IR 05000382/1989015

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Insp Rept 50-382/89-15 on 890605-09 & 20-21.No Violations or Deviations Noted.Major Areas Inspected:Storage of Emergency Diesel Generator Fuel Oil,Containment Bldg Temp Profiles & Action on Previously Identified Insp Findings
ML20246D809
Person / Time
Site: Waterford Entergy icon.png
Issue date: 07/06/1989
From: Boardman J, Stetka T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20246D808 List:
References
50-382-89-15, NUDOCS 8907110432
Download: ML20246D809 (12)


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APPENDIX'-

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report:

50-382/89-15 Operating License: NPF-38 Docket: 50-382

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Licensee: Louisiana Power & Light Company (LP&L)

317 Baronne Street New Orleans, Louisiana 70160 Facility Name: Waterford Steam Electric Station, Unit 3 (W-3)

Inspection At: W3, Taft, Louisiana Inspection Conducted: June 5-9 and June 20-21, 1989

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Inspector:

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Boardman, Reactor Inspector, Plant Date 5,tems Section, Division of Reactor Safety

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[g9 ApprovAd:

T. F. Stetka, Chief, Plant Systems Section Date /

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Division of Reactor Safri,y Inspection Summary Inspection C_onducted June 5-9 and June 20-21, 1989 (Report 50-382/89-15)

Areas Inspected: Routine, announced inspection of Raychem heat shrinkable tubing (HST) for electrical splices and terminations, the storage of emergency diesel generator (EDG) fuel oil (FO), containment building temperature profiles, and action.on previously identified inspection findings.

Results: Within the areas inspected, no violations or deviations were identified. The licensee's present programs for the control of EDG F0, and for the installation of Raychem HST for electrical connections, appeared to meet regulatory requirements. Containment building temperatures appeared to be acceptable.

8907110432 890707 I

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DETAILS-

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Persons Contacted

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LP&L Personnel y

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- #R. C. Azzarello, Nuclear Operations Engineering & Construction (N0EC)l

Manager

    1. P. N. Backes, Programs Engineering Supervisor

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    1. D. E. Baker, Nuclear Operations Support.& Assessment Manager
    1. R. P. Barkhurst, Vice President Nuclear
  • L. L. Bass ~, N0EC Supervisor B. K. Broussard, Equipment Qualification Engineer V. R. Coy, Electrical Design Engineering
  1. G. M.- Davis, Event Analysis Manager
  • W.-E. Day,1 Trending, Compliance ~and Response Supervisor
  • T. J. Gaudet, Site Licensing Support Engineer

'D. D. Grubic, Site Licensing Support Engineer J. E.: Howard, N0EC Procurement / Programs. Engineering Manager G. F.-'Koehler, Operations Quality Assurance (QA) Audit-Supervisor

  1. L. W. Laughlin, Site Licensing Supervisor

'#T. R. Lednard,. Maintenance Superintendent

  1. A. G. Larsen, Plant Maintenance Engineering

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  1. J. R. McGaha, Plant Manager

'#D. F. Packer, Assistant Plant Manager Operations and Maintenance

'#P. V. Prasankumar, Assistant Plant Manager, Technical Services

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'#M. L. Raines, Lead Equipment Qualification Engineer

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E. J. Ritzmann,. 0perations. QA-
  1. J. J. Zibritski, QA Manager

,NRC Personnel'

  1. W. F._ Smith, Senior Resident Inspector
  • T. R. Staker, Resident Inspector
  • Denotes those persons that attended the exit meeting on June 9, 1989.
  1. Denotes those persons who attended the exit meeting on June 21, 1989.

In addition, the NRC inspector contacted other members of the licensee's staff.

2.

Followup on Previous Inspection Findings (92701 and 92702)

(Closed) Violation (382/8705-01): This violation dealt with exceeding a.

procedure acceptance criteria-for testing of Limitorque valve operators.

(Closed)UnresolvedItem(382/8705-02): This unresolved item dealt with the determination and evaluation of valve cycles made at thrust values above the rated value during Limitorque operation.

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(Closed) Open Item (382/8705-03): This itern dealt with the adequacy of bypass switch settings for Limitorque operators.

(Closed) Open Item (382/8705-04): This item dealtiwith the use of the M0 VATS signature for establishing limit switch settings for Limitorque valve operators.

