IR 05000382/1998009
| ML20236P247 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 07/10/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20236P237 | List: |
| References | |
| 50-382-98-09, 50-382-98-9, NUDOCS 9807160218 | |
| Download: ML20236P247 (19) | |
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ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.:
50-382 License No.:
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Report No.:
50-382/98-09 Licensee:
Entergy Operations, Inc.
Facility:
Waterford Steam Electric Station, Unit 3 Location:
Hwy.18 Killona, Louisiana Dates:
May 3 through June 13,1998 Inspectors:
T. R. Farnholtz, Senior Resident inspector J. M. Keeton, Resident inspector G. A. Pick, Senior Project Engineer Approved By:
P. H. Harrell, Chief, Project Branch D ATTACHMENT:
Supplemental Information 9807160218 980710 PDR ADOCK 05000382 G
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EXECUTIVE SUMMARY Waterford Steam Electric Station, Unit 3 NRC Inspection Report 50-382/98-09 This routine, announced inspection included aspects of operations, maintenance, engineering, and plant support activities. The report covers a 6-week period of resident inspection.
Doerations
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A weakness was identified in the decision making process when a spent resin transfer
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pump casing drain valve was not replaced at the time it was identified as the cause of a contaminated spent resin spillin December 1997. As a result of this decision, a second spent resin spill occurred during the next attempt to transfer resin. The cause of the i
second spill was identified as being the same as the first, which was a cracked open casing drain valve. The licensee replaced the installed globe valve with a ball valve. No root cause identified for how the casing drain valve opened.
A Technical Specification (TS) 6.8.1 violation for the failure to declare Emergency Diesel
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Generator (EDG) A inoperable occurred because the operators failed to recognize that sources of missiles other than from tornadoes should have been considered when removing a missile barrier door protecting the EDG A diesel fuel oil feed tank (Section O1.3).
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control element assembly (CEA) were as expected. Good command and control l
techniques were employed and plant power changes were performed in accordance with
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approved procedures. The efforts to recover the CEA were very good. The CEA
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dropped when a power switch failure occurred and control power fuses blew (Section O1.4).
Implementation of ongoing emergency operating procedure (EOP) training was very
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l good during the upgrade to dual volumn EDPs. The methodology used for the training
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was sound, and continuous interaction between operators and instructors was observed l
(Section 05.1).
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i Maintenance Inattention to details were observed during the conduct of a high-pressure safety
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injection (HPSI) pump surveillance test. A small, active oil leak on the inboard bearing was not identified by licensee personnel upon completion of the test (Section M1.1).
Enoineerino The conduct of a thermal performance test on Wet Cooling Towers (WCT) A and B
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demonstrated that the towers were capable of removing sufficient heat following a design-basis accident. The tests were well planned and coordinated. The corrective actions following an indication of a degraded performance condition on WCT B were
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l appropriate. Engineering determined WCT B remained capable of removing the accident I
heat load and initiated plans to c!ean the WCT during a future maintenance outage.
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An error in the annual mailing in April 1998 of the public information booklets resulted in
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l some residents receiving the booklets that did not require this information and others within the.10-mile emergency planning zone not receiving the booklets. The licensee identified the error and took appropriate corrective action by mailing the appropriate residents the books in May 1998. The licensee implemented process changes to
include future verifications during mailing instead of following mailing.
Contrary to TS 6.8.1.f and the fire protection program, a fire door in the reactor auxiliary
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building (RAB) was observed to be open with no controls in place.
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I Report Details
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Summarv of Plant Status
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The plant operated at essentially 100 percent power from the beginning of this inspection period until May 29,1998, when power was reduced to approximately 68 percent in response to a dropped CEA. The CEA was recovered and power was restored to approximately 100 percent -
later that same day and remained at 100 percent power for the remainder of this inspection period.
l. Operations
Conduct of Operations (71707)
O1.1 General Comments (71707)
The inspectors performed frequent reviews of ongoing plant operations, control room
panel walkdowns, and plant tours. Observed activities were performed in a manner consistent with safe operation of the facility. The inspectors also observed several shift i
turnovers and daily routine shift activities. The shift turnovers were professional and thorough. The inspectors observed operators using self-checking and peer-checking techniques when manipulating plant equipment. Three-way communication was consistently used by operators within the control room and in external communications with equipment operators and maintenance personnel.
