IR 05000382/1990004

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Insp Rept 50-382/90-04 on 900201-28.Violations Noted.Major Areas Inspected:Plant Status,Onsite Followup of Events, Monthly Maint Observation,Monthly Surveillance Observation, Operational Safety Verification & LER Followup
ML20012D133
Person / Time
Site: Waterford Entergy icon.png
Issue date: 03/12/1990
From: Chamberlain D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20012D127 List:
References
50-382-90-04, 50-382-90-4, NUDOCS 9003260507
Download: ML20012D133 (13)


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APPENDIX B

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U.S. NUCLEAR REGULATORY COMMISSION i

REGION IV

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F NRC Inspection Report:

50-382/90-04 Operating License:

NPF-38 L

Docket:

50-382

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Licensee:

Louisiana Power & Light Company (LP&L)

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L 317 Baronne Street

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New Orleans, Louisiana 70160

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

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Inspection At: Taft, Louisiana

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Inspection Conducted:

February 1-28, 1990

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Inspectors:. W. F. Smith, Senior Resident Inspector Project Section A, Division of Reactor Projects S. D. Butler, Resident Inspector Project Section A, Division of Reactor Projects R. C. Haag, Backup Resident Inspector Project Section A, Division of Reactor Projects

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R. B. Vickrey, Reactor Inspector Operational Programs Section, Division of Reactor Safety

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Approved:

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D. D. ()famberlain, Chief, Project Section A Date Q Inspection Summary Inspection Conducted February 1-28, 1990 (Report 50-382/90-04)

g COC 8$E Areas Inspected:

Routine, unannounced inspection of plant status, onsite

followup of events, monthly maintenance observation, monthly surveillance on observation, operational safety verification, followup of previously identified

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items, and licensee event report followup.

SU no Results:

One violation was identified in paragraph 4 indicating a programmatic 8@

weakness.

During routine maintenance observations, the inspector found a l

N repetitive task work authorization designated nonsafety-related to perform

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oe preventive maintenance on a safety-related dry cooling tower (DCT) fan.

This

$@c would have resulted in less quality assurance than the licensee normally

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applied to safety-related work, had it not been immediately corrected.

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the inspector identified the problem, the licensee found nearly 50 other such repetitive tasks in the maintenance database with the same problem.

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raised questions.regarding the-adequacy of the licensee's quality assurance on some safety-related work. 'These questions were discussed with licensee

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management during this inspection and should be addressed in the violation i

response.

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A second violation was identified during a followup inspection (paragraph 7).

The violation involved failure of the licensee to adequately retest Containment Fan Cooler (CFC) C fan motor after replacement.

As a result, the CFC was not t

.available to perform its intended safety function because, af ter nearly a year, the fan was discovered to rotate backwards in slow speed.

Although there were

sufficient redundant CFCs to satisfy Technical Specification Limiting

Conditions for Operation, this problem revealed weaknesses in the licensee's postmaintenance testing program.

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-3-DETAILS I

1.

Persons Contacted Principal Licensee Employees R. P. Barkhurst, Vice President, Nuclear Operations

  • J. R. McGaha, Plant Manager, Nuclear
  • P. V. Prasankumar, Assistant Plant Manager, Technical Support D. F. Packer, Assistant Plant Manager, Operations and Maintenance
  • A. S. Lockhart, Quality Assurance Manager

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D. E. Baker, Manager of Nuclear Operations Support and Assessments R. G. Azzarello, Manager of Nuclear Operations Engineering i

W. T. Labonte Radiation Protection Superintendent

  • G. M. Davis, Manager of Events Analysis Reporting & Responses L. W. Laughlin, Onsite Licensing Coordinator
  • T. R. Leonard, Maintenance Superintendent

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R. F. Burski, Manager of Nuclear Safety and Regulatory Affairs

  • R. S. Starkey, Operations Superintendent H. D. Miller, Shift Supervisor J. M. O'Hern, Operations Training Supervisor
  • T. J. Gaudet. Engineer III. Site Licensing Support
  • Present at exit interview.

