IR 05000382/1989022

Insp Rept 50-382/89-22 on 890701-31.Violation Noted.Major Areas Inspected:Onsite Followup of Events,Monthly Maint Observation,Monthly Surveillance Observation,Operational Safety Verification & LER Followup

ML20245L361
Person / Time
Site:	Waterford
Issue date:	08/09/1989
From:	Chamberlain D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20245L335	List: IR 05000382/1989022 ML20245L331 ML20245L350
References
50-382-89-22, NUDOCS 8908220092
Download: ML20245L361 (11)

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U.'S, NUCLEAR REGULATORY COMMISSION

{ REGION-IV g s

.:..m ?NRC" Inspection Report: 50-382/89-22 Operating License: HPF-38

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Docket: 50-382/

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

'317 Baronne Street-New Orleans, Louisiana 70160

. Facility Name: .Waterford Steam Electric: Station, Unit 3 (Waterford-3)

Inspection At: Taft, Louisiana t-

Inspection Conducted: . July 1-31,1989

. Inspectors: W. F. Smith, Senior Resident Inspector, Project J -

Section A, Division of. Reactor Projects T. R. Staker, Resident Inspector, Project Section A, Division of Reactor Projects

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Approved: CV .

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D. D. Chamberlain, Chief, Project Section A

Inspection Summary Inspection Conducted July 1-31, 1989:(Report 50-382/89-22)

Areas Inspected: Routine, unannounced inspection'of plant status, onsite followup of events, monthly maintenance observation, monthly surveillance observation, operational. safety verification, fellowup of previously identified-items, licensee event report followup,"and balance of plant inspectio Resul'ts: One violation was identified in paragraph 4.e involving inadequate corrective action. In September 1988, the licensee identified missing seismic supports in the core protection calculator (CPC) cabinets. Corrective action included inspections to verify that seismic supports and fasteners were installed in all control room cabinets. This action was apparently flawed, because in July 1989 more missing seismic supports were identifie .

The inspectors reviewed licensee action in response to a plant event where the operators manually tripped the plant in response to equipment problems causing a loss of. steam generator water level control. Operator action was prompt and appropriate in response to the problem and no problems were found with licensee

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The balance of' plant- (BOP) inspection did not reveal-any weaknesse r Appropriate programs. appeared to be'in place, and based on the plant's-

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excellent availability record, the appearance of the plant, and the absence of leaks, the programs appeared to be successful to the extent observed by the NRC F staff

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DETAILS' ,

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1 ; Persons' Contacted '

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s N'  : Principal Li~ ensee' c Employees - , ,

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R./P. Barkhurst, Vice President, Nuclear Operations-

• J..R.'McGaha, Plant Manager, Nuclear

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, P. V. Prasankumar, Assistant Plant Manager, Technical Support  ;

'3 *D. F. Packer,' Assistant Plant Manager, Operations.and Maintenance  ;

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y- J. JP Zabritski, QualityJAssurance Manager .

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0. E. Baker, Manager of_ Nuclear Operations Support and Assessments: 1

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-R. GL Azzarello",' Manager of Nuclear.0perations-Engineering i N *W. T. Labonte,' Radiation Protection. Superintendent

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_j G. M. Davis, Manager of Events Analysis Reporting & Responses-

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. *L. W. Laughlin, Onsite Licensing Coordinator. '

.T. R. Leonard, Maintenance Superintendent

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A. F. Surski,) Manager of Nuclear Safety and Regulatory Affairs '

R. S. Starkey, Operations. Superintendent A. S.:Lockhart,. Management Systems Manager ,

• Present at exit interview.

LIn addition

to.the above personnel, the inspectors. held discussions with q h '

various operations, engineering, technical support, maintenance, and

. administrative' members of the licensee's staf .j

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' 2.- Plant Status'l(71707)-  !

4 m :The plant was' operating at: full power at the startE of the inspection' 1

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, . period. _ On1 July 112; 1989, power was reduced to 63 percent in' order to replace a defective component in the Steam Generator' Feed Pump A speed control circuit.- After returning the pump'to service, the plant was returned to-full power on July 13, 1989. . On~ July 15, 1989, the plant was

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manually tripped when the' No.1 Main Feedwater Control Valve failed shut.

l- After repairs to the valve,.the plant was returned to full power on' )

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July 18, 1989. This is discussed in paragraph 3.a below. The 11 ant  :

!- remained at full power through the end of the inspection peric ! :0nsite Followup of Events (93702)  !