O1.2 Review of a Soent Resin Soill Durina Resin Transfer Ooerations a.
Insoection Scoce (71707)
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The inspectors reviewed the licensee's actions following a radiologically contaminated i
spent resin spill, which occurred on May 19,1998. This event was similar to a previous spent resin spill, which occurred on December 26,1997, and is discussed in NRC Inspection Reports 50-382/97-28,50-382/98-04, and 50-382/98-08.
b.
Observations and Findinas While conducting spent resin transfer operations on May 19,1998, personnel stationed at the minus 35-foot level of the RAB noted spent resin collecting in the area of the floor drain of the resin transfer pump room. The system had been operating for approximately 80 minutes before the spill occurred. This room was posted as a locked high radiation area and was being monitored using a remote camera and television monitor. Upon seeing the resin collecting on the floor, personnel monitoring the camera notified the operator at the control panel and the pump was stopped, effectively stopping the spill.
The licensee estimated that approximately 1 cubic foot of resin was spilled onto the floor.
The licensee established a Significant Event Response Team (SERT) to investigate and l
evaluate this event. The resin transfer system and the room containing the spilled resin j
were secured such that no additional resin was spilled and no other parts of the plant were affected. Prior to sending personnel into the room, the SERT determined the two most probable causes of the spill to be either a failed resin transfer pump seal or a pump
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-2-casing drain valve (RWM-1255) failure. The cause of the previous spill (in December 1997) was determined to be resin trapped below the seat of the pump casing drain valve. This valve was verified closed on three separate occasions following the December spill and before the next attempt to transfer spent resin in May 1998. As part of the investigation after the second spill, licensee personnel entered the resin transfer pump room to determine the as-found condition of this valve. Pump Casing Drain Valve RWM-1255 was found to be approximately two turns open. The licensee concluded that this was the cause of the second resin spill. The spilled spent resin was cleaned up and the pump seal was replaced although no evidence of seal failure was identified.
One corrective action was initiated, following the May 1998 resin spill, to replace the original globe valve used in the casing drain valve application with a ball valve. This action had been previously identified following the investigation of the cause of the first resin spillin December 1997, but had not been implemented at that time. Instead, the valve replacement was scheduled to be completed at a later date when the spent resin storage tank had been emptied in order to minimize the radiation exposure to the technicians performing the work.
The inspectors considered the licensee's decision to not replace the casing drain valve with a more appropriate design after the first spent resin spill and before the next resin transfer operation to be a weakness. The cause of the first resin spill was appropriately identified, but positive action to prevent recurrence was delayed and resulted in a second resin spill.
Following completion of corrective actions, the licensee successfully transferred the remaining spent resin to a high integrity container for shipment off site. The resin transfer system performed as expected with no additional concerns identified.
c.
Conclusions A weakness was identified in the decision making process when a spent resin transfer pump casing drain valve was not replaced at the time it was identified as the cause of a contaminated spent resin spill in December 1997. As a result of this decision, a second spent resin spill occurred during the next attempt to transfer resin. The cause of the second spill was identified as being the same as the first, which was a cracked open casing drain valve. The licensee replaced the installed globe valve with a ball valve. No root cause identified for how the casing drain valve opened.
O1.3 Failure to Enter Acorooriate TS Action Statement While Missile Barrier Door Was Bemoved i
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Insoection Scooe The inspectors reviewed the situation, discussed the actions required with the shift operators, and reviewed the followup activities.
b.
