IR 05000382/1989029
| ML19332F142 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/29/1989 |
| From: | Ray Azua, Kelley D, Murphy M, Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19332F139 | List: |
| References | |
| 50-382-89-29, NUDOCS 8912130457 | |
| Download: ML19332F142 (7) | |
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APPENDIX B
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U.S.~ NUCLEAR REGULATORY COMMISSION
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REGION IV
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NRC Inspection Report: 50-382/89-29 Operating License: NPF-38
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50-382 r
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Licensee: Louisiana Power & Light' Company (LPAL)
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317 Baronne Street
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New Orleans, Louisiana.70160
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Facility Name: Waterford Steam Electric Station, Unit 3 (W-3)
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Inspection At:
W-3, Taft Louisiana t
g Inspection Conducted: October 30 through November 3, 1989 l
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. Inspectors:
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- d e/rf M. E.. Murphy, Re(ctoV Inspector, Test Programs Date
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Section, Division of Reactor Safety
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D. L.-Kelle # Reactor Inspector, Test Programs Date
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.Section, Division of Reactor Safety i
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R. V. Arua, Seactor Inspector, Test Programs Date-Section, Division of Reactor-Safety Accompanied W. C. Seidle, Chief, Test Programs Section
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Division of Reactor Safety on November 2-3, 1989 I
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Approved:.
W. C. SeidleGhief,; Test Programs Section Date
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Division of. Reactor Safety
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Inspection Summary inspection Conducted October 30 through November 3. 1989 (Report 50-382/89-?9)
Areas Inspected: Announced team inspection for system entry retests in the areas of design changes, temporary alterations, and maintenance activities.
Pesults: The licensee's design change program was found to r.,ide adequate
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technical reviews and assurance that the proper post-installa to: testing was being performed. No evidence of inadequate post-maintenance testing was found; however, the lack of specificity in testing requirements and acceptance criteria is considered a weakness in the maintenance retest area.
In the area of retest for temporary alterations, the administrative procedures contained l
deficiencies as ev1 danced by the identification of one apparent violation concerning failure to provide adequate test control, and one unresolved item
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concerning post restoration testing of a containment penetration, I
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i-DETAILS 1.
Persons Contacted LP&L
- J. Hoffpauir, Planning & Scheduling Superintendent
- L. Laughlin, Site Licensing Supervisor
- G., Davis, Manager, Event Analysis Reporting & Response
'R. Azzarello, Manager, Nuclear Operations Engineering & Construction
- T. Brennan,_ Design Engineering Manager-
- p. Prasankumar, Assistant Plant Manager Technical Support
- M. Ferri, Modification Control Manager
- R. Starkey, Operations Superintendent i
- T. Leonard, Maintenance Superintendent
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- D. Marpe, Maintenance Engineering Supervisor
- T. Smith, Plant Engineering Superintendent
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- W. Brian, Systems Engineering Supervisor
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- L. Bass, Nuclear Operations Engineering & Construction NRC
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-*W. Smith, Senior Resident inspector-
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S. Butler, Resident Inspector
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~* Denotes those attending the exit interview on November 3, 1989.
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During the inspection, the inspectors also contacted other licensee-l personnet.-
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Inspection Objectives and Method
The overall objective of this inspection was to determine the licensee's performance in the area of system entry retest identification, documentation, and conducting retests.
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To accomplish this objective, the inspection was conducted to-determine that retest requirements were evaluated during modification and
maintenance planning and that-the retest procedures met regulatory requirements, commitments, and industry guides and standards.
It was also to determine that retest requirements were considered for all system-boundary violations. The inspection also verified that the retests proved
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operability and assured that the design basis was satisfied for structures, systems, and components that were modified or subjected to maintenance during this refueling outage.
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.The inspectors rehiewed the licensee's administrative procedures for
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design changes, temporary alterations, and maintenance. The following
procedures defir.ed. responsibilities and did refer to rctest require:nents except in the temporary alteration area:
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NOP-14. " Design thanges"
UNT-005-002, " Condition Identification"
UNT-005-015, * Work Authorization Preparation and Implementation"
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UNT-005-004, " Temporary Alteration Control"
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MD-001-014. " Conduct of Maintenance"
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Work items scheduled for this refueling outage were assessed and the inspectors selected 9 design changes, 26 tempurary modification packages, t
and 26 maintenance-related work authorization packages for detailed
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review.
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Inspection Findinos Sumary
The licensee's design change program was found to provide adequate technical reviews and assurance that the proper post-installation testing g
was being performed. No evidence of inadequate post-maintenance testing
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was found; however, the lack of specificity in testing requirements and
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acceptance criteria is considered a weakness-in the maintenance retest area.
In the area of retest for temporary alterations, the administrative i
procedures contained deficiencies as evidenced by the identification of
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-one apparent violation and one unresolved item.
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,Desian Chnges (72701)
The purpose of this inspection was to determine the process by which a
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design change is developed, reviewed, installed, and tested. Most specifically, the inspector was interested in verifying that all design
- changes had been or would be tested adequately prior to the plant returning to power operation.
The inspector reviewed the licensee's Nuclear Operation Procedure No. 14
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(NOP-14)." Design Changes" dated January 1, 1989. This procedure described the licensee's design change program, which included various review processes including 10 CFR Part 50.59 reviews, technical reviews, safety evaluations, and when required, a plant operating review comittee (POPC)
review. The design change packages included post-installation testing _
requirements for the modifications. Once the design change package is approved, condition identifications (CIs) are generated followed by a work t
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authorization (WA). When the WA is completed, it is reviewed by different
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departments for adequacy and to verify that the post-installation testing requirements listed in the design change packages are addressed along with any other tests that are deemed necessary prior to placing the modification in service,
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In addition, the inspector reviewed several' of the licensee's design change packages and associated WA packages. The inspector determined that the licensee's design change packages met the requirements set forth in NOP-14, and found that they and the nuclear. operating procedure were technically adequate. Also, the inspector determined that the i
post-installation testing requirements were adequate. A review of some of
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the available WA test results by the inspector revealed that these also had been adequately addressed. One item identified by the inspector as a concern was the fact that in the WA packages, from the time they were
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initiated, reviewed, approved and then completed, pages were not sequentially numbered until the WA package was submitted to document control for final storage. This raised the question as to how a page(s) could be identified if lost during the review or implementation process.