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In addition to the above personnel, the inspectors held discussions with various operations, engineering, technical support, maintenance, and i

administrative nembers of the licensee's staff.

2.

' Plant States (71707)

At the beginning)of this inspection period, the plant was in coldfor repair of abnonn

shutdown (Mode 5

unidentified leakage and the failure of two control element drive motor cooling fan motors. The work was completed and the reactor was heated up and taken critical on February 3,1990.

By February 5,1990, the plant was restored to full power operations. On February 8,1990, when the outboard seal on Main Feed Pump A failed, plant power was reduced to 65 percent so that power operation could continue using Pump B.

On February 12, 1990, the plant was shut down to hot standby (Mode 3) in order to repair a leaking main feed pump suction isolation valve.

By February 14, 1990, the plant was back on the grid at about 65 percent power while feed pump repairs continued. The plant was restored to full power after completing Pump A repairs on February 17, 1990, where it remained until the end of the inspection period.

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3.

Onsite Followup of Events (93702)

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Failure of Feedwater Regulating Valve Control Air Tubing On February 7,1990, while the plant was operating at full power, the water level in Steam Generator (SG) No. 2 began to slowly increase to about 4 percent above nomal. Although the feedwater control system was providing a demand signal to close the feedwater regulating valve (FRV), the FRV did not move in the closing direction. The operators took manual control, but only the startup FRV would close, which was sufficient to recover water level. When the plant is at high power, the startup FRVs normally stay fully open, while the FRVs and feed pump speed modulate.

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Upon investigating, the operators discovered that the flexible tubing

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supplying control air to the SG No. 2 FRV actuator was broken on the side that closes the valve. At Waterford 3, the FRVs am located

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outdoors. The licensee stated that the cold weather tent that was placed over the FRV piping and controls during the December 1989 freeze had probably caused the failum. The tent was resting on the

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flexible connection, and pockets of water had fomed on the tent due to recent rain, adding to the weight of the tent. This condition, coupled with the nomal vibration of the FRVs, could have caused fatigue and eventual failure of the flexible connection.

While controlling SG water level manually with the startup FRV (with L

the-FRV gagged so that it would not open any further), the licensee made an emergency nonconformance repair. A flexible connection l

replacement could not be quickly found, so a piece of copper tubing with a long icep was used for flexibility. The cold weather tents were removed. Within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 1S minutes of the failum, the

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problem was diagnosed, repairs were made, and the feedwater control i

system was restored to automatic operation. Operator response to this incident appeared excellent. On February 8,1990, the inspector looked at the temporary repair and, based on engineering judgment, concluded that tie installation probably would last for several

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weeks; however, the movement due to piping ibration might

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work-harden the tubing and thus lose its flexibility as time passed.

The licensee located a proper replacement part for the failed flexible tube but was reluctant to make the repair while at power due to the potential of losing control of SG 1evel.

Engineering i

inspected the temporary tubing and concluded that the tubing would probably last until the next forced outage.

The outage occurred on

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February 12, 1990, when Main Feed Pump A failed. The tubing was then replaced with the proper part.

This part of the feedwater system was not nuclear safety-related but was Seismic Category I and was described in the Waterford 3 Final Safety Analysis Report (FSAR). The licensee implemented and documented the nonconformance repair in accordance with their l

I administrative procedures.

The inspectors reviewed the documentation L

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associated with the emergency repair to ensure that the requirements

of 10 CFR 50.59 were being met. By February 15, 1990, a 10 CFR 50.59

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review or safety evaluation was not done. This became moot on

12, 1990, February's Engineering Procedure PE-002-005when the proper part was insta

licensee Revision 11

" Engineering Wet k Authorization Processing," in combination with Administrative Procedure UNT-005-002, Revision 9. " Condition Identification," appeared to be fragmented with regard to the process of implementir immediate nonconformance repairs. There was a requirenent to perform a 10 CFR 50.59 review once a complex trail of references was followed, but it was unclear to the inspector as to when it must be done.