Observations and Findincs On May 19,1998, between 6:45 and 7:15 a.m., the missile barrier door (Door 270) to EDG A diesel fuel oil feed tank room was removed for repairs. The EDG was not declared inoperable during this time based on erroneous suppositions that Door 270 was only a missile barrier for tornado-generated missiles. However,10 CFR Part 50, Appendix A, Criterion 4 states, in part, structures, systems, and components important to safety shall be appropriately protected against dynamic effects of missiles, pipe whipping, and discharging fluids. Also, the Final Safety Analysis Report Section 3.5.2, Table 3.5-3, Table 3.5-9a, and Section 3.6A.2.2.a addressed the protection of essential equipment, including the diesel fuel oil feed tank from internally-generated missiles and jet impingement from adjacent main steam, feedwater lines, and moisture separator reheaters.
Administrative Procedure OP-100-014, " Technical Specification and Technical Requirements Compliance," Revision 9, states that, if any system becomes unable to perform its intended safety function due to maintenance, then declare that equipment inoperable and enter the appropriate Technical Specification action. Failure to declare EDG A inoperable and enter the appropriate TS action while the door was removed is a violation of TS 6.8.1 (50-382/9809-01).
The inspectors inquired from the shift superintendent if removal of the door affected EDG operability. He stated that the operations staff had verified that the weather conditions were good and that the EDG would be declared inoperable if a tornado watch,was established. The issue of other sources of missiles was not addressed prior to removal of Door 270.
After the door had been reinstalled, Condition Report 98-0710 was issued to further review the issue of missile protection and develop appropriate guidance.
c.
Conclusion A TS 6.8.1 violation for the failure to declare EDG A inoperable occurred because operators failed to recognize that sources of missiles other than from tornadoes should i
have been considered when removing a missile barrier door protecting the EDG A diesel fuel oil feed tank. The door remained open for 30 minutes.
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01.4 Ooerators Resoonse to a Drocoed CEA a.
Insoection Scoce (71707)
The inspectors observed the conduct of operators in the control room following a dropped CEA event, which occurred on May 29,1998.
b.
Observations and Findinas On May 29,1998, at 9:54 a.m., part length CEA Number 28 fully inserted into the reactor core. This was an unplanned and unexpected occurrence. The operators in the control room took immediate action for a malfunction of a CEA or a Control Element Drive Mechanism Control System (CEDMCS) in accordance with Operations Procedure OP-901-102, "CEA or CEDMCS Malfunction," Revision 2. This procedure provided immediate and subsequent operator actions to be taken in the event a CEA becomes misaligned greater than 19 inches from all other CEAs in the same group.
The operators entered TS 3.1.3.1 and a reactor power reduction was commenced within 15 minutes of the CEA insertion. Power was stabilized at approximately 68 percent, as required by Core Operating Limits Report Figure 3 " Required Power Reduction After Single CEA Deviation." This figure required that reactor power be reduced a minimum of 30 percent within 60 minutes following a dropped CEA event.
At 10:45 a.m., the licensee entered TS 3.2.3 for azimuthal power tilt due to exceeding the core protection calculators tilt allowance. Azimuthal power tilt was verified to be within the core operating limit of s 0.03 as required by TS 3.2.3. AM!c.; Statement b.2. At 10:53 a.m., CEA Number 28 was declared inoperable. At 11:54 a.m., a 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> action to shutdown the plant to Hot Standby (Mode 3) was entered in accordance with TS 3.1.3.1.
A 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> notification to the NRC was made regarding the entry into a TS-required shutdown action.
A failed power switch and a blown control power fuse associated with CEA Subgroup Number 7 was identified as the cause of the dropped assembly. During subsequent troubleshooting efforts, a second blown control power fuse associated with Subgroup Number 12 was identified. These control power fuses were considered to be backup containment penetration overcurrent protection devices, which required entering TS 3.8.4.1 for containment penetration conductor overcurrent protective devices. The power switch and the control power fuses were replaced and TS 3.8.4.1 was exited.
At 2:11 p.m., the licensee commenced recovery of CEA Number 28. By 2:41 p.m., the CEA was realigned with the other part length CEAs in that group. At 2:59 p.m., CEA Number 28 was declared operable and TS 3.1.3.1 was exited. Reactor power remained at approximately 68 percent throughout these activities. Following recovery of CEA Number 28, reactor power was returned to approximately 100 percent.