' Reactor Manually Tripped on Loss of Steam Generator Water Level j Control i

, l On July 15, 1989,'at 7:19 a.m., while the reactor was at full power, !

the feedwater regulating valve for No. 1 steam generator went shut !

due to failure of a control circuit card in the master controlle !

The operators immediately took manual control of the feedwater regulating, valve at 47 percent water level (and decreasing rapidly), ! ,

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but the system could not respond quickly enough to restore level. At the 31 percent water level, the reactor was manually tripped, as directed by;the shift supervisor. The automatic reactor trip-

'setpoint was 27.4 percent. From the time the feedwater regulatin valve was shut until the reactor was. tripped, only 18 secoads

~ transpired. Emergency feedwater was automatically actuated, and all

,; other systems' responded normally. Operator action was prompt'and appropriatetin response to the problem. The master controller was

_ subsequently repaired, i;n addition to some unrelated: shutdown repairs. By 4:37 p.m. on: July 17, 1989, the plant was back on the grid, and by 8 a.m. on July 18, 1989, the plant was back at full power. Licensee wil1' issue a Licensee Event Report (LER) for this event and the report will be due on August 14, 1989. 'The inspectors reviewed the incident with the licensee and found no problems with licensee action ' Testing of Emeroency Feedwater (EFW) System Cross Connect Valves 3~ ~-

On July 19, 1989, the licensee informed the inspectors of a. discovery that the emergency cro!.s connect valve between the Auxiliary Component Cooling Water (ACCW) pump discharge headers and the EF pump suction were not included in the Inservice Test (IST) Progra . Based on certain ~ assumptions .made in the Waterford-3 FSAR, the safety function of the valves (ACC-114 A & B and-116 A & B) was to provide an emergency ' source of EFW supply:during,the design basis tornado and-

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post-LOCA, long-term cooling because there would be an insufficient volume available in the Condensate Storage Pool (CSP). Based on these assumptions, the 170,000 gallons of water in the CSP required-by Technical Specifict, tion (TS) 3.7.1.3 would be depleted before placing the plant into forced cooldown. Thus, the 180,000 gallon volume in either of the ACCW cooling tower basins would be needed to achieve that end. Thi! failure to test these crossover valves appeared to place the EFW system in an inoperable conditio The licensee conducted a prompt evaluation to determine the i operability of ACC-114 A & B and -116 A & B and examined the adverse chemistry implications that could apply to ter> ting the valve Stroking them could contaminate the high purity CSP makeup water with impure ACCW cooling tower basin water. The inspectors reviewed the licensee evaluation an July 21, 1989. The evaluation concluded that the valves were operable on the bases that: (1) the valves showed no outward signs of deyadation, (2) there would be several hours available during the postulated accident scenarios to permit removal

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of valve internals if they should fail and water was needed, '

l (3) administrative t;ontrols were placed in effect such that cooldown would be expedited nore quickly than conservatively assumed in the i

FSAR such that ACCv basin water would not be needed, and (4) the CSP i water inventory would be maintained at 90 percent of CSP capacity rather than the 82 percent required by TS 3.7. .

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The licensee committed to~ conduct an additional review of the FSAR accident analyses and the requirements of ASME Code Section XI. It appeared that reducing the time the plant was kept in hot standby during the above accident scenarios would reduce the EFW demand to within the capability of the CSP. If-such became the case, the

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valves would not come under the purview of the IST program. This would also eliminate the potential of degrading the purity of CSP water. during IST of the valves. The inspectors will track the completion of the revices and resulting actions under Inspector-FollowupItem(IFI) 382/8922-0 Under the current safety evaluation of the FSAR, it was presumed that the above valves were to be tested under the licensee's IST program in accordance with ASME Code Section XI. Since TS 4.0.5 required performance of this testing to meet the operability requirements of TS13.7.1.2 (EFW System), the plant was operated in a condition prohibited by TS. This was in violation of NRC regulations, however, the condition was discovered and promptly evaluated by the license A Notice of Violation for this violation is not being issued in accordance with Section V.G.1 of the NRC's Enforcement Policy. The licensee will report- the details of this incident to the NRC in accordance with 10 CFR Part 50.7 . Monthly Maintenance Observation (62703)

The station maintenance activities affecting safety-related systems and components in_ accordance with the below listed work authorizations (WA)

were observed and documentation reviewed to ascertain that the activities

'were conducted in compliance with approved procedures, Technical

Specifications, and appropriate industry codes or standard a '. WA 01040725. On July 11, 1989, the inspector observed portions of the packing and plunger replacement on Reactor Coolant System Charging. Pump B. No problems were identified.