In addition, the inmediate work authorization t

form (Attachment 6.6onUNT-005-002) had a notification section for documenting contact with all the necessary personnel except the duty

engineering manager. According to PE-002-005, he nest be contacted

for immediate engineering input.

This was discussed with the

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licensee. The inspector expressed concern that proper reviews may i

not be made in a timely manner when emergency repairs are implemented unless the on-shift personnel have clear d',rection and the right tools to control the work. The licensee stated the intent to review the process and make appropriate procedure improvements within the next 2 months. This shall be tracked under Inspector Followup t

Item (IFI) 382/9004-01, b.

Failure of Main Feed pump (MFP) A Shaft Seal On February 8,1990, at about 2:30 p.m., the outboard seal on MFP A

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began to fail as indicated by elevated seal temperatures, steam emanating from the seal, and abnormal vibration. The plant was at full power at the time. The operators reduced power to 65 percent over a period of 45 minutes, and then at 3:37 p.m. the MFP A turbine was tripped. The operators attempted to isolate the pump but, by 6 p.m., a large quantity of vapor from flashed feedwater continued to discharge from the seal.

By 7 a.m., on February 9,1990, the vapor

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discharge had essentially stopped, but seal water was flowing freely out of the failed seal. At that point, the pump was at about 275"F and 35 psig, due to suction Valve CD-230A leaking by.

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The licensee tried to seat the 24-inch gate valve by applying neximum torque and hammering the disk into the seat, but to no avail. On February 10, 1990, the licensee decided to shut down and repair CD-230A. Due to instability on the arid caused by a storm which damaged the Hurtburg-Eldorado 500,006 volt transmission line in the northern part of Louisiana, the shutdown was delayed until 9:17 a.m. on February 12, 1990. The licensee disassembled CD-230A and found that the wedge angle of the disk did not match the angle of the seat. Mechanical maintenance personnel machined the disk and, on the first attempt, obtained satisfactory seating of the valve. This was a difficult task, particularly on a 24-inch gate valve. The inspectors noted excellent performance and teamwork on the part of the mechanical maintenance personnel involved.

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-6-After verifying that CD-230A could isolate MFP A, the plant was returned to power operation on February 14, 1990 The inspectors witnessed some of the disassembly of the failed MFP seal. The labyrinth shaft sleeve had parted longitudinally from the pump shaft, expanded, and wiped out the labyrinth grooves. The pump shaft was slightly scored, but the seal was destroyed. The licensee had to we an arc gouger to cut the stationary seal (break down bushing) out of

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the pump end bell. The pump seal and shaft were replaced. MFP A was reassembled, tested, and placed back in service on February 17,1990 At 8:07 p.m., the plant was restored to full power.

The licensee determined that the primary cause for seal failure was inadequate

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clearance between the labyrinth shaft seal and the breakdown bushing

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in the upper vertical axis, A root cause analysis was being documented at the end of this inspection period. The inspectors will

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review the document when it is issued. The MFPs at Waterford 3 were

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p manufactured by Pacific Pump Company, which is now owned by Dresser

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No violations or deviations were identified.

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4.

Monthly Maintenance Observation (62703)

The station maintenance activities affecting safety-related systems and components listed below were observed and documentation reviewed to ascertain that the activities were conducted in accordance with approved Work Authorizations (WAs), procedures, Technical Specifications, and appropriate industry codes or standards.

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Repetitive Task (RT) WA 01052518. On February 14, 1990, the i

inspector observed portions of preventive maintenance performed on l

DCT Fan 8B. The work included changing the reduction gear

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lubricating oil, checking alignment of the motor coupling, verifying

torque on the blade adjustment bolts, and performing vibration

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surveys. The inspector independently verified that the proper lubricating oil was being used by comparing the label on the container with that specified in the WA and again with that specified in the Plant 1.ubrication Manual. The inspector reviewed the WA package u:ed at the job site and found no problems with the instructions except that the WA cover sheet specified the DCT fan as nonsafety-rtlated.

This was inappropriate since the DCT was part of the plant's ultimate heat sink for safe shutdown of the reactor. The maintenance supervisor promptly had the WA corrected after determining from the component database (CDB) that the DCT was, in fact, safety-related.

