IR 05000382/1992027
| ML20128D154 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 01/25/1993 |
| From: | Johnson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20128D091 | List: |
| References | |
| 50-382-92-27, NUDOCS 9302100061 | |
| Download: ML20128D154 (20) | |
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APPENDIX B :
U.S. NUCLEAR REGULATORY COMMISSION I REGION IV I Inspection Report: 50-382/92-27 I
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Operating License: NPF-38 Licensee: Entergy Operations, Incorporated P.O. Box B Killona, Louisiana 70066 facility Name: Waterford Steam Electric Station, Unit 3 (Waterford. 3)
Inspection At: Taft, Louisiana Inspection Conducted: November 29, 1992, through January 9, 1993
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Inspectors: E. J. Ford, Senior Resident Inspector
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J. L. Dixon-Herrity, Resident Inspector W. McNeill, Reactor inspector
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Approved: /M y /h sW 3 killia . Johnson, Chief, Project Section A Date'
Inspection Summary Areas Inspected: Routine, unannounced inspection of operatioral safety
' verification, maintenance and surveillance observations, cold weather preparations, followup on corrective actions for violations and deviations,
, other followup, and followup of licensee event reports (LERs).
Results:
- Most plant and outside areas had good housekeeping throughout the period (Section 2.1 1).
. Housekeeping in front of the diesel generator rooms was in poor condition following the outage. Spilled boric acid presented a slipping
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- Security officers were alert and performing duties and rounds when observed during several late night tours by the inspector (Section 2.1.2).
- Security personnel conservatively removed an extension ladder from the roof of the administration building even though no violation existed (Section 2.1.2).
9302100061 930201 PDR ADOCK 05000382 G PDR
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- Gecd health physics practices were used by chemistry personnel drawing a reactor coolant system sample (Section 2.1.4).
a The maintenance department's painting project has greatly improved the appearance of the east cooling towcr area (Section 2.1.6)
- _ Control Element Assembly 3d wts declared inoperable when problems with the load transfer coil were detected (Section 2.3).
- Plant management and engineering personnel were proactive and timely in their reaction to vendor information regarding azimuthal tilt (Section 2.4).
- Ample personnel, good communications, and procedural adherence were obscrved during_the retest of the static uninterruptible power supply (Section 3.1),
e Calibration of a broad range gas monitor was well-conducted by technicians; however, they failed to properly perform independent verification during the calibratio This was.due to inadequate corrective actions in response tn a previous violation, which resulted in procedures being inadequate regarding the method of independent verification. This resul'od in a violation (Section 3.2).
- Poor communications regarding degraded start times resulted in a diesel generator having a higher than normal starting time for a period of time (Section 4.1).
- The freeze protection program was pr operly implemented, incorporating lessons learned from past problems (Section 5).
- Additional problems identified with the tracking of control room drawings affected by temporary alterations indicated that the licensee had not taken adequate corrective actions in response to a priot violation'(Section 6.2). 4 Summary of Insoection Findinos:
. Violation 382/9227-01 was opened (Sections 3.2 and 6.2).
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Viclation 382/9022-02 was reviewed but not closed (Section 6.1).
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"iolation 382/9201-01 was reviewed but not closed (Section 6.2).
- Inspection Followup Items 382/8632-08, 9008-04, 9103-04, 9130-01, 9203-05,-and Unresolved Item 9217 01 were closed (Section 7).
LERs91-023 and 92-007 were closed (Section 8).
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Attachment:
- Persons Contacted and Exit Meeting i
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-4-pETAILS l 1 PLANT STATUS
J The plant was operated at 100 percent power for the entire inspection perio OlB ATIONAL SAFETY VERIFICATION (71707)
The objectives of this inspection were to ensure that this facility was being operated safely and in conformance with regulatory requirements and to ensure that the licensee's iranagement controls were effectively discharging the licensee's responsibilities for continued safe operatio .1 Plant Tours 2.1.1 Housekeeping Following the Outage At the end of the last report period, the inspector noted that the general housekeeping condition of the +21-foot level of the reactor auxiliary building was poor. In addition to equipment, tools, and scaffolding being temporarily stored in a disorderly manner in the passageways in front of the diesel generator rooms and in the area around the hot tool room, the finor area around the boric acid mixing tank was covered with what appeared to be powdered boric acid which had been spilled. This presented a slipping hazar The inspector discussed tho condition of the area with the control room supervisor. The equipment and scaffolding had been previously discussed at the plan-of-the-day meeting. The passageway was being used to stage the equipment and scaffolding from Refuel Outage 5 for surveying before it was permanently stored. The control room supervisor ensured the inspector that it would all be. moved to the storage location. The inspector revisited the area early in this report period to ensure that the area had been cleaned. The area around the boric ar.id mixing tank had been cleaned. Most of the tools, equipment, and scaffolding had been removed and the survey station had been downsized accordingl . Security On December 9, 1992, the inspector noted that roofers had left an extension ladder on the roof of the administration building during a rain storm. This building is adjacent to the protected area fence exclusion area. It was