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5-The inspectors observed the conduct of the operators in the control room throughout these events. The operators maintained positive command and control of the plant
during the event. In general, three-way communications were used consistently between operators. Peer-checking and self-checking techniques were employed. Appropriate management oversight was provided. Plant power changes were conducted in accordance with approved procedures. Recovery efforts for the dropped CEA were effective with no concerns identified. In addition, no concerns were identified concerning the ability of any CEA to trip and fully insert if required to do so. Tne ability to shut down the reactor at any time was not compromised.
c.
Conclusions Actions by the control room operators following an unexpected insertion of a part length CEA were as expected. Good command and control techniques were employed and plant power changes were performed in accordance with approved procedures. The efforts to recover the CEA were very good. The CEA dropped when a power switch failure occurred and the control power fuses blew.
Operator Training and Qualification 05.1 Ooerator Trainino for EOP Uoorade a.
Insoection Scoce (71707)
The inspectors observed classroom and simulator training in progress to assess the effectiveness of the licensee's efforts to transition to the upgraded EOPs.
b.
Observations and Findinas in November 1996, the Combustion Engineering Owners Group approved CEN-152,
" Emergency Procedure Guidelines," Revision 4. The licensee implemented the EOP Upgrade Program, which had essentially redeveloped the Waterford 3 EOPs. The new EOPs have been developed and the simulator and in-plant verification and validation process has been completed. Operator training on the new EOPs has been ongoing.
The inspectors observed portions of the licensed operator classroom and simulator training using the new EOPs. In the classroom session, the differences between the old EOPs and new EOPs were stressed. The simulator scenarios were developed to focus on those differences. During the training sessions, the inspectors observed a continuous interaction among the operators and instructors. Lessons learned from the previous classes were brought up as part of the discussion. Problem areas were noted for resolution.
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The inspectors found that the methodology used for training was sound and the implementation of training was very good. The new procedures were scheduled to be implemented by June 30,1998.
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Conclusions Implementation of ongoing EOP training was very good during the updgrade to dual column EOPs. The methodology used for the training was sound and continuous interaction between operators and instructors was observed.
Miscellaneous Operations issues (92901)
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08.1 (Closed) Licensee Event Reoort (LER) 50-382/96-014: Broad Range Toxic Gas Monitors Not Powered From Independent Power Supplies
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The inspectors reviewed this deficiency documented in this LER and in NRC Inspection Report 50-382/96-13, Section E2.1. A noncited violation related to this deficiency had
been issued at that time because the licensee had provided for independent power supplies and reviewed other monitoring systems for similar deficiencies. The inspectors found the corrective actions encompassed the corrective actions specified in the LER; therefore, this LER is administratively closed.
08.2 (Closed) LER 50-382/96-015: Failure to isolate Containment Penetration 20 This event resulted from a failure of licensed operators to recognize that a component cooling water (CCW) system check valve had been credited as a containment isolation valve while performing maintenance on a downstream containment isolation valve. The licensee attributed the root cause to: (1) operator error for failure to recognize that check valves are not allowed to perform as a containment isolation boundary, (2) cluttered CCW system piping and instrumentation diagrams, and (3) failure to ensure the ability to positively isolate an inoperable train from an operable train but rather relied upon a check valve to maintain train separation.
The immediate corrective action included issuing a memorandum from the Operations Manager to all licensed operators to provide specific expectations related to this event, the implementation of TS 3.6.3, and the prohibition for using a check valve to maintain train separation. In addition, system engineering initiated Station Modification Request CC-024 that would modify the temporary chill water supply lines for the containment fan coolers to ensure a positive train separation boundary was maintained.
Long-term corrective actions included revising CCW drawings to provide for ease of interpretation.
In response to this issue, engineering indicated they had scheduled an update to the system piping and instrumentation diagrams, including the CCW system, prior to December 15,1998, which involved removing all Ebasco and Combustion Engineering
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tag numbers. In addition, the licensee indicated that Design Change 3542 would be implemented in Cycle 10 to ensure positive train separation of the temporary chiller supplies to the containment fan coolers.
A noncited violation was previously issued in NRC Inspection Report 50-382/97-11, Section 08.1, for this issue. The inspectors considered the corrective actions appropriate.