This, in turn, changed the quality control (QC) requirements in accordance with licensee Procedure PN-06-011 Revision 4, " General Torquing and Detensioning." A hold point was added to the WA requiring a QC inspector verification of proper torque on the fan blade bolts. The change delayed the work by about 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, but the work was properly done in accordance with the applicable procedures.

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-7-The inspector requested that the licensee explain how the RTWA could show the DCT fans as nonsafety-related when the CDB indicated them as safety-related and asked if similar errors exist in any other WAs in the maintenance database (MDB). The licensee determined that 25 of the DCT fans were designated as nonsafety-related in the MDB and that, although the CDB showed all 30 fans as safety-related, they had only recently been changed, in August 1989, from nonsafety-to safety-related.

There was an apparent failure in the licensee's program to ensure that the MDB was updated to reflect changes in the CDB. The licensee then perfonned a variance comparison between the CDB and the MDB to identify disagreement between and RTWAs and the CDB. The comparison print-out revealed roughly 50 components, including 25 DCT fans.

In some cases, the MDB indicated safety-related when the CDB indicated nonsafety-related.

As of the end of this inspection, the licensee had initiated actions to determine (1) the extent of the disparities in nun,ber, (2) the reasons for changing the identified components from nonsafety-related to safety-related or vice versa, (3) the impact of having identified each component as nonsafety-related in tenns of work performance or quality of parts and materials used. (4) the root causes of the problem,and(5)thecorrectiveactionstobetaken. The inspector reviewed Administrative Procedure UNT-5-012. Revision 1, " Repetitive Task Identification." Section 5.5.1 stated that the licensee's Station Information Management System (SIMS) automatically copies whether or not a component 11. safety-related from the CDB to RTs being generated in the MDB. Since the RTs for DCT fans were placed in the MDB before the CDB was changed, the RTs showed the DCT fans as not safety-related. UNT-5-012 appeared to suggest that RT updates should be made if source documents like the CDB are changed.

It did not specifically require it, nor did the procedure appear to establish responsibility and time-frame to keep the MDB up to date.

Failure to provide an adequate procedure to control this safety-related function is a violation of NRC regulations (382/9004-02).

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

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perfonned 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

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completeness. The inspectors ascertained that any deficiencies identified were properly reviewed and resolved.

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Procedure OP-903-032, Revision 7. " Quarterly IST Valve Tests." On February 25, 1990, the inspector observed the control room operator cycling sample and blowdown valves selected for increased frequency testing.

Previous quarterly data was well within the acceptance criteria but, due to inconsistent timing values, the engineers had j

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increased the frequency to monthly in accordance with the ASME Code to obtain more detailed trending and evaluation data. The inspector reviewed the documented data, independently verified tines on

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selected valves, and found no problems.

No violations or deviations were identified.

6.

Operational Safety Verification (71707)

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The objectives of this inspection were to ensure that this facility was

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being operated safely and in conformance with regulatory requirements, to

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ensure that the licensee's managerent controls were effectively

discharging the licensee's responsibilities for continued safe operation.

to assure that selected activities of the licensee's radiological t

protection programs are implemented in conformance with plant policies and i

procedures and in compliance with regulatory requirenents, and to inspect the licensee's compliance with the approved physical security plan.

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The inspectors conducted control room observations and plant inspection

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tours and reviewed logs and licensee docunentation of equipment problems.

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 statenents in effect.

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The licensee had experienced indications of possible seat leakage on one or both pressurizer code safety valves since the startus from Refuel 3 in November 1989. The leakage had been minor and well witain Technical Specification limits for RCS leakage but enough to cause elevated tail

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pipe temperacures. Over the past few weeks the quench tank has required periodic venting and draining to maintain proper pressure. The quench

tank is located in the containment building and is designed to receive the

effluent from the safety valves in the event they lift on high pressurtzer

pressure,

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The inspectors have monitored the safet' selve leakage status and kept regional management informed.

Plant 1 %s were reviewed and safety valve leakage was estimated based on changes in quench tank level. These estimates were compared to identified RCS leakage measurements attributed to the safety valves.