i WA 01040859. Durin I

temperature (268'F)gthelicensee'sinvestigationofahigh condition on ACCW Pump B inboard motor bearing, the bearing was found to have rotated out of position by-approximately 45*. The babbit was damaged and the bearing antirotation pin was missing. The inspector observed the bearing replacement on July 12, 1989. In addition, the antirotation pin was verified installed on the motor outboard bearing and the pump inboard bearing was; verified to be in satisfactory condition. The licensee reviewed maintenance records and determined that the inboard motor bearing was replaced' during maintenance in 1982. Maintenance records for similar motors were reviewed, and the licensee determined that no I other bearing replacements have been performed since the plant was

! placed in operation. This appeared to be an isolated incident

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attributable to a maintenance error in 1982.

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6 j WA 01041296. T0n July <26, 1989, the inspectors observed portions of the.No. 2 Diesel Fire Pump overhaul. Maintenance personnel appeared to be careful and deliberate as they performed the work, and the intent of the vendor technical manual was being followed. No I problems'were identifie d.- WA 01041140. .On July 13, 1989, Chemical and Volume Control System Charging Pump B tripped on overload. The licensee investigated and determined that the outboard connecting rod bearing bolt had failed, and then the' other end of the connecting rod fractured. Eventually,

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the shortened connecting rod jansned against the pump block, which stalled the pump and caused the overload trip. The connecting rod also gouged the lower. cross head base, and the connecting rod cam on the eccentric shaft (driver) had rotated out of position. The cross head base was repaired, and the eccentric shaft and connecting rod

, were replaced. In addition, the bearing bolts on all three connecting rods were replaced. While inspecting the pump, the system engineer observed what appeared to be a crack on the inboard cylinder block bore.- A liquid penetrant test (PT) was perfomed to confirm

'the existence of a crack with results indicating that there was no crack. Later, when preparing to install pump packing, mechanics observed penetrant in the area of the above apparent crack. A y subsequent PT. and further investigation revealed that the crack-existed and extended approximately 3 inches towards the stuffing box and about 2 inches into the suction valve port. The inspector observed portions of the disassembly and reassenfaly of the pump, and no problems were identified. The pump operated and was capacity tested with satisfactory results. At the end of the inspection

. period, the licensee was performing an operability analysis to

. determine if the pump could be returned to service with the existing crack. The licensee is evaluating the generic implications of this problem with assistance from the vendor. Followup of the licensee's analysis and further investigation on the pump failure is an Inspector Followup Item (IFI 382/8922-02). WA 01042244. On July 27, 1989, the licensee was inspecting the CPC panels in preparation for a modification to reduce control room noise. Seismic support brackets for the CPC cooling fans were found in the cabinet but not completely installed. The licensee noted that the drawings for the CPC cabinets did not show these brackets but determined by-discussion with Combustion Engineering that these brackets were installed during the seismic qualification of the CPC cabinets. The licensee then proceeded to promptly install the

. brackets. The inspector observed the installation of the brackets in CPC Cabinet D. The inspector noted that the CPC fan support brackets were not in a location that would prevent discovery by a visual inspection. During installation, the inspector observed that an additional two fasteners were not installed on components in the I cabinet. This was identified-to the licensee for corrective actio Previously, missing seismic supports for the fixed incore amplifier drawer were found in the CPC cabinets. These supports were installed in September 1988. The licensee's corrective actions for the missing

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incore amplifier drawer supports included' inspections to verify that seismic supports'and fasteners were installed in control room cabinets.(NRC Inspection Report 50-382/88-25). These inspections i were completed by the licensee on October 4,1988. In December 1988, the licensee identified in LER 382/88-034 missing seismic supports in

.the B-qualified safety parameter display cabinet, which was in the Technical Support Center.: These missing supports were not identified during the licensee's previous inspection because the scope was'

limited to control room panels.- The licensee's failure to take adequate corrective action in response to the previous findings with regard to missing supports in control room cabinets is considered an apparent violation of NRC requirements-(382/8922-03).

5.- Monthly Surveillance Observation (61726)

The inspectors observed'the surveillance testing of safety-related systems and components listed below to verify that the activities were being performed in accordance with the Technical Specifications.. The applicable procedcres were reviewed for adequacy, test instrumentation was verified to be in calibration, and test data was reviewed for accuracy' and completeness. . The inspectors ascertained.that any deficiencies identified were properlyf reviewed and resolve Procedure OP-903-005, Revision 5, " Control Element Assembly Operability Check." On July 12, 1989, the inspector observed portions of the performance of control element assembly operability

. check. No problems were identifie ' Procedure OP-903-063, Revision 6, " Chilled Water Pump Operability Verification." -On July 13, 1989, the inspector observed the operability testing on Essential Service Chilled Water Pump B. The inspector observed that permanent markings for vibration survey readings were not installed-(see NRC Inspection Report 50-382/89-08).