11. Maintenance M1 Conduct of Maintenance (61726,62707)
The inspecters observed all or portions of the following maintenance and surveillance activities, as specified by the referenced work authorization (WA) or surveillance procedure number:
WA 01165926 Troubleshoot Controller for Temperature Control
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Valve TC-135 in the Turbine Cooling Water System OP-903-030 Safety injection Pump Operability Verification
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OP-903-068 EDG and Subgroup Relay Operability Verification
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WA 01171338 Troubleshoot and Repair All CEA Problems
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in general, the inspectors considered the conduct of these maintenance and surveillance activities to be acceptable. All activities observed were performed with the work packages and/or test procedures present and in use. The inspectors observed supervisors and managers monitoring the progress of jobs as appropriate. Quality control personnel were present whenever required by procedure.
M1.1 Safety Iniection Pumo Operability Verification Test Obsery31igns a.
IDsoection Scooe (61726)
The inspectors observed the test of the Train A HPSI pump on June 2,1998. This test was conducted in accordance with Procedure OP-903-030.
b.
Observations and Findinas The inspectors observed operations, maintenance, and health physics personnel conduct the operability verification test of the Train A HPSI pump. Good coordination and communications were observed between these groups during the conduct of the test. The test results were within the acceptance criteria and no operability concerns were identified.
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8-During the test run, maintenance technicians took oil samples from the inboard and outboard bearings on both the motor and the pump. A small sample bottle was filled by siphoning oil out of each operating bearing and new oil was used to refill the reservoir.
The two bearings on the pump were equipped with glass bubblers, which were removed, filled with new oil, and replaced following the oil sample being taken. During the time the bubblers seek its proper level following replacement, it is normal to see bubbles emerging from within the glass portion of the reservoir. Following the refilling operation on the HPSI pump inboard bearing, greater than normal bubbling was observed in that bubbler and the oil level dropped more than expected. Maintenance technicians repeated the refilling operation on that bubbler and wiped up some residual oil from around that bearing. The bubbler was observed for several more minutes and no further action was required to be taken.
Upon completion of the test, the HPSI pump was secured and returned to a standby condition. The inspectors remained in the area of the pump after the licensee personnel left the area. The inspectors observed a very small, active leak in the area of the inboUd pump bearing bubbler. The magnitude of the leak was estimated to be approximately one drop every 2 minutes coming from the lower section of the bubbler assembly. No operability concerns were identified, but the inspectors considered the actions of the licensee personnel to leave the pump with an active leak on the bearing to demonstrate a lack of attention to detail. The inspectors informed the shift superintendent of the oil leak and appropriate actions were taken to correct the condition.
I In addition, the inspectors observed that a rag, used to wipe oil from the area of the HPSI pump, was left in the area following completion of the test. The concern with this practice was that the rag could potentially interfere with the operation of sump pumps or other equipment in the area. The inspectors considered this to be a second example of a lack of attention to detail during the conduct of this test.
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Conclusions Inattention to details were observed during the conduct of a HPSI pump surveillance test in that a small, active oil leak on the inboard bearing was not identified by licensee
personnel upon completion of the test.
M8 Miscellaneous Maintenance issues (92902)
M8.1 (Closed) Violation 50-382/9624-02: Failure to test safety-related actuating systems.
This violation resulted from failure of the licensee to test the valves as close as
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practicable to the conditions required during an accident. Specifically, the licensee failed
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to test the ability of Valves CC-134A(B) and -135A(B), dry cooling tower inlet, to stroke to their required safety positions using the scfety-related air accumulators. The licensee indicated that stroke testing the valves using the air accumulators and performing a test to determine the bleed off (pressure decrease) of air from the accumulators would be
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performed each outage. Further, the licensee identified additional valves with air accumulators that required similar changes to the test methodology.
