IR 05000382/1993023

Insp Rept 50-382/93-23 on 930627-0807.Violations Noted.Major Areas Inspected:Plant Status,Operational Safety Verification,Maint & Surveillance Observations & Followup on Corrective Actions for Previously Identified Items

ML20057A584
Person / Time
Site:	Waterford
Issue date:	09/08/1993
From:	Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20057A583	List: IR 05000382/1993023 ML20057A582
References
50-382-93-23, NUDOCS 9309150009
Download: ML20057A584 (12)

Text

APPENDIX A U.S. NUCLEAR REGULATORY COMMISSION l

REGION IV

Inspection Report: 50-382/93-23 l Operating License: NPF-38

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Licensee: Entergy Operations, Incorporated l P.O. Box B Killona, Louisiana 70066 Facility Name: Waterford Steam Electric Station, Unit 3 (Waterford 3)

Inspection At: Taft, Louisiana

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Inspection Conducted: June 27 through August 7, 1993  :

Inspectors: E. J. Ford, Senior Resident Inspector J. L. D on-Herrity, Resident Inspector Approved: _  ?

omafF Stetka, Chief Project (54ction D 7fN Dats 4 Inspection Summary Areas Inspected: Routine, unannounced inspection of plant status, operational safety verification, maintenance and surveillance observations, and followup on corrective actions for previously identified items.

Results: ,

• The use of adhesive-backed wrap mounts to secure high radiation and housekeeping zone temporary barriers was identified as a poor health physics practice. The licensee reacted in a timely manner and effectively addressed the poor practice (Section 2.1.1).

• The licensee identified that inadeque!e procedures resulted in the wrong component being worked under an approved work authorization packag (Sections 2.1.1). This was a noncited violation.

• The licensee identified that inadequate procedures resulted in failure to re-engage the limiter on the letdown heat exchanger temperature control valve; however, subsequent review by the inspectors resulted in concerns regarding work planning and postmaintenance testing. This is an unresolved item pending further inspector review of procedures and j work instructions related to the event (Section 2.3). 1

• Control room operators reacted quickly and effectively in response to a ;

heater drain pump trip (Section 2.1.2).

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• The licensee was pro-active and thorough in planning the letdcwn neat i exchanger repair and governor valve interface card replacement. Good communication among the different departments was observed during these evolutions (Sections 2.3 and 3.4). l l

• Alert plant personnel identified a fuse with an incorrect rating while l removing clearances (Section 3.1), and a crack in a charging pump block (Section 3.2).

Summary of Inspection Findings:

A noncited violation was identified (Section 2.1.1). .

• Unresolved Item 382/9323-01 was opened (Section 2.3)

• Inspection Followup Item 382/9203-07 was closed (Section 5.1).

Attachment:

• Attachment - Persons Contacted and Exit Meeting

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DETAILS 1 PLANT STATUS )

The plant was operating at full power from the beginning of the inspection j period until July 4, 1993, when power was reduced to 91 percent in response to i an extraction steam valve to the No. I feedwater heater going closed. The i plant returned to full power the same day after troubleshooting the problem ,

and operated until July 22, when they reduced power to 84 percent to allow for i the replacement of a malfunctioning interface card for the No. 2 turbine .

governor valve. The work could not be completed due to unexpected control  ;

system behavior. Power was returned to 100 percent while the licensee l evaluated the situation. Power was decreased to 92 percent the following day, j July 23, to do surveillance testing on the main turbine steam inlet valves and i replacement of the interface card. The plant remained at 100 percent power i until July 28, when power was slightly decreased while letdown was isolated to .

repair leaks in the letdown heat exchanger. Power was increased to t 100 percent following the repair on July 29 and remained there the rest of the l report perio ;

2 OPERATIONAL SAFETY VERIFICATION (71707)

The objectives of this inspection were to ensure that the facility was being operated safely, in conformance with regulatory requirements, and to ensure  :

that the licensee's management controls were effectively discharging the  !

licensee's responsibilities for continued safe operatio .)

