IR 05000382/1987031

Insp Rept 50-382/87-31 on 871216-880131.Violations Noted. Major Areas Inspected:Onsite Followup of Events,Monthly Maint & Surveillance Observation,Operational Safety Verification & Followup of Previously Identified Items

ML20147D599
Person / Time
Site:	Waterford
Issue date:	02/22/1988
From:	Harrell P, Will Smith, Staker T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20147D572	List: IR 05000382/1987031 ML20147D571 ML20147D589
References
50-382-87-31, NUDOCS 8803040060
Download: ML20147D599 (11)

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U. S. NUCLEAR REGULATORY COPHISSION x , ,

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f NRC. Inspection Report: 50-382/87-31 Licens$i NPF-38 s -

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- Docket:' 50-382 *

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,L icensee: Louisiana Power & Light Company.(LP&L) .);

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~;. :142 Delaronde Street - - ,

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New Orleans, Louisiana ~ 70174

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Facility Name: Waterford Steam Electric Station Unit 3 ,

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Inspection At: .Taft Louisiana - - '

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Inspection Conducted: December 16, 1987, through January 31, 1988' ,

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' Inspectors: - -

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/!II/II I W. F. Smith, Senior Residep Inspector Date

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T. R. /StakepeVdent Inspector .

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1' I Approved:- d, k }Wd P. H."HefreWMeting Chief, Reactor Project Date Sec':fon A

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Inspection Summary Inspection Conducted December 16, 1987, through January 31, 1988 (Report 50-382/87-31)

Areas Inspected: Routine, unannounced inspection cor.siating of: (1) onsite followup of events, (2) monthly maintenance observation, (3) operationci safety verification, (4) monthly surveillance observation, (5) followup of prev 1cusi, identified items, (6) licensee event report followup, (7) plant status, ano (8) 10 CFR report Results: Within the areas inspected, one violation involving two examples of a failure to adhere to procedures was identified (paragraph 3).

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DETAILS ~

1. ' Persons Contacted -

Principal Licensee Employees

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J. G. Dewease, Senior Vice President, Nuclear Operations

• R. P .Barkhurst,.Vice President, Nuclear Operations

• N. S. Carr;, Plant Manager, Nuclear

'P. V. Prasankumar, Assistant Plant Manager, Technical Suppor D. P. Packer, Assistant Plant Manager, Operations and Maintenance

, J. J. Zabritski. Manager of-Operations QA L. W. Myers, Manager of Nuclear Operations Support and Assessments J. R. McGaha, Manager of-Nuclear Operations Engineering W. T.-Labonte, Radiation Protection Superintendent D. E. Baker, Manager of Events Analysis Reporting & Response

• G. E. Wuller, Onsite Licensing Coordinator D. W. Vinci, Maintenance Superintendent R. F. Burski, Acting Manager of Nuclear Safety and Regulatory Affairs R. S. Starkey, Operations Superintendent

• Present at exit intervie .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 . Onsite Followup of Events Enforcement Discretion On December 31, 1987, NRC Region IV granted the licensee enforcement l discretion allowing a 48-hour deferral from Technical Specification l

Surveillance Requirement 4.7.6.c. This surveillance requirement

! states, in part, that individual control room air conditioning systems be demonstrated operable following painting in any ventilation zone communicating with the system. On December 31, l 1987, at approximately 9:30 a.m. while operating in Mode 3, LP&L personnel discovered that painting was being performed in the control room envelope while the B emergency filtration unit was operatin The unit was in operation in order to perform the monthly operability L surveillance required by Technical Specification 4.7.6.c. Because of l' the holiday, the licensee could not mobilize the contract personnel required to perform Surveillance 4.7.6.c without delaying entry into Mode 2. The licensee analyzed the situati e and concluded that the painting would not affect the operability of the emergency filtration syste NRC Region IV judged the effect on the HEPA and HECA filters to be minimal because of the method of paint application (brush) and

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the small time duration (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) and, therefore, concurred with the f