This was identified to the licensee and installation of vibration survey points was in progress by the end of the inspection perio No violations or deviations were identifie ; Operational Safety Verification (71707)

N The ' objectives of, this inspection were to: (1) ensure that this facility

was being operated safely and in confonnance with regulatory requirements, 1(2) ensure that the licensee's management controls were effectively

~ discharging the licensee's responsibilities for continued safe operation, (3) assure,that selected activities of the licensee's radiological protection. programs are implemented in conformance with plant policies and procedures and in compliance with regulatory requirements, and (4) inspect

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.the licensee's compliance with the approved physical security pla , Th'el inspectors conducted control room observations, plant inspection

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. tours.: reviewed logs,- and licensee documentation of equipment problem ,

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Through in plant observations and attendance of the' licensee's-plan-of-the-day meetings, the-inspectors maintained cognizance'over plant status'and Technical Specification action statements in effect.'

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'On~ July 26,.1989, the licensee took the control room ventilation. system Train A air handler out of' service'to perform routine preventive maintenance. The. air. handler unit was out of service. for.over 5 days.

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' Problems were encountered with a conflict between the. licensee's generic' ,

procedure for bearing grease.changeout and.the vendor's requirements. A previous problem with. lubrication of the Control' Room Ventilation . System Train B; air ~ handler bearings was identified in January 1988. At the end of this inspection period', the licensee removed the controlled area ventilation. system emergency filtration Unit B from service to correct problems. related to lubrication of air. handler bearings. In addition, problems with high vibration on the control room air handler units wer being investigated.! The adequacy of ~ licensee's disposition of past.and

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present concerns with with lubrication and vibration on engineered safety-features. air handler units is an unresolved item (382/8922-04) pending '

'further review of.this area by the inspecto No violations or deviations were' identifie . Followup of Previously Identified Items '(92701) (Closed) Violation 382/8813-01: Performance of maintenance <

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activities without the appropriate instr.uctions related to cleanliness. contro The inspector verified that the. committed corrective' actions were taken and were still in effect. This item was-reviewed during a regional followup inspection during the period October 24-23, 1988. See Inspection Report 50-382/88-26, dated November 17, 1989. The item was left open due to an' apparent conflict.between.two paragraphs in the licensee's cleanliness procedure. The licensee resolved the conflict by explaining the intent of the procedure in a memorandum dated November 11, 1988. The inspectors reevaluated the apparent conflict in view of the documented explanation and found no problem with the procedure as writte This item is closed, (Closed) Violation 382/8819-01: Failure to report events-to NRC  !

pursuant to 10 CFR Part 50.73. The appropriate Licensee Event Reports (LERs) were issued by September 30, 1988, 2 weeks prior to the committed date of October 15, 1988. This item was reviewed during the regional followup inspection (50-382/88-26) described above and left open pending review of the licensee's actions to prevent recurrence, which the licensee failed to address in the original response dated September 26, 1988. On January 26, 1989, the licensee's supplemental response stated that actions were taken to ensure that events are properly evaluated for deportability. To date, these actions appear to have been effective. This item is closed.

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I L 9 l (Closed) Violation 382/8819-02: Failure to acknowledge alarming control room annunciators in a timely manner. The original response, dated September 26, 1988, failed to address the licensee's actions to prevent recurrence. The supplemental response, dated January 26, 1989, addressed appropriate personnel counseling, discussions at a

- shift supervisors' meeting on January 13, 1989, and actions to eliminate nonvalid indications such that operators will have more confidence in all indications. The inspectors also reviewed an August 19, 1988, change to Operating Procedure OP-4-020. Revision 0,

" Bypassed and Inoperable Status Indication System," and found no problems. Daily observations by the inspectors over the past year since the violations occurred have not revealed any further problems in this area. The licensee has made considerable progress in achieving a " dark board" in the control room wten all systems are normal, and the operators have been responsive to alarming annunciators. This item is close i No violations or deviations were identifie . Licensee Event Report (LER) Followup (90712)

The following LERs were reviewed and closed. The inspectors verified that reporting requirements had been met, causes had been identified, corrective actions appeared appropriate, generic applicability had been considered, and that the LER forms were complete. The inspectors confirmed that unreviewed safety questions and violations of technical specifications, license conditions, or other regulatory requirements had been adequately describe (Closed)LER 382/89-003, " Inadvertent Actuations of Low Pressure Safety Injection Pump Due to Personnel Error."