2.1 Plant Tours  !

2. Tour of Fuel Handling Building and Wing Area On June 30, 1993, during a tour of fuel handling building and the -4-foot and -35-foot levels of the reactor auxiliary building wing area, the ~

inspectors found two health physics temporary barriers down in the fuel handling building. One was a housekeeping-zone rope around the fuel storage pool and the other a high radiation area barrier rope on the -35-foot level.

l In both cases, the reason appeared to be failure of the small adhesive-backed wrap mount that was glued to the wall. Even without the temporary barrier, i l

the high radiation area had sufficient other physical barriers and adequate 1

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posting to prevent entry without the individual being aware of the high I radiation designation. The inspectors informed the health physics technician on duty and the temporary barriers were promptly restore The next day, the licensee reposted the area using stanchions to hold the rope in lieu of the adhesive-backed wrap mount. In addition,=the use of I adhesive-backed wrap mounts was reviewed and new guidelines developed. The l new guidelines directed that the adhesive mounts were not to be used for high  ;

radiation areas where stanchions could be used and specified a glue in lieu of  ;

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the adhesive backing where stanchions were not feasible. The inspectors

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l -4-concluded that the corrective actions would be effective and that the problem was not representative of the licensee's improved posting program.

! During the shoe tour of June 30, 1993, the inspectors observed that a leak l l containment device installed on an overhead valve (later identified as l l BD 1041B, a manual isolation valve in one of two blowdown pressure instrument I l lines from Steam Generator 2) on the east side of the -4-foot level of the i wing area was ineffective in containing the steam condensate, and reported the condition to the control room. On a subsequent tour of that space on July 7,

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the inspectors noted that the leak had been repaired and observed technicians ,

inspecting the repaired valve and measuring an adjacent valve to prepare a

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l l clamp for it as part of its leak repai On August 4 the inspectors noted that Condition Report 93-103 had been written l with respect to the repair of valve BD-10418. Further research into the work authorization (WA) package and discussion with the mechanical maintenance l supervisor revealed that WA 01106756, written to repair BD-1041B, actually -

resulted in repairs being made to Valve BD-1042B (the manual isolation valve in the other blowdown pressure instrument line from Steam Generator 2) on l June 11, 1993. Maintenance technicians proceeding under WA 01106755 (written to repair a leak on BD-1042B) discovered the error when they saw the clamp on the wrong valve as they went to repair the leak observed by the inspectors on i June 30. The condition report was written and the packages were corrected.

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The corrective actions planned included briefing maintenance personnel on the incident and evaluating procedural requirement Both valves were located adjacent to one another in the overhead in the east ;

side of the -4-foot level in the wing area, but Valve BD-1042B did not have an identification tag (presumably blown off by the steam). Both valves had a history of leaking, BD-1041B being the worst. On June 11 the maintenance supervisor indicated to the technicians that the job was to fix a badly leaking steam valve. They made an error in assuming that the valve was BD-1041B because it was leaking and had no identification tag that could be checked. There was no requirement in the work package or procedures for them to verify that they were working on the correct equipment; further, it i represented a failure to perform a proper self-check as embodied in the l licensee's Stop-Think-Act-Review (STAR) program promulgated by management l directive. This was a violation of Technical Specification 6.8.1 but was !

licensee identified and had minor safety significance. Therefore, this will !

be an noncited violation having satisfied the criteria specified in l Paragraph VII.B.2 of Appendix C to 10 CFR Part 2 of the NRC " Rules of Practice."

2.1.2 Housekeeping i On June 30, 1993, the inspectors observed improved housekeepiag over previous I tours in the area outside of the hot tool room on the +21-foot level in the i l wing are ,

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l l-5-During maintenance on the A charging pump on July 20, the inspectors evaluated the housekeeping in the area as marginally acceptable. The inspectors  !

discussed with the mechanical maintenance superintendent the licensee's expectations regarding housekeeping in the area with work in-progress. The  ;

work site met the expectations he describe ;

2. Loss of the A Heater Drain Pump i

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On July 2,1993, the inspectors were in the control room when the A heater

drain pump tripped. Operators responded promptly to control the resulting i

transient and were effective in limiting the severity of the transient. The pump tripped as a result of excessive spray into the pump motor from a leak in  ;

the turbine cooling water line going into the pump. The leak had been

i previously identified on June 30 and was scheduled for repair on July 10 to l coincide with a power reduction for main turbine testing. However,.the leak i degraded more rapidly than anticipated such that the containment device could l not prevent the spray from entering the pump moto l