The inspectors reviewed Procedure STA-001-005, " Leakage Testing of Air and Nitrogen Accumulators for Safety-Related Valves." The inspectors confirmed that the procedure performed valve stroke testing using the air accumulators and noted that the procedure measured the accumulator pressure decrease. The inspectors verified that the licensee completed testing of the valves during Refueling Outage 8. The inspectors found the corrective actions to be satisfactory.
lit. Engineering E2 Engineering Support of Facilities and Equipment E2.1 Thermal Performance Tests of WCTs A and B a.
Insoection Scoce (37551)
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The inspectors observed portions of the thermal performance tests conducted on WCTs A and B and reviewed the preliminary test results. WCT B was tested on May 8,1998, and WCT A was tested on May 12,1998. The tests were conducted in accordance with Special Test Procedure STP-01168141.
b.
Observations and Findinas During this inspection period, the licensee conducted a thermal performance test on WCTs A and B to measure the ability of the towers to reject design-basis heat loads during a safety-related, design-basis accident. These tests were performed as part of tha licensee's efforts to address the concerns of NRC Generic Letter 89-13, " Service Water System Problems Affecting Safety-Related Equipment." At Waterford 3, the auxiliary component cooling water system serves as the equivalent of a service water system.
i The inspectors reviewed the test procedure, attended prejob briefings, and observed portions of the test in progress. The test was well planned and coordinated between different groups of participants. Operators in the control room demonstrated good awareness of changing plant conditions during the conduct of the test. Test instrumentation installed over the auxiliary component cooling water basin was secured such that the possibility of dropping an instrument into the basin, which could potentially affect operability, was minimized. The inspectors did not identify any concerns with the conduct of the test.
The acceptance criteria as specified in Section 9.0 of Special Test Procedure STP-01168141 was that the WCT thermal performance capability shall be 2102 percent. The preliminary results for WCT A indicated a capability of 111.2 percent.
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-10-i However, the preliminary results for WOT B indicated a capability of 100.4 percent. This was below the stated acceptance criteria and, therefore, resulted in an unsatisfactory test. The licensee evaluated this condition and determined that WCT B would remain operable since the capability was greater that 100 percent including instrument uncertainty. A method of inspecting and cleaning the tower to retum additional capability margin was being developed by the licensee. This work is being planned to be performed during the upcoming refueling outage currently scheduled for February 1999.
Following each test, all temporary instrumentation was removed and the tower retumed to normal operation. The inspectors considered the conduct of this test to be adequate to provide reasonable assurance that WCTs A and B were capable of removing sufficient heat following a design-basis accident. The licensee's actions following an indicated
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performance degradation of WCT B were appropriate. No current operability concerns were identified.
c.
Conclusions The conduct of a thermal performance test on Wet Cooling Towers (WCT) A and B demonstrated that the towers were capable of removing sufficient heat following a design-basis accident. The tests were well planned and coordinated. The corrective
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actions following an indication of a degraded performance condition on WCT B were appropriate. Engineering determined WCT B remained capable of removing the accident heat load and initiated plans to clean the WCT during a future maintenance outage.
E8 Miscellaneous Engineering Issues (92903)
E8.1 (Closed) Violation 50-382/9612-05: Inadequate analysis of WCT basin water as a source of emergency feedwater (EFW).
This violation resulted from a failure of the licensee to analyze the ability of the steam generators to withstand the injection of EFW at temperatures less than 70'F and from a failure to understand that the WCT basins had insufficient inventory to perform the heat removal design function and provide the source for EFW injection. The licensee had determined that TS 3.7.1.3.(b) nonconservatively allowed the use of the WCT basins as the backup to the condensate storage pool.
The licensee attributed the root causes to: (1) failure to consider all accident scenarios during development of the EFW TS, (2) inability to control correspondence and communications with the architect engineer during resolution of the requirements for TS 3.7.1.3.(b), and (3) ineffective design control for coordination of the proper design inputs into design documents.
The licensee immediately verified that operators had never aligned the WCT basin for the suction of the EFW pumps instead of the condensate storage pool. The licensee verified that Procedure W5.602, " Problem Evaluation /Information Requests," provided
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-11 appropriate guidance to resolve technicalissues. The inspectors verified that, as approved in TS Amendment 137, the licensee removed the allowance to connect the EFW suction to the WCT basins and the associated surveillance requirements. The inspectors agreed with the licensee's decision to retain the ability to connect the WCT basin to the EFW suction as specifiad in the EOPs under accident conditions.