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licensee. The. plant entered Mode 2 at 8:47.a.m. on January 1, 198 ' Satisfactory surveillance testing of the HEPA and HECA'f11ters was completed at 1 a.m. on January 1, 198 The cause of this event was determined to be that painting in the control room envelope was not considered to be a controlled maintenance activity at that time. h is now considered a controlled maintenance activity. The licensee is currently preparing procedure changes to make painting in the control room envelope and other areas of the plant serviced by engineered safety features filtrations units controlled maintenance. The surveillance procedures for.these systems are also being changed to ensure that the filtration systems are not.run while painting is being conducted. The implementation of the above procedural changes is an Open Item (382/8731-01). Failed Fasteners on Emergency Diesel Generator Turbocharger Support Brackets On December 15, 1987, an NRC inspection team was conducting a vendor interface and procurement practices review. While inspecting the emergency diesel generators (EDGs) as a followup to Cooper-Bessemer Service Bulletin Number 691, dated September 30, 1985, the team discovered problems with the turbocharger support bracket bolts on both EDG These problems could have been avoided had the licensee taken the action advised in the service bulletin. Of the eight bolts on EDG "A," three bolt heads were found broken off. On EDG "B," the bracket had one bolt head (out of eight) broken off and two other bolts loose. The resident inspectors and NRC Region IV management questioned the operability of the EDG The' licensee contacted the EDP vendor, Cooper-Bessemer, and obtained an analysis from the vendor dated December 18, 1987. The analysis report stated that as long as 1 there are at least fcur bolts (not necessarily prestressed)

contacting the support brackets and holding the supports against the engine blocks, the engines remain operable. The report also addressed bolt stress during a seismic event with only four bolts installed. The resultant stress was reported to be 57,000 pounds per square inch which is well below the maximum allowable value of 85,000 pounds per square inch. The licensee immediately implemented the vendor's recommended actions to prevent the support bracket fasteners from coming loose or failing. This consisted of replacing the bolts with long studs, spacers, and nuts thus facilitating adequate flexibility and prestress. The NRC resident inspectors verified that six of eight fasteners on each EDG were corrected in this manner. Because of structural interferences, the licensee installed shorter studs on each EDG with smaller spacers for the last two fastener The licensee stated that Service Bulletin Number 691 did not receive a plant technical staff review because of a breakdown in the program designed to take action when such information is r w ,ve . .,- .- - . --.- - - - - , . - - - -. -

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On January 11, 1988, the .rcensee briefed the NRC. resident' inspectors on a review program implemented to determine, on a priority basis, what impact other vendor information may have that had been received and classified as not requiring a plant staff.' technical review. This program will review 769 items consisting of manuais, letters, bulletins, sales flyers, etc. To date,.the licensee determined that

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no additional hardware changes, with the' exception ~of the EDG bolts described above, will be required. . Also, about seven electrical maintenance procedures will require minor changes, and five preventative maintenance task changes will be made. .The licensee committed to keep the NRC resident inspectors appraised of progress made and results achieved concerning this matter. The final outcome of this review shail be t, racked under Open Item 382/8731-0 Reactor Coolant Pump Lube Oil Strainers On December 30, 1987, and again on January 26, 1988, the plant was shut down (Mode 3) in order to replace the reactor coolant pump 28 motor lube oil strai w . In both instances, a fine fibrous material was found to be clogg 1 the 200 mesh strainers. The !icensee determined that this m m rial was not detrimental to the operation of the pump motor because of the size and type of material. Through discussions with the pump motor vendor, the licensee determined that the strainer was not required to be installed during normal pump operation. The purpose of the strainer is to clean the lube oil system during the first twenty-four hours of pump operation after maintenance. The strainer can then be removed. Based on this, plus the appearance and size of the material found in the strainer, the licensee decided to replace the strainer with a coarser, 64 mesh

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type. The licensee is also pursuing an analysis of an oil sample removed from the coolant pump as well as performing a closer inspection of the material trapped in the strainer in order to

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identify the materia No violations or deviations were identifie . Monthly Maintenance Observation The station maintenance activities listed below were observed and associated documentation was reviewed to ascertain that the activities were conducted in accordance with approved procedures, Technical Specifications, ar.d appropriate indtstry codes or standard Work Authorization 0100900 The NRC resident inspector observed the