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2.2 Loss of Extraction Steam to No. 1 Heater j i

l On July 4, 1993, the control room operators observed an unplanned reactor  ;

! power increase and immediately inserted Regulating Group 6 control element l assemblies, r'_duced turbine load, and briefly borated. During the transient, reactor power peaked at 104 percent as indicated on Core Protection Calculator  :

Channel A. Cold leg temperature fell below 5440F for a brief period resulting 1 in entry into Technical Specification Action 3.2.6 until temperature was t restored above 544*F. As plant power was being stabilized at 91 percent, -!

operators noted that the extraction steam to No. I heaters valve was shut and- l that Heater Drain Pump B had tripped on low suction pressur .

Technicians troubleshooting the valve could not identify a problem or li duplicate what had happened. Condition Report 93-099 was written to further investigate the problem and the plant was returned to a full power lineu Inspector followup of the condition report showed indeterminate results. The i mercury switches used for indicating heat exchanger level were among the first j things checked. The licensee concluded that this allowed the transient -

condition to clear, preventing the cause of the event from being identifie I The planned corrective actions were to discuss the event with instrument and  ;

controls personnel to poir.t out that readings on that type of switch should be ;

taken at the nearest electrical junction, and the condition report was to be  ;

discussed at a future reliability improvement team meetin ]

l 2.3 Letdown Heat Exchanger Outage l NRC Inspection Report 50-382/93-19 reported that, following a plant trip on-I June 15, 1993,-the' licensee had become concerned with the activity in the component cooling water (CCW) system, due to a leak in the' letdown heat .

exchanger. Prompted by ALARA concerns and economic considerations, a licensee l

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-6-task force determined that the heat exchanger could be safely repaired while operatin During early job scoping and work planning activities, the licensee discovered that the valve stroke limiting device installed on valve CC-636, the letdown

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heat exchanger temperature control valve, was disengaged. The intent of the device was to limit flow through the heat exchanger to a maximum of 1200 gpm to prevent possible damage to the heat exchanger from excessive flow. This requirement was found in the Final Safety Analysis Report Section 9.3.4.2.2(b). Subsequent investigations by the licensee disclosed that the limiting device had been disengaged or about October 16, 1992, to permit temperature calibrations to be performed and had not been re-engaged. The licensee concluded, in Condition Report 93-091, that the root cause for failing to re-engage the limiting devise was inadequate procedures in that none specifically required the re-engagement of the limiting device following calibrations. One operations and two maintenance procedures were identified as needing revision to correct the inadequacy. The licensee was preparing a final report on the problem to discuss the root cause and identify additional actions to prevent recurrenc In a subsequent review of the events leading to the failure to re-engage the limiter, the inspectors developed concerns regarding the adequacy of work planning, and postmaintenance testing as they affected disengagement and re-engagement of the limiter. The inspectors concluded that further interviews with licensee personnel and additional procedure reviews would be required to close this matter. This shall be tracked as an unresolved item (URI 382/9323-01).

The inspectors attended several work planning meetings and prejob briefings between July 2 and July 27 and observed that both of these activities were thorough and comprehensive. Appropriate contingencies, procedures, and procedure revisions were developed as necessary to suppurt the heat exchanger repair. Additionally, the inrpectors verified that related operational m&tters such as primary plant chemistry, pressurizer level control, plant response to transients (including reactor trip and safety injection actuation), and Technical Specification compliance and operability issues were properly considered as part of the work plannin Letdown was isolated on July 28 and repairs proceeded without complication The licensee identified one severed tube, and after performing eddy-current test on the forty-eight surrounding tubes, identified one additional tube with 42 percent through-wall degradation. The baffle plate was repaired and the two tubes plugge The licensee initiated a condition report to determine the cause of the tube failure, but had not completed their analysis by the end of the inspection period. The licensee planned to evaluate the possible link between the failure to re-engage the valve limiting device and the subsequent tube damag The licensee calculated CCW flow through the heat exchanger at 2100 gpm with two charging pumps running. The licensee was evaluating if the turbulence resulting from the high flow rate caused the baffle plate to come loose and vibrate against the tubes near the CCW entrance point damaging the tubes. The

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licensee had identified similar industry events for which this was the root caus '

2.4 Hurricane Season Preparation  !

As part of an agency wide effort in response to the insights gained from the i NRC analysis of Hurricane Andrew's impact on the Turkey Point site, the  !

inspectors interviewed various members of the licensee staff regarding .