These neasurements were performed by the licensee as part of required Technical Specification surveillance testing. The inspector's estimates were reasonably close to the values measured by the licensee.

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The licensee established guidelines on maximum acceptable safety valve leakage (less than the Technical Specification limit) before the unit would be shut down to repair the problem. They also performed a safety evaluation as required by 10 CFR 50.59 to operate at reduced RCS pressure to minimize safety valve leakage. As of the end of this inspection period, the RCS was being operated at 2200 psia and, as a result, venting and draining of the quench tank was reduced from a frequency of approximately twice per 8-hour shift to twice per day. The Technical

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9-i Specification limits for RCS pressure are between 2025 and 2275 psia.

l Normal operating pressure was 2250 psia. The licensee also evaluated the effect of cycling quench tank pressure on the tank's rupture disk to ensure that it would not become degraded. The inspectors will continue to i

monitor the safety valve leakage problem until it is corrected.

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The licensee had two other problems developing which could result in a i

shutdown for repairs. The stator temperature for Reactor Coolant Pump 2A had been trending upward over a period of several days. This was one of the two pumps (IB and 2A) reported as having the same problem in December 1989 and January 1990. During the January 1990 outage, the stator cooling coils for both pumps were cleaned and, after startup in early February, both were normal.

Pump 2A was at 240*F as of the end of this inspection with an erratic trend. The alarm setpoint is 266'f.

Operation at elevated temperatures will shorten motor life, according to

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the licensee, and if the temperature exceeds 260*F the licensee intends to start planning an outage to correct the problem. The inspectors will continue to monitor this problem.

In addition, Main Steam Isolation Valve A had a packing leak.

It was not causing a problem nor did it get any worse during this inspection.

If containment isolation became necessary, the packing gland would be isolated.

If the leakage gets much worse or if the plant is shut down and cooled for other reasons, the licensee has indicated plans to repack the valve. This can only be safely done with the plant cooled down. The

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. inspectors will continue to observe this valve during routine tours.

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No violations or deviations were identified.

7.

Followup of Previously Identified Items (92701,92702)

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(Closed)OpenItem 382/8818-01: This open item involved correction of technical deficiencies identified in the Emergency Operating

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Procedures (EOPs). The concerns were identified in Appendix B of the inspection report and found in the areas of steps out of sequence with CEN 152 guidelines and clarification of the preferred instrumentation to be utilized to verify plant parameters. The inspector reviewed the incorporation of the resolutions of the above concerns into the latest revision of the E0Ps.

The licensee has addressed the concerns expressed in the open item. This item is closed.

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(Cloced)OpenItem 382/8818-02:

This open item involved incorporation of instrumentation safety margins into the E0Ps, when the CEN 536 study identified the appropriate margins needed.

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licensee was a participant in CEN TASK 536, which was a task for developing a methodology for determining instrument errors to be included in the appropriate E0Ps for adverse containnent environments. The licensee was awaiting the results of this project to revise their E0Ps accordingly. The inspector reviewed the engineering itview response Letter W3B88-0261 which stated that no l

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However, the E0P operating window could be improved by full implementation of TASK 536. The licensee informed the inspector that an evaluation hed not been completed as to the cost effectiveness of the new methodology in the above case. The inspectors had no further questions. This item is closed, c.

(Closed)OpenItem 382/8818-03:

This open item involved validation of all E0P revisions with a normal operating shift. This concern was that validation of the E0Ps was completed by highly experienced personnel which caused several deficiencies to be overlooked that probably would have been identified if regular operating shifts had been used. The inspectors discussed this with the licensee and reviewed the process the licensee had initiated for validation in the latest revision of E0Ps. This process was to use a multidisciplinary approach in which all E0Ps were technically verified and validated by operating shifts.

In addition. Operations QA, ISEG, and licensing reviewed the procedures and provided comments. The licensee has addressed the concerns expressed in the open item. This item is

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closed.