"A/B" essential services chilled water pump alignment check and coupling reassembly. lhe alignment check was performed using the double rotation technique of Procedure MM-06-004, Revision 3, "Shift Coupling Alignment and Belt Tensioning." After the coupling was reassembled, the NRC inspector observed that the pump technical manual, Number 457000302, "Instruction Manual For Centrifugal Pump Size 4013 Class CRE," specified that the half spacer flange bolts and

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cover fasteners were required to be toroued to specific values during reassembly. -The NRC inspector observed that the work authorization was deficient because it did not i.nclude a step to perform torqueing or reference Procedure M-06-011, "General Torqueing and Detensioning." When questioned, the maintenance technicians performing the task indicated that.they were not sure if torqueing of these bolts was required because no instructions were contained in the work authorization. After consulting with their supervisor, the technicians informed the inspector that a change to add torqueing instructions to the work authorization was required. Due to scheduling, the NRC resident inspector's work observation ended at this point. During review of the completed work package, the NRC-inspector observed the following:

. Torqueing of the half spacer flange bolts and cover fasteners was performed per Attachment 10.1 of Procedure M-6-011, Revision Step 8.1.4 of M-6-011, requires- Attachment 10.1 to be reviewed by quality control prior to torqueing on safety-related equipmen Procedure M-6-011 was not adhered to because Attachment 10.1 was not reviewed by quality control before torqueing the flange or cover fastener bolts on the "A/B" essential services chilled water pump. This failure to adhere to procedure requirements is a apparent violation of the requirements of Criterion V of Appendix B to 10 CFR Part 5 (382/8731-03)

. Steps 2 through 4 of the work authorization contained instructions to change out the pump and motor oil reservoir These steps were not applicable.to the chilled water pum Instead, the pump bearirrls were lubricated, as required, although there were no steps in the work authorization pertaininc, lo thi The NRC resident inspector observed that the repetitive task authorization to perform the above preventive maintenance on chilled water pumps was promptly revised to correct the identified deficiencie b. Work Authorization 0100666 The NRC resident inspector observed the alignment and final alignment check of component cooling water dry tower fan motor 48. The fan motor was being reinstalled after being sent offsite for Dino-weight removal (NRC Inspection Report 50-382/87-24). The NRC inspector verified that the final alignment readings met the applicable acceptance criteria. The motor alignment was performed by shim changeout. The alignment check was performed using the double rotation method. Work was completed per Procedure M-6-004, Revision 3, "Shaf t Coupling Alignment and Belt Tensioning."

c. The NRC resident inspector observed the termination and insulation of the component cooling water fan motor power supply termin e s. Work

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was performed per Procedure ME-4-809, Revision 4, "Low Voltage (600 Volts and Less) Power and Control Cable / Conduction Termination and Splices." The procedure specified that the splices were to be constructed with Okonite 35 covering tape, Okonite T95 insulating tape, and Okonite nuclear splice cement per Detail 1 on Sheet 39 of Drawing LOV-1564-B-288. During installation, a discrepancy between the drawing and procedural steps was identified. The drawing shows an unidentified layer of material between the insulating tape and lugs. Installation of this unidentified material was not included in

.the procedure. The splices were made according to the steps in the procedur Procedure ME-4-809, Revision 4, was not adhered to because Step 4 required the splices to be installed per Drawing LOV-1564-B-288 and stated that the drawing takes precedence over the procedure if discrepancies are encountered. This second example of a failure to adhere to procedural requirements also constitutes an apparent violation of the requirements of Criterion V of Appendix B to 10 CFR Part 5 (382/8731-03)

Detail 1 on Sheet 39 of Drawing LOV-1564-B-288 was observed to be deficien The unidentified material was later identified as semiconductor tape. During a previous field change request, the semiconductor tape should have been removed from the drawin Instead, the labeling on the drawing for the tape was removed, and the unlabeled tape was still depicted in the drawing. Since this drawing had been previously referenced to perform splices on safety systems (including several recent dry cooling tower fan motor changeouts), this drawing deficiency should have been previously identified and corrected by the licensee.

( No other violations or deviations were identifie . Operational Safety Verification

The objectives of this inspection are: to ensure that this facility is being operated safely and in conformance with regulatory requirements, to

ensure that the licensee's management controls are effectively discharging the licensee's responsibilities for continued safe operation, to ensure

that selected activities of the licensee's radiological protection i programs are implemented in conformance with plant policies and procedures i

and in compliance with regulatory requirements, and to inspect the

licensee's compliance with the approved physical security plan.