The above listed findings related to licensee actions in response to NRC Bulletin 85-03, " Motor Operated Valve Common Mode Failures During Plant Transients Due to Improper Switch Settings," issued November 15, 1985.

NRC Inspection Report 50-382/87-05 dated May 4, 1987, was issued before the licensee's final response to this bulletin.

In a letter dated June 12, 1987, the licensee responded to violation (382/8705-01). On' December 21, 1987, the licensee issued their final response to Bulletin 85-03, This response addressed the issues identified in inspection findings 382/8705-01 -02-03, and -04.

The NRC inspector reviewed the licensee's response letters and determined that they adequately addressed each finding. This review verified the completion of the licensee's corrective actions.

These items are considered closed.

b.

(Closed) Open Item (382/8527-07): This item documented the lack of an industry-wide preventive maintenance program to replace electrolytic j

capacitors. The concern is that these capacitors could exceed their design life and fail resulting in a condition that could affect plant operation. This generic issue is being addressed by the NRC as part

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of the ongoing plant aging research.

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(Closed) Open Item (382/8810-02): This item dealt with the lack of a program to ensure the proper type of grease for replacement of double sealed and double shielded antifriction bearings. This item, which was initially identified at another facility, informed the licensee j

of this potentially generic concern. The licensee's personnel have j

subsequently developed a program to control lubrication of replacement antifriction bearings.

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Programs for Installation of Heat-Shrinkable Tubing (HST)

(25017)

On June 26, 1986, the NRC issued Information Notice (IN) 86-53, " Improper j

Installation of Heat Shrinkable Tubing." This IN identified industry l

problems with the installation of HST, manufactured by Raychem, used for insulation on electrical and instrumentation splice connections and terminations.

In response to IN 86-53, the licensee initiated a review that consisted of separate inspections by) equipment qualification (EQ) engineering personnel and quality control (QC inspection personnel of approximately 211 j

safety-related Raychem HST installations. All splices reviewed were j

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-4-ultimately resolved as acceptable. The licensee had decided to discontinue use of Raychem HST and has not made any Raychem splice installations since the performance,of these inspections. The licensee has used Raychem HST

only in electrical penetrations.

The NRC inspector revlewed a sampling of inspection records and EQ engineering deficiency resolutions for HST installation that the licensee inspected in' response to IN 86-53. The examples reviewed were HST install:tions:that were found to be initially unacceptable by inspection,

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but subsequently accepted by EQ engineering. No concerns were identified.

The NRC inspector also observed approximately 84 Raychem HST installations in 5 Reactor Auxiliary Building (RAB) penetrations. As the result of these observations, wire 12 in penetration 142, module 6 had the following problems:

On the end nearest the penetration, the wire markers appeared to have been covered by the HST. This condition could reduce the effective seal length of the HST.

There was a nick on the penetration end that appeared to penetrate

through the insulation such that the copper conductor was visible.

The NRC inspector discussed these findings with licensee personnel. As the result of these discussions, the licensee will determine the acceptability of wire 12. This is considered to be an inspector followup item.

Inspector Followup Item (382/8915-01): Review the licensee's acceptability determination of the splice and insulation nick on wire 12 in penetration 142.

The licensee has decided to revive the use of Raychem HST. As a result, the present program for installation of Raychem HST has recently been put in place. Recent program changes include revision of procedures and design drawings to enhance instructions and training for installation and inspection personnel.

4.

Storage of Emergency Diesel Generator Fuel Oil (25100)

The purpose of this inspection was to verify that the licensee had an adequate quality control program for emergency diesel generator fuel oil (EDG F0) that was maintained onsite.

The specific attributes reviewed included the following for which the responses are contained in Attachment 1:

The scope of the licensee's review of IN 87-04, " Diesel Generator

Fails Test Because of Degraded Fuel";

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The existence of a permanent F0 storage tank recirculating filtration

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The periodic cleaning of EDG F0 st'orage. tanks;'

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The use of'F0 antioxidation and bacteriostatic additives;~

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The tests performed'for the presence of water, oxidation, bacterial growth, etc.;.

The prompt removal of identified water contamination; The periodic cleaning of strainers, filters, etc.;

The monitoring of fouling and contamination;.