Waterford's preparedness to respond to hurricanes. The inspectors prepared a  !

set of detailed questions with the licensee's responses which was forwarded to ,

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the emergency preparedness specialists in the Region IV office. The  ;

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inspectors noted that, among other actions taken by the licensee to improve t

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their response to hurricanes, they had lowered the wind velocity threshold for declaration of an Alert classification to permit longer lead time to complete l preparatory activities. The inspectors concluded that the licensee appeared i to have adequately considered and addressed the lessons-learned from Hurricane ;

Andrew and was reasonably prepared to respond to hurricane condition ;

2.5 Conclusions Although a poor practice was identified in the licensee's new health physics -

posting program, the licensee reacted in a quick and positive manner to revise .t the practice. A licensee identified noncited violation occurred when the wrong steam generator blowdown instrumentation line valve was repaired using an approved work package. Control room operators were prompt and effective in :

mitigating the consequences of a heater drain pump trip. An unresolved item was opened to followup on questions that remained unanswered at the end of the ,

report period relative to a licensee identified failure of procedures.to ,

require the re-engagement of the valve limiter on the letdown heat exchanger  ;

temperature control valve following a calibration during Refuel Outage 5. The

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licensee was proactive and thorough in planning the letdown heat exchanger repair, and exhibited good intra-departmental communication MONTHLY MAINTENANCE OBSERVATION (62703) )

The station maintenance activities affecting safety-related systems and components listed below were observed hnd documentation reviewed to ascertain that the activities were conducted in accordance with approved WA's, procedures, Technical Specifications, and appropriate industry codes or standard .1 Shield Building Ventilation Unit A Preventive Maintenance On July 15, 1993, a Nuclear Auxiliary Operato? (NAO), while being observed by the inspectors, was removing clearance tags prior to post-maintenance testing i on Shield Building Ventilation Unit A when he noted a discrepancy between the l two fuses installed in the closing circuit. He was unable verify the' correct- l fuse at the scene and went to the control room with the fuses. The inspector i noted that both fuses had a six-amp rating with the'only obvious difference being that one was labelled FRN-R-6 and the other, OT- i l

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-8-The licensee determined the proper fuse to be OT-6 which had a fast-acting !

characteristic. The fuse designated FRN-R-6 was a slow-blow fuse. The inspectors verified through discussions with the electrical maintenance !

supervisor that there had been no degradation in breaker protection while the slow-blow fuse had been installed. The NA0 placed the correct fuses in the ,

circuit and then completed the tagout removal. After proper independent verification of tag removal and system alignment, postmaintenance testing proceeded without incident in accordance with WA 0110506 ,

The licensee prepared a nonconform ace condition identification as required by Administrative Procedure UNT-005-0U , Revision 1, " Fuse Control Program" as i'

well as a condition report to deteraine how the wrong fuse had been installe The inspectors noted that the licensee through its fuse control program was in the process of completing a review of the fuses in all switchgear and motor control centers. A portion of the fuses were reviewed during Refuel Outage 5; ;

however, the shield building ventilation system had not been completed and was ;

scheduled for a future outag '

3.2 Maintenance on Charoino Pump A

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On July 20, 1993, the inspectors cbserved as mechanical maintenance technicians took measurements of the plungers and inspected the block on the A charging pump packing under WA 01111335. One of the technicians observed a