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pointed out to the inspector by the security shift supervisor that guards stationed nearby could observe the ladder and that other protective features were also available. Nevertheless, security personnel conservatively elected to remove the ladder shortly thereafter. At various times, including backshifts, during'the inspection period, the inspector noted security officer.s perfonning required rounds and natrols with an appropriate degree of alertnes I
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-5-2.1.3 Scaffolding While touring the turbine building on December 15, 1992, the inspector noted a large number of scaffolds labeled for removal after Refuel Outage 5. The inspector had previously. noted that scaffolding similarly labeled in safety-related areas had been removed toward the end of, or soon after, Refuel Outage On December 22, 1992, the inspector observed personnel dismantling scaffolding in the turbine building. The inspector contacted the plant modification and construction director to find out the reason for the delay in removing the scaffolding from the turbine building. The director indicated that they had approximately 24 scaffolds requiring removal. The delay was caused by a lack of manpower and delays in closing the condition identifications which required the t.caffolding. The scaffolding was being removed as the work schedule allowed, but safety-related jobs requiring scaffolding and their removal took a higher priority. The director indicated that plant procedures provented anyone from using the scaffolding without authorization. The group was tracking the scaffolds and planned to remove them as quickly as their schedule allowed. The inspector continued to monitor the licensee's progress in this are .1.4 Chemistry Sample On December 22, 1992, the inspector observed a system engineer from the chemistry department draw diluted liquid samples from the reactor coolant system through the postaccident sampling system. The engineer was using the applicable technical procedure, CE-003-900, Revision 7, " Operation of the Post Accident Sampling System." The procedure required the manipulation of the post accident sampling system control panel and of valves in the sampling cubicle to draw samples. The system engineer used good health physics practices in performing the procedure. He put on a new pair of gloves each time he entered the sampling cubicle, a radiation controlled area, and
- , operly disposed of them before exiting. He said that, when he was finished, health physics would be contacted to survey the samples and escort him back to the chemistry lab with the .1.5 West Cooling Tower On December 28, 1992, the inspector toured the west cooling tower and noted that, although it was satisfactory from a plant housekeeping standpoint, pigeons were making a mess of the area. The inspector also noted a tarpaulin lying on a catwalk next to the wet cooling tower. The inspector discussed both items with the shift supervisor. Although the possibility of the-tarpaulin being blown into the cooling tower was remote, he had the tarp removed. Repainting the area was planned as part of the plant painting project led by the maintenance department. They intend to scrape the worst areas down to bare metal, repaint, and touch up other area _ . . _ _ . _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ ._ . _ -. __
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2.'. 6 East Cooling Tower i On December 30, 1992, the control room supervisor shw ed the inspector 6n i 1.-shcoed piece of concrete approximately 1 foot long which had come off a j catwalk support in.the east cooling tower. A workmar noted the piece as he was prepating the catwalk surface for painting. To prevent it from falling, j he removed the piece and brought it to the control rwn. A structural
, engineer determined that the piece of concrete that tell of f had been applied i for cosmetic reasons over the plate which supported the catwalk and served no structural purpose. The corrective action would be ta remove the rest of the
, concrete applied over the plate and to paint the olate. The inspector had one of the workmen in the cooling tower point out the set and found the above conclusion to b:: soun ,
l The inspect 0c noted a great im)rovement in the appearancre of the area duc to
- the painting that was ongoing aut cuestinned the use of tarpaulins around the wet cooling tower. A tarpaulin hac been hung under the portion of the catwalk
that was being prepared for painting, block'.ng air from entering part of the
wet cooling tower. The inspector brought this to the attention of the shif t
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supervisor and was informed that both engineering and operations reviewed the 1 area on a daily basis. The engineering review in the work package indicated that the tarpaulin blocked only 12 percent.of the air inlet area for only o cell and that calculations had determined that a 60 percent reduction of the
- air inlet area of both cells would-still allow the wet cooling' tower to reject the design heat load with a 4 percent margin. However, the ambient
- temperature had to remain below 80 f and the barrier could not be left unattended. The shift supervisor indica +.ed that it had been decided that i
three people would have to be at the site when the tarpaulin was hung. The
- inspector visited the tower during a work t,reak and noted that three workmen l were present.
I i Valve Out of Alianment i
On December 1,1992, the licensee discovered a valve out of alignnient which would-have prevented the automatic lineup of an alternate source of cooling
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water to essential service chilled water system Chiller A when the te perature
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of the normal coo' ling water rose above a set temperature. The control room i
notified the NRC in accordance with 10 CFR 50.72 but later retracted the report as essential Chiller 8 was operable and capable of performing the safety functior.. The valve out of alignment was NG-627C. This valve allowed
, instrument air or nitrogen to open Valve ACC-Il2A to supply auxiliary componer.t cooling water to the chiller when component cooling water reached a set M gh_ttmperature. The licensee declared the chiller inoperable until the cause of the problem was found, wrote a notential reportable event report, and completed a valve line-up on all eight of the safety-related accumulators.