It also raised the question as to what' the consequences would be should an important procedural step, such as post-installation testing, be omitted due to a missing page.
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The inspector stated that this was contrary to good industry practice and urged the licensee to consider alternatives that would correct this i
deficiency.
In response to the inspector's concern, the licensee agreed to include pagination requirements in an administrative procedure that is presently,being revised.
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No violations or deviations were identified in the review of this program area.
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Maintenance (62700,62702)
b The inspectors reviewed the licensee's control of maintenance activities, as described in Procedures UNT-005-002, " Condition Identification,"
l MD-001-014. " Conduct of Maintenance," and UNT-005-015. " Work Authorization
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Preparation and Implementation."
ll Anyone onsite may initiate a condition identification (CI)._ The CI identification process is accomplished using one of the several computer l
terminals located in the plant. Once the CI has been evaluated and accepted, a WA is generated by the computer.
The WA would contain procedural steps or references to existing procedures, materials and parts, and plant condition requirements, to name a few. An additional addendum sheet identifies any post-maintenance testing requirements.
Each-WA package receives the appropriate reviews, and is then scheduled for implementation. Administrative Procedure MD-001-014 contains guidance in Section 5.7 on post-maintenance testing, including the typical types of
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activities which require post-maintenance te3 ting. Administrative Procedure UNT-005-015, contains discipline responsibilities for.Various
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aspects of post-maintenance testing.
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suggested guidance or "should" statements.
The inspector reviewed 26 WAs, the majority of which were for corrective or preventive maintenance.
There were an additional 23 maintenance procedures reviewed by the inspector, which were referenced by the WAs.
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.4 The WAs fell into two categories, "in progress" or " completed." All were reviewed to determine if post-maintenance testing requirements were
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(1) demonstrated that the-maintenance corrected the identified problem; (2) did not introduce any new problems; and (3) demonstrated that the component or system was i
operable within its design basis. A review of the maintenance procedures, with the exception of those that dealt with MOVATS testing, instrument calibration, or Technical Specification surveillance requirements, revealed that they contained little specific testing or acceptance criteria.
Additionally, there is no guidance for testing in the cases where previous testing requirements had not been established.
The inspector concluded that the present post-maintenance' testing relies
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heavily upon the experience of plant personnel to fill in the gaps.
Although the inspector found no evidence of inadequate post-maintenance.
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testing, the lack of specificity in testing requirements and acceptance
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criteria is considered a weakness in the licensee's post-maintenance testing program,
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Discussions with licensee representatives revealed that the weakness in the testing program also had been identified by an outside contractor audit. The licensee is presently revising all maintenance procedures and working on a procedure which, when completed, will address all facets of post-maintenance testing.
No violations or deviations were identified in the review of this program area.
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Temporary Alterations (72701)
The inspector reviewed the licensee's temporary alteration program, which was described and administratively controlled by Procedure UNT-5-004,
" Temporary Alteration Control."
A temporary alteration request (TAR) may be generated by any plant personnel.
It receives a safety and engineering review and is then submitted to the PORC for' approval. The procedure does not require any determination or identification of retests, either for the initial installation or upon restoration to normal. The' licensee's position is that the work authorization package development will provide for the review, determination, and designation of any required retests. This appears to work in most of the temporary alterations (TAs) reviewed, but all TAs do not require WA packages. The procedure does not contain any
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guidelines for retest identification and performance. The licensee agreed i
that the TA program was deficient in this area.
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The inspector reviewed 26 TA packages provided by the licensee. This review substantiated the concerns about the program. The following concerns were verified by this review:
All TARS do not result in WAs and/or CIs.
- Many TAR packages do not reference a WA or a CI.
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r Most TAR packages do not mention retest, either for initial
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Most engineering evaluations in the TARS are silent on retest
requirements.
One TAR /WA did not require a post-restoration retest.
- One TAR /WA did' not require a retest of the temporary installation.
- Temporary alteration TA-89-21 provided service air to the reactor containment building during the refueling outage through the integrated leak rate test penetration.
The TAR package did not address a post restoration retest and the asscciated WA specifically stated "no post
, maintenance testing required." Subsequent discussions with licensee
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representatives' revealed that a local-leak rate test was separately scheduled-to be conducted prior to return to Mode 4.
This test will be followed up by the resident inspectors and, pending completion of the J
retest and work package correction, this will be considered an unresolved item.
(382/8929-01)
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i cTemporary alteration TA-89-22 provided temporary services capability inside the containment building, during the refueling outace, through one ofLthe HVAC vacuum breaker lines at Containment Building penetration -13.
i-Post-restoration and valve operability retests were properly required.
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l test to prove operability of the temporary penetration closure for the potential conditions during the period of installation.
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was silent on either a containment building penetration tightness test or an engineering evaluation. This is an apparent violation of 10 CFR Part 50, o
p Appendix B Criterion XI.
(382/8929-02)
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Exit Meeting An-exit meeting was held November 3, 1989, with the individuals noted in paragraph 1 of this report. At this meeting, the scope of the inspection l
and the findings were summarized. The licensee did not identify as proprietary any of the infortnation provided to, or reviewed by the inspectors.
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