. " scratch" in the suction side of the west cylinder block assembly and notified Quality Assurance; who performed a non-destructive examination, and determined the " scratch" was a crack. From previous research, the licensee had identified that the block material was susceptible to cracking and had procured blocks made of a new material (17-4 Ph stainless steel) and replaced the blocks on Pumps B and AB. The licensee had been monitoring the A pum It was caution-tagged in the control room to alert the operators to the condition and to minimize its use except for essential plant evolution The inspectors reviewed the work authorization (WA 01111506) and Substitute Part Equivalency Evaluation Report 9301127, Revision 0, " Evaluation of Replacement Charging Pump Block" as a part of observing the maintenance to install the new block on Pump A. The inspectors noted the report's conclusion that the minor changes made to the block during the recent procurement did rot effect the pump's form, fit, or functio During the installation, the technicians encountered minor delays due to the nut heads on the seal water galley plugs of the replacement block. They prevented the block from clearing the power frame. (The old blocks, which were made by a different manufacturer, had set-screw plugs, so this had not been a problem.) The licensee contacted the manufacturer and received authorization to shave a quarter inch from the top of the plugs. The inspectors verified that this would not be a problem as the plugs were not strength elements in the pump and would function as designed. The nut heads were shaved in increments until sufficient clearance was achieved to install the bloc A maintenance peer inspector was present and involved during all work related to the block. Quality control also had an inspector observing the work

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intermittently. A technician maintained the paperwork just outside of the contamination area and signed off the package as work was completed. The torque wrenches used were properly calibrated. The internal parts of the pump were carefully wrapped up and labeled as they were removed. The inspectors witnessed good radiation protection practice .3 Cut and Cap High Pressure Safety Injection (HPSI) System Drain Lines On July 20, 1993, the inspectors reviewed the work package and observed a portion of the work done under WA 00993375, which required cutting and capping of HPSI drain lines. The inspectors observed as an elbow was welded onto the :

drain line from the supply line for one of the B train HPSI flow control valves. The inspectors expressed concern regarding the technical

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specification operability of the B train of the HPSI system while work was in-l progress. The inspectors determined through discussion with the licensee and

! verification of the system configuration that the drain valve involved was normally locked closed, so the HPSI system would function as designe The package was part of Design Change 3375, Revision 0, " Cutting and Capping

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of HPSI/LPSI Drain Lines," which addressed a recent problem with leakage from l the safety injection tank The leakage was traced to several drain valves in l the HPSI and low pressure safety injection (LPSI) systems. Many of the drain

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lines were linked to common headers, making it impossible to perform leak checks on main safety injection header valves. The large number of drains ,

increased the number of possible leak paths from the system. The design change required that HPSI and LPSI drain lines be cut and a threaded cap l installe ;

The area where the work took place was roped-off as a contaminated area, and ,

herculite was laid down to further prevent the spread of contamination. A )

fire watch had been set up due to the welding and grinding called for in the i package. All equipment was properly staged at the job sit .4 Governor Valve No. 2 Interface Card Replacement On July 18, 1993, the operators noted that the No. 2 turbine governor valve had closed to approximately 90 percent with the plant at full powe Instrument and controls technicians investigating the problem determined that l the XHC interface card was bad. With the assistance of an offsite contractor, !

the licensee ran a proposed troubleshooting solution through the plant l referenced simulator to determine how the plant might react. Using this 1 method, they determined that the approach would be to reduce power to approximately 92 percent, take the turbine from scquential mode to single valve mode, then to valve test mode so that the interface card was out of the loop, and then to close the valve and change the car The inspectors observed this evolution (Special Test Procedure 01111343) on July 22. The turbine did not react as anticipated, power decreased to 84 percent, and the procedure was terminated. The plant was returned to its initial state of 100 percent power with the governor valve at approximately

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90 percent ope The licensee reassessed the situation and developed a I different strategy. Once again, the procedure was tested on the simulato The plant was to be ma'.ntained at 100 percent power while a small voltage was !

applied downstream of the card. This would force the valve open and electrically lock it in that state while the card was replaced. The inspectors observed when this method, using procedure STP-Ollll343A, was !

completed successfully on July 23. A 10 CFR 50.59 screening was done for both test procedures and they were reviewed by the Plant Operations Review Committe It was noted that both evolutions were strictly controlled in

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their conduct by the licensee management and technical staff who provided detailed oversign '

. 3.5 Conclusions Two alert and observant individuals identified equipment problems adverse to quality. An NA0 recognized a discrepancy in the fuses in the closing circuit *

on a breaker and a mechanical maintenance technician noted a scratch in a 1 charging pump block which was later verified to be a crac Good health '

physics and fire protection practices were noted while observing maintenance !