- Preliminary investigation into the root cause revealed that Valve NG-627C had -
undergone maintenance during the nutage and was not checked for its alignment after the retest. LER 92-016 was written as required by 10 CFR 50.73 and will
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be reviewed by the inspectors.in a subsequent report.
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-7-2.3 Control Eleme_nt Assembly (CEA) 3Q A telephone conversation was held between the inspectors, other NRC staff, and licensee representatives on December 11, 1992, to address the problem concerning CEA 38 and its history. The problem was first identified on '
November 9, 1992, when instrument.and controls maintenance personnel noticed the card status monitor light illuminated for CEA 38. Subsequent investigar. ion indicateJ the automatic control element drive mechanism (CEDM) timer module card had its upper gripper and motien failure lights illuminated, the presence of approximately -170 volts across the terminals which supply voltage to the load transfer CEDM coll, and an open circuit in the CEA 38 load transfer CEDM coll. A visicorder trace showed that the watchdog tin,er could not be seen on the load transfer coil trace. This condition went away and occurred again on November 18, 1992. The licensee contacted their vendor on November 17, 1992, to obtain recouncmMians. The '
vendor response on December 11, 1992, indicated that the CEDM could still be trippe Based en the veador's input, the licensee considered CEA 38 operabl However, treause the licensee felt that exercising CEA 38 during an upcoming Technical Specification monthly surveillance would be imprudent due to the increased risk of a rod drop and subsequent plant transient, they declared it inoperable and entered Technical Specification Action Statement 3.1.3 l(f).
This part of the action statemtut allows continued operation in Modes 1 and 2 as long as the CEA is not inoperable due to being mechanically bound. If an additional CEA becomes inoperable, this specification would require the plant to be in hot standby in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Should repairs be necessary while in Action Statement 3.1.3.l(f), the diagnosis / repair time would probably exceed the time required to be in hot standby, thus forcing a plant shutdown. The licensee submitted a change request which would modify the Technical Specification and its asse,ciated basis to allow continued plant o)eration for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with more than one full length or part length CEA inoperaale due to an electronic or electrical problem in the CEDM control system provided thct all affected CEAs could be tripped. The licensee asserted that this change recognized the-current industry position that CEA(s) which are not movable but iemain aligned and capable of being tripaed should be considered operable. This proposed Technical Specification clange was under NRC staff review at the end of this inspection perio .4 Monitorina Azimuthal Tilt during Steady State Operation On December 11, 1992, the licensee's vendor informed the engineering staff at Waterford that if steady state azimuthal power tilt was greater thar, 3 percent, compliance with Technical Specification 3.2.3 was not suf ficient to assure that the consequences of an avcnt would be bounded by the safety analysis for every analyzed event. The licensee's Technicai Specifications allowed up to 10 percent a7% thal power tilt at steady state operatian. The vendor suggested that past and present administrative controls be eva;uated to detect any occurrence of a steady state n.imuthal power tilt value greater than 3 percent.
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-8-The inspector reviewed a standing order developed by the operations department requiring the monitoring of azimuthal power tilt on a shiftly basis to confirm that in steady state conditions azimuthal power tilt was less than or equal to 3 percent if a value greater than 3 percent were discovered during this monitorin , a reactor engineer or the operations supervisor would be contacted immediate y for an evaluation. In addition, the standing order recommended that, until clarification or revision of_the Technical Specification could be obtained, the operations department was to comply with Action b.2 of Technical Specification 3.2.3 when steady state tilt was greater than 3 aercent. The licensee also reviewed past operating history for having poIsialy exceeded 3 percent and determined that this had not occurre .5 Chargino,_ oymn Op_erability
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On Decerber 22, 1992, the inspector asked if Charging Pump A could be considered operable with the controls not functioning correctly in the control room. At the beginning of the inspection period, the TX relay did not perform correctly, preventing Charging Pump A from being shut off from the control room. This problem ceased and could not be duplicated. The LX relay failed soon after and was still inoperable on December 22, 199 It caused the pump to start when the control was placed in automatic, whether or not a start signal was presen The Technical Specification definition of o)erable includes a requirement that controls for the piece of equipment be capa)le of performing their support function. The question of the Charging Pump A being operable without the relays working properly was raised with the licensee and the Office of Nuclear Reactor Regulation. The licensee asserted that the pump was oaerable because it could perform all of its safety-related functions without tie affected controls in the control room. The Office of Nuclear Reactor Regulation agreed that only thow rec'.rols necessary for the pump to perform its safety functions were required for the pump to be considered operabl .7 conclusions
- Most plant and outside areas had good housekeeping throughout the perio * Housekeeping in front nf the diesel generator rooms was in poor general condition when scaffolding and other equipment were temporarily stored there following the outage. Spilled boric acid presented a slipping hazar * Security officers were alert and performing duties and rounds when observed during several late nignt tours by the inspecto * A security supervisor conservatively elected to remove an extension ladder from the roof of the administration building, which was adjacent to the protected area fence exclusion are ,_ _ - --
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. * Good health physics practices were used by chemistry personnel drawing a reactor coolant sy, tem sampl * The maintenance department's painting project has greatly improved the appearance of the east cooling tower area.