The sampling and testing of EDG F0;

The use of duplex filters and strainers; and The use of differential pressure indication for determination of

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filter and strainer. fouling.

Summary With the completion of corrective action for Licensee Event Report (LER) 89-008-00, " Diesel Generator Fuel Oil Not Sampled per ASTM Specified Methods Due to an Inadequate Procedure " dated May 26, 1989, the. licensee's_ program for storage of EDG F0 appeared to be in compliance with NRC regulations and licensee commitments. The only anomaly identified by the NRC' inspector related to the licensee's actions in response to IN 87-04 on EDG F0 storage.

This response, stated that the double (duplex) EDG F0 strainers alarmed.

when 1 of the 2 integral strainer units became fouled. The other unit of the. duplex strainer could be aligned and used while the fouled strainer

. unit was cleaned. These features were stated as providing assurance against EDG F0 starvation. The NRC inspector determined, however, that the' licensee's present procedures ~and practices align both duplex strainer

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' units in parallel making them functionally a single (simplex) strainer.

This condition' eliminated the licensee's purported redundancy. The NRC inspector found that the EDG F0 duplex filters were similarly aligned as a simplex filter. The operational safety aspect of this condition is being followed by the NRC resident inspectors.-

The licensee's procedures relating to the EDG F0 Jorage which were reviewed included the following:

Document No.-

Revision Title l

MM-3-019 2, Change 1 Diesel Generator Fuel Oil Storage Tank Inspection l

CE-2-030 2, Change 1 Maintaining Diesel Fuel Oil l

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OP-3-009 5, Change 2'

Fuel 011 Receipt

MM-3-015-6. Change 2 Emergency Diesel Engine Inspection.

MM-6-005

Emergency Generator Diesel Maintenance-OP-9-002'

10, Change 2 Emergency Diesel Generator y

CE-2-100'

5, Change 2 Chemistry Technical Specifications-Surve11ance Performance Coordination

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CE-1-002

Logkeeping, Filing and. Record Storage CE-3-606

Determination of API Gravity.of Diesel-Fuel CE-3-601

Determination of Kinematic Viscosity l

of Diesel Fuel i

CE-3-700 5, Change 2 General Grab Sampling Techniques-

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CE-3-602

Determination of Water and Sediment irr Oil (Centrifuge)

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No violations or deviations were identified.

5.

Licensee Event Report (LER) Followup (92700)

Through discussions with the licensee's personnel anJ the review of records, LER-89-008-00 was reviewed to determine that deportability

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requirements were fulfilled, immediate corrective action was accomplished,

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accordance with the Technical Specification (TS).-

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.This LER dealt with the fact that the licensee's sampling of the EDG F0

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tanks was not in accordance with ASTM-D270-1975 as required by TS 4.8.1.1.2.c.

To correct this condition, Procedure CE-3-700, " General Grab Sampling Techniques" was revised to require sampling as specified in ASTM-D270-1975. -

No' violations or deviations were identified.

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6.

Information on Containment Temperature (TI 2515/98)

f The purpose of this inspection was to obtain containment average ambient operating temperature profiles for W-3 to determine its effect on the l

environmental qualification of equipment, and in particular, electrical insulation. The NRC inspector reviewed documentation related to the design of the containment cooling system. Containment temperature data for the periods-of plant operation from February through December 1987, and June 1988 through January 1989 were also reviewed. The TS state that

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i he' primary containment air temperature, measured at the inlet of th'e'

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-2 containment air ~ coolers, shall not exceed 120*F. Data for the periods reviewed.showed no temperatures reaching the TS-limit. Containment temperature data for 12 additional locations has been taken by the licensee. No anomalies were identified as the' result of this inspection.

A summary of the pertinent findings.is contained in Attachment 2 to this report.

7.

Exit Meeting Exit meetings were held on June 9 and 21, 1989, with those individuals denoted in paragraph 1 of this report. At this meeting, the scope of the inspection'and the findings were summarized. The licensee did not identify as proprietary any of the information provided to, or reviewed by the NRC inspector.

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ATTACHMENT 1

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4-SURVEY OF LICENSEE'S RESULTS TO

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. SELECTED EDG F0JISSUES

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. Plant Name:.