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tasks. The licensee displayed conservatism, thoroughness, and caution in planning a governor valve interface card replacement as well as good communications among the different department 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 Specification , , 4.1 Fuel Handlina Building Ventilation System Operability Check On June 30, 1993, the inspectors observed concluaing portions of the start-up of Fuel Handling Building Emergency Filtration Unit A for Surveillance Procedure OP-903-076, Revision 5, " Fuel Handling Building Ventilation Systems Operability Check." The procedure required running the unit for a minimum of ten hours with the heaters on to verify that it woulo run as required by the Technical Specification. The filter differential pressure was also checke The inspectors reviewed the procedure and the operability check data sheet and noted that the procedure and administrative control requirements were me The inspectors observed the running unit and noted nothing out of the ordinary. The inspectors followed-up the next day and determined that the system had passed the surveillanc .2 ESFAS Start of Emergency Diesel Generator A On July 19, 1993, the inspectors observed the preparations and starting of Emergency Diesel Generator A using System Operating Procedure OP-009-002, Revision 13, " Emergency Diesel Generator," and Surveillance Procedure OP-903-068, Revision 8, " Emergency Diesel Generator and Subgroup Relay Operability Verification." The test was conducted properly and all equipment

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performed within test acceptance criteria. The inspectors noted that the control room operator involved in performing the diesel start was very knowledgeable on the two procedure The system engineer and several maintenance technicians were on hand at the diesel to observe the star While there, they identified a minor jacket water leak in the head area, and initiated a condition identification to repair i .3 Conclusions Routine surveillance activities were properly performed in accordance with 4 procedure ,

5 FOLLOWUP (92701) (Closed) Inspection Followup Item 382/9203-07: Handlina of SI-405A and B Pressure Switch Drift This item was opened to follow up on long-term corrective actions taken by the licensee in response to the setpoint drift detected in the Train A shutdown '

cooling suction valve (SI-405A) hydraulic actuator pressure switch. The inspectors discussed the item with design engineering and reviewed the ,

engineering department memo addressing the actions taken and conclusions  !

reached on this problem. Environmental testing was performed on spare pressure switches obtained from the warehouse. These switches displayed similar setpoint drift. Although the cause could not be identified, the licensee's review concluded that the drift could have been due to system pressure not being applied to the switch for the duration of the tes Another factor that was not considered during the test was the temperature change when the switches were returned to ambient temperature to check the setpoint at the conclusion of the test. The temperature in containment while the plant was operating was approximately 120oF, but was 80of during refueling '

outages when these switches were checked. This temperature difference was identified as a possible factor in the initial drift identifie Because the installed switches on the valves in containment have not demonstrated drift problems since the initial incident, the licensee elected 1 to leave the original switches installed, but continued to monitor the i Several alternatives were planned to address further problems that might l arise. These included preparing a setpoint change and replacing the switche Due to the lack of recurrence of the problem and the contingency plan developed should the problem reoccur, this item was considered close I l

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ATTACHMENT 1 1 PERSONS CONTACTED Licensee Personnel

• A. Crawley, Safety and Fire Protection Specialist

• T. J. Gaudet, Operational Licensing Supervisor

• J. E. Howard, Procurement / Program Engineering Manager

• A. S. Lockhart, Quality Assurance Manager

• B. R. Loetzerich, Senior Licensing Engineer D. E. Harpe, Mechanical Maintenance Superintendent

• D. F. Packer, General Manager, Plant Operations R. G. Pittman, Instrumentation & Controls Maintenance Superintendent

• J. A. Ridgel, Radiation Protection Superintendent

• D. L. Shipman, Planning and Scheduling Manager

• R. S. Starkey, Operations and Maintenance Manager D. W. Vinci, Operations Superintendent

• Denotes personnel that attended the exit meeting. In addition to the above personnel, the inspectors contacted other personnel during this inspection perio .

2 EXIT MEETING ,

An exit meeting was conducted on August 5, 199 During this meeting, the :

inspectors reviewed the scope and findings of the report. The licensee did !

not identify as proprietary any information provided to, or reviewed by, the inspector :

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