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- CEA 38 was declared inoperable when problems with the load transfer coil were detecte * Plant management and engineering personnel were conservative and timely in their reaction to the vendor's information regarding azimuthal til 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 standard .1 Static Unintefruntible Power Supply }3R On December 16, 1992, the inspector observed the retest following corrective maintenance on static uninterruptible power Supply 3MB. The corrective maintenance consisted of troubleshooting, then replacing the frequency detector board and frequency meter. Approximately 11 people were observing or participating in the retest at the power supp11 The operator communicated with the control room prior to and following teach step of the retest that required manipulation of breakers before going on to the next step. The retest was completed successfully and static uninterruptible Power Supply 3MB was put back into service. The inspector reviewed WA 00104186 after the retest was complete. The WA appeared complete, it provided complete instructions for completing the job and retest and had all the necessary signatures. All leads lifted were recorde .2 Q, road Range Gas Monitor B On December 30, 1992, the inspector observed the postmaintenance calibration of Broad Range Gas Monitor B. The licensee had been experiencing problems with the monitors for several we@s in that they would not stay calibrate Instrument and controls personnel determined that the cause involved leaks and the need to replace the ion chamber, lhese acticns were completed on both monitors on the morning of December 30, 1992. Two instrument and controls techniciant completed the calibration. The inspector found that they were very familiar with the monitors, having participated in the troubleshooting and, on previous work, dealing with the monitors and were able to explain what ;
the problem had been. They followed Procedure MI-00*l-504, Revision 3, " Broad Range Gas Detection System Channel Functional Test and Calibration HVCIA5510 A or HVCIA5510 B," step by step, signing off required steps as they proceede In addition to performing the procedure well, they projected a definite !
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interest in their job in that they took the initiative to check out a humidity !
indicator from chemistry to see if humidity could have been a factor in the problem the monitors were havin One concern noted during the procedure was the method the technicians used in independently verifying the system lineup after performing the calibratio ,
The individual verifying the lineup observed the valve being closed but did 1 not check the valvo position himself before signing that he independently J verified their position. The inspector discussed this practice with an instrument and controls supervisor and was informed that the accepted practice i for independent verification would be for the individual verifying the i position to check the position himself, rather than to watch, but that the method used was acceptable. Later, after double checking the method with management, he came back and said the only options were to check the actual position by hand or to use alternate means to check it as described in Administrative Procedure UNT-5-010, Revision 2, " Independent Verification Program." The supervisor wrote Quality Notice QA-93-001 and repeated the independent verification of both broad range Gas Monitors A and D himsel Discussions with the maintenance superintendent indicated that the method of '
independent verification discussed above was the only one he would accept and that the instrument and controls department was the only mainterance department that performed independent verification. Operations Administrative Procedure OP-100-009 Revision ll, " Control of Valves and Breakers," provides the operators, the other group that performs independent verification, with the correct methods for verifying / checking valve positions. UNT-5-010 did not adequately describe acceptable methods of independent verification. The technician who performed the calibration of the broad range gas monitors believed he performed the independent verification on the valves in accordance with the existing procedure The detail required to perform independent verification in accordance with management's expectations did exist in maintenance at one time but was eliminated in response to a previous violation. Attachment I to letter V3P90-0247, dated February 21, 1990, identified corrective actions being taken in response to Violation 382/8941 02. Among theee, Administrative Proceaure MD-1-25, Revision 0, " Independent Verification Program " was deleted and replaced with the site procedure, UNT-5-010. Procedure UNT-5-010 did not contain all of the requirements contained in Procedure MD-1-25. Section of Procedure MD-1-25 contained a requirement for the independent verifier to do more than watch the person performing the task to be verified. This requirement was not added to Procedure UNT-5-010 when Procedure MD-1-25 was eliminated. The elimination of Procedure MD-1-25 without insuring that'a procedure for performing independent verification was included in Procedure UNT-5-010 is an example of a failure to take adequate measures to correct conditions adverse to quality (VIO 9227-01).