'Waterford-3 SES

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Docket:

50-382 I'

Ins'pector:

J. R. Boardman 1.

Has the licensee adequately reviewed and evaluated IE Information

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Notice (IN) 87-04, issued on January 16, 1987, as a result of the AN0'

Unit 2 EDG F0 starvation event which occurred on June 27,'1986?

The licensee's review of this IN appeared flawed. The review summary identified:.

That duplex EDG F0 strainers were installed.

  • The strainers had alarms which activated when 1 of the 2 integral strainer units was fouled.

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The other ' strainer unit could then be aligned and used while the

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fouled unit was cleaned.-

These features provided, assurance against' EDG F0 starvation.

  • The NRC inspector determined, however, that the licensee's procedures, and practices, aligned both strainer units in parallel. These actions made

= the 2 separate strainer units functionally a single (simplex) strainer and eliminated the purported redundancy. ' The NRC inspector identified the same parallel alignment for the EDG F0 duplex filters.

2.

Does the licensee have a permanent F0 storage tank recirculation system.

which allows for complete F0 inventory cleaning by filtering each refueling. outage,to remove accumulated. particulate?

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No.-

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Are all F0 stcrage tanks'being cleaned and inspected at a minimum of

'10-year intervals in accordance with Regulatory Guide 1.137?

i Technical Specification' (TS) 4.8.1.1.2.g. and h. require the draining, cleaning and inspection of the storage tanks at least once every 10 i

years. The first 10-year interval has not been completed.

4.

.Does the licensee's F0 program include a regular analysis of F0 samples and. bottom testing for accumulated water, at the lowest point in the F0 day tanks and'F0 storage tanks?

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. Technical' Specification 4.8.1~.1'.2.b. requires that at least'once every 311

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days
-and after each operation of the' diesel where the period of operation.

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Y is greater than, or equa1Lto,1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> a check shalle be made o_f the diesel

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. oil feed tanks for water. Accumulated water shall be removed.

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The~ licensee's personnel s'tated that the day (feed)itanks are checked for

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water accumulation and drained,'but the storage tanks are not checked.

Technical Specification 4.8.1.1.2.c. requires that at least once.every 92 days and from new oil prior.to addition to the storage tanks that.a F0

' sample be obtained'in accordance with ASTM-D270-1975.E The sample shall be tested as soon as:taken (or prior to adding new ' oil to the tank) in

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accordance with ASTM-D975-77 for water, sediment, kinematic viscosity, and v

specific gravity..Within 7 days the impurity level (insolubles) shall be determined.

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These checks are being accomplished as required by the TS.

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Is'a fuel additive being used as a fuel stabilizer which will function to

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. Yes; the licensee's program'. requires that a stabilizer and a microbicide

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'be added to each. acceptable: shipment.

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DoesIthe '1icensee effectively ensure that periodic.F0 bottom sampling and

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. analysis are being performed to. detect high particulate concentrations in the F0 supply which occurs over long-term storage due to the effects'of C

oxidati~on, and biological contamination in accordance with ASTM'D270-19757 As stated in 4..above, sampling to ASTM D270-1975 is required.by'the Unit" TS. See-LER-89-008-00 concerning the licensee's use of bottom sampling.

Are day tanks and integral tanks being checked for. water monthly, 'as a

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minimum, and after each operation of the diesel where the period of operation was 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or longer?

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. Please see the response to 4. above. ' The.. licensee's personnel stated that there were no integra1Ltanks.

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Is accumulated water removed immediately if it is determined that water is present in the storage, integral, or day tanks?

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The licensee's personnel stated that the water was promptly removed from day tanks when found. There are no integral tanks, and storage tanks are not checked (they are not considered " feed" tanks).

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Is the' licensee replacing F0 in a short period of time (about a week) if it is determined that the F0 does not meet the applicable specifications?

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The licensee's personnel stated.that no EDG FO has been determined to be

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H nonconforming. TS 4.8.1.1.2.c.3. requires initiation of corrective action within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to return the fuel supply to within acceptable

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' limits.

10. ;Are F0 components, which may be prone to fouling. being routinely monitored for. indications of fouling?

F0 strainer and filter differential pressures (DPs) are recorded in the licensee's running logs. High F0 strainer / filter DPs are input signals for the " Master Diesel Generator Trouble Alarm"'in the control room.-

11. Are F0 filters and strainers being cleaned and inspected on a periodic basis per the vendor recommendations?

Per licensee pe'rsonnel, filter and strainers are cleaned and inspected every refueling outage. Periodicity and cleaning / inspection procedures meet vendor recommendations.