The inspectors reviewed the Combustion Engineering evaluation that analyzed the temperature decrease from 70 to 40 F for cold water injection at Hot Standby conditions into the steam generators. The vendor recommended and the licensee increased the allowed number of cold water injection cyc;es from 8 to 20 since the ASME Code allowed up to 25 cycles for emergency conditions such as this. The inspectors found the 10 CFR 50.59 to be appropriate to the circumstances and verified that the licensee changed the affected design documents. The inspectors considered the actions to prevent recurrence appropriate.
IV. Plant Sucoort R1 Radiological Protection and Chemistry (RP&C) Controls During routine plant tours, the inspectors observed that radiation measurements were posted in accordance with licensee procedures and NRC regulations. A sample of doors were found locked for the purpose of radiation protection. Plant workers and supervisors in radiologically controlled areas were observed following licensee procedures for radiation protection.
P2 Status of Emergency Planning (EP) Facilities, Equipment, and Resources P2.1 1998 Public Information Booklet Mailing a.
Insoection Scoce (71750)
The inspectors reviewed the efforts of the licensee to meet the requirements of 10 CFR Part 50, Appendix E, Section IV.D.2, " Notification Procedures." This requirement provides for a yearly dissemination to the public of basic EP information.
b.
Observations and Findings The licensee performed an annual review, update, and distribution of an EP information booklet in accordance with Site Support Procedure SSP-421, " Review, Publication and Distribution on Public Information Materials," Revision 6. The purpose of these booklets was to provide basic information about the plant and the actions to be taken in the event of an emergency at the plant. The booklets were to be mailed to residents within the 10-mile Emergency Planning Zone (EPZ).
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1 in April 1998, the commercial mailing house contracted to distribute the booklets mailed a total of 41,284 copies. Several days later, a member of the licensee's staff reported that he had received one of these booklets even though he lived in an area outside the 10-mile EPZ. The licensee contacted the emergency management director for that area and the mailing house to investigate the reason for the discrepancy.
The method used to perform the mailing was to identify all U. S. Postal Service zip codes that fall within the 10-mile EPZ and mail a booklet to all residents in those zip codes.
Investigation revealed that the mailing house inadvertently included an additional zip code that was not applicable for this purpose. The number of residents in this zip code totaled 14,431. When the mailing house exhausted its supply of booklets (41,284), no j
further action was taken even though significant portions of seven additional zip codes had not been included in the mailing. This resulted in some residents receiving a booklet that did not need this information and some other residents within the 10-mile EPZ not receiving the required information.
Upon discovery, the licensee took appropriate action to correct the error. All residents that were not included in the original mailing were supplied with the booklet in May 1998.
The affected emergency management officials were contacted and indicated that no further actions were required. The licensee identified several revisions to be made in the procedure to provide additional assurance that those residents required to receive this
information were included in future mailings. The inspectors considered these actions to be appropriate.
c.
Conclusions An error in the annual mailing in April 1998 of the public information booklets resulted in some residents receiving the booklets that did not require this information and others within the 10-mile emergency planning zone not receiving the booklets. The licensee
identified the error and took appropriate corrective action by mailing the appropriate residents the books in May 1998. The licensee implemented process changes to include future verifications during mailing instead of following mailing.
S1 Conduct of Security and Safeguards Activities The inspectors periodically observed security officers screening personnel ingress to the plant protected area in accordance with the security program. Personnel observed in the protected area displayed badges and escorted visitors as required.
F2 Status of Fire Protection Facilities and Equipment F2.1 Uncontrolled Imoairment of a Fire Rated Assembiv (
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Insoection Scoce (71750)
The inspectors conducted routine observations of the licensee's facility including the condition of fire rated assemblies throughout the plant.
b.