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- An ample number of licensee personnel were involved in the retest for the static uninterruptible power suppl * Proper communications and procedural adherence were observed during this rotes * Postmaintenance calibration of a broad range gas monitor was well-conducted by qualified, conscientious technicians; however, they failed to properly perform independent verification during the calibratio * Inadequate corrective actions in response to a previous violation caused procedures to be inadequate regarding the methods of independent verificatio This resulted in a violatio BIMONTHLY 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 licensee's programs and the Technical Srecification .1 fmeraenc_v Diesel Generator and Subgrgyp Relay Operability Verification On December 7, 1992, the licensee found that they had failed to meet the maximum start time requirement on Emergency Diesel Generator A during the performance of Surveillance Procedure OP-903-068, Revision 8, " Emergency Diesel Generator and Subgroup Relay 0)erability Verification." The diesel started in 11.8 seconds compared to t m maximum of 10 seconds required by Technical Specification 4.8.1.1.2. The shift supervisor immediately entered Technical Specification 3.8.1.1. The shift supervisor indicated to the inspector that the plan of action was to complete Surveillance procedure OP-903-066 Revision 6, " Electrical Breaker Alignment Check," as required by the Technical Specification, then to repeat Procedure OP-903-068 with technicians present at the diesel to do-troubleshootin The inspector observed the completion of Procedure OP-903-068 the second time-it was done. The operators followed the surveillance procedure carefull All actions were planned out and discussed prior to performance. Two people timed the startup in the control room while watching the gauges. The diesel
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started in 10.36 seconds, failing to meet the Technical-Specification a second time, in followup on this event, the inspectors found tha- Potential Reportable -
Event.92-042 was issued by control room personnel. . Preliminary information L indicated that the possible cause of the problem was related to the-
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replacement of the turning gear interlock valves (EGA-303A and 304A) during l Refuel Outage-5. These valves were replaced because they f ailed the test that had been established in response to a violation which identified inadequacies
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in the testing performed (NRC Inspection Report-50-382/92-08). Subsequent to i
this replacement, the vendor t. hanged the classification of the component to safety-related. Q-1. The change in classification created a requirement to ;
replace the valves. A 30-day surveillance test was performed on the emergency ,
diesels following the installation. The start time.of the diesel dering the surveillance appears to have been a precursor to the current: failure in that ,
the start time was 9.75 seconds. This was within the Technical Specification !
limit of 10.0 seconds but significantly longer than the nominal.6 seconds, i'
This was noted by operators but, due to an apparent failure to communicate,-no further action was taken. The licensee is evaluat!ng corrective actions .to i preclude a recurrenc Troubleshooting after the diesel failed the' surveillance on December 7,-1992, revealed that the interlock valve control brackets were not adjusted correctly, preventing the diesel from receiving full _ starting air.- After adjustment, the diesel passed the surveillance test on December 7,1992. The licensee reported the event as required by Technical Specifications 4.8.1. ;
and 6.9.2 and Regulatory Guide 1.108 in Special Report FR-92-003-0 .2 Conclusions ,
e A failure by operators to communicate the noted increase in start time allowed a diesel generator start time to be only marginally satisfactory for a period.of time (due to incorrectly adjusted air supply components).
5 COLD WEATHER PREPARATIONS (71714)
The inspector performed the following activities to verify.that the licensee ,
has implemented a program to protect safety-related systems-against extreme cold weather,
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The inspector verified that a station cold weather. checklist (Operations j Departmental Instruction 01-004-000, " Watch Station and Shift Logs") was utilized by the licensee to ensure that exposed instrumentation and piping was-adequately protected from cold weathe ;
The inspector reviewed Departmental Instruction 01-004-000-and-discussed its contents with operations personnel.- The instruction requires an operator to check susceptible equipment on.a shiftly basis to ensure it. is adequately:
protected. The operators were knowledgeable of-the requirements and were L familiar with where freeze protection measures were applied. . Maintenance a Procedure MC-004-423, Revision 5, " Freeze Prntection-Maintenance," was also reviewed. Its purpose is to provide-instructions for performing maintenance on and rework of the freeze protection s.ystem. The freeze protection-system-
. senses ambient temperature and automatically turns on heater circuits when the temperature falls below 45aF. A system alarm activates if finsulated pipe-
- temperature f alls below 350F. Typical loads for the .systm ocludet fire protection for various' components, . storm drain sump radiat10k racnitors and piping, condensate and .feedwater components and piping, Land circulating water .
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-13-intake and discharge structure equipment. Maintenance personnal demonstrated knowledge and familiarity with the procedure and system in discussions with the inspector, and they had recently inspected and performed the necessary electrical checks of the system. The inspector reviewed the documentation associated with these activitie On several late-night plant and area tours, the inspector verified that tarpaulins used to protect exposed instrumentation and equipment had not torn loose from scaffolding erected for that purpose and that heating devices (where used) were operablo. it was also noted that procedurally required plywood covers for the fire protection pump house and the auxiliary diesel generator building air intakes were staged. Discussions with licensee management regarding previous problems in this area showed that lessons learned from these problems had been appropriately applied. The inspector
' concluded that the licensee had a well-conceived and properly implemented freeze protection progra .1 Conclusions
- The licensee's program for freeze protection appeared to be well thought out and implemented, and it incorporated lessons learned from past problem F01.LOWUP ON CORRECTIVE ACTIONS FOR VIOLATIONS AND DEVIATIONS (92702)
6.1 L0 pen) Violation 382DMLO2: Failure to Provide _ Complete and Accurate Information to the NRC This violation identified an inservice testing program relief request,
, Nu, 3.1.27, made to 10 CFR 50.55.a(g)(5)(iv) requirements in which the licerc.ea had submitted information to the NRC. The basis for the relief regeest failed to consider that main steam atmospheric dump Valves MS-ll6A and MS-1168 could hav.s been isolated to accommodate quarterly cyclin This violation was discussed in NRC Inspection Report 50-382/91-25. Relief Request 3.1.27 was replaced with Clarification 3.2.24 in Change 1 to Revision 7 of the inservice testing program dated September 3, 1991, further review of Clarification 3.2.24 by the NRC indicated that the licensee dia not have sufficient justification for the clarificatio As a result, the licensee committed to delete t.he clarification in Change 2 of Revision 7. The inspector found that this change hart never been submitted. The licensee delayed sut>mitting it until they received the safety evaluation report for Change 1 from the NRC. In that period of time, they decided not 'o resubmit a relief request but to do the test quarterly, The test was comp 1t.ed during Refuel Outage 5 and was scheduled to be dere again in January 199 The-licensee committed to delete the clarification in the next revision to the inservice test program, which is due August 19, 1993. This violation will remain open pending NRC approval of that revisio __ . . _ . __ _ __ . _ _ . _ . . __ __ ___ - . . _ _ _ .