This LER was reviewed and left open in NRC Inspection Report 50-382/89-17 due to inappropriate corrective action taken as result of the incident but not specifically reflected in the LE The licensee changed Operating Procedure OP-903-011, Revision 4,

"High Pressure Safety Injection Pump Preservice Operability Check,"

in such a manner as to make it even more difficult for the operators to perform the task in a cautious and thorough manner. On July 7, 1989, the procedure was revised again, this time in a more logical and reasonable manner. This completed the corrective actions associated with the LE (Closed)LER 382/89-005, " Failure to Perform EDG Surveillance when CCW Train A Inoperable."

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-10- Balance of' Plant (BOP)-Inspection ~(71500)

' The purpose of- this inspection was to verify the effectiveness of the

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preventive and corrective maintenance programs for 80P systems, determine the. effectiveness of management attention to the correction of B0P problems ..and determine the adequacy of the licensee's' root cause analyses L as they relate to BOP problem lhe inspectors found that the BOP maintenance program and the nuclear steam supply systems (NSSS) safety-related maintenance program were basically one and the same. The principal difference.was found in the area of Quality Assurance (QA). In the B0P, the site QA organization had little or no involvement. Quality in workmanship was the responsibility

.of the performing' department. The seccnd difference was the purchasing of material and spare parts for the B0P. Certificates of compliance were not required for B0P material, although the licensee used exact replacement

. parts, unless engineering allowed otherwis .

The' inspectors reviewed the maintenance program and related documents a , verified that equipment failures in the B0P were evaluated for input into

the preventive maintenance programs. Equipment failures and adverse trends were evaluated'and adjustments made to the preventive maintenance program as appropriate. The licensee implemented a failure and trend analysis' program in specific areas such as motor operated valves, component vibration, pump performance, and diesel generator performanc '~

These were all implemented by approved procedures.- In addition, there was a provision for trending other areas as delineated in Maintenance Administrative Procedure MD-01-016. Revision 1, " Failure and Trend

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Analysis." Through this program, Maintenance Engineering could be

- requested to trend any specific area of concern. The requests were logged and tracked to conpletion. In'1988, 11.such projects were requested; 5 ,

have been completed. In 1989, as of the end of June, 17 had been requested and 2?were closed. This indicated that many were still in progress. The

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licensee also had an Availability Improvement Program where the relative

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impact on' plant availability by specific components, B0P and NSSS and-changes thereto, was evaluate The BOP preventive maintenance (PM) program was handled the same as the NSSS.(safety-related) program. PM recommendations from vendors were included in the program,-correctly reflected in the maintenance procedures, and based on manufacturer's= documents. Corrective maintenance-(as well as PM)' items were documented by work authorization packages and were included in history records. The BOP PM program included appropriate periodic calibration and testing of protective instruments ano controller ' Approved work authorizations were used for all nonroutine and routine B0P work activities with the exception of Quality Assurance. The sane level of approval was used for B0P and NSSS work authorization _ . _ _ _ _ _ _ _ - _ _ _ _

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l Typically, replacement parts and materials for the B0P were exact replacements. If changes were proposed, it was necessary to obtain the appropriate engineering reviews and approvals. Since safety evaluations, seismic considerations, and replacement part certification documentation ,

was of less concern for B0P, substitutions were easier to proces l Warehouse inspection for 80P material was the same as for NSSS to the extent that incoming material was compared with purchase contracts and the provisions specifie Postmaintenance testing for 80P equipment was usually limited to a functional test or just observing that the repaired equipnent operated without a problem after the repai In many cases, a step was added to 4 the work authorization to verify that the repair was successful by running the equipment, conducting a soap bubble test on air systems, conducting a vibration survey on rotating equipnent, et Management support of the correction of B0P problems has been commensurate with the potential threat to reactor safety, or overall plant availabilit Management has been very successful in reducing the number and frequen of plant trips caused or complicated by BOP problem The overall excellent appearance, absence of leaks, and excellent availability of Waterford-3 reflect a B0P maintenance program that was responsive and cost effective. Maintenance personnel appeared to be knowledgeable and experienced in maintaining the B0P. No problems were identifie No violations or deviations were identifie i 10. Exit Interview The inspection scope and findings were summarized on August 1, 1989, with those persons indicated in paragraph I above. The licensee acknowledged the inspectors' findings. The licensee did not identify as proprietary  ;

any of the material provided to or reviewed by the inspectors during this j inspectio ]

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