Observations and Findinas While conducting a routine tour of the minus 4-foot level of the RAB, the inspectors observed a door (Door 150) that was not closed and not latched. No fire impairment tags were posted on or near the door and no fire or security watches were in the area. This door was labeled as a security door and as a fire door. The use of a key card was required to gain access through this door. The inspectors immediately notified security of the condition and waited for an officer to respond. The officer verified the proper operation of the door and latch mechanism and returned the door to its proper closed and latched position.
The inspectors requested and received a computer printout of personnel using this door within the previous 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The inspectors observed the open door at 4:25 a.m. on May 21,1998. The last person to use the door was the fire watch at 4:10 a.m. This showed that for a period of approximately 15 minutes the door was not closed and was not capable of performing its required function.
Door 150 was labeled as a security door but was, in fact, not used as a security door at the time the observation was made and had no alarm capability. This door is used as a security door only during plant outages when increased numbers of personnel would be expected to require access to this area of the plant. However, the door was also labeled as a fire door. The inspectors verified that this door was listed in Attachment 8.4 of Fire Protection Procedure FP-001-015. " Fire Protection System impairments," Revision 5.
i The licensee's fire protection program is controlled by Administrative Procedure UNT-005-013, " Fire Protection Program," Revision 6. Section 5.2.1 of this procedure requires, in part, that impairments to the fire protection system including fire rated assemblies are to be controlled. For a period of approximately 15 minutes, Fire Rated Assembly Door 150, was impaired but not controlled in any way.
The failure to control the impairment of Fire Door 150 is identified as a violation of TS 6.8.1 (50-382/9809-02).
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Conclusions Contrary to TS 6.8.1.f and the fire protection program, a fire door in the reactor auxiliary building (RAB) was observed to be open with no controls in place.
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V. Management Meetings l
.X1 Exit Meeting Summary The inspectors presented the inspection results to triembers of licensee management on June 22,1998. The licensee acknowledged the findings presented.
The inspectors asked the licensee whether any materials examined during the inspection l
should be considered proprietary. No proprietary information was identified.
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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED l
Licensee
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F. J. Drummond, Director Site Support C. M. Dugger, Vice-President, Operations E. C. Ewing, Director, Nuclear Safety & Regulatory Affairs
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C. Fugate, Operations Superintendent l
T. J. Gaudet, Manager, Licensing J. G. Hoffpauir, Manager, Operations T. R. Leonard, General Manager, Plant Operations D. C. Matheny, Manager, Operations G. D. Pierce, Director of Quality D. W. Vinci, Superintendent, System Engineering
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A. J. Wrape, Director, Design Engineering i
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NBC T. Dexter, RIV Security inspector INSPECTION PROCEDURES USED IP 37551:
Engineering
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IP 61726:
Maintenance Observation IP 71707:
Operations IP 71750:
Plant Support Activities IP 92901:
Followup-Operations
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IP 92902:
Followup-Maintenance IP 92903:
Followup-Engineering ITEMS OPENED, CLOSED, AND DISCUSSED Ooened 50-382/9809-01 VIO Failure to enter appropriate TS action. statement for the EDGs l
while a missile barrier door was removed (Section 01.3)
50-382/9809-02 VIO Failure to control the impairment of Fire Door 150 (Section F2.1).
Closed 50-382/96-014 LER Broad range toxic gas monitors not powered from independent power supplies (Section 08.1).
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4-2-50-382/96-015 LER Failure to isolate containment penetration 20 (Section 08.2).
.50-382/9624-02 VIO Failure to test safety-related actuating systems (Section M8.1)
l 50-382/9612-05-VIO-Inadequate analysis of WCT basin water as a source of EFW l
(Section E8.1).
l-LIST OF ACRONYMS USED
'ASME-American Society of Mechanical Engineers CCW:
component cooling water CEA
' control element assembly CFR Code of Federal Regulations EDG emergency diesel generator.
EOP:
' emergency operating procedure
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emergency preparedness EPZ emergency planning zone HPSI high-pressure safety injection LER licensee event report NRC Nuclear Regulatory Commission-PDR Public Document Room l
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RAB'
reactor auxiliary building
, SERT Significant event review team L
.TS Technical Specification WA work authorization WCT wet cooling tower
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