met, and that any deficiencies identified were properly reviewed and resolve The NRC inspector reviewed various surveillance procedures associated with the batteries discussed in T These procedures included: ME-03-100, Fire Pump Diesel Starting Battery (Weekly), Revision 2 ME-03-110, Fire Pump Diesel Starting Battery (Quarterly), Revision 2 HE-03-120, Fire Pump Diesel Starting Battery (18-month), Revision 2 ME-03-200, Station Battery Bank and Charger (Weekly), Revision 2 ME-03-210, Station Battery Bank and Charger (Quarterly), Revision 2 ME-03-220, Station Battery Bank and Charger (18-month) Revision 4 ME-03-230, Battery Service Test, Revision 3 ME-03-240, Battery Performance Test, Revision 3 ME-03-250, Station Battery Performance Evaluation, Revision 1

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-5-In ME-03-240, Step 8.2.3.2, the test current for Battery 3AB is expressed as being equal to 300 divided by the cell temperature correction facto Yet, on page 3 of 5 of Attachment 10.1 of the procedure, the test current is expressed as 150 divided by the cell temperature correction facto Technical Specification Surveillance 4.7.10.1.3.c.1 requires, in part, that every 18 months the cell plates of the fire pump diesel starting 12 volt battery bank be checked to verify that they show no visual indication of physical damage or abnormal deterioration. The battery banks in question contain batteries that are in opaque black cases and it is not possible to visually inspect the cell plates (except what can be seen through the small caps on the top). ME-03-120, Attachment 10.1, which is the actual inspection procedure that the electrician uses to do this surveillance, does not require cell plate inspection. Satisfactory cell plate inspection is a requirement of Step 8.1.2 of the main procedure and is only indirectly referenced by the acceptance criteria (by referencing Step 8.1.2.)

The NRC inspector discussed this inspection procedure with the licensee's engineering staff and was told that this problem had been recognized before and was not considered a problem because the batteries are to be regularly replaced, the battery bank contains an extra battery, and that some portion of the plates could be inspected through the cap. The NRC inspector emphasized that cell plate inspection is a TS requirement and that in such an inspection the bottom of the cell plates is the crucial area for inspection because that is where bridging of the cell plate would most likely occur. Revision of the fire pump diesel starting battery inspection procedure and/or TS is an unresolved item identified as 50-382/8533-0 No violations or deviations were identifie '

5. ESF System Walkdown The following selected ESF system was verified operable by performing a walkdown of the accessible and essential portions of the systems on December 16 and 18, 198 Emergency Diesel Generators (EDGs) A and B - Using Drawing LOV-1564-G-164, Sheets 1 and 2 as well as OP-9-002, Revision 5, Attachment 8.1, the EDG A and B starting air, combustion air, jacket cooling, fuel oil, and lube oil subsystems were inspecte No violations or deviations were identifie . Routine Inspection By observation during the inspection period, the NRC inspectors verified that the control room manning requirement.s were being met. In addition,

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-6-the NRC inspectors obsermd shift turnover to verify that continuity of system status was maintained. The flRC inspectors periodically questioned shift personnel relative to their awareness of the plant condition Through log review and plant tours, the NRC inspectors verified compliance with selected TS and limiting conditions for operation During the course of the inspection, observations relative to protected and vital area security were made including access controls, boundary integrity, search, escort, and badgin On a regular basis, Radiation Work Permits (RWPs) were reviewed and the specific work activity was monitored to assure the activities were being conducted per the RWPs. Selected radiation protection instruments were periodically checked and equipment operability and calibration frequency were verifie The fiRC inspectors kept informed on a daily basis of overall status of plant and of any significant safety matter related to plant operation Discussions were held with plant management and various members of the operations staff on a regular basi Selected portions of operating logs and data sheets were reviewed dail The NRC inspector conducted various plant tours and made frequent visits of the control room. Observations included: witnessing work activities in progress; verifying the status of operating and standby safety systems and equipment; confirming valve positions, instrument and recorder readings, annunciator alarms; and housekeepin A review of the plant documents pertaining to control of jumpers and temporary alterations revealed that presently two control systems exis Administrative Procedure UNT-5-004 was revised in October 1985 and Revision 2, " Temporary Alteration Control," is the presently approved control system. However, some of the alterations made under UNT-5-004, Revision 1, still exist even though the procedure has been supersede The remaining conditions identified under the Revision 1 system needs to be transferred to the approved control system or returned to norma fio violations or deviations were identifie . Station Emergency Plan Emergency Plan Implementing Instruction EP-1-001, Revision 8, " Recognition and Classification of Emergency Conditions," Tab. A, " Uncontrolled Release of Radioactivity," states, in part, that an unusual event should be declared if PRM-IRE-002 or PRil-IRE-0110 Channel 4 Channel 4 (condenser (plant stack vacuum noble gas monitor pump)