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' (0 pen) Violation 382/9201-01: failure to Control _(hanaes to Drawinas l
- 1 This violation was discussed In NRC Inspection Report 50-382/92-16, dated 1 August 13, 1992. It identified the licensee's failure to control a change to
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4 Drawing LOU-1564-G167, Sheet 1, " Flow Diagram-Safety injection," The drawing ,
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had been revised and filed in the control room without transferring a sticker which indicated that a temporary alteration (No.91-050) affected the drawing.
- The status of the violation remained open pending the licer.see's revision of f Administrative Procedure UNT-005-004, " Temporary Alteration Control," and additional corrective action taken in regard to the failure of an individual to identify document control nonconformance The inspector found that Revision 9 of the procedure had been issued on
. October 23, 1992. In addition, the licensee held training with document l control personnel on the corrective action program and the requirements to i
addrest recurrent problems and root causes. While reviewing the effectiveness of the licensee's corrective actions for this violation, the inspector i identified additional problems in the area of identification of control room
- drawings affected by temporary alteration ~lhe inspector reviewed the temporary alterations identified on the Temporary
- Alteration Affected Drawing List and the applicable control room drawings.
i The list indicated that there were 11 alterations outstandiag on 9 drawings.
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On December 11, 1992, the inspectors found that there were 4 errors .he document control of the control room drawings. Drawing LOV-1564-G-16r had a temporary alteration tag with a transcription error in its number (91-011 instead of 92-011). Drawings LOU-1564-G-160 and -172 had temporary alteration tags and were not listed in the Temporary Alteration Affected Drawing list.
< The temporary alterations, No.92-023. for a mechanical gag of Valve ACC-127B i and No.92-007 for a leak collection device for Valve RC-104, had been restored on November 12 and March 12, 1992, respectively. Drawing
. LOU-1564-G-853 was listed on the Temporary Alterations Affected Drawing list
, with alteration No.92-019 for a temporary heating and ventilatio1 alteration
- to the fuel handling buildir.g, although this alteration had been restored on
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December 1, 1992, i
Attachment I to the licensee's letter, W3F192-0125, dated March 11, 1992, issued in response to Violation 50-382/9201-01, stated that, as corrective actions, olant engineering generated a list of all controlled drawings
. affected )y the installation of temporary alterations. The list was to be
, updated each time a temporary alteration was installed or= removed, in addition, Attachment I stated that. Procedure UNT-005-004 was to be revised to include _ guidance on the administrative aspects of temporary alteration
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controls.
, The licensee's corrective actions taken in response to Violation 382/9201-01
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were inadequate in that the . list of all affected controlled drawings was not updated each time a temporary alteration was installed or removed. The failure of the corrective actions taken in response to Violation 382/9201-01
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-15-to prevent the errors identified above is an example of a failure to take adequate measures to correct conditions adverse to quality (VIO 9227-01).
) After the inspectors made the above observations, the licensee informed the
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inspectors that an audit of the control room drawings had been performed on November 12, 1992. The report of this audit was issued December 17, 1992, identifying three problems. One of these problems was similar to the inspectors' observation on December 11, 1992, but with different examples involving closed temporary alterations not being properly updated on thi ,
drawing list. A quality notice was issued on December 15, 199 j l
i 7 FOLLOWUP (92701)
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7.1 1 Closed) Inspection followup Item 382/8632-008: File Diset.cfancies for Conax Flectrical Penetration Assemfilies
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l During the NRC equipment qualification inspection, file EEQD 15.1 was reviewed j for Conax Model 7320 (10,000 series) penetrations and three concerns wera l identifie The first of the three concerns related to main steam line peak '
temperature analysis was addressed in NRC Inspection Re) ort 50-382/89-39 and was closed by including a report which supports the peat temperature analysis i for the main steam line break conditions in the file. The second and third concerns were related to the licensee response to NRC Information Notice 84-47 and were addressed in NRC Inspection Report 50-382/90-16. The licensee included in the file an analysis with respect to the notice in question, which responded to the :econd and third concerns. The analysis documented the plant
specific functional performance requirements and how they were satisfied.