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(Closed)OpenItem 382/8818-04: This open item involved correction

of the plant equipment deficiencies associated with the i

implementation of the E0Ps. These deficiencies,.which were identified during control room simulator and in-plant walkdowns, were

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identified in Appendix D of the inspection report. The licensee had

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comitted to correct these weaknesses. The inspector reviewed the licensee's responses to the above concerns which included correction of deficiencies and/or procedural changes. The licensee addressed the concerns expressed in the open item. This item is closed, e.

(Closed)OpenItem 382/8818-05: This open item involved upgrading the safety function recovery procedure (SFRP) training programs (simulatorandclassroom). The licensee was questioned as to the adequacy of training time devoted to SFRP in relationship to its complexity. The licensee had committed to evaluate the adequacy of the training and to revise it, as necessary, to emphasize the SFRP.

The inspector reviewed Training Requests 880204 and 880205 associated with the above concerns. As a part of the training request disposition, the licensee had added into Requalification Cycle 5, lectures for OP-902-005, " Degraded Electrical Recovery Procedure,"

compared to OP-902-008, " Safety Function Recovery Procedure." The inspector reviewed Lesson Plan Nos. L588-503-00, "FSAR Audits and Emergency Operating Procedures Review (SFRP)." L588-502-00,

" Electrical Power Distribution and Degraded Electrical Distribution Recevery (SFRP) " and LS89-502-00, " Function Based Emergency Operating Procedures Reviews," associated with the above training request dispositions. The licensee addressed the concerns expressed in the open item. This item is closed.

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(Closed)OpenItem 382/8818-06:

This open item involved upgrading the E0P evaluation program elements for providing feedback of operctor concerns and difficulties with the E0Ps. At the time this potential weakness was identified by the inspector the licensee subsequently issued a handwritten daily instruction, dated July 6, 1968, which required that the " Procedure Change Request" form of Instruction 01-019-000 be used by all instructors and trainees. The inspector reviewed Lesson Plan No. D020-005-02, " Exercise Presentation." This lesson plan addressed the pre-exercise discussion items for simulator groundrule review, the importance of procedures adherence, and the need to submit requests for changes using 01-19-000. The licensee addressed the concerns expressed in the open item. This item is closed, g.

(Closed)OpenItem 382/8818-07: This open item involved incorporation of operator ability to perform during emergency or abnormal conditions in the annual performance appraisals. This concern was raised over the marginal programs for evaluating the perfomance of the operators in the use of the E0Ps onshift. The licensee's response to the above concern was that, due to the

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infrequency of on-shift E0P use, the current evaluation process

provided the best means of appraising operations personnel.

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Operations personnel were also evaluated extensively during simulator

training and requalification.

In addition, the operation advisory I

group reviews and reports on events require the use of E0Ps. The inspector discussed the above response with the licensee and had no

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further questions. This item is closed.

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(Closed)OpenItem 382/8818-08: This open item involved upgrading of quality assurance oversight of E0P development and implecentattun.

The licensee had stated that QA had only minimal involvenent in E0P development and implementation. The licensee's QA manager committed to review this issue and provide appropriate oversight r>f E0P development and implenentation. The licensee subsequently had revised UNT-001-004, " Plant Operations Review Committee." (PORC) to include QA as a PORC member. The inspector reviewed UNT-001-004, Revision 12, and discussed QA's involvement with E0Ps with the operations QA manager. The inspector had no further questions. This item is closed.

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(Closed) Unresolved Item 382/8819-04:

Further review was required to determine the causes surrounding, and safety significance of, delays in replacing undersized wiring in an auxiliary control panel for Train A shield building ventilation system heaters. This item was addressed and left open in NRC Inspection Report 50-382/88-21. The safety significance was determined to be minimal because the wiring was subsequently evaluated as being of sufficient size.

The item was left open in that report pending the licensee's response to corrective action concerns surrounding Enforcement Action (EA)88-144 (near loss of shutdown cooling event in May 1988). The licensee has

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since responded satisfactorily and implenented corrective action l

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-12-program enhancements. The issues related to EA 88-144 were closed in NRC Inspection Report 50-382/90-01. This item is closed.