reads 5.0 x noble 104 gas monit micro ci/se Presently, the alert and high alarms for these channels are set at 7.4 x 104 micro ci/sec and 7.4 x 105 micro ci/sec. The flRC inspector questioned the plant staff as to the value of having the monitor setpoints above the point at which an unusual event had to be declare . .

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After consulting the licensee's emergency planning personnel it was determined that the EP-1-001 values had not be updated when monitor alarm setpoint changes were mad Review of UNT-7-014, "Setpoint Document Control," and Reference 2.3 of that procedure, HP-1-236, " Control of Radiation Monitoring System and Channel Items," revealed that although operations, instrumentation and controls, and health physics personnel are involved in the review and/or implementation of radiation monitor setpoint changes, emergency planning personnel are not. The appropriate procedures need to be changed to ensure the station emergency plan and associated implementing procedures contain setpoints consistent with alarm setpoints of plant radiation monitors, and a review of present EP-1-001 setpoints should be done to identify any other inconsistent value No violations or deviations were identifie . Cold Weather Preparation The NRC inspector reviewed the plant procedures for freeze protection, toured the plant looking for potential cold weather problem areas, and met with plant engineering personnel to discuss station initiatives in this area. The procedures reviewed included " Freeze Protection,"

0P-2-007, Revision 2, and " Freeze Protection Maintenance," HE-4-423, Revision 2. Following the procedure review, the NRC inspector examined selected freeze protection panels and found them in working orde Because most pieces of safety-related equipment outside of containment, including the refueling water storage pool (RWSP) and condensate storage pool (CSP), are located indoors, few areas for exposure to the elements exist. Exposed areas, such as the main steam and feed penetration areas as well as the ultimate heat sink cooling towers and diesel fuel oil storage tank, merely comunicate air with the outside and are shielded from the wind by their concrete missile protection. Consequently, temperatures would have to drop and stay extremely far below normal for this geographic location before there could be a problem in these area One other area of potential concern was the exposed emergency feedwater (EFW) piping that runs across the top of the reactor auxiliary building.

l This piping, due to previously experienced waterhammer problems, is

insulated and heat traced to maintain temperature well above 400 The plant has experienced some problems in the past with freezing in nonsafety-related systems; however, preventive measures have been and are continuing to be made by the licensee through the implementation of station modification No violations or deviations were identifie . License Conditions (Closed) 2.c.15 Qualification of Personnel - In a letter dated

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l October 30, 1985, the licensee provided information regarding plant i

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.*ee-8-operating history to the Office of Nuclear Reactor Regulation (NRR).

The licensee informed NRR that, based on operating history, the plant operating staff would meet the experience requirements specified in Attachment 2 to Operating License NPF-38, on October 31, 1985, and at that time the licensee intended to remove shift advisors from further duties. The shift advisors have been removed from control room duties and the NRC resident inspectors have verified that acceptable overall performance of licensed operators has continue . Unresolved Items An unresolved item is a matter about which more information is required to determine whether it is acceptable or may involve a violation or deviatio One unresolved item was identified during this inspection a1d is discussed in paragraph . Exit Interview The inspection scope and findings were suramarized on January 6,1986, with those persons indicated in paragraph 1 above. The licensee acknowledged the NRC inspector's findings. The licensee did not identify as proprietary any of the material provided to or reviewed by the NRC inspectors during this inspection.

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