- However, some additional information was requested at that time by the i inspectors related to the temperature that the connectors would experience during accident conditions. The sdditional information was addressed by the inclusion of a test report, IPS-380, in the file, which demonstrated that the temperature at the connectors had been envelope .2 (Closed) Inspection followup item 382/9008-04
- Verificatjsat of the
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implementation of the Licensee's Program for the Routine inspection of
' Safety-Related Doors This item identified that the licensee had not fully established and implemented a program for regular inspection of safety-related doors. 1he
- licensee established a program for inspection of safety-related doors and documented it in Maintenance Procedure MM-006-106, " Plant Door / Plant Door Equipment Maintenance." The scope and frequency of inspections were defined in the preventive maintenance program. The licensee has established 45 doors that function in a safety-related manner (e.g. airtight, flood, tornado, or containment doors). The inspectors found that these doors were in the preventive maintenance program and were being regularly inspected.
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C Inspection Followup item 3C2/9103-04: _yerification of the Corrected Label Plates for ihree Relays This item addressed the corrective action identified in Problem Evaluation /Information Request 61613 to correct the label plates on Relays CSEREL3A-6G, ACCEREL3A-3G, RFREREL3A-9F, and 4KVEREL3A-li This corrective action would complete the action required by Unresolved item 382/9026-03, which was closed in NRC Inspection Report 50-382/91-0 Condition Identification 274188 was written to document this nonconformance and the associated corrective action was identified in Work Authorization 01074609. The inspectors verified the correct labels by direct observation of the relays in questio .4 (Closed) Inspection Followup _ Liem 382/9130-01: Replacement of Steam Generator Water level Transmitte G This item identified that the licensee planr.ed to replace eight Rosemount
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transmitter , Nos. SG-1113A through -D, and SG-ll23A through -D. Following consultation with the transmitter vendor, the existing transmitters were calibrated beyond their normal range but were nevertheless operable. The long-term corrective action was to replace the transmitter During Refuel Outage 5, til eight of the steam generator water level transmitters, Rosemount Model 1153DA4, were replaced with Model 1154N024. The replacement effort was in accordance with Design Change 3307. The inspectors found the design change to be completed in regard to these eight transmitter The licensee reviewed this problem for 10 CFR Part 21 reportability and concluded that this condition was not reportable because there was no impact on safety since the transmitters would function to meet the Technical Specification required operation .5 JClosed) Inspection Followup Item 382/9203-05: Core Operatinq. Limit Supervisory System Marqin Adjustment Resolution On February 21, 1992, the licensee identified a potential nonconservatism with regard to departure from nucleate boiling ratio and peak linear heat generation rate operat ng margins due to tempereture instrument uncertaintie This was discovered by the vendor during a scoping analysis while performing a verification of statistical uncertainties in support of developing a modified combination of statistical uncertainties for core opedting limit _ supervisory system and core protection-calculations. that were to be used following Refuel Outage The licensee promptly and conservatively incorporated the higher uncertainty for the remainder of the current fuel cycle until the issue was resolved by the vendor. This item was opened to track the final resolution.
! A letter from the vendor dated September 25, 1992, concluded that the original l
Cycle 5 setpoint analysis remained bounding and that the original method for monitoring compliance with the minimum flow value in Technical (
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-17-Specification 3.2.5 provided a conservativaly large allowance for core operating limit supervisory system reactor coolant system flow uncertaint .6 _(_ Closed) Unresolved item 382/9217-01: Plastic Bao inadvertently Dropped into Basin of Wet Cooling Tower A During Chemical Addition On July 14, 1992, a plastic bag was dropped into the basin of Wet Cooling Tower A. The licensee reacted by declaring auxiliary component cooling water Train A inoperable, entering Technical Specification 3.7.3, and contract;ng a commercial diver to retrieve the bag and any other debris in the basin. The licensee exited the Technical Specification following the cleanup but did not resolve the question of whether or not the present auxiliary component cooling water basin and suction piping configuration affords sufficient protection from foreign material fouling of the pump Drawing LOV-1564G-185 showed the end of the pump's suction cipe to be approximately 1 inch below the 9-inch boxed edge and centered on the vortex eliminator which is designed to reduce the creation of a vortex when the pump is running. The intrusion of objects larger than 78.5 square inches is unlikely because the opening at the pipe sucticn is only one quarter of the total pipe cross-sectional area due to the vortex eliminator that cross bisects the opening and faces downward to the bottom of the basi In addition, large objects with negative buoyancy would tend to settle to the bottom. The licensee performed a detailed analysis to study the impact of the intrusion of objects with a ncutral buoyancy. This report, " Impact on Core Damage Probability of Debris in a Wet Cooling Tower Basin," determined that