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(Closed) Violation 382/8912-03:

This item involved failure of auxiliary operators to follow radiological protection procedures in that they failed to obey certain radiological warning signs. The inspectors noted that the licensee entered the problem into their corrective action program by initiating Radiological Deficiency Report 89-12. They also counselled the employee, pulled his dosimetry, and required him to attend a refresher course in radiation worker training. The operations superintendent issued a letter to all operations personnel (W3089-0058, dated June 22,1989) stressing their responsibility for observing and-following radiological warning signs. Since that action was taken, the inspectors have not observed any additional violations of this type. This violation is closed.

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(Closed)UnresolvedItem 382/8934.02:

Determination of whether or not a Technical Specification violation occurred and to evaluate the adequacy of the licensee's corrective actions after discovery by the licensee that CFC C was running backwards in slow speed. The licensea reported this incident in Licensee Event Report (LER; 382/89-070, dated November 20, 1989. A Technical j

Specification violation did not occur because the alternate fan (CFCA)onthatredundancytrainhadbeenavailable. CFC A was also satisfectorily verified operable when it was surveillance tested after the problem with CFC C was corrected. The work package that originally replaced CFC C in October 1988 did not specify an adequate retest to assure proper rotation in slow speed.

Proper fan rotation was checked (in f ast speed only) in October 1988 in accordance with the licensee's Electrical Maintenance Procedure ME-007-006 "480 VAC or Less Squirrel Cage Induction Motors. " The inspectors reviewed the requirements for rotational testing in this procedure and found no guidance to ensure that both slow speed and fast speed windings would be tested. Consequently, CFC C was assumed operable in slow speed from October 31, 1988, until October 19, 1989, when the licensee found the fan wired to rotate backwards in slow speed.

During a System Entry and Retest Team (SERT) inspection conducted during the period October 30 through November 3,1989, the team expressed concern that the licensee's postmaintenance testing program i

lacked specificity in testing requirements and acceptance criteria.

l The above incident appeared to be the result of such a weakness. The team reported that the licensee was working on a procedure which, when completed, would address all facets of postmaintenance testing.

See NRC Inspection Report 50-382/89-29.

L The inspectors followed up to detennine the status of such a

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procedure and found that no work had been done, but that the task l

had been authorized. After discussing this issue with licensee

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management, the weakness was acknowledged, but the actions to strengthen the postmaintenance testing area had not yet been clearly defined.

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The licensee's failure to provide adequate retest requirements to demonstrate that CFC C would function satisfactorily when called upon

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to perfom its intended safety function was a violation of NRC

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regulations (382/9004-03). This item is closed.

8.

Licensee Event Report (LER) Followup (92700. 92712)

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 the LER foms were complete. The inspectors confirmed

that unreviewed safety questions and violations of Technical

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Specifications, license conditions, or other regulatory requirements had

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been adequately described.

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-a.

(Closed)LER 382/88-025. " Fire Barrier Discrepancies Due to Procedural Inadequacy."

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r b.

(Closed) LER 382/88-026. " Tubing and Supports Not Seismically

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E Oualified Due to Personnel Error." This LER was discussed in NRC Inspection Report 50-382/89-23, dated September 27, 1989. The LER T

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was left open pending implenentation of the licensee's upgraded

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10 CFR 50.59 program, in accordance with N0P-013,10 CFR 50.59,

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" Safety and Environnental Impact Evaluations." The inspectors noted that N0P-013 was implemented in January 1,1990, as comitted in Revision 1 to the LER. The program appeared to meet or exceed the intent of 10 CFR 50.59. The inspectors noted that the licensee completed much of the employee training on this process and allows

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only those trained in N0P-013 to perfom safety screenings and

!

evaluations pursuant to 10 CFR 50.59. This LER is closed.

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c.

(Closed)LER 382/89-007, " Inadequate Design of Air Accumulators Due to Incomplete Review of Post TMI Action Plan."

No violations or deviations were identified.

9.

Exit Interview The inspection scope and findings were sumarized on March 1,1990, with those persons indicated in paragraph 1 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 inspection.

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