12. Does the F0 system utilize dual element filters and strainers which permits on line cleaning of the elements, in the event of fouling, to allow continuous operation'of the EDG7 Yes, however..see 1. for alignment that defeated this feature.

13.. Is there a differential pressure indicator for each duplex filter strainer for indication' of fouling in accordance with ANSI N195-1976?

There is differential pressure indication as discussed in question 10 above.

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14. Are F0 alarms annunciated in the main control room or incorporated into a general control room trouble alarm with local individual alarms, in accordance with ANSI N195 1976?

High F0 strainer / filter DPs are input signals for the " Master Diesel Generator Trouble ~ Alarm" in the contrn1 room.

In addition, the alarms are individually alarmed locally.

15. Are any of the instruments that perform a control function and provide an alarm seismically qualified in accordance with the IEEE Recommended Practices for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations, IEEE 344-1975?

The licensee's personnel stated that the instruments are seismically qualified.

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' ATTACHMENT 2 1.-

Plant Name:

Waterford-3 SES 2.

Docket:'

50-382 3.

What are the average containment temperatures during power operation as recorded by the licensee?

The.following data are based on the Reactor Containment Building (RCB)

temperature readings made during the' summers of 1987 and 1988 at the inlet of the containment cooling units to determine compliance with the unit Technical Specifications (TS):

1987 Location April May June July August September RCB-4

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A51119-109.05 109.57 :110.24' 110.69-110.11 105.14 i

A51127-107.31 107.53 107.91 108.37 108.55 104.07

.RC'B+21

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112.68 115.90 116.73 117.10 109.15

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A51115 111.88 A51123 109.67 109.78 113.98 114.78 115.40 108.38 AVERAGE 109.48, 109.89 112.01 112.64 112.79 106.68 1988 Location June July August September October RCB-4 A51119 109.13 110.23 111.55 111.25 110.93 A51127 107.60 108.79 110.38 110.24 109.94 RCB+21 A51115 114.53 115.94 117.05 116.39 115.47 A51123

.114.32 115.41 116.86 116.29 115.34

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AVERAGE 111.40 112.59 113.96 113.54 112.92 4.

Containment temperature at which the plant is licensed to operate (i.e.,

l operating temperature specified in the FSAR).

I The containment temperature at which the plant is licensed to operate is 120 F.

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' Review the temperature' readings and provide your assessment as to whether or not you believe the average temperature readings accurately reflect containment conditions, or if there is a significant difference, due to sensor location or stratification of containment atmosphere which could produce hot spots.

The temperature readings are as prescribed by TS. Based on study DC 3073, dated April 10, 1989, performed by the licensee's Nuclear Operations Engineering (N0E) design engineering group, the measured air temperatures in the reactor head area appear excessive (152.2-152.4'F) because of the design of the air distribution system.

In addition, air discharge from the head area is at a reactor building elevation above +100, where the temperature is not monitored. The design of the containment cooling system is shown on the licensee's drawings. Documentation indicated that the NRC was aware of this condition.

The licensea's NOE design engineering group personnel stated that certain detailed design data on containment cooling, such as cooling air flow paths (as opposed the location of duct work runs), had not been identified.

The study also identified that temperatures in the Regenerative Heat Exchanger Room are 128 degrees as opposed to the design temperature of 120 degrees. The third problem area identified in the study is at RCB elevation +46 where the temperatures are borderline (approximately 120.8 degrees). The study states that there is no environmentally qualified equipment in this third problem area.

6.

What temperature (s) is used by the licensee in its equipment environmental qualification program when calculating the remaining qualified lifetime for all equipment inside containment, and are these temperatures consistent with temperatures being experienced?

j The temperature used is 120'F, except in the 2 areas where the licensee has identified higher temperatures.

7.

Administrative temperature limit for the containment, if no technical specification limit exists?

Not applicable. There is a TS limit.

8.

Recent history of temperatures inside containment. Provide containment average air temperature in addition to the containment air temperatures

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used to compute the average air temperatures for the months of April, May, l

June, July, August, and September 1987.

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See the response to question 3. above.

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