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When onsite, the NRC resident inspectors visited the control room dail Control room staffing, access, operator behavior, and shift turnovers were observed. Tr.e NRC resident inspectors reviewed operators' logs and control panels te verify compliance with Technical Specification limiting condition for operation. The NRC i.1spector observed the unit shutdown on January 26, 1988, and noted that it was performed in a professional and orderly manor. No problems were identified.

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8 Routine tours of accessible areas of the plant'were performed in order to observe nousekeeping and general equipment condition. The inspectors noted that housekeeping. controls were well maintained. The NRC resident inspectors also observed.that personnel used the proper dosimetry and anti-contamination devices during access and performed required frisking during egress from radiological controlled area The inspectors observed the operation of the central alarm station and implementation of proper controls at the protected area access. During tours, the inspectors also verified that security barriers appeared to be well maintaine '

No violations or deviations were identifie . Monthly Surveillance Observation The NRC resident inspectors observed the surveillance testing listed below of safety-related systems and components to verify that the activities were being performed in accordance with the Technical Specifications. The applicable procedures were reviewed for adequacy, test instrumentation was verified to be in calibration, and test data was reviewed for accuracy and comp'e .nes . The NRC resident inspectors ascertained that any e deficia -ies identified were rroperly reviewed and resolve Procedure MI-3-472, Revizion 3, "Gaseous Waste Management System No:.le Gas Discharge Monitor Channel Functional Test PRM-IR0648." On Deumber 30, 1987, the NRC irspector witnessed the above functional test and noted that the technician performed the test in an orderly, step-by-step manner. Each step in the procedure was initialed and dated as it was completed as required by Step 4.4. The technician appeared to be well trained and familiar with the equipment and the procedure. During the alarm / trip test of Section 8.2 of the procedure, the technician placed the TEST / CALIBRATE switch to the

"TEST HI" position as directed by Step 8.2.4. This prematurely placed the monitor in a high radiation alarm condition before the alarm trip point could be obtained using the variable potentiomete It was immediately apparent that the TEST / CALIBRATE switch should have been left in the "TEST LOW" position in order for the procedure to work. The technician informed the control room supervisor, restored the monitor to an operable condition, and implemented a change to the procedure in accordance with plant administrative requirement The test was later resumed and completed satisfactorily without further difficult The inspector discussed with licensee management the fact that this procedure would not work and raised the question as to how the test might have been performed in the past. It was apparent that the technicians managed to previously accomplish the test by deviating from the verbatim requirements rather than stopping and changing the i procedure. A notice of violation was issued to the licensee as an appendix to NRC Inspection Report 50-382/87-22 which depicted several

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1 instances where procedures were not being followed. Past performances of this surveillance appear to be another exampl Corrective actions taken to prevent further procedure noncompliances appear to be effective because the technicians stopped the test.on December 30, 1987, and implementedsa change to correct the procedur One example of the ineffectiveness.of the licensee's corrective action on a failure to follow procedures ~is identified as a violation in NRC Inspection Report 50-382/87-22_(see above. paragraph). The two examples of failure to adhere to procedures mentioned above indicate that further attention needs to be directed:to this~ area, Procedure MI-3-121, Revision 2, "CEAC functional Test CEAC Channel 2." The NRC resident inspector observed functional testing on control element assembly calculator Channel 2 on January 12, 198 The testing was performed to satisfy, in part, the requirements of Technical Specification Section 4.3.1.1, Table 4.3-1, Item 15. -The NRC inspector identified the following procedure comments as examples I

of inattention to detail:

. Reference 2.3, "Control Element Assembly Position Isolation Amplifier, Technical Manual 457000146," is incorrect. The correct technical manual number is 45700016 . Section 6.0, "Material and Test Equipment," includes a Fluke 8600 digital multimeter and a MACS chassis card extende These items were not used or required to perform the procedur . The note above Step 8.2.4 states that the CRT diagnostic outputs the tFree patterns in Attachments 10.1 and 1 Attachments 10.1 and 10.2 contain only two patterns. During performance of the CRT diagnostic, three patterns were displaye No violations or deviations were identifie . Followup of Previously Identified Items (Closed) Open Item 382/8722-03: Correction of spent fuel pool cooling and purification system operating procedure deficiencies. The NRC resident inspector verified that the issuance of Change Number 2 to Procedure OP-2-006, Revision 8, "Operating Procedure Fuel Pool Cooling and Purification System," has corrected the identified deficiencie This item is close . Licensee Event Report (LER) Followup The following LERs were reviewed and close The NRC inspectors verified that reporting requirements had been met, causes had been identified, corrective acti.as appeared appropriate, generic applicability had been considered, and that the LER forms were complete. The NRC inspectors

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i confirmed that unreviewed safety questions.and violations of Technical Specifications, license conditions, or other regulatory requirements had

'been~ adequately describe (Closed) LER 382/87-024, "Diesel Fuel 0il Storage Tank Volume."

(Closed) LER 382/87-027, "Inoperable Fire Barrier Due to Inadequate Design Change Controls During Plant Construction."

No violations or deviations were identified.

Plant Status The plant was operating at full power at the start of the inspection period and continued at full power until December 29, 1987. At that time, power was reduced to 86 percent after the core operating limit supervisory system failed and remained out of servic The power reduction was initiated in order to operate within the more. restrictive limits.in effect

'when operating with core protection calculators only. Later that day, the l core operating limit supervisory system was restored, and the reactor was returned to full powe On December 30, 1987, the unit was shut down (Mode 3) because of a high upper thrust bearing temperature on reactor coolant pump 28. The cause of the high tempersture was determined to be a clogged strainer in the pump lube oil system. After reinstallation of the reactor coolant pump lube oil strainer and completion of the forced outage items, a plant startup was commenced on January 1, 1988. While maintaining power at 13 percent l and because of axial shape index, an auxiliary ~ reactor trip on axial shape l index occurred while cycling the turbine governor valves with the turbine

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latche 'Again, on January 26, 1988, the unit was shut down because of an increasing upper thrust bearing temperature on reactor coolant pump 2 A

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manual reactor trip was initiated from 87 percent power when the l licensee's administrative temperature limit of 210 degrees was reached.

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Prior to the trip, the unit was being rapidly shut down because of the l- thrust bearing temperatur The licensee again replaced the reactor coolant pump lube oil strainer but used a coarser mesh type (see paragraph 2). The plant was returned to critical on January 27, 1988; and after a brief delay because of core '

axial shape index, reached full power on January 29, 1988. The plant then operated at full power through the end of the report perio No violations or deviations were identifie . 10 CFR 21 Reports On December 22, 1987, the NRC inspectors forwarded the below listed 10 CFR 21 reports as required by Region IV Policy Guide Number 406 This

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policy guide ensures that the licensee has-received the: notifications-pursuant to 10 CFR 21 and tracks.the following by Region IV' inspection personnel. The licensee verbally acknowledged receipt'and has entered 0 them into'-their evaluation syste .

. Region IV Log No. P21-87-74 Date: NovemberL13, 1987 Subject: Part 21 report.regarding defective Limitorque SM800 DC motor operators (Limitorque).

. Region IV Log No. P21-87-80 Date: October 23, 1987 Subject: Containment hydrogen analyzer systems design deficiency may cause a loss of calibration gas'(Exo-Sensor, Inc.).

. Region IV Log No. P21-87-81 Date: October 19, 1987 Subject: Quality assurance controls, three nonconformances to ETI procedures regarding NDE documentation'(Eastern Testing and Inspection, Inc.).

. Region IV Log No. P21-87-82 Date: October 16, 1987 Subject: This' issue was also addressed in NRC Information

' Notice 87-61 dated December 7, 198 . Region IV Log No. P21-87-83 Date: September 29, 1987 Subject: Saturable cove transformers inadequate insulation between windings (Basler Electric).

. Region IV Log No. P21-87-84-Date: October 2, 1987 Subject: Fasteners installed in motor operated valves at Palo Verde Nuclear Generating Station, Unit 3, may fai No violations or deviations were identifie . Exit Interview The inspection scope and findings were summarized on February 1,1988, with those persons indicated in paragraph 1 above. The licensee acknowledged the NRC inspectors' 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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