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the safety impact of this type of debris is negligibl Based on a review of the system and the results of the licensee's study, it was determined that the current auxiliary component cooling water basin and suction configuration affords sufficient protection from fouling by large objects with negative buoyancy and that the impact on core damage probability due to fouling by large or small objects with _ neutral buoyacy is negligibl The licensee is considering the following actions to prevent inadvertent dropping of material in the basin while dispensing chemicals: the use of liquid chemicals that coulu be injected remotely or the use of a portable enclosed chute with a screen if dry chemicals are use ONSITE REVIEW 0F 1.ERs (92700) (Closed) LER 382/91-023: Valve Out of Position Due to inadeqqale, Position Indication labelinq On December 20, 1991,_the licensee discovered that Valve CC-304A was mispositioned such that component cooling water system Loops A and B were cross-connected. The cross connection defeated the two redundant and separate trains design of the design basis. The licensee identified that the root cause of this event was inadequate labeling of position on the valve in l
question. In addition, it was noted that operators failed to follow l
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-18-Procedure OP-100-009, in regard to documentation of the discovery of mispositioned valve The corrective actions were to inspect all butterfly valves of this type in the component cooling water and chilled water systems for sufficient valve position labeling. In addition, all valves that, if mispositioned,-could cross-connect two safety trains were inspected for adequate posittori labelin The corrective actions also included counseling the personnel involved in accordance with the improving Human Performance Program and training on Procedure OP-100-009 for the operator The licensee inspected the 215 ac m sible valves in the component cooling water and r. hilled water systems immediately, and 15 that were inaccessible during Refuel Outage 5. New labels were applied to 58 valves. The licensee immediately inspected 70 accessible valves thht would cross-connect safety trains and 2 inaccessible valves during Refuel Outage 5. New labels were applied to two valves. The inspectors reviewed the flow diagram of the component cooling water and chilled water systems and verified that the scope of the inspection by the licensee was correct and complet In regard to the additional corrective actions, records documented training on the procedure and the inclusion of the event in the Improving Human Performance Program. An analysis, Design Calculation EC-M92-002, was completed March 6, 1992, which supported the conclusions in the LER on the safety significance of this even Based on the above documentation reviews and inspection results, it was determined that the licensee has implemented appropriate corrective actions to address the identified even .2 (Closed) LER 382/92-007: Liquid Radiation Monitor Hiah Alarm Setpoint incorrect Due to Personnel Error On July 17, 1992, the licensee discovered that a radiation monitor set)oint was nonconservatively set 10 iimes too high due to iersonnel error. T ie health physics computer was out of service, requiring that manual calculations be made. A transposition error in the mantissa and a transfer error in the exponent were made on the setpoint in question. These errors were identified during the review process. However, the reviewer did not assure the correction of both errors. As a result, only the mantissa was correcte The licensee identified that the root cause of this event was personnel error and established temporary requirements for supervisory oversight of manual calculations. In the review of the other manual calculations performed at the
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time the health physics computer was out of service, five other errors were-identified, but these were conservativ The corrective actions were to revise _ health physics Procedures HP-001-231 and -235 to incorporate human factors to minimize error The licensee also stated that the individuals involved were counseled on the importance of self-checks and reviews. The .
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- inspectors reviewed records to ensure this event was included in the Improving l
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e-19-Human Performance Progra The inspectors reviewed the revised Procedures HP-001-23), Revision 5, and HP-001-235, Revision 10, and found that human factors had been incorporated into the calculation sheet in that the need to transfer numbers had been reduce Based on the abave documentation reviews, it was determined that the licensee implemented appropriate corrective actions to address the identified even _ _ _ . , _ _ _ .
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ATTACHMENT 1 PERSONS CONTACTED Licensee Personnel
- G. Azzarello, Director, Design Engineering
- P. Barkhurst, Vice President. Operations R. E. Allen, Security and General Support Manager R. F. Burski, Director, Nuclear Safety
- T. J. Gaudet, Operational Licensing Supervisor J. G. Hoffpauir, Maintenance Superintendent L. W. Laughlin, Licensing Manager
- i R. Leonard, Technical Services Manager
- A. S. Lockhart, Quality Assurance Manager D. E. Harpe Mechanical Maintenance Superintendent
- D. F. Packer, General Manager, Plant Operations R. D. Peters, Electrical Maintenance Superintendent R. G. Pittman, Instrumentation & Controls Maintenance Superintendent J. A. Ridgel, Radiation Protection Superintendent
- R. S. Starkey, Operations and Maintenance Manager D. W. Vinci, Operations Superintendent 1.2 ILRC Personnel
- D M. Garcia, Reactor Engineer
- Denotes personnel that attended the exit meeting. In addition to the above personnel, the inspectors contacted other personnel during this inspection perio EXIT MEETING The inspection scope and findings were summarized on January 13, 1993, with those persons indicated in paragraph 1 above. The licensee acknowledged the inspectors' findings. The licensee did not id- tify as proprietary any of the material provided to, or reviewed by, the inspectors during this inspection, t 1